(Beyond Pesticides, April 9, 2024) The United States Court of Appeals for the Fifth Circuit, in an opinion authored by Circuit Judge Cory T. Wilson, has vacated an action by the U.S. Environmental Protection  Agency (EPA) that had ordered the Texas-based manufacturer Inhance Technologies, L.L.C. to stop producing plastic containers that leach toxic per- and polyfluoroalkyl substances (PFAS) into pesticides, household cleaners, condiments, and additional products. EPA has taken action after the agency determined that the PFAS created during the fluorination process “are highly toxic and present unreasonable risks that cannot be prevented other than through prohibition of manufacture.”

While the court is not challenging EPA’s authority to determine the hazards associated with PFAS exposure to be unacceptable, on a technicality, it is finding that the agency used the wrong section of the Toxic Substances Control Act (TSCA), Section 5, which the court says is focused on new uses. According to the Court, “The EPA is just not allowed to skirt the framework set by Congress by arbitrarily deeming Inhance’s decades-old fluorination process a “significant new use,” even though EPA’s awareness of the PFAS contamination was “new” to the agency and not disclosed by the manufacturer. Even if EPA were to pursue another approach (Section 6) under TSCA, the court notes that the agency must “weigh the costs to businesses and the overall economy before shutting down an ongoing manufacturing process.” And so goes the limitations of federal law in protecting public health as a primary and superseding goal.

This case serves as one example, among the many under federal law, in which efforts to limit the use of petrochemical pesticides are impeded by weak policy without clear mandates. The court decision elevates the challenges posed by federal laws that do not clearly meet the enormity of the current and escalating public health, environmental, and climate crises—in this case, exemplified by long-chain PFAS contamination from one manufacturer. Organic land management practices and certified organic agriculture are critical to the systemic shift to prevent further PFAS contamination, as Beyond Pesticides continues to call on the National Organic Standards Board (NOSB) to develop a strategy for eliminating plastics and PFAS from organic as a priority issue including at the upcoming meeting this spring.

Background
The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products, such as the mosquito insecticide Anvil 10+10, raises alarm about the extent of PFAS contamination and its potential impact on public health, including contamination of drinking water and waterways. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—as the plastic containers leached PFAS. 

In response, PEER and the Center for Environmental Health (CEH) notified EPA and Inhance Technologies in October 2022 of their intent to file a lawsuit to stop the manufacture and use the PFAS-contaminated product. EPA eventually filed a lawsuit against Inhance in December 2022, as did PEER and CEH, seeking to enjoin the company from continuing to produce multiple per- and polyfluoroalkyl substances in violation of TSCA. The two cases were later combined in the District Court for the Eastern District of Pennsylvania. In April 2023, a federal district court judge dismissed the PEER and CEH suit without prejudice at the request of both Inhance and EPA on the grounds the government was “diligently prosecuting” its case.  In response to the 5th Circuit Court’s appellate decision to vacate EPA’s stop manufacturing order, PEER and CEH are moving to intervene in the DOJ suit against Inhance. In February 2024, PEER and CEH announced a newly filed lawsuit against EPA for wrongfully withholding vital information, including test data on the presence of PFAS.

The EPA’s Determination and the Fifth Circuit Decision
The two orders by EPA prohibiting Inhance from manufacturing or processing PFAS during its fluorination process were issued under Section 5 of the TSCA, which empowers EPA to oversee and examine chemicals produced or brought into the United States. (See here for EPA’s PFAS framework and TSCA section 5). However, the company argued, and the court agreed, that the agency had incorrectly applied a TSCA section related to the new uses of chemicals, asserting that its process did not represent a new use. [Inhance has been fluorinating plastic containers using the same process since 1983, a process that manufactures PFAS and produces 200+ million containers annually.] While acknowledging the unreasonable risk to human health and the environment, the court concurred with Inhance’s interpretation and vacated the orders.

The Fifth Circuit decision alarms advocates with its significant implications for public health and the environment, as the public is left exposed to toxic PFAS without adequate protection. In addition, the court’s finding raises questions about the EPA’s authority to issue significant new use rules (SNURs) under TSCA. SNURs are crucial tools for managing chemical risks, and limiting EPA’s authority in this regard weakens the agency’s ability to protect public health and the environment (see PEER and CEH response here and here). Although EPA does not regulate PFAS in pesticide formulas, the agency lists these substances in the inert ingredient database, and thus product labels do not require disclosure of contaminants fundamental to pesticide products as a result of the manufacturing or packaging process. This is yet another reason to end the use of synthetic pesticides and recognize the benefits of organic agriculture.

The Impact on Public Health  and the Only Viable Solution—Organic

As PEER noted, PFOA and twelve other PFAS chemicals are formed during the fluorination of high-density polyethylene (HDPE) plastic containers by Inhance Technologies, LLC of Houston, Texas. Inhance is the sole U.S. company conducting this type of fluorination. Studies by EPA, independent researchers, and Inhance itself show that PFAS leaches from the walls of containers into their contents, thus exposing millions of people to PFAS without their knowledge. In February 2024, EPA announced new methodology for detecting dangerous low levels of PFAS in plastic containers. The leaching of PFAS from plastic containers into various products, including pesticides, food, cosmetics, and cleaning supplies, poses a significant risk to millions of Americans though exposure via ingestion, inhalation, and dermal contact.  

PFAS have been linked to various health issues, including cancer, reproductive problems, and immune system dysfunction. Concerns of safety in the use of fluorinated plastic containers used for packaging are because exposure to PFAS comes not just from leaching into the contents of the plastic containers, but also from handling the exterior of the containers. Factory workers and farmworkers have higher cumulative exposures, while critical windows of vulnerability, from pregnancy through childhood and the elderly, experience disproportionate risks of exposure. (See here, and here). The chemicals have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. As new drinking water health advisories issued by EPA show, PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.

Certified organic agriculture can play a crucial role in addressing the widespread contamination of PFAS as the only viable solution in the long run. Organic agriculture prohibits the use of petrochemical pesticides and fertilizers under a robust regulatory system created by the Organic Food Production Act (OFPA) and overseen by the NOSB, which reports directly to the U.S. Secretary of Agriculture. As the only agricultural system with public input and standards as defined by federal law, organic promotes sustainable farming practices that prioritize soil health and biodiversity. As the governing body responsible for setting organic standards, the NOSB must take a leadership role in developing a comprehensive strategy for eliminating plastics and PFAS from organic production and packaging, ensuring that organic agriculture remains a safe and sustainable alternative to conventional farming.

Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. For more information on why organic is the healthy choice, see Beyond Pesticides’ webpage, Health Benefits of Organic Agriculture. Additionally, learn more about how the lack of adequate pesticide regulations can adversely affect human and environmental health by visiting Beyond Pesticides’ website, Keeping Organic Agriculture Strong, and a special edition of Pesticides and You, “Keeping Organic Strong.” 

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

Sources 

Inhance Technologies vs US EPA, US 5th Circuit Court Decision, March 21, 2024

US court blocks EPA order to eliminate PFAS in plastic containers, The New Lede, March 25, 2024

EPA Orders Issued to Inhance Technologies Related to Long-Chain PFAS Significant New Use Notices, EPA website, December 14, 2023

(Beyond Pesticides, April 8, 2024) When Mexico in 2020 decided to protect its traditional varieties of corn for reasons of health, safety, environmental protection, and food sovereignty with the banning of the importation of genetically engineered (GE or GM-genetically modified) corn by 2024, the powerful biotech industry and the U.S. government began a concerted campaign to stop the country’s efforts. With the opposition spearheaded by BIO, “the world’s largest trade association representing biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations” (as described in its March 15 press release), including companies like Bayer/Monsanto, the U.S government is calling Mexico’s action a trade barrier. The U.S. is invoking the U.S.-Mexico-Canada Agreement (USMCA), the trade agreement that replaced the North America Free Trade Agreement (NAFTA) in 2020.

This is just one of the latest examples of corporate power reigning over U.S. environmental and economic policies. Mexico has already announced a delay in the planned April 1 ban on the importation, production, distribution, and use of glyphosate. Interestingly, this is all happening despite reports that the Biden administration is seeking to “tackle corporate abuses,” which is apparently limited  to tax reform and encouraging competition,

>> Tell the U.S. Trade Representative and the U.S. Secretary of State to withdraw opposition to Mexico’s ban on imported GE corn. 

Mexico’s decision to stop importation of GE corn into its country is examined in report by CBAN, which highlights the scientific rationale underpinning Mexico’s decision to “safeguard the integrity of native corn from GM contamination and to protect human health.” Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under USMCA. In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban. So far, there has been no public update from the Office of the U.S. Trade Representative, however, the biotech industry said in its March 15 release, “BIO thanks U.S. Trade Representative Katherine Tai and USTR Chief Agriculture Negotiator Doug McKalip for pursuing this action in support of U.S. farmers and agricultural innovation.”

Within Mexico, there is over a decade of judicial and executive actions against the spread of GE crops, as well as the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed, effective immediately, within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, citing the need for more research and prohibited agrichemical biotech companies, including Monsanto, DuPont Pioneer, Syngenta, PHI Mexico, and Dow AgroSciences, from planting or selling GE corn seed in Mexico. Then in 2020, Mexico announced the phase out of glyphosate from use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry intervenes whenever decisions are published finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or advance restrictions on genetically engineered or modified crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, the CBAN report states, “Most GM corn plants are genetically modified to kill insect pests. The GM plants express a toxin from the soil bacterium Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects but not others. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops are different from this natural Bt in structure, function, and biological effects.” The report continues, “In fact, peer-reviewed studies across the scientific literature continue to find that Bt toxins in GM plants can harm insects (spiders, wasps, ladybugs, and lacewings, for example) that are not the intended targets.”

For background, see Ready or Not, Genetically Engineered Crops Explode on Market.

>> Tell the U.S. Trade Representative and the U.S. Secretary of State to withdraw opposition to Mexico’s ban on imported GE corn. 

 Letter to U.S. Trade Representative Katherine Tai

I am writing to ask you to withdraw U.S. opposition to Mexico’s ban on imported GE corn. Despite reports that the Biden administration seeks to “tackle corporate abuses,” the actions of the U.S. government appear to be limited to tax reform and encouraging competition, while corporate interests continue to override existential health and environmental concerns. A case in point is the attempt to stop Mexico’s ban on imported genetically engineered (GE or GM) corn.

In 2023, Mexico decided to stop importation of GE corn into its country. Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA). In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban.

Over the last decade, Mexico has taken judicial and executive actions against the spread of GE crops and the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, and prohibited agrichemical biotech companies from planting or selling GE corn seed in Mexico, citing the need for more research. In 2020, Mexico announced a phase-out of glyphosate’s use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry challenges decisions finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or restrict GE crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, most GE corn plants are genetically modified to kill insect pests, expressing a toxin from the soil bacterium Bacillus thuringiensis (Bt) that known to harm the guts of specific types of insects. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops differ from this natural Bt in structure, function, and biological effects. In fact, peer-reviewed studies continue to find that Bt toxins in GM plants can harm nontarget arthropods including spiders, wasps, ladybugs, and lacewings.

Please immediately cease U.S. opposition to Mexico’s ban on imported GE corn.

Thank you.

Letter to the Secretary of State and the White House:

I am writing to ask you to withdraw U.S. opposition to Mexico’s ban on imported GE corn. Despite reports that you seek to “tackle corporate abuses,” your actions appear to be limited to tax reform and encouraging competition, while corporate interests continue to override existential health and environmental concerns. A case in point is the attempt to stop Mexico’s ban on imported genetically engineered (GE or GM) corn.

In 2023, Mexico decided to stop importation of GE corn into its country. Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA). In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban.

Over the last decade, Mexico has taken judicial and executive actions against the spread of GE crops and the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, and prohibited agrichemical biotech companies from planting or selling GE corn seed in Mexico, citing the need for more research. In 2020, Mexico announced a phase-out of glyphosate’s use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry challenges decisions finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or restrict GE crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, most GE corn plants are genetically modified to kill insect pests, expressing a toxin from the soil bacterium Bacillus thuringiensis (Bt) that known to harm the guts of specific types of insects. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops differ from this natural Bt in structure, function, and biological effects. In fact, peer-reviewed studies continue to find that Bt toxins in GM plants can harm nontarget arthropods including spiders, wasps, ladybugs, and lacewings.

Please immediately cease U.S. opposition to Mexico’s ban on imported GE corn.

Thank you.

(Beyond Pesticides, April 5, 2024) Exposure to chemical toxicants, molds, and algae contributes to autism and attention disorders in children, according to research that bolsters earlier findings. The exposures may be most relevant, not in the children, but one generation back—in the parents. The study, “Assessing Chemical Intolerance in Parents Predicts the Risk of Autism and ADHD in Their Children,” was published in the March issue of the Journal of Xenobiotics.

Led by Claudia S. Miller, MD, an immunologist at the University of Texas at San Antonio noted for her work on chemical intolerance (CI), the authors build on previous work published in 2015 establishing parental CI as a risk factor for autism and ADHD. Dr. Miller participated in Beyond Pesticides’ 2022 Forum Series. Recordings of her presentation are available on YouTube here and here.

In 1996, Dr. Miller concluded that CI is induced by Toxicant-Induced Loss of Tolerance (TILT). For further details, see Beyond Pesticides’ Daily News Blog. Three years later Dr. Miller developed the Quick Environmental Exposure and Sensitivity Inventory (QEESI), a questionnaire for individuals tracing their toxicant exposures and symptom histories. QEESI was first developed with groups exposed to organophosphate pesticides, volatile organic compounds in reconstruction and remodeling, various military chemicals used in the Gulf War, and breast implants. QEESI has been used in 16 countries, and the Miller team believes it offers “high sensitivity and specificity for differentiating individuals with CI from the general population.”

The concept behind TILT is that either a short-duration acute exposure to a chemical or biological agent or a low-dose chronic exposure can sensitize the immune system so that further exposures at much lower doses, or even exposures to previously tolerated substances, set off a cascade of immune responses leading to CI. CI often involves symptoms in multiple body systems and may be triggered not only by environmental chemicals, but also by foods and drugs. The prevalence of CI, if clinically diagnosed, is estimated at 0.5-6.5%; if self-diagnosed, the average is 20%.

Autism globally is estimated to occur in about one percent of children. It increased by 6-15 percent a year between 2002 and 2020. Less than a fifth of autism cases can be attributed to a specific cause. The rest, the authors write, are termed “idiopathic autism,” for which interactions between genes and the environment are thought to be the best explanation.

Attention Deficit Hyperactivity Disorder (ADHD) affects about 6% of youth and 2.5% of adults, according to the authors, and there is “substantial overlap” between autism and ADHD, estimated at 28-78%. The research team published work in 2015 showing that mothers with CI have three times the likelihood of reporting a child with autism and 2.3 times the odds of reporting a child with ADHD. The current study reinforces the association between CI and children’s behavioral problems, finding that the top 10 percent of parents with CI had 5.7 times the risk of having a child with autism and/or ADHD as the bottom 10%.

They also suggest that toxicant exposures, such as heavy metals, organophosphate pesticides, and tobacco smoke, probably stimulate epigenetic changes in gene expression.

Epigenetics refers to the process by which various molecules grant or deny access to genes by other cellular components, which in turn determines whether the genes are active. Epigenetic configurations have been shown to be heritable, although there is controversy regarding whether this applies to direct offspring that were gestating at the time of the mother’s exposure. The children in the current study would have been influenced both by their mother’s exposures and directly by any environmental substance that could penetrate the placental barrier.

The Miller team drew a random sample representing all 50 states from nearly three million people who completed an 80-question QEESI questionnaire through a SurveyMonkey online portal.

Nearly 23 percent of the respondents report high levels of CI. Of those, 13 percent report having a child with an autism spectrum disorder, and nearly 29 percent have a child with an attention disorder.  

The initiating exposures reported by respondents fall into two categories: fossil fuel-derived toxicants and biogenic toxicants such as particles and volatile organic compounds from mold or algae. The scientists note that regulatory standards for “safe exposure levels” to these substances are derived from animal tests. They rely on establishing “No Observed Adverse Effect Levels” (NOAELs). For people with CI, the level of exposure sufficient to trigger symptoms is usually far below established NOAELs. Nor do those levels capture the effects of mixtures or address carcinogenicity or mutagenicity, the authors note.

When CI, TILT, and QEESI were first developed, the theory did not include a specific mechanism for how the immune cascade develops. In 2021 Miller and colleagues proposed that toxic exposures trigger mast cells—part of the immune system—to change their behaviors and overreact to chemical signals.

Mast cells were discovered more than a century ago, but their role in CI has only recently been explored by Dr. Miller and colleagues. Mast cells are highly conserved in animal physiology, having appeared some 500 million years ago in early bony fish. Generally, they are deployed near an organism’s interface with the outside world (skin, digestive, and respiratory tracts), ready to defend against allergens, toxins, and pathogens. They are usually the first immune system responders to external invasion and release several kinds of inflammatory markers, including cytokines and histamine. They contribute to wound healing, tissue regeneration, and blood vessel formation. They also communicate with the nervous system, suggesting an involvement with responses to stress. Their roles in diseases associated with highly industrialized societies are the focus of intense scientific interest. Beyond Pesticides covered Dr.Miller’s examination of petrochemicals’ influence on mast cells in 2023.

One limitation of the current study is that QEESI is a subjective measure based on self-reporting from a self-selected population, and thus provides only anecdotal information. Further, there is no standard clinical protocol or a suite of laboratory tests for diagnosing CI. Nor is there a widely accepted method for diagnosing mast cell activation syndrome, a condition thought to underlie many disorders ranging from allergies to irritable bowel syndrome and possibly including CI.

Yet there is no doubt that environmental exposures contribute to many diseases and evidence of their influence on gene expression is mounting. What can be done? Mitigating environmental exposures by avoiding pesticides and industrial chemicals in fabrics, furniture, kitchen and bathroom cleaners, personal care products, traffic fumes, smoke, and the like, may help. But for chemical sensitivity, once the problem is established, it is very difficult to alleviate.

In order to really address the problem, it must be confronted at scale. That means reducing the presence in the ambient environment of the culprit chemicals, such as everything derived from fossil fuels—pesticides, plastics, internal combustion pollution, and the myriad compounds used in commerce, such as flame retardants and surfactants. Even biological triggers like mold and algae are often connected to human activities, especially those exacerbating climate change. Earth’s biosphere is being overwhelmed with these substances’ disruptions, impelling organisms to overamp their defense mechanisms, with the results we see about us—inflammation in every physiological system, leading to many health consequences ranging from heart disease, arthritis, depression, Alzheimer’s disease, cancer—and hair-trigger chemical sensitivities, autism and ADHD. Expecting the patients with CI/TILT, autism, and ADHD to cope individually by restricting their lifestyles to the point of absurdity, such as never being able to open a window or even go outside, is again, blaming the victim and will never result in overall improvement in public health.

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

Sources:

Assessing Chemical Intolerance in Parents Predicts the Risk of Autism and ADHD in Their Children
Raymond F Palmer, David Kattari, Rodolfo Rincon, Claudia S Miller
J Xenobiot, 2024 Mar 5;14(1):350-367
https://www.mdpi.com/resolver?pii=jox14010022 

Chemical Intolerance and Mast Cell Activation: A Suspicious Synchronicity
by Raymond F. Palmer, J Xenobiot, 2023 Nov 12;13(4):704-718. doi: 10.3390/jox13040045 
https://www.mdpi.com/2039-4713/13/4/45

Drug Intolerances: Potential Risk Factors for Autism and Attention Deficit Hyperactivity Disorder
Heilbrun, L.P.; Palmer, R.F.; Jaen, C.R.; Svoboda, M.; Perkins, J.; Miller, C.S. Maternal Chemical and (ADHD). J. Am. Board Fam. Med. 2015, 28, 461–470
https://www.jabfm.org/content/28/4/461

Multiple chemical sensitivity/idiopathic environmental intolerance: A disability-rights, patient-led perspective
Sophia Jaworski, Comment J Allergy Clin Immunol Pract, 2024 Jan;12(1):265-266. doi: 10.1016/j.jaip.2023.11.023
https://linkinghub.elsevier.com/retrieve/pii/S2213-2198(23)01265-5

Mast cell activation may explain many cases of chemical intolerance
Claudia S. Miller, Raymond F. Palmer, Tania T. Dempsey, Nicholas A. Ashford & Lawrence B. Afrin, Environmental Sciences Europe, Volume 33, Article number: 129 (2021)
https://enveurope.springeropen.com/articles/10.1186/s12302-021-00570-3

Multiple Chemical Sensitivity
Review Brain Sci, Gesualdo M Zucco, Richard L Doty
2021 Dec 29;12(1):46. doi: 10.3390/brainsci12010046.
https://www.ncbi.nlm.nih.gov/pmc/articles/pmid/35053790/

The Dilemma of Mast Cell Activation Syndrome: Overdiagnosed or Underdiagnosed?
Cem Akin, MD, PhD, The Journal of Allergy and Clinical Immunology: In Practice
https://www.jaci-inpractice.org/article/S2213-2198(24)00065-5/fulltext

Parental avoidance of toxic exposures could help prevent autism, ADHD in children, new study shows
Press Release, March 28, 2024, University of Texas Health Science Center at San Antonio
https://www.sciencedaily.com/releases/2024/03/240328111021.htm#:~:text=A%20population%2Dbased%20survey%20of,in%20the%20bottom%20tenth%20percentile

The mast cell: an evolutionary perspective, Enrico Crivellato and Domenico Ribatti, Biol. Rev. (2010), 85, pp. 347 – 360.347
https://onlinelibrary.wiley.com/doi/epdf/10.1111/j.1469-185X.2009.00105.x

(Beyond Pesticides, April 4, 2024) Researchers at the National Institute of Pediatrics and National Polytechnic Institute found positive associations between pesticide exposure and heightened risk of certain childhood cancers. The finding is derived from a meta-analysis of 174 studies published between 2013 and 2023 and published in the International Journal of Molecular Science. The authors note, “Although [pesticide exposure] association with childhood cancer has not been fully demonstrated, we found that more than 80% of the epidemiological studies show positive associations [with forms of childhood cancer].”

Approximately one third of identified studies (roughly 16) find positive relationships between prenatal and postnatal pesticide exposure with heightened risk of leukemia, neuroblastoma, and rare forms of cancer, such as Wilms tumor. For central nervous system (CNS) tumors, half of identified studies (roughly 24) found a positive relationship with pesticide exposure. The researchers call on further research regarding interaction between different pesticides and health impacts on cumulative exposure.

The study is broad in scope, identifying various environmental pollutants and their associations with certain childhood cancers (e.g. radon exposure, air pollution, electromagnetic fields, indoor chemicals, and tobacco and alcohol). This Daily News focuses specifically on pesticide exposure. The researchers originally identified 6,172 studies through PubMed, however 174 studies were ultimately included after two rounds of screening with the three following criteria:

1. “Original or review epidemiological studies assessing the association between environmental pollution and childhood cancer;
2. Published between 2013–2023; and,
3. With abstracts in English or Spanish.”

Table 3 in the Results section identifies the running list of studies assessing pesticide exposure and risk of childhood cancer. Out of the 376 papers initially pulled from the database using the keywords “children,” “cancer,” and “pesticides,” the researchers included 49 articles following the criteria listed above. Regarding the type of exposure, 34 percent focused on parental exposure to pesticides, 24 percent focused on postnatal exposure, and 27% focused on maternal/prenatal exposure—a relatively even distribution of potential avenues for pesticide harms. Studies that fall under the category of “childhood cancer” typically refer to studies that investigate more than one type of cancer.

In the conclusion subsection on pesticides, researchers arrive at several determinations: “Importantly, our results revealed a high percentage of studies showing associations between CNS tumors, neuroblastoma, and pesticides (Figure 7). The mechanisms assessing the potential relationship of pesticides with these types of cancer should be explored. Although the genotoxicity of pesticides has been evaluated, their epigenetic effects need to be fully investigated because their contribution to childhood cancer etiology could be at this level []. In addition, although the risks of pesticide exposure have been vastly evaluated, the transgenerational effects of these exposures need more attention. It has been shown that the environmentally induced disease risk can be transmitted to the offspring, via epigenetic mechanisms through female and male germ lines.”

The findings from the studies in the meta-analysis do not come as a surprise for advocates who have witnessed the adverse health impacts of pesticide exposure on chemically sensitive populations such as children. In “Pesticides and Children Don’t Mix,” Beyond Pesticides outlines the myriad health risks associated with childhood exposure to pesticides that corroborate the findings of this more recent study. For example, a 2015 meta-analysis study by scientists at the Harvard University’s School of Public Health finds that children’s exposure to pesticides in and around the home results in an increased risk of developing certain childhood cancers. Authors found that cancer risk is connected most closely to the type of pesticide used and its application location. 

A 2024 Environmental Research study found an association between adverse neurodevelopment (brain function and development) among infants and exposure to the herbicide glyphosate during pregnancy. To that end, researchers indicate negative neurodevelopment becomes more pronounced at 24 months or two years. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure, leading to reduced melatonin levels that ultimately disrupt circadian rhythm and lead to sleep disorders later in life, according to a 2023 study in Antioxidants.

In addition to maternal/prenatal exposure from herbicides, children experience exposure to pyrethroid insecticides earlier in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life, according to a study published in Frontiers in Public Health in 2023. There are some elected officials who are attempting to take action. The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269, addresses many of the controversial issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S. that adversely affect farmworkers. Beyond Pesticides has documented the decades of disproportionate, adverse health impacts farmworkers face from chronic and acute pesticide exposure. Additionally, see the Daily News section on children to find further research and findings regarding pesticide exposure and children’s health.

Beyond Pesticides continues to provide resources for advocates calling on the expansion and strengthening of organic land management principles and agriculture to prevent the spread of toxic petrochemical pesticides. Please see the Pesticide-Induced Disease Database to stay informed on the latest scientific analysis regarding toxic pesticide exposure and chronic illnesses. Check out the Gateway on Pesticide Hazards and Safe Pest Management to identify which toxic pesticide ingredients are included in typical household items. Click on Eating With a Conscience to learn about potential toxic chemical and pesticide exposure in commonly consumed produce to better inform your food purchases. Moreover, you can take action by telling the U.S. Department of Agriculture (USDA)’s Food and Nutrition Service to require organic school lunches and tell U.S. Environmental Protection Agency to forego any further registration of pesticides that contain obesogens. 

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

Source: International Journal of Molecular Science

New research highlights the beneficial effects of rose essential oil (REO) on tomato plants as a plant defense potentiator (a substance or treatment enhancing natural defense mechanisms against pests, diseases, and other stressors by activating the plant’s own defense responses) for organic agriculture and horticulture. As reported in the Journal of Agricultural and Food Chemistry, REO, particularly its component β-citronellol, activates defense genes in tomato plants, enhances their natural defense mechanisms, and dramatically reduces leaf damage by 45.5%. Additionally, REO attracts beneficial insects that prey on herbivore pests. This study, “Novel Potential of Rose Essential Oil as a Powerful Plant Defense Potentiator,” adds to a growing area of scientific literature on essential oil (EO), largely unexplored as plant defense potentiators. Beyond Pesticides advocates for accelerating the switch from chemical-intensive agriculture to organic agriculture, which remains the only viable solution, in the long run, to address today’s existential crises by prioritizing natural pest control methods, soil health, and biodiversity conservation to protect farmworkers and consumers from the detrimental effects of petrochemical pesticide exposure.    

Study Methods and Results 

The researchers applied highly diluted solutions of EOs to the soil of potted tomato plants and assessed the expression levels of defense genes in the tomato leaves, such as PR1 and PIN2, which are known to play a role in plant defense responses. Additionally, they evaluated the extent of leaf damage caused by herbivores, including Spodoptera litura (a leaf eating pest) and Tetranychus urticae (spider mites), with field trials to validate the findings in a real-world agricultural setting. The researchers treated the soil of tomato plants with REO solution over three weeks and compared the pest damage level to plants treated with a control solvent. This field trial aimed to assess the practical effectiveness of REO in enhancing plant defense against pests and attracting beneficial arthropods.  

The main findings of the study include: 

1. REO, particularly β-citronellol, activates defense genes, including PR1 and PIN2, in tomato plants, which enhance their natural defense mechanisms; 
2. Tomato plants treated with REO show significant reductions in leaf damage caused by herbivores, such as Spodoptera litura and Tetranychus urticae, compared to plants treated with a control solvent.
3. Field trials confirm the efficacy of REO in enhancing plant defense in real-world agricultural conditions, resulting in a remarkable reduction (45.5%) in pest damage to tomato plants.
4. REO attracts herbivore predators, such as the Phytoseiulus persimilis mite, while not repelling the spider mite herbivores themselves. 

A specific concentration of REO (1 × 10^5 dilution), identified as optimal, echoes findings similar to those for valine menthyl ester, another plant defense potentiator, suggesting that higher doses might be detrimental, while the precise dilution used showed no negative impact on plant fitness.  Additionally, the study finds that soil application of REO was the only effective method for enhancing plant defense, as direct leaf application proved ineffectual—potentially due to the volatile nature of EOs and rapid evaporation when applied to foliage. Consideration in future research designs to calibrate and test for optimal concentrations and application methods (soil and foliar) across different environmental conditions is key to understanding how EOs or their derivatives might be systematically distributed within plants to enhance defense mechanisms even more effectively.  

The study underscores EO’s enormous potential as a safer and more effective tool of pest management—compatible with organic agriculture and horticulture—while minimizing health and environmental risks, an approach supported by Beyond Pesticides. Containing compounds with potent insecticidal and repellent properties, EOs have an “exceptional safety profile…(with) a range of bioactivities that greatly benefit human health.” EOs are a promising tool against the relentless issue of resistance. Conventional agriculture and the pesticide industry respond to weed resistance, for example, with a pesticides arms race, introducing more toxics as a solution that perpetuates the problem. Apart from the toxicity and other “downstream” issues related to many synthetic control chemicals, all organisms will eventually develop resistance against the harmful substances to which they are chronically exposed. For more information, please see Beyond Pesticides’ previous coverage here.  

Mosquito Management and EOs 

As noted in the March 24, 2022, Daily News post analyzing the study “Larvicidal and adulticidal effects of some Egyptian oils against Culex pipiens,” published in Nature, various EOs show significant larvicidal and adulticidal activity against the common house mosquito, Culex pipiens, which is a vector for diseases like West Nile virus and Saint Louis encephalitis. Egyptian scientists tested 32 EOs on C. pipiens larvae and adults, identifying garlic, dill, tea plant, fennel, fennel flower, sage, garden thyme, and sweet violet as highly effective, achieving up to 100% mortality. In addition, a 2019 study in the Florida Journal of Mosquito Control, found EO-based sprays more effective than common synthetic alternatives, supporting a science-based mosquito management approach that prioritizes preventive measures and ecological considerations while advocating for the use of less toxic, biodegradable products like EOs, based on monitoring data to minimize risks to non-target species. As communities like Boulder, Colorado, lead by example, in limiting biological larvicides in favor of ecological methods to control mosquito populations, it is vital to emphasize that even the least-toxic adulticides should be viewed as a mechanism of last resort, used under strict conditions to prevent mosquito-borne disease risks.  

Solution in Organic Methods 

EOs and other nature-based pest control alternatives offer a beacon of hope amidst the escalating crises wrought by conventional chemical-intensive agriculture. Beyond Pesticides calls for an end to the use of petrochemical pesticides and fertilizers by 2032 to safeguard human health, biodiversity, and environmental integrity. Embracing organic practices means embracing a holistic approach that nurtures the soil, promotes natural pest control mechanisms, and fosters resilient ecosystems. These ecological practices can mitigate adverse health risks associated with exposures and address the root causes of environmental degradation and climate change detrimentally impacted by petrochemical pesticides.  

By calling for a systemic shift to organic land management practices through advocacy, education, and grassroots action, Beyond Pesticides continues to lead the charge in catalyzing this transformation. In the introduction of our 2023 Transformative Change report referencing the vital need for a transformation to land and building management systems that align with nature, Jay Feldman, executive director of Beyond Pesticides, writes, “The transformative solution is a partnership with nature, practices that have been adopted in organic systems. With this approach, we honor all organisms who play a role in ecological systems on which life depends, and we seek the rapid adoption of those practices and materials that are already available to us or can be incentivized to become widely available quickly.” The fundamental solution lies in transitioning from conventional chemical farming to organic, regenerative agriculture.  

For more information, please refer to the Organic Agriculture page on our website. In addition, Beyond Pesticides’ ManageSafe™ | Least Toxic Control of Pests in the Home and Garden database is an excellent resource for safer solutions for readers. To learn about pesticides that may be used in local communities, please see Beyond Pesticides Gateway on Pesticide Hazards and Safe Pest Management. If you have a concern about pesticide use in your community, please contact Beyond Pesticides’ info desk at [email protected]. 

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

Sources: 

Novel Potential of Rose Essential Oil as a Powerful Plant Defense Potentiator, Eiki Kaneko, Kenji Matsui, Journal of Agricultural and Food Chemistry, 2024 

Products Compatible with Organic Landscape Management, Pesticides and You, Spring 2017  

https://www.beyondpesticides.org/assets/media/documents/mosquito/documents/LeastToxicMosquitoRepel.pdf 

Pesticides and Soil Health, Friends of the Earth, 2019  

Essential Oils In Organic Agriculture: A Review Of Practices And Potential, Natural Volatiles and Essential Oils, 2021 

Biocontrol Potential of Essential Oils in Organic Horticulture Systems: From Farm to Fork. Frontiers in Nutrition, 2022 

A Note on Biopesticides and EPA Definition  

“Biopesticides”—widely regarded as an alternative to chemical pesticides and hence given a special status in U.S. Environmental Protection Agency (EPA) regulation—need a better definition. Essential oils are one example of biopesticides naturally occurring substances that control pests (biochemical pesticides), microorganisms that control pests (microbial pesticides). However, Beyond Pesticides has argued that the current EPA definition for “biopesticides” is deceptive and misleading because it includes genetically modified organisms or synthetic analogs of naturally occurring biochemicals.  The development and adoption of genetically engineered (GE) and other questionable synthetic biopesticides can be seen as a diversion from the necessary shift towards sustainable food production. (See Beyond Pesticides call to action here).  

(Beyond Pesticides, April 2, 2024) There is a nascent capital investment effort in the transition to certified organic agriculture beginning to take hold across the U.S., something advocates say is critically needed to meet the current and escalating existential health threats, biodiversity decline, and climate emergency. Mad Agriculture has received early commitments from the Rockefeller Foundation, Builders Vision, and nearly a dozen other investors to contribute to the $50 million Perennial Fund II (PFII), to advance the growth of “regenerative organic” agriculture. Forbes is reporting that PFII’s primary objective is to jumpstart the organic land transition, given that this slice of U.S. agriculture makes up less than one percent of total farmland in the country relative to the European Union’s nearly 10 percent of total farmland. “We commend the work of Mad Agriculture in harnessing the spirit of organic agriculture and mobilizing the private sector to invest in farmers who engage in regenerative organic agricultural practices,” said Max Sano, organic program associate at Beyond Pesticides. In Rockefeller Foundation’s press release announcing their early commitment, Mad Capital co-founder Brandon Welch spoke on their vision: “We are aiming to build a bridge between two distant worlds that need one another to transition our food system – Wall Street and organic farmers…Providing farmers with access to capital gives humanity a shot at producing an abundance of healthy food while being ecologically accountable to our working lands and those that steward them.”

Mad Agriculture is an agricultural finance nonprofit with the specific goal of investing in the regenerative organic farmland transition in the United States. Their name is inspired by “Mad Farmer” poems from twentieth-century rural agricultural advocate and writer Wendell Berry, who warned the nation of the economic, health, and environmental consequences of farmland destruction. Mad Agriculture has four main initiatives: Mad Capital, Mad Lands, Mad Markets, and Mad Revolution. While Mad Capital is their investment fundraising arm, Mad Lands engages in business planning support for existing regenerative organic farmers providing services including impact assessments and stewardship consultancies to ensure that they are leading with ecologically beneficial practices. Meanwhile, Mad Revolution provides educational resources and Mad Markets is their newest initiative with more information to be released soon. Currently, the organization supports 79,115 acres in 14 different states. While their land portfolio is small relative to corporate commitments of millions in acreage to regenerative agriculture (not certified organic) from corporations such as General Mills, Walmart, and Unilever, Mad Capital shares Beyond Pesticides’ commitment to keeping organic strong in its theory of change, “The organic agriculture movement and certification (mainly for cropping systems) and holistic management (for livestock systems) provides a baseline of commitment to regeneration.” Mad Capital has the goal of transitioning five million acres to regenerative organic agriculture by 2032, which aligns with Beyond Pesticides’ mission to eliminate toxic petrochemical pesticides and fertilizer use from the food system by that same date.

Mad Capital is not the only player in the game. Another firm to watch is Iroquois Valley Farmland REIT, a B-corporation and real estate investment trust working in 19 states with over 60 farmers across 30,000 acres of land. “The Company is committed to scaling organic agriculture in the U.S. by getting more organic farmers on the land, funded by socially responsible investors,” according to their website. Essentially, this real estate investment trust allows investors to share the financial risk that organic farmers would otherwise take on their own by investing a minimum $10,700 over a five-year investment period, with payments available to said investors in the form of dividends at the end of their investment cycle. See here for more details on the structure of this real estate investment trust.

In their latest Public Benefit Report, Iroquois Valley identified goals for various categories, including “Environment: Where We Work,” “Customers: Our Farmers,” “Community: Our Investors,” “Workers: Our Staff,” and “Governance: Our Board” on page 11. They acquired a loan from the USDA Natural Resource Conservation Service (NRCS) to expand their soil health survey capacity to better equip their member farmers. Additionally, they added “19 new entity investors and 79 new trust accounts” into their portfolio in 2022 with the goal to continue this trajectory in 2023. It is important to note that just 55 percent of their total portfolio is certified organic as of 2022, yet 59 percent of the total production mix is devoted to cover crops –demonstrating their interest in elevating soil health as a fixture of their investment strategy even though they are not yet at 100 percent organic. Additionally, there appears to be a prioritization toward uplifting younger and more diverse groups of farmers in their portfolio. For example, in 78 percent of their clients, women are in leadership roles, and a combined 71 percent of the farm owners are Generation Z and Millennial.

“Regenerative farming without organic principles as a baseline can contribute to corporate greenwashing and misleading the public on sustainable agriculture,” said Mr. Sano. Regenerative and no-till farmers can, and often do, continue to rely on petrochemical fertilizers and pesticides, including glyphosate-based herbicide products that impose adverse health impacts, such as non-Hodgkin’s lymphoma, on farmers, farmworkers, frontline communities, and the broader public.

Surveys collected in a 2019 Friends of the Earth report, Pesticides and Soil Health, “… indicate that the majority of no-till farmers [in this study] rely on herbicides such as glyphosate, the active ingredient in Roundup. In fact, 86% of No-Till Farmer readers said they planned to plant Roundup Ready corn in 2017, while 80 percent planned to plant Roundup Ready soybeans, and some 92 percent planned to use glyphosate for weed control.” In contrast, a comprehensive study released in Journal of Cleaner Production in August 2023 identified the potential for organic agriculture to mitigate the impacts of agricultural greenhouse gas (GHG) emissions in the fight to address the climate crisis, determining that “a one percent increase in total farmland results in a 0.13 percent increase in GHG emissions, while a one percent increase in organic cropland and pasture leads to a decrease in emissions by about 0.06 percent and 0.007 percent, respectively.”

A 2019 publication from the International Monetary Fund, “Smart changes to how we farm and eat can have a huge impact on our planet,” quotes Rattan Lal of Ohio State University, a leading soil expert, who has calculated that “a mere 2 percent increase in the carbon content of the planet’s soils could offset 100 percent of all greenhouse gas emissions.”

While it is admirable that there are elements of private capital and elite financial institutions that acknowledge the contribution of synthetic pesticide and fertilizer dependency in conventional industrial agriculture in perpetuating and escalating the climate crisis, this is only one in a constellation of strategies needed—not a silver bullet. Beyond Pesticides maintains that structural change is only possible through the grassroots mobilization of concerned parents, physicians, public officials, scientists, farmers, and the broader public. See Keeping Organic Strong to learn how to engage in the public comment period for the Spring 2024 NOSB meeting, of which the deadline to contribute a comment is April 3. See Tools for Change for a range of strategies, resources, and tips to initiate grassroots advocacy in your community, town, city, or state against pesticide use on lawns, public land, and farmland.

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

Source: Forbes

(Beyond Pesticides, April 1, 2024) Comments are due 11:59 pm EDT, Wednesday, April 3.
For the public comment period—deadline Wednesday, April 3—in the lead up to the National Organic Standard Board (NOSB) meeting, advocates have identified the following priority issues:

• Getting plastics our of organic;
• Removing endocrine disrupting nonylphenols (NPs) and nonylphenol ethoxylates (NPEs) iodine from dairy production and replace with available alternatives; and
• Continuing to improve the science supporting ongoing decisions of the NOSB.

(See below for details and opportunity to submit comments on these with one click!)

Previously, Beyond Pesticides has reported on three additional priority issues, including;

• Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production;
• Eliminate nonorganic ingredients in processed organic foods as a part of the Board’s sunset review of allowed materials; and 
• Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment. 

(Please see the prior action on these issues and submit comments, if not done previously.)

Beyond Pesticides asks the public to join in commenting on priority issues that protect health and the environment as part of the upcoming NOSB meeting. The NOSB is receiving written comments from the public on key issues, preceding the upcoming public comment webinar on April 23 and 25 and deliberative in-person hearing April 29 through May 1—concerning how organic food is produced. Written comments must be submitted by 11:59 pm EDT April 3 through the link provided below. Sign up for a 3-minute comment to let U.S. Department of Agriculture (USDA) know how important organic is at the webinar by April 3. Links to the virtual comment webinars will be provided approximately one week before the webinars.

Beyond Pesticides has indicated that a strong and growing organic sector is critical to taking on the challenges of health threats, biodiversity collapse, and the climate emergency, and that the review and updating of organic standards require public involvement in the current public comment period. With this process, organic undergoes continuous improvement. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But organic will only grow stronger with public participation in voicing positions on key issues to the stakeholder advisory board, the NOSB, according to Beyond Pesticides. 

>> Submit your written comment to the National Organic Standard Board by April 3 by clicking HERE.

The NOSB is responsible for guiding USDA in its administration of the USDA organic label under the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health. Other than organic, there is no food label category that is defined in federal law and fully embraces health and biodiversity protection and enhancement, offers ongoing opportunities for public input and oversight, and is enforced with an inspection and certification system. Your comments help to make our food system what we need it to be for health, regenerative practices, and sustainability of the planet.

A draft meeting agenda is available here.  And a detailed agenda, along with the proposals, are available here.

Written comments are due by 11:59pm ET Wednesday April 3rd, 2024, as well as registration for Oral Comments. Oral Comment sign-ups fill up fast. Sign up for Oral Comments here.

The NOSB plays an important role in bringing the views of organic consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2024 Beyond Pesticides’ issues webpage.

Here are some of our high priority issues for the upcoming NOSB meeting (see others here):

• Make elimination of plastic in organic a research priority. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well documented. We need research into ways to replace all forms of plastic in organic production and handling.
  
  Microplastics—plastic fragments less than 5mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.
  
  Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products.
  
  The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics (of which 90% are at the nanoscale) with a majority containing unidentifiable chemicals. The number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. When they exposed cod eggs, embryos, and larvae to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans.
  
  Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta.
  
  
• Remove toxic nonylphenol ethoxylates from teat dips. Iodine, whose use in teat dips will be considered for relisting, is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors containing nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), in the class known as alkylphenols and their ethoxylates, are strong endocrine disruptors with impacts on many species, including gender changes. A number of alternatives are available. NPEs were banned in Europe ten years ago (in all products), and China has banned dairy product imports with NPE residues above 10 ppb. There are many commercially available non-NPE iodine-based disinfectants and teat dips that can be used instead. Iodine “without alkylphenols or alkylphenol ethoxylates” should only be listed.
  
  
• Improve the science upon which the NOSB bases decisions. The NOSB Policy and Procedures Manual (PPM) states, “A Subcommittee cannot proceed with a recommendation to list a material if it is determined that there is insufficient valid scientific information on that material’s impact on the environment, human health and its compatibility with organic principles.” When proposals have been based on Technical Reviews using the current template, they have frequently contained inadequate scientific support. These shortcomings often involve ancillary substances, nanoparticles, and excluded (GE) methods. The changes proposed on the agenda will improve the NOSB’s ability to make decisions based on science.

Comment Opportunities

• Oral Comments: The NOSB will hear oral public comments via virtual webinars on Tuesday, April 23, 2024, and Thursday, April 25, 2024, from 11:00am to approximately 5:00pm (Eastern time) OR Monday, April 29.
  
  
• In-Person Comments: In Milwaukee, WI from 2:00 to (approximately) 5:00 pm CT. Each commenter wishing to address the Board must pre-register by 11:59 p.m. ET on April 3, 2024, and can register for only one speaking slot. Instructions for registering and providing oral comments can be found HERE. The NOSB will meet in person in Milwaukee, WI, from Monday, April 29 through Wednesday, May 1, from approximately 9:00am to 6:00pm CT each day.

(Beyond Pesticides, March 29, 2024) Last week during National Agriculture Week, U.S. Senator Ben Ray Luján (D-NM) introduced S.4038, the Children’s Act for Responsible Employment and Farm Safety (CARE), aiming to elevate labor standards for young workers in the agricultural sector, as protection from pesticides remains weak. Currently, agriculture stands as the sole industry that permits children—as young as 12 years old—to work without significant limits on their hours of employment outside of school time. This scenario is a reality for hundreds of thousands of children across the U.S., who undertake the demanding tasks of planting, harvesting, processing, and packaging the food produced nationwide.

The CARE Act proposes to align the age and working hour criteria for underage workers in agriculture with those enforced in other sectors. Additionally, the legislation seeks to toughen both civil and criminal penalties for violations of child labor laws and to enhance safeguards for children against the risks of pesticide exposure. It is important to note, however, that the CARE Act would exempt farm-owning families, allowing their children to work on the family farm under the current guidelines.

Exemptions to the Fair Labor Standards Act (FLSA) currently allow children to work unlimited hours, outside of school  hours, in “non-hazardous” agricultural at the age of 12 and child farmworkers may perform may perform any agricultural job, including hazardous work, as of the age of 16. These exemptions apply only to farm labor and are significantly less stringent than laws applying to other sectors. 400,000-500,000 children and youth between the ages of 12-17 are estimated to be working in U.S. agriculture, with children ages 12-13 permitted to work in agriculture outside of school hours. Children ages 14-15 may work in nonagricultural jobs only with strict limitations on time of day and hours per week, but may work in agriculture outside of school hours without any restrictions. S.4038 will make the restrictions for agriculture child labor consistent with non-agriculture labor. Note: The CARE Act would not apply to the children of farmers working on their family farm.

Related legislation, the Fairness for Farm Workers Act (H.R. 4579/S. 2253), introduced in 2023 by U.S. Representative Raúl Grijalva (D-AZ) and U.S. Senator Alex Padilla (D-CA), would amend FLSA to provide overtime and additional minimum wage protections for farm workers. Upon introduction, Senator Padilla said, “It’s past time we correct our nation’s labor laws to include the farm workers who have been unjustly excluded from protections.”

Disproportionate Impact and “Agricultural Exceptionalism”

Creating true equity for farmworkers and specifically farmworker children, advocates point out, would require an overhaul of the laws governing pesticide use and exposure. Current law governing pesticide registration by the U.S. Environmental Protection Agency (EPA) is challenged as not adequately protective. The Food Quality Protection Act (FQPA), which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA), specifically excludes occupational exposure to pesticides from the calculation of cumulative or aggregate health risk from dietary and nondietary exposure. This means that children’s exposure to pesticides while employed in agriculture is excluded when determining the acceptable rates of their overall pesticide exposure. The statutory language of FQPA requires EPA to evaluate all exposure to the residues in food, water, and land of pesticides with a “common mechanism of toxicity” (e.g., families of chemicals like organophosphates and synthetic pyrethroids), but does not require that occupational exposure be included in that calculation.

A report released in January, US pesticide regulation is failing the hardest-hit communities. It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report, which follows an earlier article (see earlier coverage), documents the long history of “agricultural exceptionalism,” whereby agriculture is specifically excluded from many U.S. labor and occupational safety laws, can exacerbate the well-documented pesticide risks that farmworkers face on the job. 

What is the CARE ACT?

The CARE Act revises FLSA to update agricultural child labor age and work hour standards to match those for non-agricultural child labor, while still maintaining exemptions for family farms, 4-H, and educational or vocational programs that promote agricultural careers.

Key points in the legislation:

• It preserves and broadens exemptions for children working on family farms, ensuring they can continue to contribute to family agricultural operations.
• The legislation significantly raises civil and criminal penalties for child labor law violations, with civil penalties going up to $151,380 and penalties for serious violations leading to death or serious injury up to $690,000, both adjusted for inflation. Criminal penalties could reach $750,000 or include up to five years of imprisonment.
• It eliminates exceptions that currently allow for hand harvest laborers under 16 and reduces children’s exposure to pesticides by repealing certain worker protection standards. Additionally, it extends FLSA child labor protections to independent contractors, requires annual injury reports including workers’ ages to Congress, and mandates improved data sharing between the Department of Labor’s Occupational Safety and Health and Wage and Hour Divisions.
• The proposed law mandates that, within 90 days after its enactment, the Assistant Secretary of Labor for Occupational Safety and Health and the Administrator of the Wage and Hour Division must sign a memorandum of understanding. This agreement aims to enhance coordination and enforcement between the Occupational Safety and Health Administration (OSHA) and the Department of Labor Wage and Hour Division by sharing information and facilitating enforcement activities. This includes sharing records and reports related to worker injuries, illnesses, or fatalities, especially those involving children under 18. Additionally, the Assistant Secretary of Labor for Occupational Safety and Health is to encourage state agencies with approved state plans to participate in this information sharing. The memorandum is to be modeled after a similar agreement that was effective on May 4, 2023.

Risks to All Farmworkers, Children Uniquely Vulnerable

Children, in particular, face unique risks from pesticide and toxic chemical exposures. Due to their smaller body size, they absorb a higher relative amount of pesticides through the food they consume and the air they breathe. Additionally, children’s developing organ systems make them more vulnerable to the impacts of toxic exposure. Several authoritative bodies, including EPA, the National Academy of Sciences, and the American Public Health Association, have all voiced concerns about the potential dangers that pesticides pose to children. Scientific evidence has shown that pesticide exposure can negatively impact a child’s neurological, respiratory, immune, and endocrine systems, even at low levels. Some pesticides, such as synthetic pyrethroids, organophosphates, and carbamates, are known to cause or exacerbate asthma symptoms.

A specific example of the failure of EPA to protect children and specifically child farmworkers is found in the case of chlorpyrifos, a previously banned organophosphate insecticide under a federal court ruling, only to be overturned on appeal by the agrichemical and conventional agriculture industry. Beyond Pesticides has long reported on the multitude of twists and turns in EPA’s actions on chlorpyrifos, see background and a timeline of developments here. Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA’s action to allow its continued use a failure of both its protective mission and ethics. Further, it is an environmental justice failure, given that risks of exposure fall disproportionately on low-income African American and Latino families, including farmworker families, who are at the greatest risk of harm.

Despite several years of study, the science addressing neurodevelopmental effects [of the insecticide chlorpyrifos] remains unresolved,” as reported in The New York Times. This conclusion contradicts both ample scientific evidence and the agency’s own findings. Beyond Pesticides has repeatedly advocated for a ban on the use of chlorpyrifos because of the grave risks it poses. In 2019, Rep. Nydia Velásquez (D-NY) introduced the Ban Toxic Pesticides Act, H.R.230 to ban the insecticide chlorpyrifos from commerce. “It’s unconscionable for EPA to turn a blind eye as children and workers are exposed to this poison,” Rep. Velázquez said.  “If the EPA won’t do its job when it comes to chlorpyrifos, then Congress needs to act—and do so quickly.” No similar legislation has been introduced in the current Congress.

Current State and Federal Legislation

In 1938, the U.S. Congress enacted FLSA to enhance the welfare of workers, notably by restricting the employment of minors in severe forms of child labor. FLSA exempts certain types of agricultural work, permitting children aged fourteen and above to engage in non-hazardous farm tasks outside school hours. It also allows twelve and thirteen-year-olds to participate in such activities with a parent’s or guardian’s permission. The act specifically identifies eleven agricultural jobs as hazardous, which children under sixteen are prohibited from undertaking. Additionally, there are roles deemed hazardous for minors aged 16 to 18. The Department of Labor is responsible for FLSA’s enforcement.

States may pass their own child labor laws, but FLSA is seen as the “floor.” In other words, if a state law is less restrictive than FLSA, then FLSA will be the standard that employers must follow. If the state law is more restrictive than FLSA, then the state law will be the standard that employers must follow.

As documented in the U.S., according to the Department of Labor’s website, states like Alabama, Delaware, Georgia, Kansas, Kentucky, Louisiana, Maryland, Mississippi, Montana, Nebraska, North Carolina, Oklahoma, Rhode Island, Tennessee, Texas, West Virginia, and Wyoming have largely exempted agricultural labor from their child labor regulations. Meanwhile, California, Hawaii, New Hampshire, Washington, and Wisconsin stipulate that individuals must be 18 to engage in farm work during school hours. Furthermore, 14 states have designated 14 as the minimum age for children to work on farms outside of school hours. 

Federal legislation has been introduced often over many years and finds stiff opposition from big agricultural-industrial interests, including an earlier version of the CARE Act in 2023. U.S. Sen. Cory Booker (D-N.J.) also reintroduced legislation in February 2023 to increase protections against exposure to toxic pesticides. The Protect America’s Children from Toxic Pesticides Act (PACTPA) of 2023 includes a ban on the highly toxic pesticide paraquat, which is known to cause Parkinson’s disease, as well as dangerous organophosphates and neonicotinoids. The legislation addresses foundational weaknesses in federal law and the pesticide registration process that have resulted in U.S. approval of numerous pesticides already banned by many other nations.

More on Disproportionate Impact

The authors of the above-mentioned report on disproportionate harm—Nathan Donley, environmental health science director at the Center for Biological Diversity and Robert Bullard, known as the “Father of Environmental Justice” and executive director of the Robert D. Bullard Center for Environmental and Climate Justice at Texas Southern University in Houston—address the impact on child farmworkers. 

Children remain unprotected:

• Following recommendations from the National Academy of Sciences, the Food Quality Protection Act of 1996 (FQPA) established a mandate that the EPA further protect children from pesticide harm due to their heightened susceptibility to chemical exposures. This protection came in the form of a 10X safety buffer, reducing allowable exposures to all people from pesticides by tenfold as a way of protecting young children and the developing fetus. Given that children are more susceptible to harm from pesticides and children of color are more likely to be exposed to pesticides, this was widely seen as one way to protect the most vulnerable of at-risk populations.
• Unfortunately, Congress’s intent regarding protecting young children from pesticides has never been fully realized. The National Research Council found that the EPA only put in place the tenfold child safety factor for five out of 59 pesticides it analyzed, and a larger analysis of more than 400 pesticides by the U.S. Government Accountability Office (GAO) found that only 22% had the full safety factor utilized in approval decisions. A more recent analysis of 47 pesticides similarly found that only a small minority of pesticides that are present in food had any safety buffer incorporated for children.
• The lack of adequate protections can hit certain communities particularly hard. For instance, over 50% of migrant children in the U.S. have an unmet health need compared to just over 2% of all children living in the U.S. Compounding stressors can significantly increase the sensitivity of children to pesticides and other pollutants. Without added protections, children of color and those in low-income households are more likely to remain unprotected.

While OSHA is responsible for monitoring chemical exposures in various sectors, EPA has yet to implement mandatory biological monitoring for agricultural workers exposed to harmful pesticides. Such monitoring, involving the analysis of blood or urine to confirm exposure levels are not hazardous, is operational for certain pesticides through state-led initiatives in California and Washington. Findings from these programs indicate that harmful physiological effects can occur from pesticide exposure even when applied correctly and without immediate symptoms. Instituting a nationwide policy for biological monitoring, inspired by these state efforts, could mitigate risks for agricultural workers nationwide. This will take a concerted effort that rejects the chemical-by-chemical approach to reform, which at the current pace will not meet the urgency of the existential crises that we face as a nation and globe. The solution lies with proven organic methods to manage agricultural production, land spaces, and buildings without toxic chemicals. Reform legislation in Congress must meet the urgent need to make this a transformational moment.

Solutions to Protect Child Farmworker Safety and Fair Labor Standards

Advocates, including Beyond Pesticides, argue that the “precautionary principle” should be widely adopted across United States regulatory frameworks. This principle suggests a fundamental change in how government regulators approach the approval of activities that could lead to pollution. It encourages asking, “What is the minimum possible harm?” instead of, “What level of harm is acceptable?”  Implementing this approach means setting a more stringent, science-backed threshold for proving a chemical’s safety. It grants regulators the authority to preemptively halt potentially harmful actions when safety is uncertain and promotes a thorough investigation into less harmful alternatives. Although pesticides have adverse effects on child health and development, too little research has examined pesticide exposure among child farmworkers.

For more background on deficiencies in farmworker protection, see Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety.

Consumer food choices have a direct effect on those who grow and harvest food production around the world. This is why food labeled organic is the right choice. Certified organic food eliminates the most hazardous pesticides to which farmworkers are exposed in chemical-intensive agriculture. At the same time, an organic diet eliminates these pesticide residues in food and reduces a number of health threats like diabetes and increases brain function. In addition to mitigating serious health concerns associated with petrochemical pesticides and fertilizers, our decisions at the supermarket not only influence agricultural practices, but have a direct impact on the health and safety of farmworkers and their families. Advocates urge everyone to know where their food comes from and eat organic and fairly traded foods whenever possible and say thank you to those who grow and harvest our food. 

For more information on the importance of eating organic food for you, farmworkers, and the environment, please see Beyond Pesticides’ Eating with a Conscience and Organic Agriculture webpages.

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

Sources:

Senate Bill 4038: Children’s Act for Responsible Employment and Farm Safety (CARE) (S.4038)

During Ag Week, Luján Introduces Legislation to Improve Child Protections and Safety Standards for Agriculture Industry, Press Release, March 21, 2024

US pesticide regulation is failing the hardest-hit communities. It’s time to fix it., Brookings Institution, Nathan Donley, Robert Bullard, January 18, 2024

Pesticides and environmental injustice in the USA: root causes, current regulatory reinforcement and a path forward, Nathan Donley, Robert Bullard, Jeannie Economos, BMC, April 2022

(Beyond Pesticides, March 28, 2024) Last week, Maine Central reported the first application was filed for Maine’s first-in-the nation PFAS (per- and polyfluoroalkyl substances) Fund. This $70 million federal-state Fund to Address PFAS Contamination (PFAS Fund) provides compensation for commercial farmers whose health, business, and land have been impacted by PFAS contamination. A critical component of this fund enables the state to purchase contaminated farmland at fair market, pre-contamination value, which in the state of Maine hovers at approximately $3,729 per acre when including estimated market value of land and buildings, according to newly released data in the 2022 Census of Agriculture. “Maine became the first state to ban sludge recycling and approve a 2030 ban on PFAS in nonessential products,” according to reporting by Maine Central.

The state of Maine has exhibited extraordinary leadership in prioritizing public health, ecosystems, and the environment, setting an example for addressing a widespread contamination problem at the local, state, and national level. However, advocates in Maine are raising warnings after the Maine Department of Environmental Protection, according to reporting by Portland Press Herald, proposed “a compromise plan to regulate the sale of products containing forever chemicals [which] would exempt some federally regulated industries such as the automotive, aeronautical, and defense sectors from [the] 2030 ban on the sale of products that contain forever chemicals, even if a safer chemical alternative is available.” Beyond Pesticides will continue to track updates on this proposed plan as more details emerge. 

Jim Britt, Maine Department of Agriculture, Conservation, and Forestry (DACF) spokesperson, shared in a March 18 press release the expanded funding opportunities through the PFAS Fund, building on the framework of the existing PFAS Response Program: “Commercial farmers who have been impacted by PFAS contamination can now apply for an expanded suite of financial support programs:

• Administrative Cost Grants: A one-time grant intended to partially compensate commercial farms for time spent on activities common to most farms upon the initial discovery of PFAS contamination.
• Income Replacement Payments: Commercial farms that have stopped selling some or all products due to PFAS contamination may apply to DACF for up to a total of 24 months of lost income support, adjusted for inflation, while they avail DACFs technical assistance to determine a viable path forward.
• Technical Assistance / Professional Services: Financial support for professional services to help guide recovery efforts (e.g., business planning).
• Clean Feed Assistance: Short-term financial support for clean feed when it is necessary for the health and welfare of livestock and when clean feed is not available from the farm.
• Equipment and Input Cost Grants: Financial support for equipment and related input costs to allow a commercial farm to convert its operations to accommodate new products and production methods.
• Infrastructure Grants: Financial support for infrastructure projects (permanent physical assets and structures) that will help a commercial farm transition to new products and production methods.
• Debt Service on Existing Loans: Payments toward loan obligations directly related to farm infrastructure built/installed just prior to the discovery of PFAS contamination.
• New Loan Assistance: Financial support for costs associated with obtaining new loans.”

A growing list of state governments and industry actors are moving to phase out and ultimately ban PFAS in consumer products:

• “Maine, Minnesota, and Washington have given state agencies the authority to ban PFAS in a wide range of products.
• Twelve states, including California, Colorado, Connecticut, Hawai’i, Maine, Maryland, Minnesota, New York, Oregon, Rhode Island, Vermont, and Washington, have enacted phase-outs of PFAS in food packaging.
• Eight states, including California, Colorado, Maine, Maryland, Maine, New York, Vermont, and Washington, have adopted restrictions on PFAS in carpets, rugs, and/or aftermarket treatments.
• Six states, including California, Colorado, Maryland, Minnesota, Oregon, and Washington, are taking action to eliminate PFAS in cosmetics.
• Twelve states, including California, Colorado, Connecticut, Hawai’i, Illinois, Maine, Maryland, Minnesota, New Hampshire, New York, Vermont, and Washington, have banned the sale of firefighting foam containing PFAS.
• 32 unique retail chains, [including Burger King, McDonald’s, Starbucks, Sweetgreen, among others,] have committed to eliminating or reducing PFAS in food packaging, textiles and/or other products.”

Significant documentation and scientific research indicates the adverse health effects of PFAS for humans, wildlife, ecosystems, and environmental justice communities. A 2023 Environmental International study published by the U.S. Geological Survey (USGS) reveals that 45% of U.S. tap water is contaminated with at least one of the more than 12,000 types of PFAS. This percentage is likely to be on the low end, according to USGS Survey authors, given that only 32 of the 12,000 types of PFAS are detectable by their lab tests. The U.S. Environmental Protection Agency (EPA) last year proposed new limits to PFAS levels in drinking water. The urgency of public health implications for PFAS is stark, given that they have been found in water supplies in nearly 3,000 locations in all 50 states and two territories. PFAS chemicals have also been found in human breast milk, umbilical cord blood, deer meat, fish, and beef. One study using data from the National Health and Nutrition Examination Survey (NHANES) found PFAS compounds in 97% of Americans. Studies have suggested a wide range of health effects, including raised cholesterol levels, high blood pressure or pre-eclampsia during pregnancy, and increased risk of kidney cancer. Just as Bayer/Monsanto have faced waves of lawsuits regarding failure to warn liability claims of the severe adverse health impacts on their product labels, industrial chemical companies have faced similar scrutiny in the legal realm. In 2023, DuPont, Chemours, and Corteva agreed to a $1.185 billion dollar settlement with cities and towns across the United States to cover the cost of PFAS remediation and monitoring in public drinking water systems. To learn more about policy action, litigative history, and scientific literature, see the Daily News Archive on PFAS.

Beyond Pesticides is committed to eliminating the use of toxic petrochemical pesticides, including PFAS, by 2032. To realize this goal, we continuously engage grassroots organizers, communities, and cross-cutting movements in actions to contact state legislatures, Congress, and federal agencies. In 2024 alone, there are two ongoing actions to participate in including “Tell Your Delegate to Protect Marylanders from ‘Forever’ PFAS Pesticides” and “Tell Congress to Protect Farmers and the Public from PFAS.”

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

Sources: Central Maine, Maine Department of Agriculture, Conservation, and Forestry

(Beyond Pesticides, March 27, 2024) A preliminary experiment conducted by Public Employees for Environmental Responsibility (PEER) reveals concerning levels of toxic per- and polyfluoroalkyl substances (PFAS) on the skin of soccer players and coaches after playing on artificial turf fields. The Washington Post reported on March 12 on the PEER test results, which found PFAS levels increased on the skin in three out of four participants following soccer matches on artificial turf. In contrast, no similar increase was observed after games on natural grass fields. The presence of PFAS is alarming due to their association with several serious health issues, including cancer, birth defects, and developmental and immune deficiencies, among others.

The U.S. Environmental Protection Agency (EPA) writes that PFAS exposure risks are particularly concerning for young children, who are more susceptible due to their developing bodies and at risk for higher levels of exposure than adults. Known as “forever chemicals” for their persistence in the environment, PFAS continue to accumulate in the human body, posing long-term health risks. Kyla Bennett, PhD, science policy director at PEER and a former scientist and lawyer with EPA, emphasized the need for further research. “Although this study is preliminary, it highlights the potential risk of dermal absorption of PFAS from artificial turf,” Dr. Bennett stated. She also pointed out the significant gap in our understanding of PFAS exposure through skin contact, a potentially major pathway of exposure. Larger scale scientific studies are currently underway; as The Washington Post noted, “Wayne State University researchers are preparing to conduct a study on whether the chemicals found in turf can affect the endocrine system. For more information, please see Beyond Pesticides reporting on PFAS adding to the legacy of persistent toxics hurting generations of people and the environment.

“If the intent was to spread PFAS contamination across the globe, there would be few more effective methods than lacing pesticides with PFAS,” said Dr. Bennett. Her remarks underscore the significant environmental impacts as these chemicals can leach into surrounding surface and groundwater, posing a threat to drinking water sources. In addition, broader systemic impacts are emerging in addition to the direct contamination of water. As Beyond Pesticides reported, PFAS persistence is due to a fluorine–carbon atom bond being among the strongest ever created. PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply, among other resources, is a ubiquitous and concerning contaminant across the globe.

With health risks including developmental and endocrine system disruption, reproductive harm, cancer, and damage to the liver, kidneys, and respiratory system, PFAS presents a chronic danger that demands action. According to Dianne Woelke, a retired nurse and member of Safe Healthy Play Fields, “PFAS chemicals are so toxic that they are measured in parts per trillion,” Ms. Woelke said. “For every 80,000 square feet of plastic turf, there is between one and 38 pounds of various PFAS chemicals.” She further elaborates on the toxicity of the tire crumbs in between the synthetic blades of turf—found to contain over 350 chemicals. “Parents need to be made aware… just because a consumer product has been made for sale does not mean it is safe.”

States and local communities are taking action

The United States has an estimated 12,000 to 13,000 synthetic turf sports fields, with over a thousand new installations each year. Activists have sparked increased efforts to limit or remove artificial turf from various settings, including schools, parks, and professional sports arenas, spurring states and local governments to take action. New York has banned the sale of artificial turf with PFAS, starting at the end of 2026, and recognizes that recycling artificial turf can be a greenwashing fallacy (see NRDC 2022). Bills prohibiting the purchase of new artificial turf fields in select locations, such as schools, have also been introduced in Massachusetts and Vermont. In addition, California passed a 2023 bill banning the sale of PFAS-containing artificial turf, but it was not signed into law last year by Governor Gavin Newsom, who sought stronger enforcement and signaled that the issue could return in this legislative year. Newsom did allow cities and counties to again ban artificial turf when he signed a new law reversing a previous law preventing, or preempting, local governments from banning artificial turf. As Times of San Diego reported in October 2023, some California cities have already begun moving to prohibit synthetic lawns, including Millbrae in San Mateo County and San Marino in Los Angeles County. “Emerging research is making it clear that artificial turf poses an environmental threat due to its lack of recyclability and presence of toxins such as lead and PFAS,” said state senator Ben Allen, a Redondo Beach Democrat who authored the state bill. With the new law, “Local governments will again be able to regulate artificial turf in a way to both protect our environment in the face of drought and climate change but also by preventing further contribution to our recycling challenges and toxic runoff,” he said.

Organically managed natural grass is an overlooked solution

Beyond Pesticides and local advocates are fighting with a campaign to bring organically maintained natural grass into the ongoing discussions about artificial turf use. Cortney Jansen, a concerned parent from Sunnyvale, California, expressed her views to the Fremont Union High School District regarding this matter. Despite concerns, the district has agreed to replace six fields with new synthetic turf. [A notable conflict of interest, highlighted by the situation in Sunnyvale—the landscape consultant and construction firm engaged to provide impartial advice on turf replacement was the same entity granted a $14.5 million contract to carry out the work. This consultant was initially tasked with evaluating various alternatives for the replacement of 12 artificial turf fields due for removal before reaching their expected lifespan of eight to ten years.]

Testing for PFAS in artificial turf

Testing for PFAS in water is well defined. For an in-depth discussion that explains the science for non-science audience, please see Toxics Use Reduction Institute (TURI) at University of Massachusetts Lowell fact sheet, Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf Carpet. As TURI notes, testing for PFAS presents significant challenges due to the vast number of compounds within this class and their ability to cause adverse effects at very low concentrations. While testing methods for drinking water and wastewater have been developed, there is a lack of standardized guidelines for assessing PFAS in solid materials, such as artificial turf components. One important way to overcome these challenges includes developing techniques for assessing the total concentration of fluorine-containing organic compounds, which do not specifically target PFAS but indicates their presence. The importance of fluorine atoms as a proxy to measure the presence of PFAS is recognized by 20 states and is the subject of Maryland’s proposed HB1190 bill that would ban pesticides that contain PFAS. Read Beyond Pesticides’ call to action here and testimony here.

Does the synthetic turf industry know this and harken back to the tobacco industry’s playbook? In an email to the Washington Post, Melanie Taylor, the president and chief executive of the Synthetic Turf Council (STC), a trade association for the industry, pointed to the tests showing the presence of PFAS in soil. “STC has worked with its members to ensure their products contain no intentionally added PFAS constituents,” Ms. Taylor said. Advocates note that the real explanation for PFAS contaminated soil could be from pesticides containing PFAS commonly used on conventional natural grass turf, the same PFAS containing pesticides that are the subject of Maryland’s proposed ban.

Given the extreme toxicity of PFAS, its alarming ubiquity, its persistence, and the cost of remediating contaminated drinking water, there is an urgent need to do all we can to stop adding it to the environment. As the federal government has been slow to regulate the industry, local residents, and communities have taken up the call to eliminate the use of PFAS. One impactful area that can be addressed at this level is land management. 

A common and dangerous misconception is that the options for community athletic fields are limited to synthetic turf or synthetically managed natural turf. This is a false dichotomy. There is a third option that avoids both sources of PFAS: organically managed natural turf. Organic management practices build soil health, cycle nutrients naturally, enhance turf resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers. The organic alternative is central to a community’s discussion about its residents’ commitment to the elimination of practices and products that are petrochemical-based and the ability of organically managed soils to draw down (sequester) atmospheric carbon as a reasonable price point—even factoring in water and labor costs.

To take action, sign up to be a Parks Advocate today to encourage your community to transition to organic land management! For more information on the Parks for a Sustainable Future program, please reach out to our team at [email protected].

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

Sources:

PFAS in Artificial Turf Coats Players’ Skin, Dermal Uptake Little Examined Exposure Pathway for Toxic PFAS, PEER, March 12, 2024  

Turf fields may have ‘forever chemicals.’ Should kids be playing on them? The Washington Post, March 12, 2024

Dermal uptake: An important pathway of human exposure to perfluoroalkyl substances? Environmental Pollution, August 15, 2022

Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf Carpet, Toxics Use Reduction Institute (TURI) University of Massachusetts, Factsheet, February 2020

Gestational and childhood exposure to per- and polyfluoroalkyl substances and cardiometabolic risk at age 12 years, Environment International, February 2021

Organic vs Chemical Land Management Differentiating Two Approaches Beyond Pesticides, Pesticides and You, Winter 2019-2020

Recycling Lies: “Chemical Recycling” of Plastic Is Just Greenwashing Incineration, Natural Resources Defense Council, September 2022

The Devil they Knew: Chemical Documents Analysis of Industry Influence on PFAS Science, Annals of Global Health, 2023

PFAS in Artificial Turf Technical Report, New Jersey Department of Environmental Protection Division of Science and Research, Sandra Goodrow, Ph.D., February 2023

(Beyond Pesticides, March 26, 2024) The authors of a case study in Canale D’Aiedda, Taranto, Italy, published in Scientific Reports, conclude that, “[T]he results of monitoring and modeling activities revealed a chronic risk associated with the presence of Cu [copper] from November to April in several river reaches and acute risk associated to the presence of glyphosate in several reaches mainly in the wet season.”  According to the authors, “The most important factor influencing the chronic risk for Cu were the combination of two factors: the high surface runoff and the Cu applications. The most important factor influencing the glyphosate peaks of concentration is the streamflow.”

The authors of the study measure the flow of pesticide concentrations through the soil and water assessment tool (SWAT). The ecotoxicological data was collected at two stations in Germany that flow into Italy, within the Canale d’Aiedda basin. The streamflow was monitored between August 2017 and December 2019. Out of hundreds of pesticides and six metabolities investigated in this study, “only traces of copper and glyphosate were found.” The authors continue, “The banks and the bed of the river system are almost all covered by concrete. The hydrological regime is natural and intermittent in the upstream part of the basin, while it is almost perennial, in the remaining area, due to the presence of the discharges from three wastewater treatment plants (WWTPs), located in the municipalities of Montemesola, Monteiasi, and San Giorgio Ionico.”

While the researchers found significant levels of glyphosate and copper in the study area, they also acknowledge the potential gaps in the SWAT model. “The SWAT model performed satisfactory and good for Cu and glyphosate, respectively. However, it underestimated measured concentrations for both compounds,” as the study reports. “This could depend on the fact that SWAT does not simulate the drift loss which occurs during a pesticide application[], it is still unable to spatially reflect the fate of the drifted part of particles explicitly due to oversimplification[]. Other sources of uncertainty, which could have influenced the results, are related to the quality and quantity of measurements (i.e. discrete data instead of continuous data) used for the calibration and to the temporal discrepancy between the calibration of the streamflow and the calibration of the pesticides concentration[]. Similarly, the input data (i.e. application rates of the pesticides), which were derived from regulations or from the safety sheet, could be affected by a large uncertainty and they have had a key role in the modelling pesticides concentrations [].”

There are years of scientific studies and reporting that indicate the adverse ecological and public health consequences of widespread glyphosate-based herbicide use in agriculture and land management. A 2023 study in Chemosphere points out that glyphosate exhibits strong evidence of genotoxicity, epigenetic alterations (heritable changes in gene expression), oxidative stress, chronic inflammation, endocrine disruption, and disturbs gut microbiota implicated in lymphomagenesis (growth and development of lymphoma). See the Gateway on Pesticide Hazards and Safe Pest Management for more information and analysis of glyphosate harms. The petrochemical pesticide industry faces continuous litigation from victims of pesticide exposure, including Bayer/Monsanto on Roundup Ready. As of 2022, Bayer settled over 100,000 lawsuits on glyphosate/Roundup, paying out approximately $11 billion. The company faces an additional 30,000 lawsuits pending, according to reporting by Forbes. For a full history of litigation see, “Bayer/Monsanto in Roundup/Glyphosate Case Stung with Largest Multi-Billion Dollar Jury Award, Asks States to Stop Litigation.”

Copper is widely used in agriculture, both conventional and organic for fungal and bacterial diseases in a wide range of crops, including orchards and vegetable production. It is also widely used to treat utility poles throughout communities. Under the Organic Foods Production Act, “The National List [of Allowed a Prohibited Substances] may provide for the use of substances in an organic farming or handling operation that are otherwise prohibited under this title only if” the synthetic allowed materials fit in several categories including copper.

Copper sulfate is widely used in organic rice production to control algae and an invertebrate known as tadpole shrimp. Most of the world transplants rice seedlings into flooded paddies. Dryland rice production eliminates the need for control of tadpoles, which eat the rice seedlings in flooded fields. Ironically, tadpole shrimp are regarded as a biological control for algae. In 2021, the Crops Subcommittee of the National Organic Standards Board (NOSB) acknowledged the following:

It appears that to date there is sufficient evidence to conclude that:

1. use of copper sulfate in rice fields can cause environmental damage,
2. alternative seeding practices could eliminate the need for copper sulfate as both algae and tadpole shrimp cease to be problematic once seedlings are established, and
3. international standards do not allow for spraying of copper sulfate for organic rice production.

Copper sulfate is a toxic pesticide that has documented incidents of adverse impacts on reproductive, kidney, and liver health. A recent study found that copper sulfate has an association with the development of Parkinson’s disease. Studies also found that copper sulfate is moderately toxic to birds, and it is toxic to fish and aquatic organisms. In previous years, Beyond Pesticides has called for expanded research to determine alternatives to copper sulfate and continues to call for its phase-out of organic agriculture. A 2023 study published in Science of the Total Environment identifies a progressive decline among three endpoints: motor skills, cognitive function, and mental health regarding depression. Markedly, individuals living near residential areas or working in occupations with higher exposure to copper sulfate experience a rapid decline in all endpoints.

The NOSB has previously discussed alternative growing systems that would eliminate the need for copper sulfate and made such alternatives a research priority. Copper sulfate is widely used in organic rice production to control algae and an invertebrate known as tadpole shrimp. Most of the world transplants rice seedlings into flooded paddies. Dryland rice production eliminates the need for control of tadpoles, which eat the rice seedlings in flooded fields. Ironically, tadpole shrimp are regarded as a biological control for algae.

Beyond Pesticides encourages the public to engage with the National Organic Standards board to end the use of all toxic petrochemical pesticides. Every six months the NOSB hosts meetings, reviews allowed substances, and continuously updates their review to ensure the integrity of the organic label and the protection of health and the environment.  People are encouraged to see Beyond Pesticides’ Keeping Organic Strong webpage to learn about next month’s NOSB meeting and a link for submitting comments (due April 3, 2024).

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

Source: Scientific Reports

(Beyond Pesticides, March 25, 2024) Because of their widespread infiltration into the environment and the bodies of all organisms, including humans, plastics contamination requires a holistic strategy to protect life— with consideration given to practices and chemical use that reduce or eliminate harm. Pesticides and other toxic chemicals are adsorbed (adhered) to microplastics, resulting in bioaccumulation and widespread contamination. This adds to the complexity of the problem, which is largely ignored by federal regulatory agencies. While most environmental policies attempt to clean up or mitigate health threats, new data reinforces the need to stop the pipeline of hazardous chemicals, wherever possible.

With new data on the harm associated with plastics and related contamination, it becomes urgently necessary for all government agencies to participate in a comprehensive strategy to eliminate plastics and pesticides. Beyond Pesticides points to the evolving science on plastics contamination and their interaction with pesticides as yet another reason to transition to holistic land management systems that take on the challenge of eliminating hazardous chemical use. Organic land management policy creates the holistic systems framework through which plastics can be eliminated.

>> Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food.

The human and environmental health implications of plastic and related contamination are becoming increasingly well documented. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—on a wide range of organisms. 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. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. A study published by researchers at Columbia and Rutgers universities in the January 2024 Proceedings of the National Academy of Sciences reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale.

Researchers at Norway’s MicroLEACH project published a study that analyzes the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys and balloons. They found, as in previous studies, that many hazardous chemicals are in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown.

In the Columbia/Rutgers study, the researchers checked for seven types of plastic, but they were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. (Tap water also contains microplastics in many places, although in much lower concentrations.) The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.” The Norwegian scientists also exposed cod eggs, embryos and larvae to water containing microplastics. The toxic effects they observed include spinal deformities reminiscent of scoliosis in humans.

In other new studies, out of a total of 257 patients who completed the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles been found in human lungs, blood, feces, and breast milk. They have even shown up in the brain as well as the placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

>> Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food.

Letter to EPA:

Because of the adsorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask EPA to develop drinking water standards and ambient water quality standards for microplastics. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size. 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. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

Researchers at Columbia and Rutgers universities in the January 2024 Proceedings of the National Academy of Sciences reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Researchers checked for seven types of plastic but were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. Tap water also contains microplastics in many places. The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.”

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown. They also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) leach out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

Please do your part to eliminate microplastics from our water supplies.

Thank you.

Letter to USDA:

Because of the adsorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask USDA to discourage the use of plastic in agriculture. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size. They 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. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

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.

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown. The scientists also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

Please do your part to eliminate microplastics from our food and environment by discouraging the use of plastic mulch and other plastics in agriculture.

Thank you.

Letter to FDA:

Because of the adsorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask FDA to develop standards for food containers and food contact materials to eliminate movement of plastics and associated contaminants into food and bottled water. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—which 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. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

A study published by researchers at Columbia and Rutgers universities reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Researchers were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. Tap water also contains microplastics in many places, although in much lower concentrations. The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.”

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. The scientists also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and the placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

Please do your part to eliminate microplastics from our food and water supplies.

Thank you.

(Beyond Pesticides, March 22, 2024) With long-running efforts to keep organic land management in the forefront of public health and environmental measures to eliminate petrochemical synthetic substances, including pesticides and fertilizers, plastic again emerges as an increasing threat in a study linking microplastics to cardiovascular disease. The study by Italian researchers, published in the March 7 issue of the New England Journal of Medicine, finds an elevated risk factor for heart attack and stroke associated with plastics found in the plaque of the majority of patients’ carotid arteries. A holistic approach to agriculture that embraces principles and values to enhance biodiversity and protect health, the organic system requires that synthetic substances are compatible with that system. In this context, the environmental and public health effects of plastics are increasingly subject to scrutiny as they permeate nearly every aspect of food production, including fields, crops, foods, and food packaging.

Plastics also migrate from other sectors into agriculture via wind and water and are now ubiquitous in every environment. Removing plastics from any ecosystem is extremely problematic, so getting them out of agriculture will be difficult – but necessary, given the accumulating evidence of their toxicity.

Beyond Pesticides continues to push for eliminating plastic use in organic agriculture. The organization is urging the U.S. Department of Agriculture’s National Organic Standards Board (NOSB) to increase its research into ways to accomplish this. The NOSB is accepting online public comments on its policy goals until April 3 this year. In a recent comment to the NOSB, Beyond Pesticides notes that major sources of plastic inputs to agriculture include plastic mulches, compost, and leachate that migrate from landfills into ground and surface water. Beyond Pesticides has identified key issues, available here, and urges the board to take important actions regarding microplastics and compostable materials.

Beyond Pesticides’ comment states that in addition to their direct harm to health, microplastics “also act as carriers of toxic chemicals that are adsorbed to their surface.” For example, many plastics contain additives such as bisphenol A, organotins and phthalates, all known endocrine disrupters, and these can hitch a ride on the plastic particles. The letter continues, “Some studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.” Studies have shown that microplastics migrate into many human tissues, including the lungs, liver, breast milk, urine, blood, and the placenta.

The universal distribution of plastics ensures that they cannot be avoided. Humans and other organisms take up plastics in the form of micro- and nano-particles by inhalation, ingestion, and skin contact every day. Micro-plastics are about the width of a human hair; nano-plastics are much smaller, about twice the width of a DNA strand. Larger pieces of plastic are ground down to these tiny sizes by weathering, temperature, biological processes, and chemical conditions.

Emerging evidence shows that plastics affect many organs and physiological processes. They can influence cellular metabolism, cell signaling, iron transport, and other vital cellular processes. As scientists find closer connections among various systems previously considered separate, such as gut health, mental health, and immune responses, plastics’ effects on cardiovascular health are attracting more scrutiny. Plastics can impair heart function. They can induce several markers of oxidative stress and associated inflammation. Pregnant mice fed microplastics developed disturbed gut microbes and changes in lipid metabolism, including cholesterol levels, which are factors in cardiovascular disease.

The Italian researchers studied a group of 257 hospital patients who had been diagnosed with plaque in their carotid arteries, a major risk factor for heart attack and stroke. Plaque is a sticky goo of cholesterol and fats that narrows arteries. The researchers examined each patient’s plaque for the presence of microplastics. (They added micro- and nano-scale sizes together in their analysis.) They found two types of plastic out of the 11 they looked for: polyethylene (PE) and polyvinyl chloride (PVC), two chemically related compounds used globally in massive quantities. At 36 percent of the global plastics market, PE is the highest-production non-fiber plastic in the world; PVC is third at 12 percent.

More than half of the full group of patients had PE in their plaque; 12 percent had PVC. The team divided their subjects into those with microplastics and those without microplastics and followed both groups for 34 months, tracking their incidence of cardiovascular events. At the end of the study period, the scientists found that the group with microplastics was at “a higher risk of a composite of myocardial infarction, stroke, or death from any cause” than the group without microplastics. The team tested a set of inflammation markers in the plaques, finding sharply higher levels in the group having microplastics in their plaque. They also checked collagen levels in the plaque as an indicator of activity by lymphocytes and macrophages, immune cells with a role in cardiovascular disease development, finding higher levels associated with the microplastics group.

The study results were adjusted to account for age, sex, body mass index, total cholesterol, diabetes, hypertension, and other conditions. The patients with microplastic-laden plaques were younger, more likely to be male, less likely to have hypertension, more likely to be diabetic, and to have heart disease and high cholesterol. They were also more likely to smoke. Thirty of 150 patients with microplastics in their plaque died or had non-fatal cardiovascular events, while only eight out of the 107 patients without microplastics experienced such events. 

Size matters at the scale of these plastic particles. The smaller the particle, the farther it can travel and the more types of tissues it can enter. Nanoplastics are in the size range of viruses, which means they may enter individual cells. The present study’s authors suggest that nanoplastics likely account for the bulk of the plastics in the plaques. In addition, the smaller a particle, the larger its surface area in proportion to its mass. This makes micro- and nanoplastics able to carry relatively high amounts of absorbed chemicals like pesticides, increasing their effects. And more surface area increases the likelihood of chemical reactions with other substances in the environment, so that the microplastics themselves may be more reactive with biochemistry than their larger versions. Nanoscale particles can also cross the blood-brain barrier. These properties have not been comprehensively assessed for their role in health risks, but they are of increasing concern regarding the smallest particle sizes.

It is also dawning on researchers that plastics’ full chemical interactions with biology are only dimly comprehended and not confined to any compound’s disclosed ingredients. Beyond Pesticides’ letter to NOSB cites a Norwegian study finding that “the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys and balloons…could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products. This suggests that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown.” This problem applies to micro- and nano-plastics to an even greater degree, partly because of the abovementioned property of increased chemical reactivity with increased surface area at small scales.

A 2017 Science Magazine review titled “Production, use and fate of all plastics ever made” observed that “without a well-designed and tailor-made management strategy for end-of-life plastics, humans are conducting a singular uncontrolled experiment on a global scale, in which billions of metric tons of material will accumulate across all major terrestrial and aquatic ecosystems on the planet.”

As widely recognized, plastics are a form of fossil fuel, and it is not just its contribution to the climate crisis that is of concern. Their intractable ubiquity makes the urgency of removing plastics to the greatest extent possible from food production systems all the more dire. Plastic production must be cut drastically back, and a way to recover and sequester even the smallest particle sizes must be developed and implemented without delay. Fossil fuels must, from now on, be left in the ground rather than extracted, extruded, and distributed as micro- and nano-scale invaders of the biosphere.

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

Sources:
Microplastics and Nanoplastics in Atheromas and Cardiovascular Events, N Engl J Med 2024;390:900-10, DOI: 10.1056/NEJMoa2309822, https://www.nejm.org/doi/full/10.1056/NEJMoa2309822; PVC, other microplastics found in clogged arteries: Medical News Today, March 12, 2024, https://www.medicalnewstoday.com/articles/pvc-other-microplastics-found-in-clogged-arteries; Production, use, and fate of all plastics ever made, Roland Geyer, Jenna R. Jambeck, Kara Lavender Law, Science Magazine, July 2017, https://www.science.org/doi/epdf/10.1126/sciadv.1700782; The need for environmentally realistic studies on the health effects of terrestrial microplastics, Lauren Mills, Joy Savanagouder, Marcia de Almeida Monteiro Melo Ferraz and Michael J. Noonan, Microplastics and Nanoplastics,  https://doi.org/10.1186/s43591-023-00059-1, https://microplastics.springeropen.com/articles/10.1186/s43591-023-00059-1; Farm animals as a critical link between environmental and human health impacts of micro-and nanoplastics, Hilde Aardema, A. Dick Vethaak, Jorke H. Kamstra & Juliette Legler, Microplastics and Nanoplastics, volume 4, Article number: 5 (2024), https://microplastics.springeropen.com/articles/10.1186/s43591-024-00082-w; Interactions of Microplastics with Pesticides in Soils and Their Ecotoxicological Implications, Aránzazu Peña, José Antonio Rodríguez-Liébana and Laura Delgado-Moreno, Agronomy (2023) 13(3), https://doi.org/10.3390/agronomy13030701, https://www.mdpi.com/2073-4395/13/3/701; Nanoplastics and Human Health: Hazard Identification and Biointerface, Hanpeng Lai, Xing Liu, and Man Qu, Nanomaterials, April 2022, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9026096/, Genotoxic and neurotoxic potential of intracellular nanoplastics: A review, Claudio Casella and Santiago J Ballaz, Journal of Applied Toxicology, 24 February 2024, https://analyticalsciencejournals.onlinelibrary.wiley.com/doi/epdf/10.1002/jat.4598; Microplastics derived from plastic mulch films and their carrier function effect on the environmental risk of pesticides, Xin Bao, Yuntong Gu, Long Chen, Zijian Wang, Hui Pan, Shiran Huang, Zhiyuan Meng, Xiaojun Chen, Science of the Total Environment, 10 May 2024, https://www.sciencedirect.com/science/article/pii/S0048969724016139?via%3Dihub

(Beyond Pesticides, March 21, 2024) Alarming levels of a hazardous pesticide plant growth regulator linked to reproductive and developmental effects, chlormequat, is found in 90% of urine samples in people tested, raising concerns about exposure to a chemical that has never been registered for food use in the U.S. but whose residues are permitted on imported food. Published in the Journal of Exposure Science and Environmental Epidemiology in February 2024 and led by Environmental Working Group toxicologist Alexis Temkin, PhD, a pilot study finds widespread chlormequat exposure to a sampling of people from across the country. U.S. Environmental Protection Agency (EPA) regulations only permit the use of chlormequat on ornamental plants and not food crops grown in the U.S. As explained in the journal article, “In April 2018, the U.S. EPA published acceptable food tolerance levels for chlormequat chloride in imported oat, wheat, barley, and some animal products, which permitted the import of chlormequat into the U.S. food supply.” In 2020, EPA increased the allowable level of chlormequat in food. Then in April 2023, EPA proposed allowing the first-ever U.S. use of chlormequat on barley, oat, triticale (a hybrid of wheat and rye), and wheat. Existing regulatory standards explain the higher detections of the chemical in U.S. residents tested, as observed in the study and pending domestic use allowances will only increase exposure further. Advocates note that this study on one pesticide reflects systemic failures in the regulatory review process. 

Like many other pesticides, exposure to chlormequat raises significant concerns about the potential impact on public health, as animal studies have linked chlormequat to reduced fertility, harm to the reproductive system, and altered fetal growth, including negative impacts on reproduction and post-birth health, and proper weight and bone development. The study notes that published toxicological research has found potential health effects from chlormequat exposure at doses lower than the current regulatory limits set by the EPA and European Food Safety Authority (EFSA). 

Additionally, chlormequat residues are found in over 90% of conventional oat-based products, while organic food products showed minimal contamination. The report argues the necessity for ongoing biomonitoring to assess the potential health impacts of chlormequat exposure at environmentally relevant levels, especially during critical periods such as pregnancy. Advocates point to the chlormequat findings as evidence of the importance of supporting organic agriculture and organic food products as a means of avoiding harmful chemical exposure.

Research findings and methods

This study investigates the presence of chlormequat in urine samples collected from adults in the U.S. between 2017-2023. Study results detect chlormequat in most urine samples, with detection frequencies increasing from 69% in 2017 to 90% in 2023. Food products purchased in the U.S. and U.K. were also tested, with chlormequat found more frequently in U.S. non-organic oat products than wheat. U.K. oat food samples have 15 times higher chlormequat levels than U.S. samples. The study suggests exposure levels may rise further if chlormequat is approved for domestic agricultural use in the U.S. It raises potential health concerns given toxicology studies linking chlormequat exposure to reduced fertility and impacts on fetal growth.

Toxicological effects at doses lower than EPA’s allowed reference dose (and below the safety limit set by the European regulatory agency)

The pervasive presence of chlormequat in the U.S. population and its detection in conventional oat-based and some wheat-based products demand a comprehensive reevaluation of the risks associated with this chemical, which should raise alarm at the EPA’s current consideration of allowing chlormequat to be used in the U.S. on non-organic agricultural products. The report notes, “Additionally, the regulatory thresholds do not consider the adverse effects of mixtures of chemicals that may impact the reproductive system, which have been shown to cause additive or synergistic effects at doses lower than for individual chemical exposures [22], raising concerns about the potential health effects associated with current exposure levels, especially for individuals on the higher end of exposure in general populations of Europe and the U.S.”

Specifically, the report noted that animal studies showed:

• Mice and pigs exposed to doses under the EPA’s reference dose (allowed exhibited reduced fertility, harm to the reproductive system, and altered fetal growth.
• Pregnant mice exposed to a dose equal to the no observed adverse effect level used to set the EPA limit experienced altered fetal growth and metabolic/body composition changes in neonatal mice.

Additionally, the regulatory thresholds do not account for potential additive or synergistic effects from mixtures of chemicals that impact the reproductive system, as some studies have demonstrated.

This raises concerns that the current exposure levels in some populations, especially those with elevated exposures, could still pose health risks. The study argues that the toxicology research suggests a reevaluation of the safety thresholds may be warranted to better protect public health, and expanded biomonitoring is warranted. Beyond Pesticides advocates for consumers to avoid unnecessary exposure by eating organic food and certified organic food products and to support a systemic change to organic and regenerative organic agriculture.

Assessing chlormequat exposure in U.S. food products purchased between 2022 and 2023

To assess whether chlormequat levels detected in U.S. urine samples correspond to potential dietary exposure, analysis was conducted on oat and wheat-based food products acquired in the U.S. during 2022 and 2023. Results found that non-organic oat products contain chlormequat with a median concentration of 104 parts per billion (ppb). This variability could be attributed to differences in product sourcing, including domestic versus Canadian origins (chlormequat is widely used in Canadian grain crops, while not currently allowed in U.S. agriculture), and whether the oats were treated with chlormequat. In contrast, U.K. food samples demonstrated a higher prevalence of chlormequat, especially in wheat-based products like bread, where 90% of samples had detectable chlormequat levels, and in oat products, where levels were over 15 times higher than those found in U.S. samples. Beyond Pesticides reported in 2014 on U.K. contamination of bread supply, when it was found that over 60% of the country’s bread supply was tainted with chlormequat and glyphosate pesticide residues.  

The presence of chlormequat in urine samples prior to 2018 suggests exposure despite the absence of established food tolerance levels for this pesticide in the U.S. The study hypothesizes that such exposure likely resulted from dietary sources, considering chlormequat’s rapid degradation. According to the authors, “These data indicate likely continuous exposure given the short half-life of chlormequat in vivo, with low levels from 2017 to 2022 and higher exposure levels in 2023.” The formation of chlormequat from choline precursors in wheat and egg powder has been observed under the high temperatures used in food processing, leading to concentrations ranging from 5 to 40 ng/g. These findings imply that dietary exposure to chlormequat could stem from its formation during food processing and from imported products treated with chlormequat. Factors such as geographical location, dietary habits, and occupational exposure in environments like greenhouses could influence individual exposure levels.

This research underscores the need for a broader and more varied analysis of processed foods to thoroughly investigate potential dietary sources of chlormequat, especially in individuals with elevated exposure levels. Future research should encompass the examination of historical urine and food samples, alongside dietary and occupational surveys, to provide a comprehensive understanding of chlormequat exposure sources within the U.S. population. Given that chlormequat is presently restricted to imported oat and wheat products in the U.S., with its domestic use on non-organic crops under review by EPA, there is potential for increased chlormequat levels in the food supply and, consequently, higher exposure levels among the U.S. population.

This study constitutes the first biomonitoring of chlormequat presence in the urine of adults in the United States, expanding the scope of monitoring beyond limited research focused on the United Kingdom and Sweden. A comprehensive pesticide biomonitoring effort involving over 1,000 Swedish adolescents from 2000 to 2017 revealed a 100% detection rate for chlormequat, underscoring the widespread use of chlormequat in the UK, European Union (and Canada), and resulting human exposure levels. 

The discernible spike in urinary chlormequat concentrations in 2023, relative to preceding years, is potentially indicative of its recent introduction into the American food chain, a development that coincides with EPA  of permissible chlormequat levels in food in 2018 and an increase in these limits for oats in 2020.

In assessing whether the urinary chlormequat concentrations reflected potential dietary exposure, this research measured chlormequat levels in oat and wheat-based food products available in the U.S. market in 2022 and 2023. Oat products exhibited a higher frequency of chlormequat presence compared to wheat products, with significant variability in chlormequat content among oat-based items, potentially attributable to differences in sourcing of oats from the U.S. versus Canada. The study suggests that exposure to chlormequat predates 2018, prior to the establishment of food tolerance levels in the U.S., hypothesizing that such exposures were likely dietary in nature given chlormequat’s short half-life. The absence of chlormequat monitoring in U.S. food products and historical data complicates this assertion. However, the natural formation of chlormequat from choline precursors under high-temperature conditions typical of food processing has been documented, leading to chlormequat concentrations within a similar specific range. The variability in chlormequat levels observed in food samples, including those from the only organic oat-based product out of eight organic oat products tested, had low levels of chlormequat, aligning with this phenomenon of natural formation, and suggesting dietary exposure as a plausible source of the pre-2023 urinary chlormequat levels. The elevated levels detected in 2023 may result from dietary exposure to naturally occurring chlormequat and the consumption of imported, chlormequat-treated products. What is unequivocal is the widespread use of chlormequat in Canada, the U.K., and the European Union, where, as previously noted, human biomonitoring studies showed the U.K. and Sweden have almost 100% exposure in the population tested. 

Solutions found in buying organic oat and wheat products, supporting organic farming

Organic food products have been found to have zero contact with pesticides unless due to herbicidal drift from other farming operations. The best defense against pesticide exposure is, whenever possible, choosing to purchase and consume organic. For more information on pesticide residue exposure for different organic versus non-organic forms of common produce, please check out the pages on Eating with a Conscience and Buying Organic Products (on a budget!). For those with some background experience or interest in gardening, see Grow Your Own Organic Food for best practices, tips, and resources to get started. If you believe that you were exposed to pesticides, please click to access our section on Pesticide Emergencies.

Beyond Pesticides continues to closely monitor potential EPA actions to register chlormequat for use in the U.S. on non-organic crops. Click here to subscribe to action alerts and a weekly newsletter of the Daily News! 

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

Sources

A pilot study of chlormequat in food and urine from adults in the United States from 2017 to 2023, Journal of Exposure Science and Environmental Epidemiology, February 15, 2024 https://www.nature.com/articles/s41370-024-00643-4 

A mixture of 15 phthalates and pesticides below individual chemical no observed adverse effect levels (NOAELs) produces reproductive tract malformations in the male rat, Environment International, November 2021 https://www.sciencedirect.com/science/article/pii/S0160412021002403

Maternal chlormequat chloride exposure disrupts embryonic growth and produces postnatal adverse effects, Toxicology, September 2020 https://pubmed.ncbi.nlm.nih.gov/32622971/

Currently used pesticides and their mixtures affect the function of sex hormone receptors and aromatase enzyme activity, Toxicology and Applied Pharmacology, 2013 https://www.sciencedirect.com/science/article/abs/pii/S0041008X13003013  

(Beyond Pesticides, March 20, 2024) A report by CBAN unpacks the ecosystem and wildlife health impacts of genetically engineered (GE) corn in the context of Mexico’s 2023 decision to stop its importation into the country. The phase out of genetically modified (GM) corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA), which replaced the North American Free Trade Agreement (NAFTA) as the primary vehicle for North American trade policy. In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban. There has been no public update from the Office of the U.S. Trade Representative as of this writing.

The CBAN report highlights the scientific rationale underpinning Mexico’s decision to “safeguard the integrity of native corn from GM contamination and to protect human health” with this ban. In 2020, Mexico announced a four-year phase-out of the weed killer glyphosate, which along with other petrochemical herbicides is integral to GM corn production. When Mexico’s Minister of the Environment announced the phase-out, he said it is part of an effort to transform the country’s food system to one that is “safer, healthier and more respectful of the environment (más seguro, más sano y respetuoso con el medio ambiente).” The Minister said that Mexico would be looking to Indigenous farming practices as an alternative. In addition to traditional agriculture, Beyond Pesticides points to organic agricultural practices as a systems approach that simultaneously prohibits the use of toxic petrochemical pesticides such as glyphosate and genetically engineered crops.

The CBAN report explains the background on the USMCA trade deal:

“The United States and Canada are challenging the measures in Mexico’s Presidential Decree of February 13, 2023 that pertain to the use of genetically modified [corn]:

• [A]n immediate ban on the use of GM corn for human consumption (white corn intended for use in dough and tortillas);
• [T]he revocation of existing GM corn authorizations and a halt to future approvals; and
• [A] phase-out of the use of GM corn for animal feed and processed food ingredients.

Mexico’s decree also phases out the use of the herbicide glyphosate but this measure is not being challenged by the US and Canada. Mexico already bans the cultivation of GM corn.”

The USMCA was adopted with the stated goal of creating “a more balanced environment for trade, will support high-paying jobs for Americans, and will grow the North American economy.”

In deciding to ban GE corn, Mexico compiled a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, the CBAN report states, “Most GM corn plants are genetically modified to kill insect pests. The GM plants express a toxin from the soil bacteria Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects but not others. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops are different from this natural Bt in structure, function, and biological effects.” The report continues, “In fact, peer-reviewed studies across the scientific literature continue to find that Bt toxins in GM plants can harm insects (spiders, wasps, ladybugs, and lacewings, for example) that are not the intended targets.”

Similar to the threat of pesticide drift is the threat of genetic drift -typically pollen from a GE crop field being carried by wind or pollinators like honey bees, which are known to travel six miles or further. The National Organic Standards Board, in a unanimous vote in the spring of 2012, sent a letter to Secretary of Agriculture Tom Vilsack saying, “We see the potential of contamination by genetically engineered crops as a critical issue for organic agricultural producers and the consumers of their products. There are significant costs to organic producers and handlers associated with preventing this contamination and market loss arising from it.” 

Within Mexico, there is over a decade of judicial and executive actions against the spread of GE and genetically modified crops, as well as the use of toxic petrochemical pesticides. As reported by Beyond Pesticides in 2013: “[A] judge in Mexico issued an injunction against the planting and selling of genetically engineered (GE) corn seed, effective immediately, within the country’s borders. The decision comes nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, citing the need for more research. The decision prohibits agrichemical biotech companies, including Monsanto, DuPont Pioneer, Syngenta, PHI Mexico, and Dow AgroSciences, from planting or selling GE corn seed in Mexico.” Then in 2020, Mexico announced the phase out of glyphosate from use or importation into the country by 2024. Mexico joins several other nations that have issued bans, including Germany (the country where Bayer was founded), Luxembourg, and Vietnam. See Genetic Engineering for a list of resources regarding state and local action against GE crops and the corresponding section on Daily News.

The U.S. government and corporate agribusinesses have a history of intervening when other countries or advocates in the U.S. move to ban glyphosate use or advance restrictions on genetically engineered or modified crops. Farmers and environmentalists have taken action in an effort to prevent the proliferation of new pesticide products, including Enlist Duo (glyphosate and 2,4 D hybrid with inert ingredients). A 2017 Daily News reported that: “[A] coalition of farmers and environmental and public health organizations filed a lawsuit against the Environmental Protection Agency (EPA) for approving agrochemical giant Dow Chemical’s toxic pesticide combo, Enlist Duo, among the newer more highly toxic pesticide mixtures used in genetically engineered (GE) herbicide-tolerant crops. Comprised of glyphosate and 2,4-D (50% of the mixture in the warfare defoliant Agent Orange), Enlist Duo is typically marketed alongside commercial crops like corn, cotton and soybeans that are engineered to withstand pesticide exposure, leading to problems of resistance and driving the evolution of super weeds.” A 2023 Daily News reported, “British biotechnology company Oxitec is withdrawing its application to release billions of genetically engineered mosquitoes in California, according to a recent update from the California Department of Pesticide Regulation.” EPA approved the us[e of] a nucleic acid—double-stranded RNA (dsRNA)–called “interfering RNA, or RNAi—to silence a gene crucial to the survival of the Colorado Potato Beetle (CPB), the scourge of potato farmers around the world. (See Daily News.)

Beyond Pesticides continues to support advocates who are passionate in our mission statement of abolishing toxic petrochemical pesticides by 2032. In the spirit of human and ecological health, advocates in our network believe that organic land management and farming principles are the primary pathway forward to make these toxic practices obsolete. See Organic Agriculture and Keeping Organic Strong to learn about the health and environmental benefits of organic land management principles and opportunities to strengthen the National Organic Program as the next National Organics Standards Board (NOSB) meeting begins at the end of this month. See Parks for a Sustainable Future to learn more about the importance of organic land management principles in the context of public parks at the city and county level.

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

Source: Canadian Biotechnology Action Network

(Beyond Pesticides, March 19, 2024) This month the United Nations Environmental Programme (UNEP) announced the creation of a new initiative to combat the health and environmental impacts of toxic petrochemical pesticides in agriculture. Launched by seven countries—Ecuador, India, Kenya, Laos, Philippines, Uruguay, and Vietnam—the Financing Agrochemical Reduction and Management (FARM) Programme is a $379 million initiative that “will realign financial incentives to prevent the use of harmful inputs in food production.” This international cohort aims to phase out the use of “toxic persistent organic pollutants (POPs)—chemicals which don’t break down in the environment and contaminate air, water, and food.” The work of FARM echoes Beyond Pesticides call for the banning of toxic petrochemical pesticides by 2032.

The program will help countries implement their commitment to eliminate POPs and plastics in agriculture. As it is described, “FARM…will support government regulation to phase out POPs-containing agrochemicals and agri-plastics and adopt better management standards, while strengthening banking, insurance and investment criteria to improve the availability of effective pest control, production alternatives and trade in sustainable produce.” The 2001 Stockholm Convention on Persistent Organic Pollutants requires signatories to adopt a range of measures to reduce and, where feasible, eliminate the release of POPs. All FARM members are signatories and most ratified the Convention as of 2006, with Laos being the most recent to ratify in 2013.

“The five-year programme is projected to prevent over 51,000 tons of hazardous pesticides and over 20,000 tons of plastic waste from being released,” according to the latest UNEP press release. “[W]hile avoiding 35,000 tons of carbon dioxide emissions and protecting over 3 million hectares of land from degradation as farms and farmers convert to low-chemical and non-chemical alternatives,” the release continues. FARM is supported by the Global Environmental Facility, UN Development Programme, UN Industrial Development Organization, and the African Development Bank. The goal of FARM is, “for banks and policy-makers to reorient policy and financial resources towards farmers to help them adopt low- and non-chemical alternatives to toxic agrochemicals and facilitate a transition towards better practices.” Beyond Pesticides applauds this important step FARM countries are taking to transition away from pesticide dependency; however advocates reiterate the importance of organic land management principles as an opportunity to adopt a systems change framework rather than a product substitution framework that replaces toxic pesticides with less toxic pesticides. According to the U.S. Environmental Protection Agency (EPA), POPs are “intentionally produced chemicals currently or once used in agriculture, disease control, manufacturing, or industrial processes” and “unintentionally produced chemicals…that result from some industrial processes and from combustion.”

There are cascading socio-ecological impacts of toxic pesticides, including POPs, that has been widely documented. (See Daily News.) Organochlorine compounds (OCs), including organochlorine pesticides (OCPs) and polychlorinated biphenyls (PCBs), are examples of persistent organic pollutants that cause adverse health impacts to wildlife including humpback whales and pandas. A 2021 study published in Environmental Pollution identifies, among female whale populations, “levels of POPs in blubber are higher in juveniles and subadults than in adults, primarily from the transference of contaminants from the mother to her calf.” The study goes on to report previously unknown adverse health impacts, “including reproductive toxicity, immune dysfunction, and increased susceptibility to disease.” Meanwhile, a 2021 study published in Environmental Pollution found that the “Quinling Panda species [‘the rarest subspecies of giant pandas’] are generally exposed to moderate levels of OC pollution. Higher levels of OCs are present in captive pandas relative to wild pandas. The authors identify PCB and OCP residues as coming from atmospheric transportation. At the same time, the study identifies PCBs as a cancer risk to the pandas, in fact the most notable toxicant with the highest carcinogenic risk index of PCB 126 (the most potent highly toxic industrial byproduct that incites numerous adverse physiological effects).”

Beyond individual animal species, POPs are emerging in remote ecosystems such as coral reefs and Arctic glaciers, leading to harmful impacts and long-term implications for biodiversity and human health. A 2021 study published in Chemosphere based on coral reefs in the South China Sea, “indicate[d that] 17 of the 22 OCPs are detectable in seawater, and all 22 OCPs are detectable in ambient air samples from the SCS. The most prominent chemicals found in air and water samples are CHLs, HCBs, DDTs, and Drins. Although coastal corals have higher chemical concentrations than offshore species, the chemical composition is similar, with DDT and CHL compounds dominant among tissue samples.” The presence of OCPs in the South China Sea raises serious concerns about the long-term biodiversity impacts as they cause adverse health impacts on animals and humans alike, including “respiratory issues, nervous system disorders, and birth deformities to various common and uncommon cancers.” A 2020 study published in Environmental Science and Technology found that POPs are found to be re-released after bioaccumulating in Arctic ice for decades, exacerbating the potential exposure levels facing marine animals, oceans, and humans as the climate crisis rages on and causes Arctic ice to melt in the coming decades. POPs are also found to have adverse health impacts on humans, including prenatal and early-life exposure leading to chronic illnesses such as developmental disorders to cancer. Persistent organic pollutants can also act like endocrine disruptors and studies link their exposure to female reproductive health disorders such as endometriosis.

As the U.S. EPA states, “Many POPs were widely used during the boom in industrial production after World War II, when thousands of synthetic chemicals were introduced into commercial use.” After the war, the chemical industry looked to commercialize the petrochemical pesticide products for use in pest management and public health. “Just as U.S. industry and public forged an alliance to prepare for World War II, advocates must join with farmers, public health advocates, scientists, and elected officials to demand a new regulatory approach in service of public health, environmental justice, and addressing the climate crisis,” says Max Sano, organic program associate at Beyond Pesticides. Advocates are steadfast in their belief that strengthening federal organic policy and standards will address the proliferation of toxic petrochemical pesticides into soil, waterways, and ecosystems. See Keeping Organic Stronger to learn how to engage in the National Organic Standards Board April meeting and public comment periods to engage in protecting and expanding climate-health-soil protections for the National Organic Program. See Pesticide-Induced Disease Database and Gateway on Pesticide Hazards and Safe Pest Management to view an ongoing list of scientific studies that link pesticide exposure, such as POPs, to chronic illnesses to learn how to engage with elected officials and participate in regulatory reviews with the aim of strengthening their regulation and minimizing additional exposure levels.

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

Source: United Nations Environment Programme

(Beyond Pesticides, March 18, 2024) Comments are due by 11:59 pm EDT on April 3, 2024. Organic standard setting provides for democratic input, full transparency, and continuous improvement. The current public comment period is an important opportunity for the public to engage with the organic rulemaking process to ensure that the National Organic Standards Board (NOSB) and the USDA National Organic Program uphold the values and principles set forth in the Organic Foods Production Act (OFPA). With the threats to health, biodiversity, and climate associated with petrochemical pesticide and fertilizer use in chemical-intensive land management, advocates stress that this is critical time to keep organic strong and continually improving.

Organic maintains a unique place in the food system because of its high standards, public input, inspection system, and enforcement mechanism. But, organic will only grow stronger if the public participates in voicing positions on key issues to the NOSB, a stakeholder advisory board. Beyond Pesticides has identified key issues for the upcoming NOSB meeting below!

The NOSB is receiving written comments from the public on key issues through April 3, 2024. This precedes the upcoming public comment webinar on April 23 and 25 and the deliberative hearing on April 29 through May 1—concerning how organic food is produced. Written comments must be submitted by 11:59 pm EDT on April 3 through the “click-and-submit” form linked or via Regulations.gov.

Sign up for a 3-minute comment to let U.S. Department of Agriculture (USDA) know how important organic is at the webinar by April 3. Links to the virtual comment webinars will be provided approximately one week before the webinars.  

>>Submit your written comment HERE to the National Organic Standard Board by April 3. (See high-priority issues below.)

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

A draft meeting agenda is available here.  And a detailed agenda, along with the proposals, are available here. 

Written comments are due by 11:59 pm ET on Wednesday, April 3, 2024, as well as registration for oral comments. Oral comment sign-ups fill up fast! >> Sign up for oral comments here.  

The NOSB plays an important role in bringing the views of organic consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2024 Beyond Pesticides’ issues webpage.  

Some of our high-priority issues for the upcoming NOSB meeting: 

• Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production. Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks” that might include, for example, “compostable” food containers. 
  
  Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don’t know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.” Biosolids—fortunately never allowed in organic production—should be a lesson to remember.  

• Eliminate nonorganic ingredients in processed organic foods as a part of the sunset review. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials. 
   
• Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment. The NOSB has passed repeated recommendations instructing USDA’s National Organic Program (NOP) to replace the generic listings for “inerts” that may be biologically and chemically active (currently using EPA Lists 3, 4A, and 4B “inerts”) with specific substances approved for use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert” ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.
  
  OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active” ingredients, but not to “inert” ingredients, which make up the largest part of pesticide products—up to 90% or more.
  
  A comparison of the hazards posed by active and “inert” ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts” than actives pose a hazard. The NOSB and NOP must act on “inerts” NOW and meet OPFA standards.

>> Submit your written comment HERE to the National Organic Standard Board by April 3. 

Comment to NOSB

I would like to address three priority issues in this comment that are of concern to me as a stakeholder in organic.

(1) Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production.
Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks” that might include, for example, “compostable” food containers. 

Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don’t know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.” Biosolids—fortunately never allowed in organic production—should be a lesson to remember.

(2) Eliminate nonorganic ingredients in processed organic foods as a part of the sunset review.
Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials.

(3) Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment.
The NOSB has passed repeated recommendations instructing USDA’s National Organic Program (NOP) to replace the generic listings for “inerts” that may be biologically and chemically active  (currently using EPA Lists 3, 4A, and 4B “inerts”) with specific substances approved for use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert” ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.

OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active” ingredients, but not to “inert” ingredients, which make up the largest part of pesticide products—up to 90% or more.

A comparison of the hazards posed by active and “inert” ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts” than actives pose the hazard. The NOSB and NOP must act on “inerts” NOW and meet the standards of the Organic Foods Production Act.

Thank you for your consideration of my comments.

(Beyond Pesticides, March 15, 2024) Toxic pesticides harm all beings and ecosystems, including coral reefs. Large benthic foraminifera (LBF) are single-celled organisms found on reefs that face adverse metabolic impacts after exposure to the weed killer glyphosate and insecticide imidacloprid, according to a study published in Marine Pollution Bulletin. The study found that “even the lowest doses of the fungicide and herbicide caused irreparable damage to the foraminifera and their symbionts.” Beyond Pesticides reiterates our mission of banning toxic petrochemical pesticides by 2032 and that this goal applies to land and water exposure to pesticides. LBFs are typically used as bioindicators for coral health because they are found in substantial quantities and gathering data is not intrusive or damaging to reef health.

Researchers in this study screened three different herbicides (one insecticide, one fungicide, and one herbicide) at three different concentration levels. The experiments were performed in six well-samples, each with 10mL of filtered artificial seawater and a singular LBF. The control plates are artificial seawater and the experimental plates include artificial seawater with the addition of three pesticides (imidacloprid, glyphosate, and tebuconazole). Each pesticide was applied at low, medium, and high doses to measure the direct impacts of each pesticide after dilution in seawater. The research team conducted two different experiments, one based on pulse-amplitude-modulation (PAM) fluorometry and the other to measure isotopic uptake. For the PAM fluorometry experiment the researchers “measured the photosynthetic performance of the photosymbionts [an organism in a photosymbiotic relationship] for two weeks at days 1, 3, 5, 7 and 14 using variable chlorophyll fluorescence imaging of photosystem II (PSII; Imaging PAM Microscopy Version–Walz GmbH; excitation at 620 nm). Measurement of the variable fluorescence over the maximum quantum yield fluorescence (Fv/fm) estimates the efficiency of photosystem II []. Fv/fm serves as a proxy for the vitality of the photosymbionts [] and therefore it can be used as an indicator of the health of the foraminifera themselves [].” In terms of the isotopic uptake experience, “Two-way ANOVAs (level of significance p = 0.05) were run to test if the type of pesticide, the concentration and/or incubation time significantly affected uptake of ¹⁵N and ¹³C, respectively. Significant results were further analyzed for group differences using Tukey’s post hoc test (level of significance p = 0.05).”

This study differs from existing literature in how the researchers quantified the impact based on amount of pesticide products rather than solely on the individual pesticides that make up the main ingredient of the targeted products. “Roundup© [with the active ingredient glyphosate] only contains 1 % glyphosate, in Pronto©Plus the active substance tebuconazole has 13.6 % and in Confidor© the imidacloprid concentration is 20 %, according to the manufacturer’s information,” says the research team. “Based on that, the concentration of active pesticide substances, which can be found in the environment are not a factor of 10 smaller than ours tested, they are approximately the same concentration or even 10 times higher.” The scientists in this study found that, “the photosynthetic area decreased as the amount of pesticide added increased and as the incubation time increased.” Glyphosate-based Roundup Ready in particular “caused a reduction of the photosynthetic area in all foraminifera…independent of concentration.” The scientists also found that, “Foraminiferal [inorganic carbon] ¹³C uptake was significantly reduced at the highest pesticide concentration compared to the control (p < 0.001). The herbicide and fungicide showed comparable reductions of ¹³C uptake (p = 0.945), the reduction caused by the insecticide was less pronounced.”

Oceans and water advocates continue to remind elected officials that we cannot talk about climate action without talking about oceans and waterways stewardship. Bodhi Patil, a UN-recognized oceans solutionist and co-creator of Ocean Uprise, a global activist accelerator initiative, guides his advocacy with the understanding that ocean health is human health. “Mitigating toxic pollutants, excess fertilizers, pesticides, and chemicals entering upstream water bodies and flowing into downstream reef ecosystems is a direct way to reduce the stressors on critically important coral reefs” says Bodhi. “Improved water quality and reduced water pollution will contribute to their long-term health and climate resiliency. We have to think about the ocean as a being that is connected to all waterways, because she is!”

Advocates have worked tirelessly to codify ocean rights in a United Nations-recognized framework as the impacts of toxic pesticides continue to impact ocean creatures big and small. In 2023, due to the years of advocacy by people like Bodhi, 193 nations approved the draft version of the High Seas Treaty (also known as Biodiversity Beyond National Jurisdiction), an international framework that establishes universal rights to protect the oceans from harm. To date, 88 countries have signed the treaty and two countries (Chile and Palau) have ratified the treaty in their national legislatures. At least 60 countries must ratify the High Treaty for it to become international law. The exorbitant loss of over 90% of planktonic organisms from the 1940 baseline is analogous to the decline in terrestrial pollinator loss over the past several decades. Additionally, “In its 2017 risk assessment for the most widely used neonicotinoid, imidacloprid, EPA found, ‘[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates.’ The agency evaluated an expanded universe of adverse effects data and finds that acute (short-term) and chronic (long-term) toxicity endpoints are lower (adverse effects beginning at 0.65 μg/L (micrograms per liter)-acute and 0.01 μg/L-chronic effects) than previously established aquatic life benchmarks (adverse effects from 34.5 μg/L-acute and 1.05μg/L-chronic effects).” Beyond Pesticides has reported on the linkage to the climate crisis and toxic petrochemical pesticide use in relation to aquatic organisms, oceans, and water.

Beyond Pesticides acknowledges the intersectional nature of the climate crisis and that pesticide drift and exposure (including glyphosate and imidacloprid) is a problem that applies to both terrestrial and marine environments. To avoid the introduction of toxic pesticides into ecosystems at the place of origin, advocates are calling on strengthening organic standards and providing new incentives to expand the domestic production and consumption of organic foods and products. See Keeping Organic Strong to learn how to engage with the National Organic Standards Board Spring 2024 meeting. Whether or not you live in a coastal city or along a waterway, see Parks for a Sustainable Future to learn about how to transition a higher education institution or a local parks department to organic land management principles.

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

Source: Marine Pollution Bulletin

 (Beyond Pesticides, March 14, 2024)  A recent review in the New England Journal of Medicine (NEJM) highlights the urgent need to address the widespread chemical pollution stemming from the petrochemical industry, underscoring the dire implications for public health. Tracey Woodruff, PhD, author and professor at the University of California San Francisco (UCSF), emphatically states in an email comment to Beyond Pesticides, “We need to recognize the very real harm that petrochemicals are having on people’s health. Many of these fossil-fuel-based chemicals are endocrine disruptors, meaning they interfere with hormonal systems, and they are part of the disturbing rise in disease.” Beyond Pesticides echoes this concern, noting that endocrine disrupting chemicals (EDCs) include many pesticides and are linked to a plethora of health issues such as infertility, diabetes, cardiovascular diseases, obesity, early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers.  (See Beyond Pesticides’ Disease database here and news coverage here). The review further calls on the clinical community to advocate for policy changes aimed at mitigating the health threats posed by petrochemical-derived EDCs and climate change. Beyond Pesticides urgently calls for the elimination of petrochemical pesticides and fertilizers and advocates for a systemic shift to organic regenerative agriculture.  This call to action is grounded in the understanding that the petrochemical industry’s growth poses existential threats to climate, human health, and biodiversity.  

Dr. Woodruff’s article adds to a series, “Fossil Fuel Pollution and Climate Change,” that NEJM launched in 2021. The journal joined with more than 200 health journals worldwide in publishing a joint editorial “calling for urgent action to limit greenhouse gas emissions to protect human health, adding to growing demands from around the globe.” 

Highlighting the explosive growth in petrochemical production, including plastics, pesticides, and fertilizers, Dr. Woodruff’s report draws a direct line between these activities and a growing burden of chemical exposure responsible for at least 1.8 million deaths annually. As the demand for oil and gas declines due to the shift toward renewable energy sources, multinational fossil-fuel corporations have ramped up the production of plastics and other petrochemicals. This transition is highlighted in the report as a significant factor driving both climate change and increased exposure to health-impacting chemicals through contaminated air, water, food, and a range of manufactured products (including plastics, pesticides, and consumer goods). This body of work is among numerous studies pointing to the far-reaching effects of endocrine disruption on both humans and wildlife. Endocrine disruptors can cause significant harm even at very low exposure levels, with embryonic and fetal development stages being particularly vulnerable to their adverse effects. The report notes, “Consequently, experts believe there is no risk-free level of exposure to these chemicals across the population.”  The report underscores the omnipresent nature of petrochemical-derived EDCs, noting that national biomonitoring data and epidemiologic studies have detected around 150 chemicals in human bodily fluids, including during pregnancy.  “This represents a fraction of potential EDC exposures, since standard detection technology measures less than 1% of totally chemicals in use,” the authors note.  

Of serious concern is the disproportionate impact on communities of color and low-income communities, contributing to health inequities. While the report sheds light on this disparity, it stops short of delving into the environmental justice issues specific to petrochemical pesticide use, which significantly affects farmworkers and their families (see here and here). While the report focuses on what healthcare clinicians can do to reduce EDC exposures for their patients (and includes a helpful example of an environmental exposure history and suggestions of how patients can protect themselves), Dr. Woodruff acknowledges that “most exposures are beyond individual control” and even when one chemical is removed from consumer products, the result is often a substitution of a similar toxic chemical.  

Regulatory Failure 

After a nearly two decade defiance of a federal mandate to institute pesticide registration requirements for endocrine disruptors, the U.S. Environmental Protection Agency (EPA) accepted public comments until last month on establishing a testing protocol for pesticides. (See here for comprehensive Beyond Pesticide comments). Advocates, including Beyond Pesticides, are criticizing the agency’s proposed evaluation as too narrow. EPA never completed protocol for testing potential endocrine-disrupting pesticides that disrupt the fundamental functioning of organisms, including humans, causing a range of chronic adverse health effects that defy the common misconception (and EPA risk assessment assumption) that dose makes the poison (“a little bit won’t hurt you”), when, in fact, minuscule doses (exposure) wreak havoc with biological systems. Beyond Pesticides detailed comments call for EPA to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine system risk per the mandate in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as amended by the 1996 Food Quality Production Act. Under FIFRA, there is an inherent presumption of risk, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine system risks to human health and wildlife, then the agency is obliged to deny registration of said pesticide. Further, it is not the agency but pesticide registrants that have the burden to demonstrate with adequate data that their products will not pose unreasonable adverse effects, including the inherently presumed endocrine-disrupting effects.  

Beyond Pesticide’s Call for an End to Petrochemical Pesticide and Synthetic Fertilizer Use by 2032 

The petrochemical industries’ growth is a driver of three existential threats: climate, human health, biodiversity. In addition to the petroleum used to produce synthetic pesticides, Beyond Pesticides has reported on the plastic saturation of the planet, including through the use of plastic coating of some synthetic pesticides and fertilizers, as well as treated seeds. The reliance on petroleum-based pesticides, fertilizers, and plastics reveals a deep connection of chemical-intensive agriculture to the climate crisis and biodiversity decline and establishes a vivid contrast to organic agriculture which eschews these inputs.​​  

The plastic problem is vast and complex. A 2022 study in Environmental Science & Technology reports that plastics caused chemical pollution has the potential to “alter vital Earth system processes on which human life depends.”  The inherent “chemically inert” property of plastics, once thought benign, has proven to be a double-edged sword. Under certain conditions, plastics are not benign at all; they can leach toxic chemicals into their surroundings. Moreover, plastics do not easily break down into their constituent compounds after their intended life. The result is a world where microplastics, pieces less than five millimeters in diameter, have suffused every ecosystem, as the Guardian reported from the heights of Everest to the depths of the oceans, and even in Antarctica. These microplastics, along with the toxicants they may carry, have entered the food chain, impacting marine organisms, terrestrial livestock, and humans through multiple exposure routes. 

Rising petrochemical production spells disaster for efforts to curb greenhouse gas emissions and avert climate catastrophe​​.  Agriculture is a major consumer of other plastic products, using them for purposes ranging from mulching to irrigation. The United States alone uses approximately 816 million pounds of agricultural plastics annually, with significant environmental implications due to the lack of recycling policies and the resultant soil contamination that affects crop yield and ecosystem health​​. As Center for International Environmental Law in its December 2022 reissued report, Sowing a Plastic Planet: How Microplastics in Agrochemical Are Affecting  our Soils, Our Food, And Our Future writes, “Non-plastic alternatives already exist for most of the agricultural uses of microplastics (organic and organic regenerative agriculture). Accordingly, there is no justification for allowing the continued use of microplastics in fertilizers and pesticides.”  In response to these and other challenges, the United Nations Food and Agriculture Organization (FAO) and other bodies have advocated for a return to traditional, organic farming practices that eschew synthetic materials in favor of organic mulch materials, cover crops, and nonchemical management strategies. These practices reduce dependence on fossil fuel-based inputs and thus, the negative climate, health, and environmental impacts.  Beyond Pesticides supports the transition to organic regenerative agriculture as a comprehensive solution to the myriad problems posed by chemical and plastic use in farming. Organic agricultural approaches offer numerous benefits over chemical methods, including enhanced safety for people and the environment, improved soil health, a more nutritious and nutrient dense food supply, in many cases, superior yields and and can mitigate the effects of agricultural greenhouse gas (GHG) emissions. As the Rodale Institute notes, conventional farming isn’t just contributing to the climate crisis, organic farming is essential to address it and wrote, “Organic methods can produce competitive yields in good weather and outperform conventional in times of drought or flooding, and organic uses less energy and generates fewer emissions while revitalizing the soil and sequestering carbon.  If we’re going to decrease farming’s impact—and we must decrease farming’s impact—then we need organic. Because farming doesn’t only contribute to climate change; it’s greatly affected by it. And it is getting harder and harder to grow food in extreme weather.”  

Solutions to Existential Crises of Climate, Human Health, and Biodiversity 

Beyond Pesticides noted in January 2023 that there is no solution to this wide array of crises that includes continued fossil fuel use. The organization wrote: “While the solutions are in reach, tremendous public action is needed to stop the fossil fuel and agrichemical industries from their short-sighted pursuit of profit at any cost…. Arguments are made that high intensity, industrial chemical agriculture is the only way to feed the world, and fossil fuels are the only way to provide energy. Scientific data has spelled out exactly what we are in for if we continue to endorse these dangerous myths.” With chemicals, like pesticides, long advanced by the synthetic pesticide and fertilizer industry as the answer to feeding the world, the United Nations  Special Rapporteur on the right to food concluded in 2017 that industrialized agriculture has not succeeded in eliminating world hunger, and has only hurt human health and the environment in its wake.  

Beyond Pesticides established the Parks for a Sustainable Future program to assist with the transition to organic land management in communities across the U.S. The organization also strives to maintain the integrity of organic standards through Keeping Organic Strong campaign and historical work to transition agriculture to organic practices. In 2022, Beyond Pesticides sponsored a Climate Change Calls for Phase Out of Fossil Fuels Linked to Petrochemical Pesticides and Fertilizer series of national virtual seminars (with archived videos) covering health, biodiversity, and climate. For more on climate-friendly organic agriculture, see Daily News and the groundbreaking work of the Rodale Institute, as captured in its Farming Systems Trial — 40-Year Report, which shows the efficacy and benefits of organic agriculture. California Certified Organic Farmers Association’s Roadmap to an Organic California provides a policy framework for advancing agricultural programs that combat climate change.   

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

 Sources:

Health Effects of Fossil Fuel-Derived Endocrine Disruptors, Dr. Tracey Woodruff, The New England Journal of Medicine, March 7, 2024  

‘Explosive growth’ in petrochemical production poses risks to human health, The Guardian, March 6, 2024

Sowing a Plastic Planet: How Microplastics in Agrochemical Are Affecting  our Soils, Our Food, And Our Future, Center for International Environmental Law, Reissued December 2022  

(Beyond Pesticides, March 13, 2024) A comprehensive study released in Journal of Cleaner Production in August 2023 identifies the potential for organic agriculture to mitigate the impacts of agricultural greenhouse gas (GHG) emissions in the fight to address the climate crisis. In “The spatial distribution of agricultural emissions in the United States: The role of organic farming in mitigating climate change,” the authors determine that “a one percent increase in total farmland results in a 0.13 percent increase in GHG emissions, while a one percent increase in organic cropland and pasture leads to a decrease in emissions by about 0.06 percent and 0.007 percent, respectively.” This descriptive study affirms the urgency of Beyond Pesticides’ mission to ban toxic petrochemical pesticides by 2032, given the projected adverse impacts that conventional agricultural dependence on these toxic pesticides will continue to have on people, wildlife, and ecosystems.

The study refers to various studies focused on a comparative analysis of conventional to organic farming on energy use, greenhouse gas emissions (GHGe), nutrient leaching, soil quality, and biodiversity. The consensus is that organic farming is more sustainable than conventional agriculture. For example, “[S]everal studies comparing conventional to organic agriculture found that the latter used 10%–70% less energy per unit of land for all analyzed crops.” However, measurements on a meta-analysis of soil quality and biodiversity show “significant variability across studies with 16% of them showing a negative effect of organic farming on species richness.” Drawing on this past research, the authors of this study accomplish what the previous research could not: “provide categorical supporting evidence… for the general expectation that organic farming is more environmentally sustainable than conventional farming.”

These researchers used U.S. state-level data from 1997 to 2010, excluding the years 1998, 1999, and 2009 due to bad data. Additionally, researchers drew GHGe data from the World Resources Institute, economic data (e.g. “real per capita GDP (in chained 2009 dollars), output share for utilities, manufacturing, oil and natural gas, and transportation” as a percentage of state GDP) from the U.S. Bureau of Economic Analysis, Department of Commerce. Additional data was gathered from the U.S. Department of Transportation’s Federal Highway Administration, the U.S. Department of Agriculture’s Economic Research Service, and the U.S. Census Bureau.

To determine a statistical relationship between GHGe and organic farming in the U.S., the researchers use a model based on the STIRPAT (Stochastic Regression on Population, Affluence, and Technology) approach. Researchers summarize the benefits of this analytical method, “Given the importance of transportation to farming, this would help examine whether the potential environmental benefits of organic food production, if any, are substantial enough to outweigh the environmental harm of transportation output embodied in organic farming.”  See Subsection 3.2 under Methods for a full breakdown of the empirical specifications of their methodology.

The spatial distribution (as seen above in Figure 2) of the statistical comparison between conventional and organic agricultural across all fifty states amounts to three overarching findings:

1. “The spatial distribution of agricultural GHG emissions in the United States is uneven: High-emissions states are concentrated in the Great Plains extending south to NM and the southeastern area of the United States. Meanwhile, low-emissions states are in California and the northeastern region extending to MI in the north and MD in the south.
2. Agriculture is a significant contributor to GDP within the high-emissions states, but organic agriculture represents only a small proportion of total farmland: The contribution of agriculture to GDP in high-emissions Great Plains states ranges from 1.11% to 5.94%, while organic agriculture as a share of total farmland ranges from 0.02% to 0.33%. In the southeastern states, the contribution of agriculture to GDP ranges from 0.39% to 1.41%, and organic agriculture ranges from 0.003% to 0.005%.
3. Agriculture has a substantially lower contribution to GDP within low-emissions states, but organic agriculture represents a large proportion of total farmland: The contribution of agriculture to GDP ranges from 0.063% to 0.95%, while organic farming as a share of total farmland ranges from 0.14% to 3.13%.”

Years of reporting by Beyond Pesticides corroborates the findings in the study that organic agriculture is a monitorable and critical solution to address cascading crises relating to climate change and public health. Rodale Institute’s Farming Systems Trial – 40-Year Report highlights the success of regenerative organic agriculture:

• Organic systems achieve 3–6 times the profit of conventional production;
• Yields for the organic approach are competitive with those of conventional systems (after a five-year transition period);
• Organic yields during stressful drought periods are 40% higher than conventional yields;
• Organic systems leach no toxic compounds into nearby waterways (unlike pesticide-intensive conventional farming)
• Organic systems use 45% less energy than conventional agriculture, and
• Organic systems emit 40% less carbon into the atmosphere.

There are also numerous reports that highlight the threat of toxic petrochemical pesticides and fertilizers to the broader climate crisis. For example, a 2020 study documents the use of synthetic fertilizers as a driver of nitrous oxide (N2O) emissions. This phenomenon is of critical concern to advocates given that, “Growth in nitrous oxide emissions over these last four decades has been considerable, with human-caused release, mostly from fertilizer use on cropland, increasing by 30%. Compared to pre-industrial levels, nitrous oxide levels increased 20% from all sources.” While nitrous oxide emissions only make up 6 percent of total greenhouse gas emissions in the U.S., “the impact of one pound of N2O on warming the atmosphere is 265 times that of one pound of carbon dioxide.” In Sub-Saharan Africa, meanwhile, years of soaring fertilizer costs (for both organic and conventional products) that began with the pandemic and continue with currency fluctuations wracked by geopolitical actions, including the Russia-Ukraine War, prevent many farmers from maintaining soil health to produce agricultural products. The climate crisis is also causing significant harm to bumblebees, according to a 2023 study that adds to research tying together the compounding impacts of extreme temperature fluctuations and toxic insecticide exposure in relation to their physical fitness and pollinating capabilities.

Beyond Pesticides strongly advocates for strengthening organic regulations to ensure the positive impact of organic principles in addressing the compounding ecological, public health, and climate crises. See Keeping Organic Strong as the National Organic Standards Board to find the opportunity to suggest changes to the National Organic Program through public hearings, comment periods, and written testimonials that will open up in April.

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

Source: Journal of Cleaner Production

(Beyond Pesticides, March 12, 2024) A study released in Science of the Total Environment unpacks the threat of emerging chemicals of concern (CECs), including toxic pesticides, in the groundwater of Tunisia. Researchers highlight that the impact of pesticide drift and leaching into groundwater reserves is not siloed to the Middle East and North Africa (MENA) region, but a key concern for most industrialized countries, including the United States. Authors of this study build on literature of CECs already conducted in the region that have broader implications for the spillover effects of pesticide regulation in broader contexts. This descriptive study and accompanying Environmental Risk Assessment (ERA) demonstrate the urgency of Beyond Pesticides’ mission to ban toxic petrochemical pesticides by 2032 because of the pervasiveness of toxic residues, be it pesticides, antibiotics, or other substances, from groundwater systems to human bodies.

The researchers performed the tests in thirteen wells in the Grombalia shallow aquifer, an area of northeast Tunisia that feeds into the Wadi El Bay watershed, which is defined as a “high population density [with] intensive agricultural activity [in ‘one of the most polluted areas in Tunisia’].” The researchers gathered data “during two seasons and were analyzed with two high resolution mass spectrometry approaches: target and suspect screening. The latter was screening banned pesticides.” For more information on the suspect screening approach for pesticide analysis, see Subsection 2.4 under the Materials and Methods.

The researchers identified 20 target pesticides in this study: Anabasine, atrazine, bendiocarb, bentranil, carbaryl, carbofuran, DEET, desethylatrazine, desethylterbuthylazine, dimethomorph, fenfuram, imidacloprid, isoproturon, methfuroxam, mexacarbate, propamocarb, propoxur, pyroquilon, spiroxamine, and terbuthylazine. Table 2 delineates the concentrations of the most frequently detected pesticides in groundwater samples, which include DEET, mexacarbate, propoxur, desethylatrazine, and terbuthylazine. The authors are particularity concerned with the presence of “several carbamate insecticides…due to their acute and chronic toxicity.” The main source of carbamate insecticides are from agricultural use, which is not surprising given that the Grombalia region’s economy is mainly based on citrus: “77.3 percent of the irrigated area [in this region] is planted with citrus [].”

“The most frequently quantified pesticides belong to the family of triazine herbicides and carbamate insecticides. Triazines have been highly used on several agricultural crops. The occurrence of triazine herbicides in groundwater has been found very commonly [] with most likely no potential human-health concerns at the observed levels of detection [],” authors report in Section 3.1.2 on the results and discussion subsection on pesticides. According to the report: “The frequent detection of triazines can also be expressed as a function of their groundwater ubiquity score (GUS) index, used to predict the behavior of pollutants in groundwater. Triazines are the compounds with the highest GUS index and detection frequency, indicating their high leachability. Atrazine and its degradation product desethylatrazine are by far the most abundant herbicides detected in shallow groundwater []. Atrazine was not detected in the sampling sites, while its metabolite desethylatrazine was detected in 13 samples in both sampling campaigns []. Some researchers have shown that pesticide metabolites are often detected in groundwater at higher concentrations compared to parent compounds [] and that their presence can be more toxic than their parents. []” This last line on pesticide metabolites is consistent with findings from numerous studies which demonstrate the relationship between groundwater and pesticide residue exposure and infiltration in the United States, for example, “90 percent of Americans having at least one pesticide biomarker (includes parent compound and metabolites) in their body,” according to the Centers for Disease Control and Prevention.

Beyond the focus on pesticides, the study also documents the occurrence of CECs, which include “commonly prescribed drugs [‘antimicrobials, analgesics, anti-inflammatories’], artificial sweeteners [sucralose], insecticides [fipronil], and UV filters.” Sixty-nine compounds of CECS and one transformation product [metabolites or degradation products of the precursor analyte’] and 20 pesticides were detected per well, “ranging between 43 and 7384 ng L⁻¹ and 7.3 and 80 ng L⁻¹, respectively. The unit ng L^-1 refers to one nanogram of a substance per liter of water.

Researchers in this study found it pertinent to study toxic substance exposure in Tunisian groundwater since a vast majority of the population accesses water resources through wells linked to aquifers. A 2023 Gallup poll indicates a record dissatisfaction with water quality across 81 percent of the population, particularly in southern regions of the country. “Industrial waste from phosphate mining—phosphogypsum—has led to spikes in cancer rates, infertility, and miscarriage in the region. Once famed for its thriving marine ecosystems, fish stocks have plummeted. Groundwater has been polluted, with diminishing reserves for households.” One of the reasons these researchers focused on an area in northeast Tunisia was because of the lack of existing data regarding toxic substance residues in groundwater reserves generally.

There is extensive reporting by Beyond Pesticides on the human, wildlife, and ecological health implications of pesticide leaching into groundwater. For instance, marine ecosystems along the U.S. West Coast are threatened by forest management practices that permit the use of pesticides including certain herbicides (indaziflam, hexazinone, and atrazine), fungicides (fluopicolide and pyraclostrobin), and insecticides (bifenthrin and permethrin). In Arizona, the State Auditor General reported deep concern over the insufficient amount of groundwater monitoring for pesticides by the Arizona Department of Environmental Quality between 2017 and 2021 which flew in the face of legal requirements.

Beyond Pesticides continues to call on Secretary of Interior Deb Haaland to expand USGS mapping of pesticide use and monitoring and inform the U.S. Environmental Protection (EPA) Administrator Michael Regan that pesticides shown to contaminate rivers and streams must be banned. The regulation of and rulemaking around pesticide infiltration in groundwater is more complicated in the aftermath of Sackett v. EPA (2023), a Supreme Court case that limited EPA’s authority to protect critical wetland ecosystems through a narrower definition of, “Waters of the United States (WOTUS). In the 5-4 SCOTUS decision, regulation of groundwater (including protections against pesticide residue) was undermined once WOTUS was defined by the language, “continuous surface connection to bodies.”

Beyond the patchwork of state and national law that impacts water and pesticide regulation, investing in the protection of organic agricultural and land management principles is a critical approach to prevent the overwhelmingly majority of toxic petrochemical pesticides from leaching into groundwater in the first place. Beyond Pesticides affirms the decades of advocacy that went into establishing organic agriculture standards through the Organic Foods Production Act of 1990. This legislation established mechanisms for compliance, oversight, and enforcement of the national List of Allowed and Prohibited Substances to protect the public against toxic pesticides that EPA permits acceptable use in conventional, industrial agriculture. See Keeping Organic Strong as the National Organic Standards Board will offer the public the opportunity to suggest changes to the National Organic Program through public hearings, comment periods, and written testimonials in April.

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

Source: Science of the Total Environment

(Beyond Pesticides, March 11, 2024) Inside a recent disagreement between the Office of the Inspector (OIG) and the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) on the agency’s review of pet flea and tick collars—leading to thousands of deaths and poisonings—is a basic question of the adequacy of pesticide regulation. The disagreement is over the cause of 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury, and the February 2025 OIG report’s conclusion that “[EPA] has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” While the disagreement focuses on a number of EPA process failures, Beyond Pesticides urges that the findings advance the need for the agency to address a key element of chemical mixtures in pesticide products not currently evaluated, potential synergistic effects—the increased toxic potency created by pesticide and chemical combinations not captured by assessing product ingredients individually. 

Key to the dispute is what many see as a foundational failure of EPA to evaluate the effect of pesticide mixtures and full formulations of pesticide end products, a longstanding criticism of the agency’s pesticide registration process, which focuses on pesticide products’ active ingredients. The manufacturer identifies the active ingredient as the compound in the product formulation that kills the target pest—even though the other ingredients (called inerts) may be toxic. The concern stems from two scenarios present with the Seresto collar in which EPA is not evaluating (i) the mixture of chemicals in the product purchased by consumers, including the so-called inert ingredients (other chemical agents to increase performance, such as adjuvants, surfactants, solvents, carriers, etc.) and contaminants (both not disclosed on the product label); and (ii) the effect of the mixture of two or more active ingredients in the pesticide product, which may increase the product’s overall toxicity.

In the case of the Seresto flea and tick collar, there is concern that EPA missed the true toxicity of the product by not fully evaluating whether there is a synergistic effect that increases the product’s overall toxic effect. Seresto contains two active insecticide ingredients—the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.

As Beyond Pesticides pointed out in 2021, when the pet poisonings and deaths made headlines, a 2012 study found that flumethrin and imidacloprid have a synergistic effect in attacking fleas. However, EPA dismissed or ignored this science, stating in a 2016 EPA bulletin, “The risk of the combination of the two active ingredients, flumethrin and imidacloprid, was not assessed because the two chemicals act in completely different ways.”

Synergistic effects have been widely reported. For example, Beyond Pesticides has reported that researchers found elevated neurotoxic effects from exposure to the glyphosate/Roundup formulation with the so-called inert ingredient polyethoxylated tallowamine (POEAs), also shown to kill human cells. 

>>Tell EPA to start protecting people and pets from pesticide poisoning. 

Despite all the concerns, at the time the poisoning and deaths of pets made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “’eligible for continued registration’ based on best available science, including incident data… No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.”

Overall, the OIG highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to): 

• Failure to address combined effects of multiple pesticides; 
• Failure to investigate impacts on pets; 
• Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment; 
• Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and 
• Failure to assure the public of the safety of the products. 

Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. Advocates point out that If the labeling is not protecting people, then the agency is not fulfilling its responsibility to protect public health and safety and the pesticide products should not be allowed on the market

>>Tell EPA to start protecting people and pets from pesticide poisoning. 

Letter to EPA

More proof of multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) to protect people and their pets from pesticides was presented in a report of the Office of Inspector General (OIG) report, published on February 29, 2024.

The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data. . . . No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars— the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.

The OIG points out that EPA’s handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to):

– Failure to address combined effects of multiple pesticides;

– Failure to investigate impacts on pets;

– Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment;

– Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and

– Failure to assure the public of the safety of the products.

Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. When EPA cannot protect against ongoing harm to humans and the biosphere with the labeling it approves on pesticide products, it must remove the pesticide product from the market. When faced with evidence of harm from a pesticide, despite its labeling restrictions and warnings, EPA must take steps to halt its use. 

The deaths and poisonings associated with Seresto animal collars requires EPA to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects. When will you do this?

Thank you for your consideration.

Letter to U.S. Congress

More proof of multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) to protect people and their pets from pesticides was presented in a report of the Office of Inspector General (OIG) report, published on February 29, 2024. 

The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data… No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars— the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.

The OIG points out that EPA’s handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to):

– Failure to address combined effects of multiple pesticides;

– Failure to investigate impacts on pets;

– Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment;

– Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and

– Failure to assure the public of the safety of the products.

Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. When EPA cannot protect against ongoing harm to humans and the biosphere with the labeling it approves on pesticide products, it must remove the pesticide product from the market. When faced with evidence of harm from a pesticide, despite its labeling restrictions and warnings, EPA must take steps to halt its use. 

Please let EPA know that the deaths and poisonings associated with Seresto animal collars requires it to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects.

Thank you for your consideration.

(Beyond Pesticides, March 8, 2024) A major problem has vexed pesticide regulators and researchers for decades: Humans and other organisms almost always have multiple pesticides in their bodies, but techniques for assessing their combined effects, or cumulative body burden from multiple chemical classes are not typically available. A new study from Chinese and British researchers provides the first combined assessment of multiple classes of pesticides in human blood. The authors believe they are the first to develop a way to quantify multiple types of pesticides in human serum (clear liquid part of blood) as opposed to urine or from other sample collection methods. This is a tool that authors say is a more accurate way of assessing the real world exposure and ultimately the adverse impact of pesticide use on human health.

The researchers had a small sample of 31 men and 34 pregnant women in Wuxi, China. They chose 73 pesticides and a few of their breakdown products to identify from three categories: fungicides, neonicotinoid insecticides, and triazine herbicides. Their testing protocol confirms their expectation that food—primarily produce—is the major source of pesticide exposures. This result reinforces Beyond Pesticides’ mission of supporting the shift in agriculture to pesticide-free methods and regenerative practices. Eating organic food is the most effective way to reduce the body burden of pesticides.

The researchers detect a total of 40 pesticides and 10 related chemicals in the sample. No sample was free of all pesticides. More than 80 percent contained more than 10 pesticides. The researchers note that this adds to the evidence that pesticides are ubiquitous in human bodies. As Beyond Pesticides often stresses, it defies belief that these chemicals could have no effect on human (and ecosystem) health.

Based on the sampling data, the team calculates each subject’s estimated daily intake (EDI) of each pesticide, adding those together to find a cumulative EDI. They then compare the EDI with acceptable daily intake (ADI) standards for each pesticide set by various countries and international organizations, including the U.S. Environmental Protection Agency (EPA) and the World Health Organization. ADI is an estimate of how much of a substance a person could consume daily over a lifetime without suffering adverse health effects. Then they derive a cumulative hazard quotient (HQ), which is an estimate of the health effects resulting from exposures above the ADI.

Of the three pesticide categories, fungicides occurr most often and at the highest levels. Boscalid, a carbamid compound, is the most common fungicide in the samples. Upon its registration in 2003, EPA described it as “practically nontoxic.” But it inhibits succinate dehydrogenase (SDH) a chemical whose structure and functions, in the words of one review, are highly conserved in “nearly all extant eukaryotes”—that is, everything but bacteria and their unicellular cousins, the archaea. Therefore, what it does to one organism it may very well do to all (including humans). Studies in zebrafish show unambiguously that boscalid affects central nervous system development and function and glucose metabolism, causes oxidative stress, and disrupts reproductive hormones.

Four of the fungicides are triazoles, which the authors note can cross the blood-brain barrier and infiltrate cerebrospinal fluid. The current study is the first to find them in human serum. Triazoles affect a steroid synthesis pathway in fungi that is the same in humans. Triazoles are known to damage cardiac tissue and trigger oxidative stress in rats.

Simazine is the most common triazine herbicide in the samples. The triazine family includes the notorious endocrine disrupter atrazine; simazine is used for weed control in fruit and nut orchards, berry fields and cornfields, and aquatic environments. EPA regulates simazine according to its similarity to atrazine. It was approved in 1972 for algae control in swimming pools, hot tubs and whirlpools until 1994, when EPA withdrew this registration based on “unacceptable cancer and non-cancer health risks to children and adults.” However, by 2022, EPA declared in a rule establishing tolerances for certain crops that “cancer risk is not a concern and a quantitative cancer risk was not conducted.” Researchers have found effects of simazine on the hypothalamic-pituitary-gonadal axis leading to, for example, “constant estrus [in heat]” and “continuous estrogen stimulation of mammary gland” in female rats. Endocrine disruption is a well-established factor in the development of many cancers.

Neonicotinoids are widely recognized to be neurotoxic to many beneficial insects such as bees as well as humans, but they may also have other harmful effects, including disruption of metabolic functions involving lipids and leading to obesity and cardiovascular disease. A previous study in Wuxi by different researchers identified nine neonicotinoids in human serum along with nine lipids already known to be affected by environmental contaminants, including dioxins, polychlorinated biphenyls, polycyclic aromatic hydrocarbons, and organophosphorus flame retardants. The authors of the current study found eight neonicotinoids in their samples, three of which had not been observed in human serum before. They also observed that, like some fungicides, neonicotinoids can cross the blood-brain barrier.

The authors found that there is a clear linear relationship between maximum residue levels allowed in foods, also called tolerances, and the serum levels of pesticides in their study subjects—the higher the allowable residue in food, the higher the serum level of that pesticide. This means that setting these tolerances lower or eliminating them altogether would go a long way toward reducing pesticide exposures, as would better monitoring and enforcement of such regulations in the U.S., especially on imported foods.

One important aspect of the current study is the identification of numerous troubling pesticides not previously found in human serum, findings that adds to the urgency of further investigation. But the study did not directly demonstrate that any of the pesticides they analyzed are causing adverse health effects. The study’s main significance is that it establishes a method for measuring, comparing, and determining cumulative levels of numerous pesticides in human serum. This method can help determine the extent and severity of those pesticides’ consequences individually and cumulatively.

Perhaps unintentionally, the study also highlights the inadequacy of methods calculating exposures and health hazards using the crude estimates of EDI, ADI, HQ and maximum residue levels/tolerances. These concepts are imprecise almost to the point of “hand waving.” They rest on the assumption that there are some levels of pesticides in the body that are harmless—which, even if true, fails to account for the total risks and hazards presented by the ubiquitous body burdens of multiple pesticides. The most rational course to protect humans and ecosystems from pesticide exposures is to switch agriculture to organic methods as soon as possible. For more on the public health outcomes linked to pesticide exposure, see Beyond Pesticides’ Pesticide-Induced Diseases Database.                                                            

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

Sources:
Exposure levels and health implications of fungicides, neonicotinoid insecticides, triazine herbicides and their associated metabolites in pregnant women and men. Nanxiu Shang, Yingying Yang, Yilin Xiao, Yukang Wu, Kaixuan Li, Xiaoman Jiang, Edmond Sanganyado, Qing Zhang, Xinghui Xia, Environmental Pollution, Volume 342, 1 February 2024. https://www.sciencedirect.com/science/article/abs/pii/S0269749123020717

A comprehensive review of 1,2,4-triazole fungicide toxicity in zebrafish (Danio rerio): A mitochondrial and metabolic perspective. Tao Huang, Haibo Jiang, Yuanhui Zhao, Jia He, Hongguang Cheng, Christopher J. Martyniuk, Science of The Total Environment 2022. https://www.sciencedirect.com/science/article/pii/S0048969721062550

Biomonitoring and risk assessment of human exposure to triazole fungicides panel. Luiz P.A. Marciano, Luiz F. Costa, Naiane S. Cardoso, Josiane Freire, Fernando Feltrim, Geovana S. Oliveira, Fernanda B.A. Paula, Alessandra C.P. Silvério, Isarita Martins, Regulatory Toxicology and Pharmacology, Volume 147, February 2024. https://www.sciencedirect.com/science/article/pii/S0273230024000060

Serum concentrations of neonicotinoids, and their associations with lipid molecules of the general residents in Wuxi City, Eastern China. Qianyu Chen, Yayun Zhang, Jianhua Li, Guanyong Su, Qi Chen, Zhen Ding, Hong Sun, Journal of Hazardous Materials, Volume 413, 5 July 2021

See Beyond Pesticides info:

Disproportionate Risks: The Effects of Pesticide Exposure Among the Population.  https://www.beyondpesticides.org/resources/disproportionate-risks/overview

Read More on Beyond Pesticides’ Agricultural Justice Page. https://www.beyondpesticides.org/programs/agricultural-justice

Pesticide-Induced Diseases: Body Burden. https://www.beyondpesticides.org/resources/pesticide-induced-diseases-database/body-burden

Of Note During Organic Month, Study Finds Organic Diet and Location Affect Pesticide Residues in the Body. https://beyondpesticides.org/dailynewsblog/2023/09/of-note-during-organic-month-study-finds-organic-diet-and-location-affect-pesticide-residues-in-the-body/