(Beyond Pesticides, August 14, 2024) Pesticide exposure is linked to negative birth outcomes in a recent study in the American Journal of Epidemiology. This study adds to that body of science, but is novel research since, “Epidemiological studies of pesticide exposures and stillbirth in the United States have not been published in the past two decades, a time period that has seen dramatic changes in pesticide use compared to the 20th century,” the authors state.

The study analyzes Arizona pesticide use records and birth certificates from 2006-2020. Researchers correlate mothers living within 500 meters of any pyrethroid, organophosphate (OP), or carbamate insecticide applications during specific windows before and during pregnancy with stillbirth. The authors focus on exposure during the prenatal period, as it is a susceptible time frame in which any contact with pesticides can negatively impact health. Numerous studies report several adverse birth and childhood outcomes with prenatal exposure.

To link pesticide exposure and negative birth outcomes, Arizona records that encompass 1,237,750 births, 2,290 stillbirths, and 27 pesticides were analyzed. The authors “evaluate associations of pyrethroids, OPs, and carbamate insecticides with stillbirth by using data from the Arizona Pregnant women’s Environment and Reproductive outcomes Study (Az-PEARS), a project that links Arizona’s Pesticide Use Registry with birth certificates in the state of Arizona.” The geocoded birth certificates were provided by Arizona’s Department of Health Services, which mandates the recording of all birth certificates for stillbirths/fetal deaths for fetuses greater than 20-week gestation.

Arizona also requires that all commercial agricultural pesticide applications, including aerial applications, are reported, allowing the authors to determine maternal exposure. “Mothers were defined as exposed,” the researchers comment, “if their residential address on the birth certificate was within 500 meters of a given pesticide application, during a specified trimester (preconception/Trimester 0; Trimester 1).”

During the first preconception window (the window from 180 days to 90 days prior to conception), correlation to stillbirth for only the OP insecticide tribufos is noted, while the second preconception window (the 90 days immediately preceding conception) shows associations for the specific pyrethroids cyfluthrin, zeta-cypermethrin, and pyrethroids as a class. Organophosphate associations are observed as a class, specifically malathion, during the second preconception window, as well as the carbamates, carbaryl and propamocarb hydrochloride. During the first trimester, the pyrethroids fenpropathrin and permethrin, organophosphates as a class, the specific OPs acephate and dimethoate, and the carbamate formetanate hydrochloride are associated with stillbirth.

“Stillbirth, fetal death, and miscarriage present major physical and psychological health burdens for pregnant women,” the authors state. They continue, “Stillbirth occurs in approximately 4-5 per 1,000 births in developed countries, and up to 3% of births in low and middle income countries.” In finding a correlation between incidence of stillbirth and pesticide exposure, the study highlights additional risks during pregnancy and for those who wish to become pregnant. Those who live near agricultural areas, and specifically female farmworkers, are at a disproportionate risk for these adverse effects.

Previous toxicology studies document the pyrethroid cyfluthrin as altering placental development, which has been hypothesized as a cause of stillbirths and miscarriages. As pesticide exposure causes biological effects on female reproductive organs and hormonal activity, this provides a possible explanation for the correlation of exposure to negative birth outcomes. “Metabolites of permethrin and cypermethrin (which are shared with zeta-cypermethrin) act as endocrine disruptors and interact with cellular estrogen receptors. Such hormonal influences can affect women’s reproductive cycles and cycle lengths, and the overall quality of the uterine environment during pre-implantation,” the authors say. Any effects on uterine and reproductive cells and placental health from pesticide exposure can influence the outcomes of pregnancy.

Impacts on male reproduction from pesticide exposure are also documented. Beyond Pesticides has a long history of highlighting the relationship between reproductive anomalies and toxic pesticides, particularly with endocrine-disrupting compounds. Studies show decreased male fertility including reduced sperm count and quality, as well as abnormal sperm development.

The U.S. Environmental Protection Agency (EPA) fails to regulate endocrine disruptors, which prompts advocates to call for proper data analyses prior to product registration, as they say the agency’s evaluation process is too narrow. More extensive examination is needed prior to products being approved for use, since many widely used pesticides lack comprehensive testing. On August 6, EPA issued an emergency suspension of all registrations of the pesticide dimethyl tetrachloroterephthalate (DCPA or Dacthal) under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) due to pregnant mothers, who were exposed to this compound, experiencing negative birth outcomes. The press release says exposure to Dacthal leads to “changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life, some of which may be irreversible.” (See more on this topic here and here.) EPA has not issued an emergency action such as this in almost 40 years, which raises flags and highlights how this would have been avoidable if initial testing was more thorough.

Active ingredients in pesticide products are proven harmful years after being approved for use and after deleterious, and often irreparable, damage to human health and the environment has occurred. By transitioning to organic agriculture and land management, these impacts can be avoided. The principles of organic offer a holistic solution that alleviates climate change, improves soil health, restores biodiversity, enhances ecosystems, and contributes to human health for future generations.

Be part of the solution by becoming a member of Beyond Pesticides and adding your voice to the urgent movement to eliminate fossil fuel-based pesticide use within the next 10 years. Sign up to receive Action of the Week and Weekly News Updates delivered right to your inbox and stay up to date on the health and environmental hazards of pesticides, pesticide regulation and policy, pesticide alternatives, and cutting-edge science through the Daily News.

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

Source:

Furlong, M. et al. (2024) Pre-conception and first trimester exposure to pesticides and associations with stillbirth, American Journal of Epidemiology. Available at: https://academic.oup.com/aje/advance-article-abstract/doi/10.1093/aje/kwae198/7714541.

(Beyond Pesticides, August 13, 2024) With novel methods to provide a big-picture view of the overlap between high pesticide use and cancer incidence across the U.S, a new study has again linked pesticide exposure to a range of cancers. The study by Jacob Gerkin, D.O. and colleagues, “Comprehensive assessment of pesticide use patterns and increased cancer risk,” published in Frontiers in Cancer Control and Society, examines the association between high-pesticide use and cancer diagnoses along with smoking incidence data and the Social Vulnerability Index, a measure used by the Centers for Disease Control and Prevention (CDC) that includes variables such as poverty, poor housing, and exposures to natural disasters and chemical spills. The researchers consider 69 pesticides used in agriculture that are monitored by the U.S. Department of Agriculture. They use U.S. Geological Survey data to map areas of similar crops and pesticide use patterns and incorporate public health data from the CDC to develop their final picture.

In terms of threats to health, cancer remains top of mind for most people. Globally, about ten million people die of cancer each year. And while treatments for cancer and survival times have burgeoned over the years, many cancers—particularly colorectal and breast cancer—are on the increase, and the increase is most dramatic among people between 55 and 64. At the same time, the evidence of pesticides’ role in cancer incidence is also increasing.

Pesticides have been linked to numerous diseases, including Parkinson’s, dementia, allergies and diabetes, as well as many cancers. But the science behind pesticide-cancer associations is contested turf, with much resistance being mounted by the pesticide industry and skepticism being expressed by regulatory scientists. For example, in 2022 Beyond Pesticides discussed evidence that EPA colluded with Monsanto in 2017 to downplay the carcinogenic effects of glyphosate, even after the International Agency for Research on Cancer had made the connection in 2015.

An important assumption of the study, the authors write, is that “more pesticide use leads to higher cancer incidence” because “no evidence has ever been reported of pesticides reducing cancer rates.” However, as is standard in epidemiological research, they stop short of drawing direct causal connections between pesticides and cancer because the study is population-based and does not reach the level of individuals. Yet they do find associations between “pesticide use and increased incidence of leukemia; non-Hodgkin lymphoma; bladder, colon, lung, and pancreatic cancer; and all cancers combined that are comparable to smoking for some cancer types.”

Different pesticides correlate with added risks for different cancers, but overall there is strong evidence that most pesticides add risks for multiple cancer types as well as particular cancers. That is, it is not a one-pesticide, one-cancer association. For example, atrazine adds risk for all cancers and colon cancers; dicamba is consistently at the top of the list in regions where there is a high risk of colon cancer and pancreatic cancer; and glyphosate is at the top in areas with high risk of all cancers, colon cancer, and pancreatic cancer.

Because the study also accounts for social vulnerability factors and smoking, it measures these against cancer types, overall cancer incidence, and pesticide use patterns. The researchers find that for some cancers, smoking is clearly the biggest risk factor, but pesticides are far more influential than social vulnerabilities or population size for individual cancer types. For non-Hodgkin lymphoma, bladder cancer and leukemia, pesticides actually outpace smoking. For pancreatic cancer, smoking is the highest risk factor by orders of magnitude compared to other variables.

The current study contrasts with a 2018 analysis of glyphosate and cancer based on the Agricultural Health Study (AHS) of 89,000 farmers and their spouses, which found no increased risk between glyphosate and lymph system cancers, but Dr. Gerkin and colleagues point out that the AHS study population focused only on a subset of the whole communities that are embedded in agricultural areas, and observed that the whole population—not just farmers—is repeatedly exposed to multiple pesticides and frequent spray drift events. The AHS is an ongoing program of the National Institutes of Health and National Institute of Environmental Health Sciences.

Dr. Gerkin and colleagues assert that “organic farms that do not use pesticides often have 15%-50% lower yields compared to conventional farms.” This is somewhat misleading, as Beyond Pesticides has established numerous times, and depends heavily on how the effects of pesticides are measured. For example, Beyond Pesticides has covered how plant diversity in fields fosters productivity, and how pesticides’ harms to pollinators reduce productivity. However, the study authors conclude that the highest cancer risk is associated with regions of the country with the highest pesticide use, making it clear that any increased productivity based on pesticides comes at an unacceptable price.

A 2023 review by New York University professor Leo Trasande, M.D. and colleagues, “Exposures to pesticides and risk of cancer: Evaluation of recent epidemiological evidence in humans and paths forward,” states that “Most evidence suggesting pesticide carcinogenicity—in the [2017] International Agency for Research on Cancer (IARC) report [reviewing tetrachlorvinphos, parathion, malathion, diazinon and glyphosate] and elsewhere—has come from animal and mechanistic studies, as the epidemiology literature was insufficient to draw conclusions. Epidemiologic evidence has since increased in both quantity and quality, and now covers many other pesticides that were not included in IARC’s review, or in those of other national and international agencies.” Dr. Trasande and colleagues conclude that “there is sufficient evidence for action to regulate pesticides based on their carcinogenicity.”

Regarding glyphosate, they also point out that regulators have mostly focused on the technical compound and ignored the more complex glyphosate-based formulations, for which the evidence of carcinogenicity is stronger than for technical glyphosate. And while the 2015 IARC report considered only peer-reviewed literature, EPA and the European Food Safety Assessment included “industry studies conducted by private companies that register the chemicals in question.”

This question of regulatory capture by industry affects every aspect of pesticide policy. Dr. Trasande and colleagues note that “calls have been made within the scientific community for more independently conducted epidemiological research.” There has been little success so far. A typical example of pesticide industry influence on the scientific literature is a 2021 paper, “Cancer and occupational exposure to pesticides: an umbrella review,” by Carol J. Burns, PhD  and Daland R. Juberg, PhD. The authors found “there was neither strong nor consistent epidemiologic data supportive of a positive association between pesticide exposure in occupational settings and cancer.” Dr. Burns’ affiliation is listed as “Sanford, USA,” while Juberg’s is “Indianapolis, USA.” These are completely inadequate identifications and are clearly an attempt to hide their industry connections. Further investigation reveals that Dr. Burns worked for The Dow Chemical Company for 21 years, while Dr. Juberg worked for Dow for 15 years and is now retired from Corteva Agriscience. Both are ostensibly independent consultants. Corteva is a spinoff from DowDupont. The study was funded by CropLife International. Studies have shown that there is strong association between conclusions of studies and review papers and their funding sources.

The current study by Dr. Gerkin and colleagues is a significant addition to the epidemiologic literature on cancer and pesticides. It is, the authors assert, “the first comprehensive evaluation of cancer risk from a population-based perspective at the national level.” By accounting for possible confounders such as smoking, poverty, and exposure to disasters, the authors have clarified that there is an undeniable link between pesticide exposure and cancer incidence. The mechanism of carcinogenesis is not yet exactly clear for individual cancers, although it is obvious that smoking and pesticide exposure provide a lethal double dose of risk. This likely affects most the very groups that do the bulk of agricultural work, have little job security, no health insurance, and few other resources.  

The authors point out one step that could help get the point across to farmers, government officials, health care professionals, and the pesticide industry: “If, when buying a new property, purchasers were notified that the land is in proximity to particularly elevated levels of pesticides or the use of certain pesticides that may be especially harmful, then public awareness of this issue would rise, garnering the attention that this issue calls for….[T]he safety of these chemicals needs to be approached with more skepticism. Healthcare officials in these regions should exercise a level of skepticism of the safety of the chemicals used.”

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

Sources:

Comprehensive assessment of pesticide use patterns and increased cancer risk; Jacob Gerken, Gear Thomas Vincent, Demi Zapata, Ileana G. Barron and Isain Zapata; Frontiers in Cancer Control and Society, July 25, 2024
https://www.frontiersin.org/journals/cancer-control-and-society/articles/10.3389/fcacs.2024.1368086/full

Exposures to pesticides and risk of cancer: Evaluation of recent epidemiological evidence in humans and paths forward; Haleigh Cavalier, Leonardo Trasande, Miquel Porta; International Journal of CancerVolume 152, 5 Mar 2023
https://onlinelibrary.wiley.com/doi/epdf/10.1002/ijc.34300

Cancer and occupational exposure to pesticides: an umbrella review; Carol J. Burns and Daland R. Juberg; International Archives of Occupational Environmental Health, January 25, 2021
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8238729/

Toxic Pesticides Found, Again, to Yield No Increase in Productivity or Economic Benefit for Farmers
https://beyondpesticides.org/dailynewsblog/2019/09/toxic-pesticides-found-again-to-yield-no-increase-in-productivity-or-economic-benefit-for-farmers/; Beyond Pesticides, September 20, 2019

Plant Diversity Enhances Productivity, Reduces Pesticide Use
https://beyondpesticides.org/dailynewsblog/2020/11/plant-diversity-enhances-productivity-reduces-pesticide-use/; Beyond Pesticides, November 10, 2020

Pesticide Threat to Pollinators Decreases Agricultural and Economic Productivity, and Food Security; https://beyondpesticides.org/dailynewsblog/2023/06/pesticide-threat-to-pollinators-decreases-agricultural-and-economic-productivity-and-food-security/; Beyond Pesticides, June 22, 2023

The Link Between Ovarian Cancer and Pesticides Increases Among Female Farmers; 
https://beyondpesticides.org/dailynewsblog/2024/02/the-link-between-ovarian-cancer-and-pesticides-increases-among-female-farmers/; Beyond Pesticides, February  6, 2024

Childhood Leukemia Linked to Pesticides Used in Vineyards;
https://beyondpesticides.org/dailynewsblog/2023/11/childhood-leukemia-linked-to-pesticides-used-in-vineyards/; Beyond Pesticides, November 1, 2023

Daily News Blog Archive for the ‘Prostate Cancer’ Category
https://beyondpesticides.org/dailynewsblog/category/diseasehealth-effects/prostate-cancer/

Study Finds an Association between Dicamba Use and Increased Risk of Developing Various Cancers
https://beyondpesticides.org/dailynewsblog/2020/05/study-finds-an-association-between-dicamba-use-and-increased-risk-of-developing-various-cancers/; Beyond Pesticides, May 21, 2020

With Endometrial (Uterine) Cancer on the Rise, the Science Points to an Association with Pesticides
https://beyondpesticides.org/dailynewsblog/2023/12/with-endometrial-uterine-cancer-on-the-rise-the-science-points-to-an-association-with-pesticides/; Beyond Pesticides, December 13, 2023

(Beyond Pesticides, August 12, 2024)  When the U.S. Environmental Protection Agency (EPA) issued an emergency ban of the weed killer Dacthal (DCPA) last week, it said that there are no “practicable mitigation measures” to protect against identified hazards—a clear and honest assessment of the limits of pesticide product label changes and use restrictions. Now, the question is whether the same thinking can be applied across the EPA’s pesticide program, addressing the urgent need to protect biodiversity.

In the Dacthal proclamation, EPA said it consulted with the U.S. Department of Agriculture (USDA) on “alternatives to this pesticide,” and presumably determined that there were “alternative chemicals” that could be used in chemical-intensive agriculture—while not considering “alternatives to chemicals.” This is the framework that is understood to be EPA’s process that keeps pest management on a pesticide treadmill except in extremely rare cases (this being the second in nearly 40 years). It is also the framework that has led to catastrophic events or existential crises on biodiversity collapse, health threats, and the climate emergency.

On biodiversity, the mix of diverse and intricate relationships of organisms in nature that are essential to the sustaining of life, EPA’s pesticide program, the Office of Pesticide Programs, has led the U.S. down a road that can only be described, according to many health and environmental advocates, as apocalyptic, starting with the “insect apocalypse” and extending to all life. This is happening despite the availability of “alternatives to chemicals” that EPA does not factor into its decisions to allow, day-after-day and year-after-year, the use of deadly pesticides that are neither necessary nor the most effective way to achieve quality of life, public health protection, efficacy of pest management, productivity and profitability of agriculture, aesthetics for lawns and landscapes, and a livable future.

>> Tell EPA and Congress to support measures that protect endangered species and their habitats and to reject measures that weaken that protection.

Listen (read these words aloud) to what EPA has to say (see page 4 of linked document) about its current ability to conduct regulatory reviews to “protect” endangered species: “Even if EPA completed this work for all of the pesticides that are currently subject to court decisions and/or ongoing litigation, that work would take until the 2040s, and even then, would represent only 5% of EPA’s ESA [Species Act] obligations.” This has given cause for too many in the U.S. Congress to call for a weakening of ESA, rather than charting a course for the transition to organic land management.

As a result, EPA has come up with a draft strategy, not to transition to alternative systems without reliance on toxic pesticides, but “to provide flexibility to growers to choose mitigations that work best for their situation.” Presumably, if that “situation” in a chemical-intensive agricultural operation requires continued use of a chemical known to destroy endangered species, that may be permitted. The strict standards required to meet the crisis head-on is not a part of this EPA proposal. Because, this is the frame that EPA is using, in the agency’s own words: “Without certain pesticide products, farmers could have trouble growing crops that feed Americans and public health agencies could lack the tools needed to combat insect-borne diseases.”

Recognizing the real threat with an honest assessment is the first step in adopting a transformational approach to change. Biodiversity, like the threat to human health (and they are intertwined) is an important place to begin to elevate the urgent need for transformational action.

The biodiversity crisis is one of multiple crises that are compounding one another. While human actions are contributing to an ongoing Holocene or sixth mass extinction, we are also facing crises in human disease and climate change. The Endangered Species Act focuses on the species and habitats most at risk of extinction. However, the statement of purpose also recognizes the importance of conserving the ecosystem on which they depend.

Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first at the ways it has contributed to the crisis in the first place. 

The near extinction of a species of vulture brings into focus the importance of maintaining biodiversity for protecting human health. The loss of these underappreciated carrion eaters in India led to pollution of waterways by effluent from rotting carcasses and a burgeoning population of feral dogs, many of whom carried rabies. Similarly, in Wisconsin, researchers found that the presence of wolves reduced vehicle collisions with deer by 24%—an economic benefit 63 times greater than the cost of wolves killing livestock. 

The World Health Organization (WHO) summarizes the connections between biodiversity and human health: 

• Biodiversity provides many goods and services essential to life on Earth. The management of natural resources can determine the baseline health status of a community.  
• Biodiversity supports human and societal needs, including food and nutrition security, energy, development of medicines and pharmaceuticals and freshwater, which together underpin good health. It also supports economic opportunities, and leisure activities that contribute to overall well-being. [For example, 70% of all cancer drugs today are natural or based on nature. Other potential benefits include a fungus that can eat plastic.] 
• Land use change, pollution, poor water quality, chemical and waste contamination, climate change and other causes of ecosystem degradation all contribute to biodiversity loss and can pose considerable threats to human health. [“You rely on nature if you want to survive: It gives you food, it gives you water, it gives you trees that will protect the quality of the air you breathe,” says Maria Neira, MD, director of the Department of Environment, Climate Change, and Health for WHO. “It’s common sense: You need to protect what is protecting you. If we don’t, we are the losers, not the planet.”] 
• Human health and well-being are influenced by the health of local plant and animal communities, and the integrity of the local ecosystems that they form. [We depend on an ecological balance that regulates our planet’s oxygen, water, and nutrient cycles to pollinate, nourish, and support all the organisms we consume.]  
• Infectious diseases cause over one billion human infections per year, with millions of deaths each year globally. [Approximately two-thirds of known human infectious diseases are shared with animals, and most recently emerging diseases are associated with wildlife. Habitat destruction brings humans and wildlife into closer contact, dramatically increasing the risk of diseases caused by pathogens jumping to humans from wild animals.] 

Biodiversity loss is harming our health and threatening the basic ecological cycles that keep us alive. “We are out of harmony with nature,” United Nations (UN) Secretary-General António Guterres told world leaders at the 2022 Biodiversity COP 15 (Conference of the Parties). “Humanity has become a weapon of mass extinction. … And ultimately, we are committing suicide by proxy.” 

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

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

>> Tell EPA and Congress to support measures that protect endangered species and their habitats and to reject measures that weaken that protection.

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

While it is well known that climate change affects biodiversity, the reverse is not so well appreciated. Biodiversity is essential for limiting climate change. As summarized by the United Nations,  

• When human activities produce greenhouse gases, around half of the emissions remain in the atmosphere, while the other half is absorbed by the land and ocean. These ecosystems—and the biodiversity they contain—are natural carbon sinks, providing so-called nature-based solutions to climate change. 
• Protecting, managing, and restoring forests, for example, offers roughly two-thirds of the total mitigation potential of all nature-based solutions. Despite massive and ongoing losses, forests still cover more than 30 percent of the planet’s land. 
• Peatlands—wetlands such as marshes and swamps—cover only 3 percent of the world’s land, but they store twice as much carbon as all the forests. Preserving and restoring peatlands means keeping them wet so the carbon doesn’t oxidize and float off into the atmosphere.  
• Ocean habitats such as seagrasses and mangroves can also sequester carbon dioxide from the atmosphere at rates up to four times higher than terrestrial forests can. Their ability to capture and store carbon make mangroves highly valuable in the fight against climate change. 
• Conserving and restoring natural spaces, both on land and in the water, is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving nature’s ability to absorb emissions.  

Action is urgently needed to conserve—protect and enhance—biodiversity. Among the targets for 2030 set by the nations at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, this will require intensive actions that protect species and their habitats from toxic and other destructive threats, while restoring degraded ecosystems. The Kunming-Montreal Global Biodiversity Framework (GBF) adopted by COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.”  

Studies upon studies upon studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments. 

Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. Agricultural intensification, in particular pesticide and fertilizer use, is the leading factor driving declines in bird populations. 

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity. 

In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. If EPA is to really protect endangered species, it must eliminate the use of toxic pesticides and encourage organic production. The agency’s recent proposals to “protect” endangered species from herbicides and insecticides are totally inadequate. 

Congress is also considering measures that would weaken endangered species—and hence, biodiversity—protection. Five joint resolutions—S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86—have been introduced to roll back ESA regulations adopted in the Biden administration to those enacted in the Trump administration. S. 4753, “A bill to reform leasing, permitting, and judicial review for certain energy and minerals projects, and for other purposes,” has been passed out of the Senate Committee on Energy and Natural Resources. It weakens ESA protections by creating much shorter timelines for judicial review, additional categorical exclusions from the National Environmental Policy Act (NEPA) that could result in less science and planning for projects, tighter deadlines for agencies to complete the permitting process without increased capacity or funds. The Department of the Interior and its land management agencies have been consistently underfunded and understaffed. Shortening their deadlines without fixing those issues would lead to a rushed permitting process and limited public engagement.  

>> Tell EPA and Congress to support measures that protect endangered species and their habitats and to reject measures that weaken that protection.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress. 

Letter to EPA
Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first at the ways it has contributed to the crisis in the first place.

Biodiversity is critical for human health. It provides many goods and services essential to life on earth, supports human and societal needs, influences human health and well-being, and protects against exposure to zoonotic diseases. Biodiversity loss harms our health and threatens the ecological cycles that keep us alive. 

Biodiversity is essential for limiting climate change. It provides land and sea ecosystems that are natural carbon sinks, forests with two-thirds of the total mitigation potential of all nature-based solutions, wetlands covering 3 percent of the world’s land and storing twice as much carbon as all the forests, and seagrasses and mangroves that can sequester carbon dioxide at rates up to four times higher than terrestrial forests. 

Conserving and restoring biodiversity is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving Earth’s ability to absorb emissions. 

Among the targets for 2030 set by The UN Convention on Biological Diversity (CBD) at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since only 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, actions that protect species and their habitats from toxic and other destructive threats are critical, while restoring degraded ecosystems. COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.”

Pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always endangered insects on a global level. Pesticides threaten food webs in aquatic and marine environments, warp the growth and reproduction of all animals, and are a leading factor driving declines in bird populations.

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

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. The UN Environment Program (UNEP) identifies the global food system as the primary driver of biodiversity loss, pointing to the conversion of natural ecosystems to crop production and pasture with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases. In contrast, organic producers are required to conserve biodiversity.

Thus, a major reason that species are endangered is that EPA has registered pesticides that harm them. EPA must protect endangered species by eliminating the use of toxic pesticides and encouraging organic production. 

Thank you.

Letter of Congress
The biodiversity crisis is one of multiple crises that compound one another. While human actions are contributing to a sixth mass extinction, we are also facing crises in human disease and climate change. 

Biodiversity is critical for human health. It provides many goods and services essential to life on earth, supports human and societal needs, influences human health and well-being, and protects against exposure to zoonotic diseases. Biodiversity loss harms our health and threatens the ecological cycles that keep us alive. 

Biodiversity is essential for limiting climate change. It provides land and sea ecosystems that are natural carbon sinks, forests with two-thirds of the total mitigation potential of all nature-based solutions, wetlands covering 3 percent of the world’s land and storing twice as much carbon as all the forests, and seagrasses and mangroves that can sequester carbon dioxide at rates up to four times higher than terrestrial forests. 

Conserving and restoring biodiversity is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving Earth’s ability to absorb emissions. 

Among the targets for 2030 set by The UN Convention on Biological Diversity (CBD) at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since only 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, actions that protect species and their habitats from toxic and other destructive threats are critical, while restoring degraded ecosystems. COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.”

The Endangered Species Act (ESA) focuses on the species and habitats most at risk of extinction. However, the statement of purpose also recognizes the importance of conserving the ecosystem on which they depend. Biodiversity loss is harming our health and threatening the basic ecological cycles that keep us alive. “We are out of harmony with nature,” UN Secretary-General António Guterres told the 2022 Biodiversity COP 15 (Conference of the Parties). “Humanity has become a weapon of mass extinction. … And ultimately, we are committing suicide by proxy.”

Congress is considering measures that would weaken endangered species—and hence, biodiversity—protection. Five joint resolutions—S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86—have been introduced to roll back ESA regulations adopted in the Biden administration to those enacted in the Trump administration. S. 4753, “A bill to reform leasing, permitting, and judicial review for certain energy and minerals projects, and for other purposes,” has been passed out of the Senate Committee on Energy and Natural Resources. It weakens ESA protections by creating much shorter timelines for judicial review, additional categorical exclusions from the National Environmental Policy Act (NEPA) that could result in less science and planning for projects, tighter deadlines for agencies to complete the permitting process without increased capacity or funds. The Department of the Interior and its land management agencies have been consistently underfunded and understaffed. Shortening their deadlines without fixing those issues would lead to a rushed permitting process and limited public engagement. 

Please support 30X30 and other goals of COP 15. Please oppose S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86 and S. 4753.

Thank you.

(Beyond Pesticides, August 9, 2024)​​ A study in the journal Biology and Fertility of Soils has confirmed once again that organic agriculture contributes significantly to soil health, improving ecological functions that are harmed by conventional, chemical-intensive farming practices. Organic soil amendments (fertilizers) that feed soil organisms increase beneficial protistan predators and support sustainable predator-prey relationships within the soil microbiome. [‘Protist’ is a catch-all term that describes ancient lineages of eukaryotes—organisms with a nucleus—that are neither a true plant, animal, or fungus.] The study shows that organic farming creates a healthy ecosystem able to support a balance of life forms in the soil. Moreover, the study finds that the use of chemical fertilizers for agricultural management disrupt the stable biological relationship between protistan predators and their bacterial prey in soils, adding to the argument for transitioning away from conventional systems that lean on toxic inputs.  

Healthy soil contains millions of living species that form the microbiome. Most of the biodiversity in soil consists of bacteria and fungi, and their number and type are regulated partially by predatory protists and nematodes that feed on bacteria. Akin to the impact of predators keeping a herd of prey healthy by hunting the sick, protists keep the bacteria population healthy by removing the more inert microbes and releasing nutrients into the soil. In working together, these tiny organisms in organic land management systems determine the health of the soil for plant growth.

The authors indicate that they chose to examine protists because of the relative lack of studies regarding the effect of different fertilizers on the diversity and composition of soil protists, their importance to soil health, and their relative vulnerability to variations in agricultural practices. Compared with other microbial groups, researchers also cite evidence that protistan predators are more sensitive to the effects of petrochemical fertilizers. Fertilizers may cause changes in the diversity and taxonomic and functional compositions of soil protist communities. 

The study researchers from China analyze the soil from organic and conventional agricultural systems—200 and 179 soil samples, respectively—where bacterial and protistan data was available. The analysis compares the diversity and functionality of microbial communities between the two systems and how differences in soil properties contribute to changes in microbial abundance and diversity. Researchers also analyze a case study—based on cucumber cultivation with either organic or chemical fertilizers for three years between 2014 and 2016—for differences in soil properties resulting from different fertilizer management practices that contribute to changes in the soil biome. The case study includes an analysis of soil pH, organic matter, total nitrogen, total phosphorus, total potassium, and available nitrogen, phosphorus, and potassium.

Researchers found that organic soils have more bacteria and thereby support more heterogeneous communities of bacteria and protists. By providing more nutrients via organic soil amendments, organic agricultural systems allow faster and more abundant bacteria growth, which in turn feeds more protists than conventional farming. Moreover, protistan predators may prey on plant pathogens, thereby enhancing plant health. They also contribute significantly to nutrient cycling in the soil ecosystem and free up nutrients that can be used for plant growth.

The idea of organic systems, growing out of the study of composting, started with respecting the health of the soil as a living ecosystem. As J.I. Rodale and the Rodale staff wrote in The Complete Book of Composting, “At the very foundation of good nutrition is the soil—soil that is fertile and alive, that is kept in shape to grow plants as nature meant them to be grown. The life and balance in this soil [are] maintained by returning to it those materials which hold and extend life in a natural cycle, and aid in replenishing the nutrients needed to produce healthy, life-supporting crops. Soils that lack vital plant nutrients cannot give these food values to what is grown in them.”

In addition to supporting a healthy soil ecosystem, organic farming is necessary to stop and address the existential threat of global warming and the climate crisis. A study in the Journal of Cleaner Production in August 2023 concludes that “a one percent increase in total farmland results in a 0.13 percent increase in greenhouse gas 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.” Meanwhile, the 30% growth in emissions of nitrous  (N2O), a potent greenhouse gas, over the last four decades is mostly attributable to petrochemical nitrogen fertilizer use on cropland. Harmful nitrogen oxides (NOx, NO, NO2) increase public health risks for asthma and other respiratory illnesses through the creation of smog and acid rain.

While reducing the influx of dangerous nitrogen compounds into the atmosphere, organic systems additionally sequester significant amounts of carbon from the atmosphere. As previously reported by Beyond Pesticides, healthy soil can absorb and store 1,000 pounds of carbon per acre foot of soil annually under organic land management. This translates to roughly 3,500 pounds of carbon dioxide per acre drawn down from the air and sequestered into organic matter in soil. It is also noteworthy that the use of synthetic fertilizers undermines the carbon-capture ability of some kinds of terrain, such as salt marshes.

As Beyond Pesticides has repeatedly emphasized, serious health threats, biodiversity collapse, and the climate emergency are existential crises that undermine a livable future. The solution requires a meaningful holistic strategy that commits the nation to ending our fossil fuel-based economy and use of petroleum-based materials that release harmful levels of carbon and noxious gases into the environment. Just as there are proposals to end production of the combustion engine and move to electric vehicles, advocates must demand that agriculture—across the board and on an expedited schedule—shift to organic practices, whose standards are already codified in federal law with a proven and commercially viable track record.

A seemingly intractable problem remains: the vested economic interests in the petroleum and chemical industry are holding on to the status quo of a chemical-intensive pesticide treadmill. To address this challenge, Beyond Pesticides urgently calls for critically needed national grassroots collaboration to reframe the public debate and shift the needle of conversation towards holistic systems change via support for organic land management. A precautionary approach, embraced by organic principles, starts with the premise that we do not need toxic chemicals to achieve food productivity goals or beautiful landscapes.

Help affect a shift away from petrochemical pesticides and fertilizers and to safer organic land care practices through purchasing certified organic food whenever possible.  Please visit Beyond Pesticides’ Eating with a Conscience webpage to learn why eating organic foods is the right choice and how to eat organic on a budget. Consider supporting local organic farmers through farmers’ markets. And join Beyond Pesticides in fighting to protect the importance of organic integrity—earn why public engagement is needed to ensure the National Organic Standards Board upholds strict rules regulating organic agriculture.

Take action to change land care in homes, gardens, schools, and public parks, as well as agriculture.  The focus on soil health is a basic principle in organic agriculture that directly applies to all land management, including organic lawn and landscape care. See Beyond Pesticides’ website to learn about lawns and landscapes, hazards, and safer alternatives to using lawn pesticides and please visit the Tools for Change page to learn how to organize your community to end pesticide use and adopt organic land care.

Beyond Pesticides, with the support of our generous sponsors and local activists, has launched the Parks for a Sustainable Future program in partnership with local communities nationwide to transition two demonstration sites to organic land management. The demonstration sites become the basis for broader changes as a model approach towards organic land care. Sign up to be a Parks Advocate today to let us know you’re willing to speak with local leaders about the importance of this program.

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

Sources:

Investigating protistan predators and bacteria within soil microbiomes in agricultural ecosystems under organic and chemical fertilizer applications, Biology and Fertility of Soils, July 20, 2024

Soil protists: An untapped microbial resource of agriculture and environmental importance, Pedosphere, February 22, 2022

Protist – an overview (chapter), Physiological and Molecular Plant Pathology, 2023

Synthetic Fertilizers Accelerate Climate Crisis; The Way We Feed People Conflicts with Stabilizing Climate, Beyond Pesticides, Daily News Blog, November 2020

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

Fertilizers Compatible with Organic Landscape Management, Beyond Pesticides, Pesticides and You, Fall 2017

(Beyond Pesticides, August 8, 2024) With the use of its emergency authority—not used in nearly 40 years, the U.S. Environmental Protection Agency (EPA) on August 7 banned a pesticide (the weed killer Dacthal or DCPA—dimethyl tetrachloroterephthalate) under the “imminent hazard” clause of the federal pesticide law. At the same time, the agency is exercising its authority to prohibit the continued use of Dacthal’s existing stocks, a provision that EPA rarely uses. EPA identified serious concerns about fetal hormone disruption and resulting “low birth weight and irreversible and life-long impacts to children [impaired brain development, decreased IQ, and impaired motor skills] exposed in-utero” and finds that there are no “practicable mitigation measures” to protect against these hazards. The last time EPA issued an emergency action like this was in 1979 when the agency acknowledged miscarriages associated with the forestry use of the herbicide 2,4,5-T—one-half of the chemical weed killer Agent Orange, sprayed over people to defoliate the landscape of Vietnam in the war there—with the most potent form of dioxin, TCDD (2,3,7,8-Tetrachlorodibenzo-p-dioxin).

While EPA has been congratulated for using its emergency authority, which it is obviously reluctant to use, and health and environmental activists say could be used broadly, the timeline for review and action on individual pesticides has taken decades since the nation’s pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), was overhauled in 1972. The law has been criticized for creating a risk-benefit standard that allows for high levels of harm, especially to farmworkers and those handling pesticides, and public exposure through residues in food, water, and air. EPA’s decisions are subject to agency risk assessments that have been criticized by Beyond Pesticides as adopting flawed assumptions and ignoring vulnerable populations like children and those with preexisting health conditions, like cancer, endocrine system disruption, neurological illness, and other health effects that are exacerbated by exposure. Amendments to the law in 1996, in the Food Quality Protection Act, have done little to reduce the ongoing reliance on toxic chemicals in food production and land management, despite the growth of the $70 billion organic industry—still not considered by EPA to be a legitimate alternative to be evaluated when determining the “reasonableness” or “acceptability” of risk under pesticide law. Instead, EPA calculates acceptability of risk in the context of available alternative chemicals. In its press release on the Dacthal decision, EPA said, “In deciding whether to issue today’s Emergency Order, EPA consulted with the U.S. Department of Agriculture to understand how growers use DCPA and alternatives to this pesticide.” The agency’s consultation with USDA evaluated alternative chemicals, not alternative organic management systems and organic compatible substances.

The chemical manufacturer of Dacthal, AMVAC Chemical Corporation, can under FIFRA challenge the agency’s findings and seek court review, but EPA’s action takes effect immediately while any appeal is considered. Meanwhile, EPA has stopped use under 7 U.S.C. 136 et seq., pursuant to section 6(c)(3) (7 U.S.C. 136d(c)(3). See Unit IV. The prohibition on the use of existing stocks is mandated under Section 6(a)(1).

EPA explains DCPA uses as follows:
DCPA is a benzoic acid herbicide (Herbicide Resistance Action Committee/Weed Science Society of America Group 3) that inhibits cell division of root tips in target plants. It controls annual grasses and broadleaf weeds before they emerge in a variety of agricultural crops. DCPA is registered for agricultural uses, including Allium species, Brassica species, cucurbits, root vegetables, fruiting vegetables, strawberries, sod, and nursery ornamental production. Non-agricultural uses of DCPA include non-residential grass/turf including golf courses and athletic fields. While these turf uses are considered non-residential because the treated turf is not a home lawn, there is still the potential for residential post-application exposures as a result of application to these use sites. The registered end-use product may be applied by handheld, ground, aerial, and chemigation equipment.

In making its decision, EPA states that it considered:

1️⃣ The seriousness of the threatened harm;
2️⃣ The immediacy of the threatened harm;
3️⃣ The probability that the threatened harm will occur;
4️⃣ The benefits to the public of the continued use of the pesticide; and
5️⃣ The nature and extent of the information before the Agency at the time it makes a decision.

Beyond Pesticides points out that these criteria could be met for most of the pesticides for which EPA has negotiated settlements with pesticide manufacturers, resulting in partial withdrawals of pesticides from the market and compromises that threaten health and the environment.

The current system that EPA uses—negotiated settlements instead of regulatory action—compromises the health of people and the environment, often disproportionately for people of color and workers, who are the first to be exposed as applicators or agricultural workers. A clear-eyed understanding of the EPA process on one of the most toxic and widely used insecticides on the market (still widely used in agriculture), chlorpyrifos (Dursban), serves as a case study in providing context for the Dacthal decision. Could the Dacthal decision be a watershed moment to change a regulatory process that allows daily pesticide exposure, poisoning, and contamination at rates that EPA deems acceptable—despite the overwhelming science linking real-world pesticide use (homes, to parks and playing fields, schools, and farms) to dreaded illnesses, biodiversity collapse, and the climate crisis? (See Pesticide-Induced Diseases Database and the Pesticide Gateway.)

Will an understanding of EPA practices and the Dacthal decision change the path forward?
When EPA in June, 2000 reached an agreement to stop the sale of most home, lawn, and garden uses for the insecticide chlorpyrifos because of its health risks to children, it left most agricultural uses on the market. It should be noted that EPA’s negotiated regulation allowed Dow Chemical and all the users and sellers of the chemical to use up all their existing stocks for a full year, until the end of 2000—allowing the continued known threat to children in their homes, schools, parks, and playgrounds. Similar to the language in the Dacthal decision, children were identified by the agency as being at very high risk. Chlorpyrifos is a neurological toxicant that damages the brains of young children. However, the agency chose to use a lengthy and incomplete regulatory process. Exposures lead to decreased cognitive function, lower IQs, attention deficit disorder, developmental delays, and a host of other pervasive developmental and learning disorders in children. Because of this, it was evident to scientists and regulators at the time that this chemical must be taken off the market. Yet, the best the agency could achieve through the negotiations and settlement were restrictions that protected children from residential exposure, indoor and outdoor. See The LowDown on Dursban: MOEd Down by EPA: Do EPA Negotiations with Pesticide Manufacturers Compromise Public Health?

After over two decades since its original negotiated settlement on chlorpyrifos, with the EPA announcement that it was removing the chemical from the market, the frustration of the resource- and time-intensive effort associated with this decision on this one chemical bubbled up. Beyond Pesticides in a commentary wrote the following:

Does a science-based, public health-oriented, occupationally safety-focused, children-concerned, ecologically protective society allow the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? Should victims of poisoning have to plead with regulators to protect them? Should organizations have to fight chemical-by-chemical to achieve basic levels of protection from individual neurotoxic, cancer-causing, endocrine-disrupting pesticides? Of course not. But, the EPA announcement that it is stopping food uses of the insecticide chlorpyrifos after being registered 65 years ago provides us with an important opportunity for reflection, not just celebration. The collective effort to remove this one chemical is a tremendous feat in eliminating one exposure to a hazardous material for children. That is the point. The action we’re celebrating required an amazingly resource-intensive effort at a time in history when we are running against the clock in an urgent race to transition our society and global community away from the use of petroleum-based, toxic pesticides—to move to meaningful practices that sustain, nurture, and regenerate life. In this context, let’s put chlorpyrifos in perspective. EPA was forced into its decision by a court order that was precipitated by an agency decision to reverse course after proposing to stop food uses of chlorpyrifos in 2017. Despite a mountain of scientific data challenging chlorpyrifos’s safety, it was embraced by industrial agriculture, the golf industry, and others, and deemed too valuable to the bottom line of its manufacturer, Corteva (formerly Dow AgroSciences).

Then in November 2023, after over two decades of reviews, mountains of science, litigation, advocacy, and Congressional debate establishing that chlorpyrifos severely harms farmworker children, the 8^th Circuit Court of Appeals reversed EPA’s decision. Decisions to cancel uses of chlorpyrifos products are still trickling out of EPA, including those uses announced today.

The Dacthal decision may be an anomaly because EPA does not expect a fight from the manufacturer. However, the normal course of events under FIFRA is a drawn-out process that incentivizes delay. Even with Dacthal, the most recent round of requirements, review, and probably negotiations were drawn out over 11 years, while children’s exposure continued unabated.

Here is how EPA describes its truncated process:
In 2013, the agency issued a Data Call-In (DCI) to AMVAC Chemical Corporation, the sole manufacturer of DCPA, requiring it to submit more than 20 studies to support the existing registrations of DCPA. The required data included a comprehensive study of the effects of DCPA on thyroid development and function in adults and in developing young before and after birth, which was due by January 2016. Several of the studies that AMVAC submitted from 2013-2021 were considered insufficient to address the DCI, while the thyroid study and other studies were not submitted at all.

In April 2022, EPA issued a very rarely used Notice of Intent to Suspend the DCPA technical-grade product (used to manufacture end-use products) based on AMVAC’s failure to submit the complete set of required data for almost 10 years, including the thyroid study. While AMVAC submitted the required thyroid study in August 2022, EPA suspended the registration based solely on AMVAC’s continued failure to submit other outstanding data on Aug. 22, 2023, following an administrative hearing.  In November 2023, the data submission suspension was lifted after AMVAC submitted sufficient data. Most DCPA use on turf was voluntarily canceled by AMVAC in December 2023, but unacceptable risks from other uses remained.

The need for reform is an understatement according to most familiar with the failed regulatory system. As society and the global community struggle with petrochemical pesticides and their contribution to health threats, biodiversity collapse, and the climate emergency, and the fact that Dacthal is one active ingredient among over 1,000 in 56,000 pesticide products, Beyond Pesticides is calling for a phaseout by 2032 of petrochemical pesticides, which can be replaced by organic systems and substances compatible with the protection of health and the environment and a livable future.

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

(Beyond Pesticides, August 7, 2024) Using mass spectrometry techniques, researchers in Luxemburg and France detect 69 biomarkers of pollutants and pesticides—12 of which are banned—in hair samples from over 200 French children. This study, published in Environment International, is the first to target over 150 biomarkers in a single hair sample, which “represents the most comprehensive assessment of chemical exposome in humans,” the authors say.

All children in the study were 3.5 years old and recruited from the Étude Longitudinale Française depuis l’Enfance (ELFE) [French Longitudinal Study since Childhood] cohort in the country of France, a major pesticide consumer in Europe. The ELFE survey is a joint project between the French Institute for Demographic Studies (INED) and the National Institute of Health and Medical Research (INSERM), which provides the first comprehensive national scientific investigation of children in France by following them from birth to adulthood.

Through analysis of hair samples from children in the ELFE cohort, this study evaluates pesticide exposure and compares it with prenatal exposure data from their mothers while also, according to the scientists, “investigat[ing] the roles of children’s biological sex and geographical differences as possible determinants of exposure.”

Exposure to pesticides during early childhood poses significant health risks. In assessing 32 chemical families through liquid chromatography tandem mass spectrometry and gas chromatography tandem mass spectrometry in 222 hair samples, exposure markers can be identified in children from the ELFE cohort. Biomarkers, according to the U.S. Environmental Protection Agency (EPA), are “measurable substances or characteristics in the human body that can be used to monitor the presence of a chemical in the body, biological responses or adverse health effects.”

Hair analyses were chosen as a sampling method as they are non-invasive and provide simplicity of collection, storage, and analysis. “During growth, hair traps chemicals from the bloodstream, forming a historical exposure record,” the authors state. “Moreover, hair samples can be analysed years later as hair can retain pesticides and other chemicals well due to its durable keratin structure, which preserves chemicals from degradation by environmental factors like light, microbial activity and temperature.”

In the study, the scientists find that, “Among the biomarkers tested in children’s hair samples, 69 had a detection frequency of ≥ 50%, with 20 showing a 100% detection rate. Sex-specific differences were observed for 26 biomarkers, indicating the role of the child’s sex in exposure levels. Additionally, regional differences were noted, with Hexachlorobenzene varying significantly across the different French regions.” Over 100 different types of pesticides from the various chemical classes were detected in at least one sample, twenty of which are organochlorines. Organochlorines are a major chemical class known as which impact hormones that play an essential role in growth and development. Exposure to these compounds at a young age is especially harmful. The majority of the detected pesticide biomarkers are known or suspected endocrine disruptors. The most notable of which include fipronil and piperonyl butoxide (both found in 100% of samples), permethrin and α-endosulfan (99%), tebuconazole (96%), and carbaryl (85%).    

In each hair sample from the children, the number of chemicals detected ranged from 55 to 82 compounds out of the 159 biomarkers that were screened for. The authors note that, “12 banned compounds were detected in > 10% of the children’s hair, and these were from the organochlorine, polychlorinated biphenyl (PCBs), and brominated flame retardant (PBDEs) families.” The presence of these chemicals highlights the persistence within the environment of many pesticides that can affect multiple generations even after being banned.

This study reveals 26 biomarkers, including synthetic pyrethroid insecticides that impact nerves and brain function, with significant differences between the sexes, which suggests that “the child’s sex played a significant role in the model for these specific biomarkers. Specifically, 15 biomarkers showed significantly higher levels in males, while 11 biomarkers exhibited significantly higher levels in females. In particular, among these biomarkers, pyrethroid parent compounds, permethrin and tetramethrin, were found at significantly higher concentrations in females. In contrast, the levels of their metabolites, Cl2CA, 3-PBA, and CDCA, were significantly higher in males,” the scientists state. Permethrin is known for not only neurotoxicity but also endocrine disruption and reproductive effects, particularly for females. The authors continue by saying, “It is possible that these variations stem from inherent biological differences, encompassing hormonal and metabolic variations, along with societal factors that shape unique interactions between boys and girls with their environment.”

Regional differences in the results are also noted. Eleven biomarkers show differences in exposure, including three organochlorines: hexachlorobenzene, metazachlor, and metolachlor. The authors postulate that, “These variations could be due to localized agricultural practices and specificities in the local food supply chain in each region. Furthermore, the overlap of certain clusters is likely attributable to the broad range of biomarker concentrations that uniformly influenced all regions. Compounds such as pyrethroid parents, which showed uniform concentration levels across all regions, in both urban and rural areas, exemplify this phenomenon.”

Within the ELFE cohort sampled, 46 of the mother-child pairs took part in previous sampling, with additional insecticides detected. “Correlations were performed to investigate potential links between the exposure of mothers (indicative of prenatal exposure) and their corresponding children (indicative of post-natal exposure). The results of the investigation revealed that, except for Fipronil, Fipronil Sulfone, and Azoxystrobin, there were no statistically significant correlations between the levels of biomarkers found in the hair samples of the mothers and that of their respective children,” the researchers find. “These findings suggest the possible shared sources of contamination with the children. The detection of chemicals such as heptachlor (59%), metazachlor (61%), and malathion (78%) in more than half of children’s hair samples, but rarely in the pregnant women’s samples (heptachlor 2%, metazachlor 2%, and malathion 0%), can suggest age-related exposure differences. Such variations might arise from children’s frequent outdoor activities and direct contact with grass, soil, or plants treated with specific chemicals.”

The elevated levels of pollutants, classified as both persistent and non-persistent, in young children highlights exposure risks during key developmental stages that are not fully evaluated by EPA when performing risk assessments for pesticides. With multiple routes of exposure, including oral ingestion, respiratory inhalation, and dermal absorption, and the propensity for children to explore the world through taste and touch, exposure to pollutants has a heightened risk in youth. Their developing bodies make them more vulnerable as well, as they are less able to detoxify toxic chemicals.

Chemical exposure at an early age increases the body burden of harmful toxicants, many of which can stay in the body for a lifetime and escalates the risk for certain diseases such as cancer and Parkinson’s disease. Learn more about the hazards of pesticides for children’s health and how “Children and Pesticides Don’t Mix.” Beyond Pesticides promotes healthy environments for learning and recreation for children. Alternatives are available for schools and for creating sustainable parks that do not unnecessarily put children’s health at risk. Make The Safer Choice to avoid hazardous home, garden, community, and food use pesticides to protect children as they grow and develop.

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

Source:

Macheka, L. et al. (2024) Exposure to pesticides, persistent and non − persistent pollutants in French 3.5-year-old children: Findings from comprehensive hair analysis in the ELFE national birth cohort, Environment International. Available at: https://www.sciencedirect.com/science/article/pii/S0160412024004677.

(Beyond Pesticides, August 6, 2024) Factory fish farming companies sinched a win in Scotland in July after the Scottish government announced it would not put forward restrictions on emamectin (aka emamectin benzoate)—a toxic pesticide used to kill parasitic sea lice that also kills various nontarget marine life up and down the trophic ladder—until 2028. As reported over many years by The Ferret, an independent journalism cooperative based in Scotland, seafood corporations lobbied the Scottish government in a multiyear campaign to weaken environmental protection standards to advance their economic interests. Health and environmental advocates in the United States acknowledge the parallels of agribusiness, pesticide manufacturers, and their allies in undermining science-based policy and continue to call for intercontinental coordination on organic principles and standards that would render the use of toxic pesticides like emamectin obsolete.

Emamectin benzoate is a derivative of avermectin, a family of macrocyclic lactone compounds often used as the primary active ingredient in insecticides targeting parasites. The U.S. Environmental Protection Agency (EPA) considers emamectin benzoate a restricted-use pesticide that is toxic to fish, mammals, and aquatic organisms. Avermectins act as poisons to the nervous system of target pests, stimulating the gamma-aminobutyric acid (GABA) system (a chemical “transmitter” produced at nerve endings). ManageSafe™ identifies ants, cockroaches, and tree-boring caterpillars as primary targets for residential use of this type of insecticide, given that the result of using avermectins on pests begins with paralysis and eventual death after a handful of days. Studies gathered in the Pesticide-Induced Diseases Database category find avermectins linked to adverse reproductive, neurological, and developmental effects for humans, as well as toxicity to bees and aquatic life.

Scotland and Farm-Raised Fish Lobby

Rob Edwards, investigative journalist and co-founder of The Ferret, lays out a succinct timeline of the Scottish government’s increasingly lax approach to regulating seafood corporations operating farms in Scotland—leading up to this most recent decision.

The Scottish Environment Protection Agency (SEPA) identified the ecosystem threat emamectin posed in 2016:

• Usage of emamectin at Scottish Fish Farms: “It is of note that between 2002 and 2015 the amount of biomass in Scottish fish farms has doubled whereas the total mass of emamectin benzoate used in Scottish fish farms has increased sixfold over the same period.”
• Bioaccumulation: “The data suggest that emamectin benzoate remains in the tissues of marine organisms for an extended period (>90 days)… The metabolism and depuration rate [speed at which the pesticide is excreted from the body] is slow in fish.”
• Toxicity for Saltwater Organisms: The most sensitive species to both acute and chronic exposure to emamectin is the mysid shrimp (Americamysis bahia). At the lower end of the trophic pyramid, many crustaceous organisms rely on mysid shrimp as their primary food source.
• Toxicity for Freshwater Organisms: The most sensitive species to both acute and chronic exposure is the water flea (Daphnia magna) and the most sensitive taxa are crustaceans.

Despite their analysis of the potential threats to ecosystem health, SEPA abandoned its proposed policy to ban the use of emamectin back in 2017, opting instead for an interim limit of allowable levels of the chemical in marine sediments. The limit in its original format only applied to new fish farms or existing farms that wanted to increase emamectin use, which did not apply to most of the nation’s 200 salmon farms at the time. However, as Mr. Edwards reported, “Between 2017 and 2023 the limit was raised three times following a series of interventions by the industry, ending up at 272 ng/kg – 23 times higher than SEPA’s initial limit.” This slow but persistent weakening of the restrictions came amid significant lobbying from Salmon Scotland, the trade association representing Mowi, Bakkafrost, and Scottish Sea Farms—three multinational salmon farming companies that operate in Scotland. Farmed-raise salmon products from Mowi and Bakkafrost are sold in U.S. supermarkets and direct-to-consumer. The same year that this limit was introduced a scientific study published by the Scottish Aquaculture Research Forum found that emamectin “could reduce the number of crustaceans near salmon farms by 83%.”

In a previous Daily News, Farmed Salmon during Covid-19 Pandemic Subject to Increased Pesticide Use in Scotland, it was noted that SEPA at the time relaxed rules on both emamectin and azamethiphos to support salmon farms that were suffering due to Covid-19 pandemic restrictions. The legacy of this ongoing regulatory failure is a cautionary tale not only to consumers who are subjected to these products and nontarget fish and wildlife that involuntarily consume these toxic chemicals, but to regulators and elected officials who fail to meet the moment in establishing strong standards in service of public health and environmental protections.

“The separation of corporations and public institutions are crucial to ensuring that peer-reviewed, independent science guides policy rather than skewed conclusions that pad profit margins,” says Max Sano, organic program associate at Beyond Pesticides. See Daily News, Environmental and Trade Groups Successfully Call for End to Pesticide Company Alliance with UN-FAO, to learn about the legacy of CropLife International (trade organization for pesticide manufacturers) and its member companies—BASF, Syngenta, and Bayer-Monsanto—and the ways in which they directly influence regulatory and scientific analysis at the United Nations Food and Agriculture Organization and various national regulatory bodies.

Fish Farming and Pesticide Resistance

So what is emamectin benzoate? Emamectin, or emamectin benzoate, is a commonly used pesticide used to treat sea lice contamination in fish populations in farm settings. There have been notable examples in recent years of litigation against fish farm companies, including against Canada-based Northern Harvest Sea Farms in 2018 in response to charges stemming from the off-label use of Salmosan 50 WP (the organophosphate azamethiphos) added to its operations to combat severe sea lice outbreaks the previous year. The company was fined just $12,000 for violating the Pesticides Control Act in New Brunswick. One month after this court ruling, Norwegian seafood conglomerate Mowi (then-called Marine Harvest) acquired the company. Parasitic salmon lice (Lepeophtheirus salmonis) are already growing resistant to emamectin benzoate, as discovered in a 2022 study published in Scientific Reports based on data gathered from Pacific Ocean open-net fish farms. This builds on existing research published in Conservation Letters that parasitic lice found in both wild and farm-raised salmon had high rates of resistance.

[Please see the Daily News sections on resistance and emamectin to learn more about the sprawling and adverse health impacts associated with overreliance on toxic chemicals across various sectors of the food economy.]

Seafood and Organic Standards

Currently, there are no standards for allowable or prohibited inputs for “organic-certified” seafood products under organic regulations in the U.S. that distinguish from the existing standards for livestock production, which must be followed for any animal or product sold with the USDA organic certification seal.

During the Obama Administration, there was a push to develop standards for aquaculture (see Beyond Pesticides’ comments on the development of organic aquaculture standards), but this did not move forward. During that same period, the Department of Commerce and National Oceanic and Atmospheric Administration’s (NOAA) Fisheries Service under that administration pushed for loosening of restrictions for fish farming in federal waters. The U.S. allows for the importation of organic certified seafood from other countries that have their own standards. For example, the Canadian General Standards Board released the final version of the Canadian Organic Aquaculture Standard, a voluntary private third-party label, in 2012. One of the central controversies with the standard is that it allows fish from open pen systems (net pens), where fish are managed in a netted enclosure in an open body of water, to be certified as organic. Another controversy in that standard is an allowable use of parasiticides under veterinary supervision. The European Union Organic Aquaculture standard, which went into force in 2010, establishes a baseline standard for aquaculture products across the 27 member states. Although EU only produces 1.3% of global aquaculture products, the organic aquaculture market has exploded in recent years with 56% growth between 2012 and 2020, signaling interest across the continent to develop more stringent standards. See Organic Aquaculture in the EU: Current Situation, Drivers, Barriers, Potential for Growth, a European Commission-led report published in 2022, for more information.

Until the National Organics Standards Board (NOSB) installs official guidelines for organic aquaculture, U.S. consumers will continue to rely on imports from other nations that may or may not follow standards necessary to preserve trust in the organic label. See Beyond Pesticides recommendations to the National Organics Standards Board in 2014 Spring Meeting for further details on what organic aquaculture could look like pending strict criteria. See Keeping Organic Strong to learn more about how to engage in the public consultation and comment period process ahead of the fall 2024 meeting with further information available to you in the coming months.

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

Source: The Ferret

(Beyond Pesticides, August 5, 2024) As the longstanding problem of involuntary pesticide exposure through chemical drift continues unabated, EPA announced “new, earlier protections” that are being criticized by Beyond Pesticides as inadequate. The organization is calling on the public to let EPA and Congress know that it must comprehensively eliminate nontarget chemical trespass. Beyond Pesticides notes that the recent EPA announcement does not stop the movement of pesticides off the target sites restricted by pesticide product labels and therefore does not protect the public and environment in agricultural, rural, suburban, and urban areas from resulting health and ecological threats.

EPA’s July 15, 2024, press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift” states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”

>> Tell EPA and Congress that EPA must protect against all forms of pesticide drift.

Pesticide drift—more properly designated “chemical trespass”—is a threat to people living in agricultural, rural, suburban, and urban areas, as toxic chemicals move off the treated target site. While drift is a major exposure threat wherever pesticides are being used outdoors—from lawns, gardens, parks, playing fields, rights-of-way, to agricultural fields—pesticide drift is a major threat to those living near treated areas, as wind and rain can carry these chemicals miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to anyone in the application area or working and/or living near treated areas.

Included among those at high risk from drift are families of farmworkers who live near agricultural parcels. Schools, playgrounds, recreational fields, and other facilities at which children are frequent visitors, have been affected by pesticide drift—all the more concerning because children have elevated vulnerability to chemicals, given their sizes and developmental stages. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Another study finds that children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia.

Two participants in a Beyond Pesticides’ 2021 National Pesticide Forum session titled “Fighting Chemical Trespass,” were organic farmers who could not sell their then-contaminated crops as organic, and one of them could not sell them at all because the compounds that were sprayed are illegal for use on food crops. That same farmer, formerly in robust health, has suffered serious chronic health consequences, is now legally disabled, and has acquired $100,000 in medical debt as a result of the chemical poisoning she endured across multiple incidents.

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

That same farmer contends that reform of drift policy at the state level—currently a kaleidoscope of varying, or no, regulations—is critical. He also suggests that organic farmers, in particular, secure personal liability insurance for any health/medical debt they might incur as the result of a drift or spray incident.

Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency’s efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers’ “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act (ESA) for protecting endangered species and their habitats amid an unprecedented rate of global extinction is called into question.

A major problem with EPA’s efforts to address drift is the agency’s exclusion of vapor drift. Mitigation measures—such as buffer zones—designed to reduce the movement of droplets or dust are inadequate to address pesticides that move much further as vapors after volatilizing from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders.

Furthermore, EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, “The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review.” Why would one assume a lower-than-labeled rate anywhere in the treated area?

When pest management strategies rely on spray and dust pesticide application, drift is inevitable. Aerial pesticide application is of greatest concern, where an estimated 40% of pesticides used are lost to drift. Inert (nondisclosed) ingredients—amines—that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology. Amines are often added to herbicide formulations for glyphosate, dicamba, and 2,4-D products to increase solubility and reduce volatilization. While in theory, amines reduce volatilization by forming herbicide-amine salts that lock the herbicide vapors in place, the researchers found evidence that even new forms of dicamba billed by the agrichemical industry as “low volatility,” and restricted to formulations that include very specific amines, continued to cause drift problems for farmers.

From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming, it is simply ignored or not realistically restricted. These adverse effects are “unreasonable” because of an alternative—an organic production system—that does not harm human health, other species, or ecosystems and, in addition, helps to mitigate climate change. In its registration decisions, EPA must use organic production as a yardstick, denying any use for which organic production and land management is successful.

>> Tell EPA and Congress that EPA must protect against all forms of pesticide drift.

Letter to EPA:
EPA’s press release says, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift.” Yet EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”

Pesticide drift (chemical trespass) is a major threat to those living in agricultural, rural, suburban, and urban areas, as chemicals are carried by air and water miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to anyone working or living nearby. Among those at highest risk are farmworker families who live near farms. Children, who are more vulnerable to chemicals, use schools, playgrounds, and recreational fields that are subject to drift. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Additionally, children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia.

Also affected are organic farmers who cannot sell their contaminated crops as organic or cannot not sell them at all because the compounds that were sprayed are illegal for use on food crops. Organic farmers have huge concerns about such chemical trespass—for the safety of the food they produce, farmworker safety and health, the health and integrity of pollinators and biodiversity, and lost production and income. Once contaminated, a USDA Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation.

Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to its Draft Herbicide Strategy Framework, weakening ”protections” for endangered species from herbicide use. By reducing the stringency of the strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act amid an unprecedented rate of global extinction is called into question.

EPA’s failure to consider vapor drift is a major problem. Measures—such as buffer zones—designed to reduce movement of droplets or dust are inadequate in controlling vapors that move far from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders.

EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, “The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review.” Why would one assume a lower than labeled rate anywhere in the treated area?

When pest management strategies rely on spray and dust pesticide application, drift is inevitable. An estimated 40% of pesticides applied by air are lost to drift. Amines that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology.

From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming. The harm from drift is unreasonable given the alternative—an organic production system—that does not harm human health, other species, or ecosystems and helps to mitigate climate change. In the registration of toxic pesticides, EPA must recognize that successful organic land management eliminates the harm and uncertainties associated with drift.

Thank you.

Letter to U.S. Representative and Senators:
EPA issued a press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift.” Yet it states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”

Pesticide drift (chemical trespass) is a major threat to those living near in agricultural, rural, suburban, and urban areas, as chemicals are carried by air and water miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to those living or working nearby. Among those at highest risk are farmworker families who live near farms. Children, who are more vulnerable to chemicals, use schools, playgrounds, and recreational fields that are subject to drift. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Additionally, children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia.

Also affected are organic farmers who cannot sell their contaminated crops as organic or cannot not sell them at all because the compounds that were sprayed are illegal for use on food crops. Organic farmers have huge concerns about such chemical trespass—for the safety of the food they produce, farmworker safety and health, the health and integrity of pollinators and biodiversity, and lost production and income. Once contaminated, a USDA Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation.

Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to its Draft Herbicide Strategy Framework, weakening ”protections” for endangered species from herbicide use. By reducing the stringency of the strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act amid an unprecedented rate of global extinction is called into question.

EPA’s failure to consider vapor drift is a major problem. Measures—such as buffer zones—designed to reduce movement of droplets or dust are inadequate n controlling vapors that move far from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders.

EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, “The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review.” Why would one assume a lower than labeled rate anywhere in the treated area?

When pest management strategies rely on spray and dust pesticide application, drift is inevitable. An estimated 40% of pesticides applied by air are lost to drift. Amines that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology.

From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming. The harm from drift is unreasonable given thealternative—an organic production system—that does not harm human health, other species, or ecosystems and helps to mitigate climate change.

Please ensure that in its registration decisions, EPA recognizes that successful organic land management eliminates the harm and uncertainties associated with drift.

Thank you.

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

(Beyond Pesticides, August 2, 2024) In a recent study published in Science, a team from the University of Massachusetts and Yale University provides quantitative insight into the significant effects of a recent U.S. Supreme Court decision on the nation’s water quality. This research highlights the essential role of ephemeral streams—water sources that flow temporarily after rainfall—in transporting pollutants, including pesticides, sediments, and nutrients from land to larger water bodies. 

This comprehensive study underscores the devastating risk to U.S. water quality, stemming from the May 2023 U.S. Supreme Court decision, Sackett v. Environmental Protection Agency (EPA), which dramatically limits the agency’s ability to protect ephemeral streams as well as critical wetland ecosystems under the Clean Water Act (CWA).  As a May 2024 report by Clean Water for All Coalition notes, “The [Sackett] decision has endangered the drinking water sources of at least 117 million Americans by stripping protections from over half of the nation’s wetlands, as well as up to nearly 5 million miles of rain-dependent and seasonal streams that feed into rivers, lakes, and estuaries.”

At a time when an immediate response to the climate crisis and chemical pollution is more urgent than ever, the U.S. Supreme Court’s judicial decisions are seen by environmentalists and public health advocates as undermining necessary actions for a sustainable future. The Sackett decision reverses 40 years of environmental protection and water quality improvement under CWA, leaving ephemeral streams and many wetlands at risk for widespread and unrestricted contamination. 

Methodology and Results

Researchers compare long-term monthly water table depths with predicted bankfull depths across discrete water bodies, routing water through river systems using a published river-lake-reservoir routing framework to ensure that the newly mapped ephemeral channels were not immediately downstream of perennial rivers. The ephemeral stream map was validated using 7.207 in situ site assessments, and the model quantified the fraction of each river’s mean annual discharge—contributed by upstream ephemeral catchments—by tracking water as it moved downstream.

After modeling ephemeral stream contributions to the U.S. network—more than 20 million rivers, lakes, reservoirs, canals, and ditches—the results indicate “… that ephemeral streams are likely a substantial pathway through which pollution may influence downstream water quality, a finding that can inform evaluation of the consequences of limiting U.S. federal jurisdiction over ephemeral streams under the CWA.” The findings indicate that these ephemeral streams account for more than 50% of the water in major rivers like the Mississippi and Columbia, and over 90% in the Rio Grande.

Ephemeral streams, often overlooked waterways and drainage networks, account for 55% of the annual discharge from HUC4 (large river basins) drainage networks on average, with a higher influence in the western basins compared to the Eastern U.S. Ephemeral streams are particularly dominant in the desert and endorheic (completely isolated) basins of the Southwest and Great Basin, accounting for 59% of the total drainage network. Also, smaller streams have a higher percentage of ephemeral water, with first-order streams (smallest streams in a drainage network, also known as headwater streams or tributaries) averaging 79% from ephemeral sources. Overall, 68% of networks contain water that is at least 50% ephemeral.

Yale law professor Douglas Kysar, JD, coauthor of the Science piece, commented in a news article posted to the Yale School of the Environment website, saying, “When the Supreme Court narrowed the scope of the federal Clean Water Act, it did so by referring to abstract dictionary definitions rather than science. This research underscores the impact of that approach since, by our estimate, over half of annual discharge from U.S. drainage networks will no longer be protected by the Act.” The Yale article states, “By highlighting the importance of ephemeral stream flow to the downstream water quality, the results provide a basis for Congress to amend the CWA to expressly include ephemeral streams as an exercise of its power over interstate commerce.” Kysar said that the study findings also point to the need of enhanced regulation by state and local governments.

This is important because the adverse impacts on water quality will impact the waterways as a system. As coauthor Peter Raymond, PhD, Yale professor of biogeochemistry, notes, “The chemistry of water is dependent on how you manage the entire watershed, not just pieces of it. These streams are a critical source of water and pollutants and have to be regulated.”

“A State-by-State Fight” Responses Since Sackett Decision

Since the Supreme Court’s Sackett decision, nine states have proposed or adopted new or stronger protective measures for wetlands and ephemeral waters to fill the federal regulatory void, while seven states have attempted or passed rollbacks of wetland and water protections.

Colorado adopted HB24-1379, restoring previous federal protections through a new state permitting program. Illinois proposed but failed to pass legislation to establish a wetlands permitting program. Enhanced protections or programs have been established by:

• New Mexico: $7.6 million allocated for water quality.
• Washington: Expanded permitting with additional resources.
• California: Legislation aimed at no net loss of wetlands.
• Maryland: New rights for residents to sue over water pollution.
• Delaware: Developing new freshwater wetlands regulations.
• Wisconsin: Funding for local wetland conservation efforts.
• North Carolina: Implemented a policy for increased wetland conservation through the Governor’s executive order, despite legislative challenges seeking to rollback protections.

Seven states introduced rolled back protections. Indiana alone passed significant reductions in wetland protections. Rollback efforts were introduced but stalled in Missouri, Tennessee, Florida, North Carolina, South Carolina, and Louisiana.

The Clean Water for All Coalition report details state regulatory actions and notes that protecting water quality cannot effectively be accomplished with a patchwork of state laws, since water and pollutants flow across jurisdictions. Importantly, the report calls out the disproportionate impact of the Sackett decision, putting “our public health, local ecosystems, and communities at risk—especially in places like environmental justice communities that are already vulnerable to pollution and intensifying climate disasters.”

At best, state-by-state regulation poses both financial and capacity challenges for individual states, creating opportunities for polluting companies to exploit the weakened regulatory landscape. At worst, as Louisiana’s anti-clean water legislation shows, this weakened federal regulatory landscape risks drinking water supplies, environmental devastation, flooding, and disproportionately impacts vulnerable, environmental justice communities.

Ubiquitous pesticide use is evident in the widespread presence of pesticides in U.S. rivers and streams, with almost 90% percent of water samples containing at least five or more different pesticides—as Beyond Pesticides noted when reporting on a 2020 report by USGS, National Water-Quality Assessment (NAWQA) Project. Many of these pesticides are also linked to a range of human and environmental health effects, including cancer, birth defects, and neurological and reproductive health impacts (see Beyond Pesticides database here of Pesticide-Induced Diseases, with searchable access to studies that link public health effects to pesticides). The sheer number of different chemicals in the nation’s waterways and thus potential for toxic mixtures presents significant risks to health and the environment directly and from mixtures of contaminates. The data on water contamination has become one of the compelling reasons, according to health and environmental advocates, to abandon reliance on toxic chemicals in favor of organic land management.

Organic Agriculture and Land Care Reduces Water Contamination and Pollution

The research published inScience demonstrates the critical role of ephemeral streams, which consist of at least half of the water in the nation’s waterways. Without the authority provided by CWA to safeguard the quality of these waters, there remains a major threat to water quality. Advocates note that without federal regulation, steps must be taken immediately to curtail synthetic, petrochemical pesticide and fertilizer use and adopt organic practices and products to protect the nation’s waterways.

The focus on a holistic system of land management, as espoused by organic regenerative agriculture, demonstrates that relying on toxic chemical inputs for crop yields is unnecessary. Creating healthy soils, which is the foundation of organic systems, conserves water, nurtures fertility, reduces surface runoff and erosion, and decreases the need for nutrient input, and critically, eliminates the toxic chemicals that threaten so many aspects of human and ecosystem life, including water resources.

Solutions

With a focus on eliminating the very pesticides and synthetic fertilizers that are contaminating surface and ground water, certified organic agriculture is the only food production system that defines acceptable practices and allowed substances under rules adopted by the U.S. Department of Agriculture. Beyond Pesticides publishes the Daily News and conducts weekly actions that focus on a range of issues critical to health and the environment, from protection and integrity of organic standards to the underlying science that defines the threat of pesticides. Consider subscribing to the Action of the Week to engage in advocacy and receive a recap of the week’s top reports and developments.

Learn more about how Beyond Pesticides’ Parks for a Sustainable Future program works with universities, school districts, parks departments and on town, city, and county lands throughout the U.S. to support the transition to organic land management.  This two-year program supports community land managers with in-depth training to transition two public green spaces to organic landscape management, providing the knowledge and skills necessary to be able to transition all public areas in a locality to these safer practices. To encourage your community to transition to organic land management, sign up to be a Parks Advocate today. For more information that informs the threats and support health and environmental advocacy, see the most recent issue of Pesticides and You.

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

Sources: 

Ephemeral stream water contributions to United States drainage networks, Science, June 2024

Wetlands and Streams Most in Danger After the U.S. Supreme Court’s Sackett v. EPA Ruling – Earthjustice, Earthjustice press release, May 14, 2024

Study Finds Small Streams, Recently Stripped of Protections, Are a Big Deal, New York Times, June 27, 2024 

Ephemeral Streams Likely to Have Significant Effect on U.S. Water Quality, Yale School of the Environment press release, June 27, 2024 

UMass study finds most water draining into US rivers isn’t protected by federal pollution laws, Mass state law goes farther, Boston Globe, 2024

Sackett v. EPA: The State of Our Waters One Year Later, report by Clean Water for All and Protect Our Waters, May 2024

This Independence Day, Protect Democracy, Beyond Pesticides Daily News Blog, July 4, 2024

Recent Supreme Court Ruling on Clean Water Act “will take our country backwards,”Beyond Pesticides Daily News Blog, June 15, 2023

Organic Land Management and the Protection of Water Quality, Pesticides and You, Beyond Pesticides, Winter 2013-2014

Organic Systems: The Path Forward, Pesticides and You, Beyond Pesticides, Spring 2019

Threatened Waters: Turning the Tide on Pesticide Contamination, Beyond Pesticides website

(Beyond Pesticides, August 1, 2024) The city council of Newbury, Massachusetts unanimously voted to ban second-generation anticoagulant rodenticides (SGARs) on private property earlier this year, according to a press release by Mass Audubon. Several other local governments across the state have passed proposed rodenticide or pesticide ordinances since the fall of 2023 – including the cities of Arlington, Orleans, and Newton. Moreover, proposed legislation sitting in the state legislature calls for designating glyphosate as a restricted-use pesticide on public lands (S.516, S.517, and H.813) and establishing ecologically based mosquito management plans at the state and local levels. (S.445 and H.845) The combination of these pending actions demonstrates the public’s concerns over adverse impacts of toxic pesticides and demands for a transformation toward an ecologically sustainable land management system rooted in organic principles in the absence of federal action.

Massachusetts is one of about 45 states that, in some form, preempts local governments from establishing pesticide ordinances. If a municipality’s elected officials vote to pass a pesticide ordinance, some states (including Massachusetts) require passage through the state legislature. This is known as the Home Rule petition process. Back in the 19^th century, U.S. Supreme Court Justice John F. Dillon established what is known as the Dillon Rule, which provides guidance for the distribution of powers between local and state governments. Under the rule, local governments are to be treated as “political subdivisions” that derive their authority from the state government. On many matters, ranging from the incorporation of a new fire department, establishing a real estate transfer fee for local properties, or prohibiting the use of a pesticide that is not prohibited statewide, actions of local governments—after voting on a measure within their own body—must go through review by the State Attorney General’s office and both chambers of the state legislature before becoming local law. See this report by the Massachusetts Division of Local Services in the Department of Revenue for more information and history. For further analysis of pesticide regulations and local preemption, see “State Preemption Law: The Battle for Local Democracy” for a detailed breakdown of pesticide ordinance law on a state-by-state basis.

In Massachusetts, the town of Orleans passed a pesticide ordinance that would prohibit the use of nonagricultural use of toxic pesticides on private and public land except for an allowed list in alignment with the National List of Allowed and Prohibited Substances, a cornerstone of the Organic Foods Production Act. The towns of Newton and Arlington passed similar resolutions to Newbury in prohibiting the use of SGARs on public land but not explicitly mentioning a prohibition on private property.

There is substantial peer-reviewed scientific research and lived experiences of those living in communities that are routinely exposed to SGARs that motivates communities to chart a path for ecologically based pest management. The United States has yet to ratify the Convention on Biological Diversity (CBD), nor has the U.S. Environmental Protection Agency (EPA) incorporated biodiversity targets as a national priority across all its programmatic areas.  Earlier this year in February, advocates across the nation called on the U.S. Environmental Protection Agency (EPA) to improve its protection of endangered species from rodenticides in a public comment period. In 2021, advocates demanded the prohibition of aerial rodenticide dropping on California-based Farallon Islands as it would impose undue health consequences on seabird and sea lion species in northern California and across the Pacific coastline. Reliance on toxic rodenticides also poses threats to public health. Beyond Pesticides reported last fall that guests at a Pittsburgh, PA extended-stay hotel were evacuated by health officials due to a contamination and poisoning incident caused by an unidentified rodenticide. Officials confirmed that the particular rat poison involved in the incident, when exposed to water, releases the highly toxic phosphine gas. According to the Centers for Disease Control and Prevention (CDC), the gas causes many symptoms, including nausea, vomiting, stomach pain, diarrhea, thirst, muscle pain, difficulty breathing, and the accumulation of fluid in the lungs, with acute and prolonged exposure potentially leading to more severe consequences.

Growing out of local advocacy, the California state legislature in 2020 passed the California Ecosystems Protection Act— a law that prohibits (with limited exceptions) the use of highly toxic rodenticides, specifically SGARs. Rodents that are poisoned by SGARs often do not die immediately and are often left weakened or deceased for other mammals and birds to consume; ultimately, this permits the bioaccumulation and spread of toxic rodenticides through local and regional food webs. A 2022 meta-analysis published in Frontiers in Ecology and Evolution reviews over 100 studies that reinforce the necessity to transition to a nontoxic pest management systems as biodiversity collapse is imminent and public health is on the line. In 2023, EPA released a decades-worth of Pesticide Incident Reports from its Incident Data System and the Center for Biological Diversity noted over 1,169 reported incidents involving brodifacoum, one of the most widely used rodenticides in rodenticide products. The vast majority of this incident data is gathered by pesticide and chemical companies as required by the Federal Insecticide, Rodenticide, and Fungicide Act (FIFRA), raising concerns among public health advocates that there is a likelihood of underreporting. Learn more about the adverse health effects of SGARs, including bromadiolone, through Beyond Pesticides’ Gateway on Pesticide Hazards and Safe Pest Management.

Federal preemption is on the docket once again in this year’s Farm Bill negotiations, as reported in previous Daily News (here, here, and here). In the Republican-back version that passed the U.S. House of Representatives Agriculture Committee in June, the Farm Bill draft, if passed, would prohibit the rights of state and local governments to restrict or ban pesticides in the service of public and environmental health. The draft bill establishes preemption language in both Sections 10204 and 10205:

• “Prohibit any State, instrumentality or political subdivision thereof… from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or packaging that is in addition to or different from the labeling or packaging approved by the Administrator of the Environmental Protection Agency.” (SEC. 10204. UNIFORMITY OF PESTICIDE LABELING REQUIREMENTS).
• “A political subdivision of a State shall not impose, or continue in effect, any requirement relating to the sale, distribution, labeling, application, or use of any pesticide or device. . .” (SEC. 10205. AUTHORITY OF STATES). 

See Action of the Week to contact your U.S. Congressional Representative and Senators to protect local and state authority to enact more stringent restriction of pesticides in the final Farm Bill.

Health and environment advocates believe in the significance of transitioning to new models of pest management that prohibit the use of toxic petrochemical-based pesticides and chemicals. See Daily News section on adverse impacts of rodenticides on public well-being, wildlife health, and ecological stability. See Safety Source on Pest Management Providers to learn how to best identify pest management companies that utilize the least toxic and pesticide free practices. See Gateway on Pesticide Hazards and Safe Pest Management to easily identify active ingredients in rodenticide and insecticide products and their potential for adverse health impacts. See Parks for a Sustainable Future to learn more about how to engage your community in organically managed public parks and lands. If you are concerned that you or a loved one was exposed to a toxic pesticide, see What to Do in a Pesticide Emergency.

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

Source: Mass Audubon

(Beyond Pesticides, July 31, 2024) The latest commentary on “forever chemicals” in Environmental Health Perspectives captures growing concerns for the class of per- and polyfluoroalkyl substances (PFAS) that are found in pesticide products and cause persistent contamination that threaten human health and the environment. The authors share, “Given that pesticides are some of the most widely distributed pollutants across the world, the legacy impacts of PFAS addition into pesticide products could be widespread and have wide-ranging implications on agriculture and food and water contamination.”

Fluorination, which adds fluorine to a compound, is used to modify properties, such as the stability of chemicals. It can also increase residual activity of pesticide ingredients. Fluorinated molecules, including PFAS, are “a serious environmental health concern owing to their highly persistent nature, often potent toxicities, potential to bioaccumulate, and widespread presence in people, animals, and the broader environment,” the authors state. They continue in saying, “The long-term impacts of using mixtures of extremely persistent chemicals on potentially hundreds of millions of acres of US land every year is, to us, a cause for concern.”

The commentary, titled “Forever Pesticides: A Growing Source of PFAS Contamination in the Environment,” explores how and to what extent PFAS can be introduced into pesticide products, and how this impacts health and the environment, through public records requests to state and federal agencies in the United States and Canada, as well as from publicly accessible databases. As a result, the authors find that, “The biggest contributor to PFAS in pesticide products was active ingredients and their degradates [chemical breakdown products]. Nearly a quarter of all US conventional pesticide active ingredients were organofluorines and 14% were PFAS, and for active ingredients approved in the last 10 y[ears], this had increased to 61% organofluorines and 30% PFAS.”

The classification of PFAS is also of concern, as the number of PFAS in the U.S. heavily depends on the U.S. Environmental Protection Agency (EPA) definition, which is on a “case-by-case” basis during rulemakings and agency actions. The broad definition of PFAS as a compound with at least “one fully fluorinated carbon” has been adopted by many states and other authorities, such as the U.S. Geological Survey (USGS) and the Toxics Release Inventory (TRI) under Section 313 of the Superfund Law, or Emergency Planning and Community Right-to-Know Act (EPCRA).

Aside from active ingredients that are defined as PFAS, there are also inert ingredients that play a role in contamination. While inert ingredients do not need to be disclosed on labels and have limited toxicity testing as a part of pesticide formulations, they are often “far from being inert,” the authors say. “Many of these ingredients have chemical properties that can influence the toxicity or alter the bioavailability of the active ingredient or have unintended off-target effects themselves to people and wildlife.”

The authors submitted a public records request to EPA and received a response that “indicated that the agency had 24 registered inert ingredients that it had identified as PFAS or that the agency suspected may be PFAS.” In reviewing this list, the authors confirmed 11 of the compounds contained “fluoro” in the ingredient name field and should be classified as PFAS. Canada’s Pest Management Regulatory Agency (PMRA) also has a list of currently registered inerts, seven of which were identified as being PFAS. Since inert ingredients can be even more toxic than the active ingredients and are undisclosed within pesticide products, this raises additional considerations.

In compiling and analyzing test data by USGS for pesticides in ~500 streams throughout the U.S. between 2013 and 2017, 225 pesticide compounds were found in water samples. Twenty-nine total PFAS analytes were identified, 13 of which are PFAS active ingredients and 16 are fluorinated degradates. Degradates, such as trifluoroacetic acid (TFA), which correlate strongly with pesticide use, can be detected in waterways and food. “The USGS estimates that anywhere from 10.4 to 15.9 million kg of PFAS active ingredients are used across the United States each year—the vast majority of which contain at least one—CF3 [trifluoromethyl] group and could potentially metabolize into TFA or other persistent, fluorinated water contaminants,” the authors state. They continue with, “Organically grown food has also been found to have lower levels of TFA than food grown with synthetic pesticides,” which offers a healthier alternative.

While the practice of fluorinating plastic containers started in the 1950’s, PFAS leaching from storage containers, especially in those that contain pesticides, has gained publicity more recently as a major topic of concern. “Today hundreds of millions of high density polyethylene (HDPE) containers that contain agricultural products, personal care products, household cleaning supplies, home improvement products, and food are fluorinated each year,” the authors state, continuing, “It is estimated that 20%–30% of all hard plastic containers used in the agricultural sector are fluorinated, elevating concerns about widespread PFAS contamination.”

In 2021, EPA committed to not only facilitate the remediation of legacy PFAS contamination but also to intervene to limit the introduction of unnecessary new PFAS into the environment through its PFAS Strategic Roadmap. The overwhelming body of science that highlights PFAS throughout the environment, and the negative effects they have on human health and the environment, show that EPA is failing at this task. “The enormous potential for human exposure and environmental contamination belies the importance of understanding complete product compositions and their environmental fate and transport,” the authors comment, which is lacking in current EPA risk assessments. PFAS are highly persistent and analyzing chemicals within this class over only a few months does not capture the entire picture of how these chemicals transform over long spans of time.

PFAS, including chemicals in the group such as PFOA (perfluorooctanoic acid) and PFOS (perfluorooctane sulfonic acid), “are known to harm the immune system, weaken the antibody response to vaccinations, and increase the risk of infectious disease,” the authors comment. The immunotoxic effects of PFAS threaten human health, and yet are not fully evaluated by EPA. As the authors share, “Between 2012 and 2018, the US EPA granted 223 of 229 waiver requests (97%) for immunotoxicity testing of pesticide active ingredients… Troublingly, the number of active ingredients that are fluorinated or that meet the definition of PFAS has increased considerably from 2012 to the present—the very time period that the US EPA granted 97% of waiver requests for immunotoxicity study requirements. This suggests that fluorinated or PFAS active ingredients may be more likely to be immunotoxic than other types of active ingredients and that any associated immunotoxicity may not be accounted for owing to the lack of requirement for scientific study.”

As a result of these findings and previous documentation of the consequences of PFAS being released into the environment, the authors recommend that:

1) the practice of fluorinating plastic containers should be discontinued,

2) all pesticide ingredients including inerts need to be disclosed on pesticide labels and material safety data sheets,

3) immunotoxicity studies should no longer be waived,

4) all PFAS pesticides and their degradates must be fully evaluated for environmental persistence, and

5) the US federal government must expand environmental monitoring and biomonitoring programs to include all PFAS pesticides.

One of the authors, Kyla Bennett, PhD, is a former EPA official and now works with the Public Employees for Environmental Responsibility (PEER) nonprofit. In an article in The Guardian, Dr. Bennett says, “We should be eliminating PFAS from all products, but particularly pesticides because you’re spraying them on crops, and there’s not a more direct way to expose the population than that… We should not be going in this direction.” A new lawsuit filed by PEER targets the inaction of EPA on PFOA in plastic containers. Due to the widespread risks to health, the complaint says that EPA must “halt the manufacture and distribution of tens of millions of plastic containers with dangerous levels of PFOA” under the Toxic Substances Control Act (TSCA).

A recent petition, submitted by the Center for Food Safety (CFS) on behalf of 12 other petitioners, including Beyond Pesticides, echoes these concerns and asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.” In the latest Action of the Week, readers can urge EPA to approve this petition, and tell Congress to demand that EPA act immediately.

The path forward is organic land management. The National Organic Standards Board (NOSB) reports directly to the U.S. Secretary of Agriculture and provides a sustainable system with public input and standards as defined by federal law for farming practices. These practices prioritize soil health and biodiversity and can provide an alternative to plastics, PFAS, and pesticides with organic production and packaging. The ongoing development of organic standards through NOSB offers national requirements for the production, handling, processing, and labeling of organically grown food that supports human health and the environment. Beyond Pesticides is working to get plastics out of organic. (See here and Beyond Pesticides’ comments to the NOSB.) You can grow your own organic food or buy organic products to help reinforce the shift away from petrochemical pesticides and fertilizers to healthier alternatives.

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

Source:

Donley, N. et al. (2024) Forever Pesticides: A Growing Source of PFAS Contamination in the Environment, Environmental Health Perspectives. Available at: https://ehp.niehs.nih.gov/doi/10.1289/EHP11900/.

(Beyond Pesticides, July 30, 2024) The U.S. Environmental Protection Agency (EPA) announced on July 15 what it described as a new process for evaluating the risks of spray drift—the migration of pesticides from their target area to off-site zones. According to a statement by EPA Chemical Safety and Pollution Prevention Assistant Administrator Michal Freedhoff, PhD in an Oregon Public Broadcasting story, the agency took the step so that “people don’t have to wait years for the protections they deserve and need.” However, EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in [its] 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” EPA has said, “Spray drift is governed by a variety of factors which govern how much of the pesticide application deposits on surfaces where contact with residues can eventually lead to indirect exposures (e.g., children playing on lawns that are next to treated fields and where residues have deposited).” The new policy will add spray drift evaluation to occasions when the agency receives an application for a new pesticide and when a registered pesticide is intended for a new use or applied to a new crop. The change will also be integrated into the implementation of the Federal Insecticide, Fungicide, and Rodenticide Act and EPA’s obligation to fold pesticide harms into its regulations under the Endangered Species Act.

Pesticides are applied as sprays from aircraft, spraying machines traversing fields, and by hand by people using backpacks. Details like nozzle size also affect the droplet size, which in turn affects how far it will travel. High pressure applications with small droplet size, such as those used on fruit tree canopies, tend to produce the highest number of illnesses from spray drift, followed by aerial applications. Pesticides are sprayed on crop fields, forests, park and school grounds, golf courses and roadway margins as well as private properties. The reason that spray drift is a problem is that it makes people, animals, and plants sick, especially noticeable in acute exposures at the time of spraying.

The economics of spray drift are such that one would think the pesticide industry—or at least farmers—would be desperately seeking for a solution to the problem. And in fact, it is clear that the pesticide industry is deeply concerned about spray drift, and its messaging is almost entirely devoted to advising farmers on how to reduce it. CropLife International, for example—the industry’s primary mouthpiece—admits that “in the long run, the consequences of repeated spray drift can mean that growers lose access to key weed control tools” through regulation and that spray drift can mean the intended recipient field is missed, neighbors’ crops may be damaged, and there may “even [be] a health hazard for humans and animals.” The solution, CropLife says, is “operator knowledge.” This is yet another case of placing the burden on the worker lowest on the totem pole when the entire premise of agricultural pesticides is a macro-scale problem.

Pesticides cannot be precisely applied only to existing target plants. Air is a fluid, which means that anything in the air can potentially go anywhere. According to a 2011 French study, up to 86.6 percent of sprayed fungicides can miss the target crop entirely. Even with soil-applied glyphosate, the study found that less than half the amount applied stayed on the plants, and much of it accumulated in the bodies of test snails. EPA’s July announcement took pains to point out that the rule change won’t require more data or fees from the “regulated community” because these ““could disincentivize registrants from introducing new tools for growers and could lead to unclear labels and confusion at the user level.”

Dicamba is perhaps the most notorious culprit in spray drift damage to humans and plants. Beyond Pesticides has covered dicamba’s multiple harms repeatedly (for example here and here). Dicamba’s drift-prone behavior is becoming even more severe because of climate change. The worst form for pesticide application is as a gas, or fumigant, and dicamba exhibits an increasing tendency to vaporize as temperature increases. Advice for spraying pesticides already includes strong emphasis on monitoring specific wind conditions such as speed and direction, avoiding atmospheric inversions, and applying when non-applicators are not present. A stricture should be added against applying dicamba when the air temperature is above 85 degrees Fahrenheit, the point where dicamba turns from a liquid to a gas, known as volatilization. As we are currently undergoing the hottest year in Earth’s recorded history, there may be very few days when dicamba could be applied without entering its gas phase. And as the Arctic melts, as Beyond Pesticides has covered, the Arctic serves as a reservoir for both banned and current-use pesticides which will be decanting from permafrost and ice into the world oceans and terrestrial regions. To compensate for climate’s exacerbation of agricultural degradation, see Regenerative Organic Agriculture and Climate Change: A Down-to-Earth Solution to Global Warming.

Where do sprayed pesticides go? Mostly to areas adjacent to the target zone. This is often next-door farms but can include schools and many other buildings, including homes, especially those of farmworkers. Along roadways pesticides travel into whatever adjoins the road and easily make their way into ditches and streams. Pesticides can continue to volatilize for long periods after application.

There is no federal requirement for sprayers to notify neighbors of the date of spraying, although there are patchy state notice requirements, most of which are voluntary and require registration by people to receive notices ahead of time. Nor is there any requirement to notify farmworkers from neighboring farms, who suffer by far the most egregious exposure to these wasted pesticides. A 2017 report on human exposure to spray drift by the Northwest Center for Alternatives to Pesticides (NCAP) and Columbia Legal Services (CLS) noted a Washington State Department of Health study showing that 56 percent of the people sickened by pesticide drift were workers on another farm; the next largest group, 28 percent, were nearby residents—in sum, 84 percent of the victims were not present on the farm applying the pesticides.

There are many routes of exposure: direct skin contact and inhalation at the time of exposure, but also contact with soil and water, consumption of water, animals and plants also exposed to pesticide spray, and contact with clothing used by the applicator, to name a few. EPA’s July announcement does not mention inhalation at all, and, regarding children, refers only to “incidental oral exposure” to 1-to-2-year-olds who play on grass and put things in their mouths. The NCAP/CLS report considered acute symptoms rather than long-term effects in the spray victims of a 2014 event, all of whom reported neurologic problems including shaking, headache, and fainting, with large majorities also experiencing nausea, vomiting, coughing, rashes, and burning eyes. Some were hospitalized. Importantly, as much as 88 percent of spray drift illnesses are not reported by victims. In a Washington Department of Health study, workers in a focus group said they did not seek medical care for pesticide exposure because they needed their wages and feared being fired, did not know that workers’ compensation would cover their health care, and believed health care workers were on their employers’ side.

Despite regulators’ and industry groups’ efforts to develop adjustments to spray applications such as controlling nozzle size and timing of application, the incidence of illness from spray drift has not declined by much. The Washington Department of Health report cited by NCAP/CLS showed that the number of people who were sickened jumped from 43 in 2012 to 129 in just two years, by 2014. This occurred even though the actual number of pesticide drift events increased only from 15 to 22 in the same two years. In New Zealand, cotton growers reported the 2022-2023 growing season as one of the worst on record for spray drift damage. “EPA has made assumptions that are not true, and ignores reality, never incorporating any real science into exposure assessments,” said Beyond Pesticides executive director Jay Feldman.

The NCAP/CLS report cites a 2004 University of Washington School of Public Health study finding “spray drift occurring despite adherence to general precautionary pesticide application guidelines.” Both EPA and industry tout the inclusion of buffer zones, but these are often far too small to be effective. EPA’s effort to incorporate pesticide policy into the Endangered Species Act includes larger buffer distances for salmon—60 to 300 feet—in Washington, Oregon and California than many buffers designed to protect off-target plants and people. A 2012 state bill to establish a half-mile buffer between applications and nearby workers failed to pass the Washington legislature. “While EPA does not incorporate a lot of buffer zones into pesticide restrictions,” Feldman said, “even buffer zones are arbitrary and do not extend nearly far enough to truly be protective. If they were to be truly protective, it would be too burdensome to farming operations because they would have to take land out of production” to provide the buffer.

All the controls, mitigations, and advice doled out by EPA and the pesticide industry are likely not effective enough to seriously reduce the problem of spray drift. EPA’s new announcement will do little to reduce the harms of pesticides in the short term. EPA even claims its new and tepid policy is “furthering protections to bystanders wherever pesticide spray drift may occur, and thereby strengthening environmental justice protections associated with the use of pesticide products.” This is a specious claim at best, since it will still take years to incorporate spray drift into EPA’s regulatory structures and essentially nothing has been done to protect bystanders and residents near sprayed fields, forests and road verges. As Feldman put it, “The true effect of drift, if calculated, would be a good argument for the organic alternative. From an economic perspective, drift is an externality that is never calculated in the true cost of chemical-intensive farming. It is simply ignored or not realistically restricted.”

In fact, both regulators and the pesticide industry rest their actions on a severe contradiction that generates a queasy sense of cognitive dissonance: Both take for granted the idea that pesticides can never go away, and therefore it is a great leap forward to incorporate probably ineffective steps into the constant parade of new pesticides coming down the pike because old pesticides become useless so rapidly through resistance among pests and their own inherent biological toxicity. It is strikingly illogical to keep doing the same thing repeatedly when it does not work except on very short timescales, and at the expense of the biosphere that is necessary to human survival. Baby steps in this case are simply deflection, denial and disregard for consequences.

Beyond Pesticides will suggest public comments through our Action of the Week at the end of this week. See Getting the Drift on Chemical Trespass.

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

Sources:
Implementing Chemical Specific Human Health Spray Drift Analysis for Pesticide Registration Action July 14, 2024
https://www.regulations.gov/document/EPA-HQ-OPP-2013-0676-0124

Human Exposure to Pesticide Drift: Washington State Report
Northwest Center for Alternatives to Pesticides and Columbia Legal Services
February 2017
https://columbialegal.org/wp-content/uploads/2018/11/PesticideReportFINALWeb.pdf

Washington State Department of Health, Learning from Listening: Results of Yakima Farmworker Focus Groups about Pesticides and Health Care (2004)
https://ntrl.ntis.gov/NTRL/dashboard/searchResults/titleDetail/PB2005100332.xhtml#

Court Strikes Down EPA’s Allowance of Weedkiller Dicamba after Scathing Inspector General Report
Beyond Pesticides, February 13, 2024

Court Strikes Down EPA’s Allowance of Weedkiller Dicamba after Scathing Inspector General Report

Call for EPA to Reject Harmful Weed Killer; Politicized Supreme Court Takes the Reins from Agencies
Beyond Pesticides, July 1, 2024

Call for EPA to Reject Harmful Weed Killer; Politicized Supreme Court Takes the Reins from Agencies

Tell EPA To Ban Drift-Prone Pesticides
https://www.beyondpesticides.org/action-of-the-week/tell-epa-to-ban-drift-prone-pesticides?contactdata=&nvep=&hmac=&emci=4035f12e-7f35-ef11-86d2-6045bdd9e096&emdi=ea000000-0000-0000-0000-000000000001&ceid=

“Legalized Poisoning of 5,500 People” Message Highlights Controversy Over Aerial Pesticide Spray in Oregon
Beyond Pesticides, September 5, 2023

“Legalized Poisoning of 5,500 People” Message Highlights Controversy Over Aerial Pesticide Spray in Oregon

Snails as indicators of pesticide drift, deposit, transfer and effects in the vineyard
Science of The Total Environment
Volume 409, Issue 20, 15 September 2011
Coline Druart, Maurice Millet, Renaud Scheifler, Olivier Delhomme, Caroline Raeppel, Annette de Vaufleury
https://www.sciencedirect.com/science/article/abs/pii/S0048969711007224?via%3Dihub

The Washington aerial spray drift study: assessment of off-target organophosphorus insecticide atmospheric movement by plant surface volatilization
Jaya Ramaprasad, Ming-Yi Tsai, Kai Elgethun, Vincent R. Hebert, Allan Felsot, Michael G. Yost, Richard A. Fenske
Atmospheric Environment
Volume 38, Issue 33, October 2004
https://www.sciencedirect.com/science/article/abs/pii/S1352231004005199

Dicamba: Past, present, and future
Bob Hartzler
Iowa State University
2017 Integrated Crop Management Conference
https://crops.extension.iastate.edu/blog/bob-hartzler/dicamba-past-present-and-future

Equipment and Application Techniques in relation to pesticide drift and residues
Wesley E. Yates and Norman B. Akesso
Report of the Fourth Agricultural Aviation Research Conference
University of California, Davis
1962
https://www.google.com/books/edition/Report_of_the_Fourth_Agricultural_Aviati/dnXDfa7bCgIC?hl=en&gbpv=1&dq=spray+drift+AND+livestock&pg=PA154&printsec=frontcover

(Beyond Pesticides, July 29, 2024) Beyond Pesticides is asking the public to support a petition to the U.S. Environmental Protection Agency (EPA), filed by environmental and farm groups, to require the agency’s pesticide registration program to ban PFAS (so-called “forever chemicals”) as pesticide ingredients and all their uses that result in contamination of pesticide products. The petition, submitted by the Center for Food Safety (CFS) on behalf of 12 other petitioners, asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.” PFAS—per- and polyfluorinated substances—is a group of nearly 10,000 highly persistent, human-made toxic chemicals. A commentary released last week in Environmental Health Perspectives, Forever Pesticides: A Growing Source of PFAS Contamination in the Environment, “explore[s] different ways that PFAS can be introduced into pesticide products, the extent of PFAS contamination of pesticide products, and the implications this could have for human and environmental health.”

The petition addresses the fact that EPA continues to register hundreds of PFAS pesticide ingredients. In addition, the agency has allowed the ongoing use of pesticide storage containers treated with PFAS, despite its own findings that these containers leach the chemicals into pesticide products—which are then dispersed into the air, water, and soil. PFAS persistence is due to a fluorine–carbon atom bond being among the strongest ever created.

Tell EPA to approve the petition filed by the Center for Food Safety—joined by 12 environmental and farm petitioners—and eliminate the distribution of PFAS chemicals through pesticides. Tell Congress to urge EPA to act immediately. 

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. The use and associated public and environmental exposure to PFAS as active ingredients represent a grave threat as a result of their application in homes, emergency rooms, health care facilities, schools, and lawn care. The contamination extends to structures, gardens, food, soil, and water, including as a contaminant in drinking water. Among the wide variety of sources, contamination is attributed to the use of fertilizers made from so-called “biosludge” (biosolids) from local waste treatment plants where PFAS active ingredients can end up. In addition, run-off from land treated with PFAS active ingredients, these treatment plants may discharge millions of gallons of wastewater into waterways, contaminating them; current waste and water treatment generally does not eliminate PFAS compounds from the treated effluent water.

Among the wide use of PFAS in pest management products is the mosquito insecticide Anvil 10+10. 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 leach PFAS. PFAS have been linked to various health threats, including cancer, reproductive problems, and immune system dysfunction.

As PEER notes, 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 through exposure via ingestion, inhalation, and dermal contact.  

The number of pesticide ingredients classified as PFAS in the U.S. heavily depends on EPA’s definitions. Many experts describe EPA’s initial definition as significantly underinclusive compared to state and international definitions. EPA took a further step away from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas.

In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states, including Colorado, Washington, Maine, Maryland, New York, and California, encompasses a broader range of compounds.

In the context of pesticide ingredients, the “one fully fluorinated carbon” definition encompasses up to 200 pesticide ingredients. Maine will prohibit these starting in 2030, following its ban on pesticides that include intentionally added PFAS and pesticides contaminated with PFAS. This definition covers bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, and the main ingredient in over 600 pesticide formulations today, which recent testing has found elevated amounts of bifenthrin in numerous agricultural crops, exceeding the agency’s safety levels.

Concerns about safety in the use of fluorinated plastic containers used for packaging are based on exposure to PFAS 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 vulnerable people, from pregnant women through children 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 National Organic Standards Board (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.

Tell EPA to approve the petition filed by the Center for Food Safety—joined by 12 environmental and farm petitioners—and eliminate the distribution of PFAS chemicals through pesticides. Tell Congress to urge EPA to act immediately. 

Letter to EPA:
Numerous studies document the devastating impacts on public health, wildlife, and pollinators caused by the broad use of PFAS chemicals and the resulting environmental contamination. While acknowledging PFAS as an urgent public health and environmental issue, EPA continues to register hundreds of PFAS pesticide ingredients and allows the ongoing use of fluorinated pesticide storage containers, despite its own findings that these containers leach PFAS chemicals into pesticide products—which are then dispersed into the air, water, and soil.

The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products raises alarm about the extent of PFAS contamination and its potential impact on public health. 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—plastic containers that leached PFAS.  Studies by EPA, independent researchers, and manufacturers show that PFAS leaches from the walls of containers into the contents, thus exposing millions of people to PFAS without their knowledge. Exposure to PFAS also results from handling the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, including pregnant women, children, and the elderly, experience disproportionate risk. PFAS have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. EPA’s drinking water health advisories find PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.

The number of pesticide ingredients classified as PFAS in the U.S. depends on EPA’s definitions. EPA retreated from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas. In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states, encompasses a broad range of compounds, among them up to 200 pesticide ingredients, such as bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, a main ingredient in over 600 pesticide formulations, which tests have found to exceed EPA safety levels in numerous agricultural crops.

A petition submitted by the Center for Food Safety (CFS) on behalf of CFS and twelve other petitioners asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.”

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.

Please approve the Center for Food Safety petition filed on July 23, 2024 on behalf of itself and 12 environmental and farm petitioners to eliminate the distribution of PFAS chemicals through pesticides.

Thank you.

Letter to U.S. Representative and Senators:
Numerous studies have document the devastating impacts on public health, wildlife, and pollinators caused by the broad use of PFAS chemicals and the resulting environmental contamination. While acknowledging PFAS as an urgent public health and environmental issue, EPA continues to register hundreds of PFAS pesticide ingredients and allows the ongoing use of fluorinated pesticide storage containers, despite its own findings that these containers leach PFAS chemicals into pesticide products—which are then dispersed into the air, water, and soil.

The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products raises alarm about the extent of PFAS contamination and its potential impact on public health. 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—plastic containers that leach PFAS.  Studies by EPA, independent researchers, and manufacturers show that PFAS leaches from the walls of containers into the contents, thus exposing millions of people to PFAS without their knowledge. Exposure to PFAS also results from handling the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, including pregnant women, children, and the elderly, experience disproportionate risk. PFAS have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. EPA’s drinking water health advisories find PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.

The number of pesticide ingredients classified as PFAS in the U.S. depends on EPA’s definitions. EPA retreated from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas. In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states, encompasses a broad range of compounds, among them up to 200 pesticide ingredients, such as bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, a main ingredient in over 600 pesticide formulations, which tests have found to exceed EPA safety levels in numerous agricultural crops.

A petition submitted by the Center for Food Safety (CFS) on behalf of CFS and twelve other petitioners asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.”

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.

Please urge EPA to approve the Center for Food Safety petition filed on July 23, 2024 on behalf of itself and 12 environmental and farm petitioners and eliminate the distribution of PFAS chemicals through pesticides.

Thank you.

(Beyond Pesticides, July 26, 2024) Beyond Pesticides released the latest issue of Pesticides and You this week, a compendium of scientific research on pesticide threats to human and environmental health. The issue is a breathtaking warning from the science community that environmental, health, and labor laws are not protecting the public. Beyond Pesticides says in its introduction that a shift away from toxic pesticide use is urgently needed.

Included in this issue are scientific reviews of research reported by Beyond Pesticides in 2023, providing a critique of the independent peer-reviewed literature with a shocking range of adverse effects, including cancer, neurotoxicity, brain effects, reproductive impacts, diabetes and obesity, chronic kidney and liver disease, Parkinson’s, respiratory illness and asthma, learning and behavioral abnormalities, and more, as well as disproportionate harm to people of color. In addition, the science documents pesticides’ catastrophic harm to the ecosystems that sustain life. In total, these dramatic findings call for an end to the use of toxic pesticides, incompatible with respect for living organisms and, to environmental, health, and labor advocates, unconscionable given the availability of viable, cost-effective organic practices.

This issue adds to the body of knowledge from two previous issues of Pesticides and You (Transformative Change: Informed by Science, Policy, and Action, and Retrospective 2021: A Call to Urgent Action) with scientific warnings that keep getting louder. The abject failure of the law and regulations to respond to the scientific warnings highlighted in this issue has contributed to existential crises, including severe health threats, biodiversity collapse, and the climate emergency—and, as Beyond Pesticides states, calls for holistic solutions, rather than piecemeal approaches focused on individual chemical restrictions. In this context, articles about organic land management and crop production practices that are ecosystem-compatible inform the path forward.

The issue includes five sections that track the science of the last year:

In Section 1, Toxicology—Human Health Threats, studies address breast cancer and other cancers, disruption of the endocrine system (the message system of the body leading to cancer and other effects), reproductive effects, Parkinson’s disease, liver damage, metabolic disorders, chronic kidney disease, diabetes, obesity, shingles, pregnancy, and reproductive complications, developmental effects in children, nervous system disruption, neurodevelopmental problems, seizure disorders including epilepsy, gut-brain effects, behavioral effects, asthma, and respiratory disorders, mast cells impact (immune system regulators), brain effects, pregnancy and fetal effects, PFAS (polyfluoroalkyl substances) contamination linked to a large range of effects including cardiovascular risks, and issues pertaining to indoor air contamination, highly destructive accidents, and regulatory weakness that questions scientific integrity conflicts of interest, and pesticide dangers at golf courses.

In Section 2—Disproportionate Harm, studies address global malnutrition linked to pollinator decline with the highest threat to low-income people, governmental support of environmental justice to ameliorate disproportionate effects of pollution and climate change, history of disproportionate harm on Juneteenth, neurodevelopmental disorders, effects to farmworker pregnancy, and Indigenous people’s knowledge applied to protecting biodiversity.

In Section 3—Threatened Biodiversity and Ecosystems, studies on limits of mitigation measures to protect pollinators, degradation of color discrimination in pollinators, fungicide linked to adverse brain effects through oxidative stress, impacts on bee gut microbiota, adverse impacts on birds, butterfly decline, insect decline, waterway contamination, dying oceans, threatened endangered species, and bee-toxic pesticides.

In Section 4—Pest Resistance and Failed Efficacy, studies on disease transmission through pesticide-resistant mosquitoes, bed bug resistance, resistant Colorado potato beetle attacked with genetically engineered pesticides, incomplete data on RNAi, antibiotic resistance, glyphosate causing reduced crop yields and climate effects, organic compared to glyphosate on yields and climate, EPA failure to conduct pesticide efficacy reviews, and crop failure with genetically engineered plants.

In Section 5—Organic Transition and Nontoxic Practices, studies on soil health in climate debate, perennial crops to fight biodiversity collapse, crop diversification and Intercropping, cultivating natural predators, organic pilot sites in New York City parks, National Football League (NFL) call for end to synthetic turf, strengthened USDA organic enforcement exceeds chemical-intensive agriculture, National Organic Standards Board issues, challenging hydroponic organic, strengthen EPA’s Safer Choice with organic compatible practices and products, and California Roadmap weaknesses.

A Holistic Framework for Moving Forward

The intersectionality of the science on health threats, biodiversity collapse, and the climate emergency may not be captured by any one individual study in this issue, but, taken as a whole, what emerges from the body of science on pesticides and alternatives contained in this issue is a call to action. Threats in each category of harm are in and of themselves devastating, deadly, and unsustainable, whether the subject matter is health, biodiversity, or climate.

Beyond Pesticides on Change

According to Beyond Pesticides: The change needed requires collective action and a societal embrace of organic systems that put an end to the multiple toxic mixtures and involuntary exposure, from contamination of land, air, water, and food. Although we recognize the importance of attempts to restrict individual pesticides through improved chemical regulation and effective toxic pesticide use reduction strategies, a crosscutting national grassroots collaboration is critically needed, especially now, to help reframe the public debate to be holistic. A precautionary approach, embraced by organic principles, starts with the premise that we do not need toxic chemicals to achieve food productivity goals or beautiful landscapes.

Beyond Pesticides on this Issue: As with previous issues, Beyond Pesticides views this issue as a tool for empowering activism and the necessary dramatic changes in practices and policies. This issue alone does not capture the entire body of the scientific literature (which we strive to accomplish with our web-based databases and program pages). Still, it adds significantly to the documentation that must compel decision makers to take meaningful action in eliminating petrochemical pesticides and fertilizers. At the same time, it is intended to provide a path forward with organic practices and links to our hands-on development of organic models for land management in communities across the country.

For more: See Beyond Pesticides recording of the 40th National Forum, Forging a Future with Nature: The existential challenge to end petrochemical pesticide and fertilizer use (see recording at bp-dc.org/ Forum2023), where scientists and advocates discuss cutting-edge science and strategies for change.

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

Source: Pesticides and You

(Beyond Pesticides, July 25, 2024) On July 10, the Oregon Court of Appeals ruled that the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) does not preempt pesticide exposure victims’ state law claims against pesticide manufacturers, based on reporting from The New Lede. This decision builds on years of judicial precedent from the Supreme Court of the United States (SCOTUS) that protects individuals’ right to use failure-to-warn claims against producers of toxic pesticides, including Bayer-Monsanto. The importance of judicial review is critical to protecting the public against public health impacts of toxic pesticide use in the context of last month’s SCOTUS decision ending Chevron Doctrine, and with it the end of deferring to federal regulatory agencies on ambiguities in statutory mandates. A growing coalition of environmental and public health advocates, organic farmers, trial attorneys, farmworkers, and physicians are united in pushing back against a concerted effort by industry and its allies to attack victims’ ability to sue under “failure-to-warn” through the Farm Bill, state legislatures, and the proposed federal budget for Fiscal Year 2025.

Oregon Court of Appeals

In 2022, a local trial court in Oregon ruled in favor of Monsanto on a lawsuit initiated by Jackson County residents Larry and Gayle Johnson that alleged Mr. Johnson’s non-Hodgkin lymphoma diagnosis was caused by exposure to glyphosate-based Roundup Ready. The jury ruled against the defendant—who used the general-use pesticide product on his property for decades—citing the U.S. Environmental Protection Agency’s (EPA) preemptive authority over pesticide registrations pursuant to FIFRA. Mr. Johnson appealed the trial court’s decision in favor of Monsanto because of that court’s decision to exclude the testimony of Charles Benbrook, PhD, on the grounds that his testimony “would be inadmissible” for three reasons: lack of qualifications, helpfulness, and harmlessness. Under state statute OEC (Opinion Evidence from Experts) 702,  

“If scientific, technical or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training or education may testify thereto in the form of an opinion or otherwise.”

The Appellate court indicates that the trial court erred in not considering Dr. Benbrook’s robust experience as a scientist specializing in agricultural economics with over 40 peer-reviewed articles, reports, and book chapters on pesticide regulation and risk assessment (please see the Daily News from May 21, 2024, Weed Killers Dicamba and 2,4-D Found in Pregnant Women in Midwest USA, Linked to Serious Effects, examining a peer-reviewed study he coauthored this year), former staff director for the U.S. House of Representatives Subcommittee on Department Operations, Research, and Foreign Agriculture, and consultant for companies seeking pesticide registration and label reviews. Dr. Benbrook has also served as an expert witness on previous cases, such as State v. Rogers (200), Pilliod v. Monsanto Co. (2021), and Johnson v. Monsanto Co. (2020).

The Court of Appeals also disagreed with the trial court’s determination that Dr. Benbrook’s testimony would not be helpful. Various courts have “permitted regulatory experts to testify on complex statutory or regulatory frameworks when that testimony assists the jury in understanding a party’s actions within that broader framework.” This court agrees that FIFRA regulation falls into this category of “complex statutory or regulatory frameworks.” On the matter of “harmlessness,” the Court agreed that Dr. Benbrook’s testimony is important, given that the trial court jury had to make an informed decision on EPA approval of Roundup’s label under FIFRA, which was not otherwise provided by other expert testimony offered in the case. 

The Oregon Court of Appeals decision overruling the trial court is consistent with opinions from the 9^th Circuit Court of Appeals and 11th Circuit Court of Appeals that ruled on state civil tort failure-to-warn laws, as well as the broader matter of federal preemption, according to reporting by Capital Press.

Legacy of Litigation and Court Rulings

As mentioned above, the Court of Appeals for the 9th Circuit determined that EPA’s 2020 approval of glyphosate is unlawful, building on the SCOTUS denial of certiorari in Bayer’s appeal to reverse rulings against the company for liability against the company. This SCOTUS ruling is consistent with the Bates v. Dow Agrosciences (2004) ruling where the Supreme Court found:

“The long history of tort litigation against manufacturers of poisonous substances adds force to the basic presump­tion against preemption. If Congress had intended to deprive injured parties of a long available form of compen­sation, it surely would have expressed that intent more clearly. See Silkwood v. Kerr-McGee Corp., 464 U. S. 238, 251 (1984). Moreover, this history emphasizes the im­portance of providing an incentive to manufacturers to use the utmost care in the business of distributing inherently dangerous items.” (Please see the Daily News  further analyzing the court rulings on glyphosate here.)

Bayer has been forced to pay over $4 billion in verdicts and $9.6 billion in settlements to head off additional litigation, and yet there are still over 50,000 claims pending as of December 2023. See Bayer/Monsanto in Roundup/Glyphosate Case Stung with Largest Multi-Billion Dollar Jury Award, Asks States to Stop Litigation for further information on the financial implications of litigation against pesticide manufacturers.

Pesticide Immunity Push

After Bayer/Monsanto failed to get the U.S. Supreme Court to preempt (and reverse) multimillion-dollar jury verdicts for its failure-to-warn on the hazards of glyphosate (Roundup), pesticide manufacturers and their allies are pursuing several measures to establish immunity against future lawsuits. (Please see the Daily News here and here.) The industry is now advancing legislation through the Farm Bill, state legislatures, and other federal bills to insulate itself from litigation and local pesticide restrictions. Historically, the current industry has pushed to seek immunity from litigation by those who have been harmed by their products or from more stringent local restrictions than those established by federal law.

The strategy to seek a legislative fix for losses in the courts is a key part of the industry’s playbook. For example, after losing a landmark case in the U.S. Supreme Court, in Mortier v. Casey (1991), the industry effectively reversed the Court’s decision through legislation in virtually every state, except six. Environmental advocates therefore point to the current industry strategy as a serious threat to public and environmental health and safety.

Within the House Farm Bill text, there is a provision in Section 10204 that would: “prohibit. . .a court from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or packaging that is in addition to or different from the labeling or packaging approved by the Administrator of the Environmental Protection Agency.” This follows a pattern of attempts to preempt local and state authority along numerous policies, including pesticide ordinances and CAFOs. See more coverage on Farm Bill negotiations and their connection to undermining failure-to-warn liability framework. (Here, here, and here).

Pesticide immunity language has also appeared in House Interior Appropriations bill text for Fiscal Year 2025, “None of the funds made available by this or any other Act may be used to issue or adopt any guidance or any policy, take any regulatory action, or approve any labeling or change to such labeling that is inconsistent with or in any respect different from the conclusion of— (a) a human health assessment performed pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136 et seq.); or b) a carcinogenicity classification for a pesticide.” (Section 467: PESTICIDES, p. 216).

State legislators in Missouri, Idaho, and Iowa attempted—but ultimately failed—to push forward legislation that would have changed state civil tort law to undermine failure-to-warn in those states on the ground that EPA labels inherently serve as a warning to any potential adverse health effects. Industry allies argue that pesticides registered with the EPA undergo human health assessments including carcinogenicity tests, meaning that the label meets the disclosure standard. This line of thinking is inconsistent with EPA’s label review and pesticide registration process and “does not absolve the registrant’s liability if the pesticide is misbranded.” In other words, the argument of “the label is the law” shrouds the fact that EPA has a track record of failing to incorporate peer-reviewed scientific studies into their pesticide registration and review process.

Environmental and public health advocates across the nation are demanding elected officials in Congress and state legislatures to protect local and state authority to regulate pesticides, as well as the failure-to-warn liability framework. Please join us in taking action on relevant topics [here, here, and here] and consider subscribing for future opportunities to engage. We welcome you to access the Daily News sections on litigation, label claims, and Farm Bill to review additional analysis and historical review of pesticide preemption to further inform your advocacy.

Source: The New Lede

(Beyond Pesticides, July 24, 2024) The Center for Food Safety—joined by environmental, farm, and grassroots organizations including Beyond Pesticides—submitted a groundbreaking petition yesterday to the U.S. Environmental Protection Agency (EPA), urging immediate action to address the presence of per- and polyfluoroalkyl substances (PFAS) in pesticides and pesticide containers. Numerous studies have shown that the broad use of PFAS chemicals, and the resulting environmental contamination, has devastating impacts on public health, wildlife, and pollinators. Despite acknowledging PFAS as an urgent public health and environmental issue, EPA has upheld hundreds of registrations of pesticide ingredients that fall into the PFAS category. Furthermore, EPA has allowed the ongoing use of fluorinated pesticide storage containers, despite the agency itself finding that these containers leach PFAS chemicals into pesticide products.  

PFAS, known as “forever chemicals” due to their ability to persist in the environment, are endocrine disruptors, which are linked to developmental issues, cancers, and organ damage. Crops can uptake PFAS from soil, resulting in dietary exposure for both the public and wildlife, while PFAS ingredients in pesticides can also leach into groundwater, contributing to widespread PFAS drinking water contamination. In recent years, EPA has acknowledged this critical issue and committed to addressing PFAS contamination outside the context of pesticide regulation, including issuing the first-ever enforceable drinking water standard to protect communities from exposure to two PFAS chemicals (PFOS and PFOA).  

“While the Biden Administration has taken steps to address PFAS contamination in other areas, the EPA has allowed these forever chemicals to be used on our nation’s food supply, public playgrounds, school lawns, and backyard gardens unabated,” said Sylvia Wu, attorney for Center for Food Safety and counsel for the petitioners. “We call on the administration today to live up to its commitment to protect communities and the environment and swiftly end the use of PFAS in pesticides.”  

“With EPA having permitted the proliferation of PFAS in pesticide products—contaminating land, air, water, and food with multigenerational threats to health and ecosystems—the petition establishes that it well past the time for the agency to comply with the law, and stop the chemicals’ entry into commerce,” said Jay Feldman, executive director of Beyond Pesticides. “We have safe alternative practices and products,” he said.

Today’s Petition calls on EPA to: (1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.  

The petition represents the concerns of numerous groups focused on protecting the health of both people and pollinators essential to our food system from pesticide use and PFAS exposure. In addition to the Center for Food Safety, it is endorsed by: American Bird Conservancy, Beyond Pesticides, Massachusetts Pollinator Network, Maine Organic Farmers and Gardeners Association, Norwalk River Watershed Association, Pesticide Action Network North America, Northeast Organic Farming Association Interstate Council, Northeast Organic Farming Association of Vermont, Northwest Center for Alternatives to Pesticides, Rural Vermont, Toxic Free NC, and Tom Neltner. 

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

(Beyond Pesticides, July 23, 2024) In analyzing the interactions between neonicotinoid pesticides (NNPs) and microplastics (MPs), a recent study in The Science of The Total Environment finds that neonicotinoids such as thiacloprid (THI) become more bioavailable in soils containing traditional and biodegradable plastics. Increased bioavailability, which quantifies the extent to which organisms are exposed to chemicals in soil or sediment, puts soil microbiota at risk and leaves all consumers susceptible to adverse effects in contaminated food crops. This study raises a grave deficiency, among others, in the pesticide registration and regulatory review process, which currently ignores interactions of pesticides with other contaminants, like microplastics, in the environment when conducting health and ecological effects assessments.  

The researchers, from China University of Geosciences, Beijing Academy of Agriculture & Forestry Sciences, Chinese Academy of Agricultural Sciences, and University of Swat in Pakistan, chose to study thiacloprid as an example of NNPs to explore “the adsorption-desorption process and mechanism of NNPs on MPs,” as well as the main factors affecting adsorption, since these are two contaminants of concern in agricultural environments. 

Adsorption [clinging to the surface] and desorption [releasing after adsorption] of thiacloprid by both traditional and biodegradable MPs, and the impact of MPs aging on adsorption, is assessed. Prior to the study, the authors hypothesized that “(1) traditional and biodegradable MPs have different mechanisms of adsorption-desorption for NNPs, and due to the stronger hydrophilicity of biodegradable MPs, we assume that biodegradable MPs will adsorb more of the similarly hydrophilic NNPs; (2) Aging can alter the properties of MPs, thereby affecting their adsorption of NNPs; (3) The MPs in soil can alter the mode of existence of NNPs in the soil, thereby altering the bioavailability of neonicotinoid pesticides in the soil.” 

The researchers share that, “Polyamide 6 (PA6) and poly (butylene adipate co-terephthalate) (PBAT) were selected as representative MPs. Among them, PA6 is a non-degradable plastic, and PBAT is the most frequently used degradable plastic in degradable plastic films. Further, as a representative of NNP, thiacloprid (THI) was selected due to its high detection rate.” Adsorption kinetic studies were performed using “a slightly higher initial concentration than the actual environmental level,” which the authors say “reduces the impact of measurement errors on the experimental results, which is favorable for precisely investigating adsorption behavior and mechanism.” 

PA6 and PBAT age differently, with PA6 generating pores on the surface and PBAT with a roughened surface containing wrinkles and cracks. However, both of these changes over time allow for “solutions to penetrate the interior of the MPs easily and potentially offers more sites for adsorbing pollutants,” as the researchers state. This suggests that chemicals can not only adsorb on the surface but also absorb into the plastics. 

In studying the surface morphology of these plastics, “the elemental analysis results of the MP surface showed a reduction in C [carbon] content and an increase in O [oxygen] content after aging. This suggests that oxygen-containing functional groups are produced through oxidation on the surface of MPs during aging. The increase of oxygen-containing functional groups also increases the hydrophilicity of MPs, making it easier to interact with water-soluble substances.” This study shows that aging of microplastics increases the adsorption capacity for pollutants, which leads the authors to postulate that, “Aged MPs have a higher ability to absorb THI and are more likely to become environmental carriers of THI.”  

The effects of pH, salinity, and dissolved organic matter (DOM) on the adsorption of MPs with THI are also analyzed. The researchers find that:  

1. “The pH value of the solution mainly affects adsorption in two aspects: one is the change in the form or solubility of pollutants, and the other is the change in the surface charge of MPs.” 

1. “The potential for MPs to adsorb THI increases as the environment transitions from freshwater to marine [salt water].” 

1. “The adsorption behavior of contaminants on MPs can be impacted by the diverse functional groups present in DOM, which is abundant in aquatic environments.” 

The authors conclude that the “addition of MPs alters the physical and chemical properties of soil, the presence of MPs increases the number of soil aggregates, which due to their anaerobic conditions, may promote the selective growth of denitrifying bacteria while inhibiting the activity of aerobic bacteria. These changes could ultimately affect the structure of the bacterial community and potentially reduce the degradation efficiency of THI in the soil.” They continue in saying, “The bioavailability of pollutants in soil may be altered by MPs for various reasons, including altering the distribution of THI in soil through a series of adsorption and desorption processes. Another cause may be that MPs modify the physicochemical characteristics of the soil and fill its adsorption sites, thereby increasing the instability of contaminants and their susceptibility to ingestion by plants and animals.” 

Adding MPs to soil can also alter the distribution pattern of THI in the soil, and the different patterns found in the two soil types within the study also highlight the fact that “soil properties cannot be ignored when studying the bioavailability of pollutants,” according to the researchers. The addition of MPs to the soil leads to a greater distribution of THI in the soil solution and “increases the possibility of THI migration and potential passive entry into plants, which is also the reason for the increased bioavailability of THI after adding MPs to the soil.” 

Sorption processes, which include absorption, adsorption, and desorption, are all physical and chemical processes that involve one substance attaching to another. According to an article in Nature Education Knowledge, while absorption is the process of removing ions or molecules from a solution and accumulating them within solid constituents, adsorption collects the ions or molecules at the surface. Desorption is the opposite process where ions or molecules are released back into a solution. These processes are crucial in evaluating the effects of pesticides within the soil, as well as exposure through the skin. 

Neonicotinoid pesticides “represent an emerging class of chemical insecticides derived from the natural toxin nicotine. Since their introduction in 2010, they have become the most widely used insecticides, comprising approximately a quarter of the pesticide market,” the authors comment. They continue, “70% of NNPs will persist in soil or water after application, causing potential hazards to the health of plants and animals and the ecological environment.” Beyond Pesticides has extensively covered the adverse effects of neonicotinoids, which greatly threaten pollinators and biodiversity.  

“In addition to NNPs, the pollution problem of microplastics (MPs) in agricultural environments is also becoming increasingly prominent. After entering the soil, these MPs have the potential to alter the physicochemical properties of soils, impair soil fertility, and have detrimental effects on the soil microbiota,” the authors state. “Soil organisms, including plants and animals (e.g., earthworms), are susceptible to absorbing MPs, which can hinder their development and have a negative impact on the quality of the harvested crops.” 

MPs in agriculture occur through many avenues, such as with mulch film and fertilizer application. “Presently, biodegradable mulch film is [considered] a significant solution to the residual pollution caused by agricultural plastic film… Degradable plastics can degrade 85% to 99% within 18 weeks under appropriate composting conditions such as temperature, humidity, and microbial biomass. However, the degradation of biodegradable plastics in natural environments also takes a long time. Thus, degradable plastic film can also contribute to the pollution caused by MPs,” the authors share. Beyond Pesticides has written extensively on “biodegradable biobased mulch film,” and has raised concerns before the National Organic Standards Board (NOSB) while pointing to organic compatible mulching systems. See comments (scroll to mulch sections) to the NOSB here. 

These MPs, both traditional and biodegradable, can adsorb pollutants and then desorb them back into the environment, “resulting in changes to the coexistence of pollutants’ levels, persistence, bioavailability, and ecological hazards.” Within this study, the MPs in soil altered the distribution of THI in the soil which led to an increase in the bioavailability of THI while inhibiting its degradation. These results showcase “the significance of examining the combined pollution caused by MPs and NNPs,” the authors highlight. 

As previously covered by Beyond Pesticides, petrochemical pesticides, fertilizers, and plastics are linked to dire health effects and there is overwhelming regulatory failure regarding this that comes from a lack of data on the effects of pesticides prior to approved registration, as well as the ignorance of peer-reviewed scientific research that shows pesticides that pose unreasonable adverse effects.  

This study adds to the growing body of science that supports the need to transition away from plastics and pesticides with a holistic strategy. Take action to tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food to prevent health risks from plastics and adhered pesticides here and sign up to receive Action of the Week and Weekly News Updates. 

The solution is organic. To protect human health and biodiversity, mitigate climate change, and preserve natural lands and wildlife, a national land management plan with organic agriculture as the basis is needed. Join Beyond Pesticides in our mission to protect healthy air, water, land, and food for ourselves and future generations by eliminating the use of petrochemical pesticides and fertilizers by 2032.  

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

Source: 

Wang, K. et al. (2024) Interactions of traditional and biodegradable microplastics with neonicotinoid pesticides, The Science of The Total Environment. Available at: https://pubmed.ncbi.nlm.nih.gov/38972406/.  

(Beyond Pesticides, July 22, 2024) Mosquito management practices, typically reliant on toxic pesticides, can be antithetical to biodiversity protection. In this respect, consideration being given to biodiversity conservation goals in the Commonwealth of Massachusetts raise important issues critical of the chemical-intensive practices that are conventionally used to control mosquitoes. The state is taking public comments until August 30, 2024 on the development of biodiversity conservation goals. In an executive order (no.618), Biodiversity Conservation, issued September 21, 2023, Governor Maura Healey (D) directed the state’s Department of Fish and Game to “conduct a comprehensive review of the existing efforts of all executive department offices and agencies to support biodiversity conservation in Massachusetts [and] recommend biodiversity conservation goals for 2030, 2040, and 2050 and strategies to meet those goals.”  [Massachusetts residents, please look out for an action from Beyond Pesticides.]

In response to development of biodiversity goals in Massachusetts, last week Beyond Pesticides testified before the Massachusetts Fish and Game Department and urged the state to adopt a broad government-wide strategy that establishes biodiversity protection and enhancement as a basic tenet for all programmatic decisions going forward. In this context, Beyond Pesticides identified the following issues, among others, which stand out as emblematic of issues that require attention under the Commonwealth’s Biodiversity Conservation Goals: (i) Ecologically-based mosquito management requirements, (ii) aggressive efforts and chemical restrictions to protect pollinators and stave off the “insect apocalypse” and wildlife decline, and (iii) organic land management practices for all Commonwealth lands in accordance with defined practices and allowed substances in conformance with the federal National Organic Program’s National List of Allowed and Prohibited Substances.

In the Governor’s executive, among the list of compelling concerns that are driving this process is the following acknowledgement that ecosystems: “filter our air; clean our water; provide food security; provide economic opportunity; regulate climate by removing carbon from the atmosphere; provide resiliency against the worsening impacts of climate change like extreme weather events, heat, sea level rise, and flooding; provide recreational opportunities; and provide a range of other ecosystem services[.]”                                                       

The focus on biodiversity in Massachusetts is taking shape as mosquito season has begun, resulting in broadcast spraying of pesticides to kill them. Not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds.

>> Tell your Governor and Mayor to ensure ecological mosquito management by eliminating the use of pesticides that threaten mosquito predators. 

While the appetite of purple martins for mosquitoes is well known, most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year.

Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, grackles, chickadees, sparrows, nighthawks, and even the much-maligned starlings. Attract these birds to keep mosquitoes from feasting on you.

On the other hand, insectivorous birds are threatened directly by pesticide use and indirectly by the loss of their prey. In 1962, Rachel Carson drew attention to the poisoning of songbirds in her book Silent Spring. Despite restrictions on the organochlorines used in 1962, over three billion birds, or 29% of 1970s numbers have been lost in North America over the last 50 years. Research shows that 57% of bird species are in decline, and mosquito-eating birds lead the list. Ninety percent of all declines were within 12 bird families that include sparrows, warblers, blackbirds, larks, sparrows, swallows, nightjars, swifts, finches, flycatchers, starlings, and thrushes. Only waterfowl and wetland bird species show any increase.

Meanwhile, the world is experiencing an insect apocalypse. Recent research has found dramatic drops in overall insect abundance, with leading entomologists identifying steep declines in insect populations. Various studies have found reductions of up to a factor 60 over the past 40 years—there were 60 times as many insects in some locations in the 1970s. Insect abundance has declined more than 75% over the last 29 years, according to research published by European scientists.

Insectivorous birds are an essential part of global food webs that bring balance to ecological communities, but birds are not the only insectivores to feed on mosquitoes. Animals who contribute to maintaining ecological balance by consuming mosquito larvae and adults include insects, spiders, fish, amphibians, and bats. All are threatened by pesticides. (The state of Massachusetts’ Department of Fish and Game, under the direction of the Governor, is currently developing Biodiversity Conservation Goals and environmentalists are asking that mosquito management be incorporated into their interagency effort.)

On a personal level, people can nurture a safe haven for birds and other mosquito predators. And remember there are safer personal repellents. See How To Repel Mosquitoes Safely. Spread the word to neighbors on safer mosquito management with Beyond Pesticides’ doorknob hanger, Manage Mosquitoes This Season without Toxic Chemicals.

Urge state and community to adopt biodiversity conservation principles that include ecological mosquito management practices.

>> Tell your Governor and Mayor to ensure ecological mosquito management by eliminating the use of pesticides that threaten mosquito predators. 

Letter to Governor:
Mosquito season is upon us, and to many that means spraying pesticides to kill them. But not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds. Most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year.

Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, grackles, chickadees, sparrows, nighthawks, and even the much-maligned starlings.

On the other hand, insectivorous birds are threatened directly by pesticide use and indirectly by the loss of their prey. In 1962, Rachel Carson drew attention to the poisoning of songbirds in her book Silent Spring. Despite restrictions on the organochlorines used in 1962, over three billion birds, or 29% of 1970s numbers have been lost in North America over the last 50 years. Research shows that 57% of bird species are in decline, and mosquito-eating birds lead the list. Ninety percent of all declines were within 12 bird families that include sparrows, warblers, blackbirds, larks, sparrows, swallows, nightjars, swifts, finches, flycatchers, starlings, and thrushes. Please note the overlap with mosquito-eating birds. Only waterfowl and wetland bird species show any increase.

Meanwhile, the world is experiencing an insect apocalypse. Recent research has found dramatic drops in overall insect abundance, with leading entomologists identifying steep declines in insect populations. Various studies have found reductions of up to a factor 60 over the past 40 years—there were 60 times as many insects in some locations in the 1970s. Insect abundance has declined more than 75% over the last 29 years, according to research published by European scientists.

Insectivorous birds are an essential part of global food webs that bring balance to ecological communities, but birds are not the only insectivores to feed on mosquitoes. Animals who contribute to maintaining ecological balance by consuming mosquito larvae and adults include insects, spiders, fish, amphibians, and bats. All are threatened by pesticides.

The use of pesticides that threaten birds and others who consume mosquitoes is not consistent with ecological management of mosquitoes.

Please eliminate the use of pesticides that imperil birds, other mosquito predators, and their insect food supply. Please adopt biodiversity conservation goals that include: (1) ecological mosquito management including measures that recognize the benefit of preventive strategies, which establish source reduction programs that manage breeding sites on public lands and educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonicotinoids; and (3) land management on public lands–including hospitals, higher education institutions, schools, and parks–using regenerative organic principles and organic certified practices and products, to transition to a viable organic system that prioritizes long-term health of the public, ecology, and economy.

Thank you.

Letter to Mayor:
Mosquito season is upon us, and to many that means spraying pesticides to kill them. But not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds. Most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year.

Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, grackles, chickadees, sparrows, nighthawks, and even the much-maligned starlings.

On the other hand, insectivorous birds are threatened directly by pesticide use and indirectly by the loss of their prey. In 1962, Rachel Carson drew attention to the poisoning of songbirds in her book Silent Spring. Despite restrictions on the organochlorines used in 1962, over three billion birds, or 29% of 1970s numbers have been lost in North America over the last 50 years. Research shows that 57% of bird species are in decline, and mosquito-eating birds lead the list. Ninety percent of all declines were within 12 bird families that include sparrows, warblers, blackbirds, larks, sparrows, swallows, nightjars, swifts, finches, flycatchers, starlings, and thrushes. Please note the overlap with mosquito-eating birds. Only waterfowl and wetland bird species show any increase.

Meanwhile, the world is experiencing an insect apocalypse. Recent research has found dramatic drops in overall insect abundance, with leading entomologists identifying steep declines in insect populations. Various studies have found reductions of up to a factor 60 over the past 40 years—there were 60 times as many insects in some locations in the 1970s. Insect abundance has declined more than 75% over the last 29 years, according to research published by European scientists.

Insectivorous birds are an essential part of global food webs that bring balance to ecological communities, but birds are not the only insectivores to feed on mosquitoes. Animals who contribute to maintaining ecological balance by consuming mosquito larvae and adults include insects, spiders, fish, amphibians, and bats. All are threatened by pesticides.

The use of pesticides that threaten birds and others who consume mosquitoes is not consistent with ecological management of mosquitoes.

Please eliminate the use in our city of pesticides that imperil birds, other mosquito predators, and their insect food supply. Please adopt biodiversity conservation goals that include: (1) ecological mosquito management including measures that recognize the benefit of preventive strategies, which establish source reduction programs that manage breeding sites on public lands and educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonicotinoids; and (3) land management on public lands–including hospitals, higher education institutions, schools, and parks–using regenerative organic principles and organic certified practices and products, to transition to a viable organic system that prioritizes long-term health of the public, ecology, and economy.

Thank you.

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

Image: EneasMx, CC-BY-SA 4.0 <https://creativecommons.org/licenses/by-sa/4.0/>, via Wikimedia Commons

(Beyond Pesticides, July 19, 2024) Former mayor of Mexico City and climate scientist Claudia Sheinbaum, PhD was elected President of Mexico on June 2, making her the first female and Jewish citizen to hold the highest political office in the nation. She will be inaugurated on October 1, 2024. Dr. Sheinbaum’s ascension to the presidency comes at a time of increasing pressure from the United States government to acquiesce to its demands to open agricultural markets to genetically engineered (GE) crops (particularly corn) and the use of the carcinogenic weed killer glyphosate. With the formal review of the United States-Mexico-Canada Agreement (USMCA) approaching in 2026, Mexico will soon decide under Dr. Sheinbaum’s leadership whether it will be an international stalwart against the unfettered spread of GE corn amidst pressure from the U.S. Trade Representative and as industry continues to enable the cascading crises of the climate emergency, public health crisis, and biodiversity collapse.

With new administrations in the United Kingdom and France, and the upcoming election in the U.S., how governments around the world, independently and collectively, choose to seriously confront or soft-pedal the existential environmental crises will determine the livability of the planet. According to The Washington Post, despite Dr. Sheinbaum’s complicated record on green energy, “Her election has given hope to environmentalists and diplomats who’ve despaired as Mexico has gone from a global leader on climate change to a laggard.” Dr. Sheinbaum’s environment secretary in her mayoral administration told The Post that for the President-elect, “Environmental improvements have to be accompanied by social justice.”

Academic, Political Background, and Climate Record

Who is this new president? President-elect Sheinbaum holds a doctorate in energy engineering from the National Autonomous University of Mexico City. President-elect Sheinbaum was a co-contributor to the IPCC Fourth Assessment Report on Working Group III: “Mitigation of Climate Change” in 2007; consequently, the team went on to win a Nobel Peace Prize. Dr. Sheinbaum also contributed to the IPCC Fifth Assessment Report in 2015.

Moving beyond academic literature, observers will be evaluating if President-elect Sheinbaum will build on the pro-environmental aspects of the previous environmental policies of her mayoral administration. As mayor of Mexico City, she launched a six-year Environmental and Climate Change Program focusing on urban and rural revegetation, sustainable water stewardship and management, zero-waste, public transit, air pollution, and solar development. In a 2024 progress report, several accomplishments indicate progress such as planting over 15 million plants and trees since 2019, the creation of 450 pollinator gardens in 2019 and 2020, and the expansion of the public bus system to over 173 new vehicles (however only 10 are fully electric) and a new “Electric Transportation Service” of 193 new electric trolleybuses (only 50 so far are in use). In spite of these accolades, Climate Home News interviewed Xochitl Cruz Núñez, PhD—Dr. Sheinbaum’s colleague on the fifth IPCC report—“criticized the city’s diesel-powered bus system, water scarcity and increased urbanization under Sheinbaum’s leadership, saying it had caused ‘uncontrolled’ construction in surrounding conservation areas.” Mayor Sheinbaum did begin converting city buses to electric power.

“Peasant organizations have raised the need for a national strategy for agroecological transition to Claudia Sheinbaum,” Fernando Bejarano, Director at Action Network on Pesticides and Alternatives in Mexico (RAPAM), shares his perspective on the incoming administration. “It is expected that the next government will reformulate and continue supporting small and medium-sized farmers to achieve food self-sufficiency in basic crops with support for agroecological practices, but also greater dialogue with agribusiness organizations where transnational pesticide and seed companies participate.

“In the opinion of RAPAM, an inter-ministerial state policy is needed that articulates two objectives: the agroecological transition of the food system and the gradual prohibition of highly dangerous pesticides. This gradual ban with measurable and quantifiable goals is a Recommendation of the National Human Rights Commission (CNDH) 82/2018, issued in December 2018, which has not yet been fulfilled.”

USMCA, GE Import & Glyphosate Bans, and Mexico Food Sovereignty

USMCA replaced the North American Free Trade Agreement (NAFTA) in 2020 as the trilateral trade policy for North America. That same year, AMLO announced that Mexico would phase out glyphosate from use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam. As the 2024 deadline loomed near, AMLO indefinitely delayed the glyphosate ban ahead of April 1. See the Daily News article that calls out advocates’ frustration on this policy change and the Action of the Week calling for the U.S. Trade Representative and U.S. Secretary of State to formally withdraw their opposition to Mexico’s ban on imported GE corn and glyphosate use.

There have been over a decade of judicial and executive actions in Mexico 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, 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.

As a presidential candidate, Dr. Sheinbaum “promised farmers to end the use of glyphosate, a herbicide harmful to the environment, but gradually because ‘we have already seen that its replacement is not so simple.’” She made this promise to a crowd of four thousand or more people representing twenty agricultural workers and peasant organizations nationwide. Reporting also indicated that “the presidential candidate endorsed that transgenic corn will not be planted or brought into the country.” It seems like President-elect Sheinbaum wishes to build on the legacy of President Andrés Manuel López Obrador’s “Fourth Transformation” speech in 2019 upon the first-year anniversary of his 2018 election win to move beyond a neoliberal governance system with the goal “to strengthen the popular economy” by “prioritiz[ing] agricultural recovery.” Mexico Business News shared that Sheinbaum will build on the legacy of her soon-to-be predecessor López Obrador (AMLO) through a proposed initiative dubbed “National Project for Rural Development.” According to this report, “Sheinbaum emphasized ensuring non-GMO grain for human consumption.”

Glyphosate use and genetically modified crops pose threats to public health and biodiversity, as well as the erosion of Indigenous food systems and cultural preservation through seed and food sovereignty. In 2015, the International Agency for Research on Cancer (IARC) designated glyphosate as a “probable” carcinogen. This determination builds on substantial peer-reviewed science that links glyphosate exposure to non-Hodgkins’ Lymphoma and several other diseases and chronic health conditions including but not limited to diabetes, obesity, asthma, Alzheimer’s disease, amyotrophic lateral sclerosis (ALS), and Parkinson’s disease.

Allowing GE crops to be grown close to organic and non-GE conventional crop fields increases the risk of genetic drift, as pollen from GE crops has the potential to spread to non-GE crops and produce offspring. Genetic drift undermines the integrity of organic certification since GE crops are prohibited under organic standards. See Genetic Engineering and Herbicide Tolerance to learn more about genetic drift. See Daily News for an analysis of the U.S. government’s proposed framework for GE crops and biotechnology.

Environmental advocates are looking to the incoming Mexican president to embrace a holistic, systems-based framework for agriculture and land management practices. Embracing organic standards will immediately ban the use of glyphosate and other toxic petrochemical pesticides that undermine human health, ecosystem stability, and deepen farmers’ reliance on industry products. See Action of the Week to learn more about how to advocate for a transformation of policy at state, national, and international levels.

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

Source: Reuters

(Beyond Pesticides, July 18, 2024) A recent study in The Journal of Toxicological Sciences shows that a single dose of the neonicotinoid insecticide clothianidin (CLO) induces behavioral abnormalities, predominantly in female mice, throughout key stages of development. In testing mice at various ages, sex-specific changes were identified that highlight not only varied effects on males and females but also how pesticide exposure at a young age can cause lasting impacts throughout adulthood in mammalian species. 

The researchers, at the Laboratory of Animal Reproduction and Development at Tohoku University in Japan, “utilized murine [mouse] models to compare the sex-specific differences in behavioral effects following CLO exposure at different developmental stages. [They] orally administered CLO to male and female mice as a single high-dose solution (80 mg/kg) during the postnatal period (2-week-old), adolescence (6-week-old), or maturity (10-week-old), and subsequently evaluated higher brain function.”  

As the authors remark, “Most studies on the neurotoxicity of CLO have targeted only males, with limited insights regarding the neurodevelopmental toxicity in females. There are significant sex differences in brain development due to hormonal, genetic, epigenetic, and other sex-specific factors. Moreover, there are also a number of sex-based differences in the prevalence of developmental disorders, such as attention deficit hyperactivity disorder, and autism spectrum disorder, with susceptibility to neurological disorders being as much as 2- to 5-fold greater in one sex than in the other.” This study began with an aim to address the discrepancy in past clothianidin studies by testing exposure in both male and female mice at multiple stages in their lifecycle. 

The researchers continue in saying, “Many reports have indicated varying behavioral toxicities due to chemical exposure depending on sex. Given these findings and the high susceptibility of the brain to chemical exposure during the developmental period, it is possible that CLO exposure during development may cause differences between males and females. Therefore, it is imperative to observe the toxic effects of CLO in females as well.” 

The study design includes a solution of methyl cellulose and acetone with dissolved clothianidin that was administered to mice “at two weeks of age (2w-CLO I), six weeks of age (6w-CLO I), and ten weeks of age (10w-CLO I), respectively. The 2w-CLO II, 6w-CLO II, and 10w-CLO II groups received the same treatments.” The control groups, called vehicle control groups I and II (VC I and VC II), also received the solution with methyl cellulose and acetone (known as the vehicle) without any neonicotinoid insecticide at 2, 6, and 10 weeks of age to establish a baseline. A behavioral battery test (BBT) was conducted at 3 months of age in group I and at 7 months of age in group II for both the control and treatment groups, which consisted of an open field test, light/dark transition test, and contextual/cued fear conditioning test. 

Locomotor activity in the mice was measured in the open field test by the total distance traveled by the mice, total number of movement episodes, and the time spent at the center area during the test. In the light/dark transition test, the “total distance traveled in a light box, the latency to enter the light box for the first time, and the transition number between the light and dark boxes” was recorded. The contextual/cued fear conditioning test consisted of a series of experiments in which mice were placed into a chamber with stainless steel rods on the floor. These rods were utilized with tone-shock pairings to condition the mice and analyze their fear of the chamber with and without the tone that had been followed by a shock. This allowed the researchers to measure the freezing response (inability to move due to fear) of the mice under those conditions. Following behavioral testing, the brains of all mice were surgically removed for histological and immunohistochemical analysis. 

After the single dose of clothianidin and before the behavioral tests began, “acute peripheral neurotoxicity in our mouse models, such as tremors in the limbs” was noted by the authors. Within the tests, behavioral changes are seen in exposed female mice more than the males. Anxiety-like behavior in these mice was first noted in the open field test. “The time spent at the center area by female mice of the 2w-CLO II group was significantly decreased… This result was attributed to the excessive anxiety of these mice after introduction to a novel environment,” the authors state. They continue in saying, “These results suggest that CLO administration during the early postnatal period induces anxiety-like behaviors only in female mice.” 

The results of the light/dark transition test show that the distance traveled in the light box by the female mice in the 6w-CLO I group significantly decreased and that female mice in 2w-CLO II group entered the chamber with a notable delay relative to female mice of the VC II group. The fear tests reveal that the contextual freezing rate significantly decreased in 6w-CLO II female mice and the cued freezing rate significantly decreased among 2w-CLO II and 10w-CLO II group female mice. 

With the fear test results, the authors comment that this “suggests that CLO exposure during adolescence may lead to spatial memory abnormalities only in female mice. We noted similar responses during the cued fear test, as the freezing rate among female mice in the 2w-CLO II and 10w-CLO II groups significantly decreased. Moreover, the freezing rate of the 6w-CLO II female mice was lower than that of their VC II group counterparts… In contrast, the freezing rate response of male CLO II mice during the cued fear test, was comparable to that of control males. These results suggest that cued memory retrieval impairments occur only in the female CLO II groups.” 

These sex-specific behavioral changes highlight the importance of testing both males and females for effects of pesticide exposure, as reactions can vary greatly. The researchers also observed a reduction in astrocytes in the female mice of the 2w-CLO II group and 6w-CLO II group. “Astrocytes within the hippocampus undergo a rapid increase during early postnatal development, particularly around postnatal day 14. As such, the decrease in the number of astrocytes may have been influenced by CLO exposure during the early postnatal period,” the researchers postulate. 

Astrocytes are a subtype of glial cells making up most cells in the human central nervous system, which raises alarm for pesticides like clothianidin that affect astrocyte numbers. “Astrocytes in the hippocampus are largely involved in mammalian behavior. Astrocytes actively contribute to information processing and the establishment of the blood-brain barrier. Several neurological disorders, including anxiety and fear-related disorders, are thought to be associated with astrocyte dysfunction,” the authors report. Sexual dimorphism, which shows variations in individuals of different sex in the same species, occurs in human brain composition with females having more glial cells than males and can help explain why astrocytes may be impacted more predominantly in females.  

“The increased anxiety-related behaviors displayed by the 2w-CLO II group, together with the limited spatial associative memory capabilities of the 6w-CLO II group during behavioral tests, were consistent with the typical behavioral abnormalities observed when hippocampal astrocyte function is compromised,” the researchers find. “Therefore, the reduced number or reduced activity of astrocytes in the [hippocampus] of 2w-CLO II and 6w-CLO II adult female mice may impede normal information transmission, and could be related to these behavioral abnormalities.” 

Neonicotinoids, such as clothianidin, are widely used as agonists, which mimic the action of acetylcholine at the nicotinic acetylcholine receptor (nAChR), and lead to insect death. While insects are the intended targets of neonicotinoids, many organisms have nAChRs and “reports have indicated that neonicotinoids can cross the mammalian blood-brain barrier and demonstrate a higher affinity for mammalian nAChRs than originally thought,” the study authors share.  

Clothianidin is commonly sprayed over forests and agricultural areas and is known for its neurotoxic effects on mammals. Since “CLO is used as a wood preservative, as well as in food crops, and given that multiple generations of people are exposed to CLO, understanding the differences in the effects of CLO on behavior based on developmental stages is essential,” the researchers emphasize. With brain plasticity differing greatly at different developmental stages, studies like these are crucial.  

Prior research reveals that acute CLO exposure induces neurotoxicity as a behavioral abnormality, and this study highlights the behavioral differences between males and females after a single-dose CLO administration across multiple developmental stages. The authors conclude that, “The observed female-specific behavioral abnormalities underscore the importance of evaluating the effects of chemicals in both sexes, not just in males.” Beyond Pesticides has previously covered studies that show sex-specific effects, favoring both males and females, for a multitude of pesticides (see more here, here, here, and here). These impacts are trivialized by the U.S. Environmental Protection Agency (EPA) in current regulatory processes. 

While there are a multitude of studies that pinpoint detrimental effects on many species after exposure to pesticides, there are data gaps in the studies analyzed in risk assessments. EPA underestimates the real-world threats from pesticides (such as neonicotinoid insecticides), ignores potential chemical interactions or synergistic effects, and has a lack of scientific integrity with an over-reliance on industry-funded science that contradicts peer-reviewed studies.  

Within single species, there can be great variation between sexes and even time of exposure as shown in this study. Between species in the same family, there can be drastically different tolerance levels as well. Risk assessments only focus on a snapshot of data and do not look at the whole picture for how pesticides threaten the health of all organisms and the environment. This study, which adds further complexities to the research that needs to be considered by EPA when approving regulations for chemicals that cause unreasonable harm, supports those who advocate for a precautionary approach.  

The only solution moving forward is to look at the overwhelming body of science that supports organic agriculture as the answer for sustainably producing food and managing land. Organic agriculture protects not only wildlife and the environment but is also of particular importance to farmworkers, consumers, and children. Children are even more susceptible to the effects of pesticide exposure because they have developing organ systems that are more vulnerable and less able to detoxify toxic chemicals.  

Be part of the organic solution by taking action and supporting organic. Sign up now to get our Action of the Week and Weekly News Updates delivered right to your inbox. Become a Parks Advocate and encourage your community to transition to organic, and stay up to date on the latest health and environmental hazards of pesticides, pesticide regulation and policy, pesticide alternatives, and cutting-edge science with our Daily News.  

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

Source: 

Kaku, K. et al. (2024) A single dose of clothianidin exposure induces varying sex-specific behavioral changes in adulthood depending on the developmental stage of its administration, The Journal of Toxicological Sciences. Available at: https://www.jstage.jst.go.jp/article/jts/49/7/49_301/_article.   

(Beyond Pesticides, July 17, 2024) National election results in the United Kingdom (UK) and France in recent weeks have shocked the world amidst concerns of a rising tide of right-wing authoritarianism on the eve of European Parliament election results—trending toward what was initially perceived as a conservative majority earlier in June. With new leadership in some of the biggest economies and policy leaders across the Atlantic, environmental and health advocates are hopeful that this will signal a new momentum to advance the mission of transitioning to a fully organic land management and food system that replaces the status quo reliant on toxic petrochemical-based pesticides and fertilizers that exacerbate the climate crisis, biodiversity collapse, and public health fragility.

Citizens of the United Kingdom overwhelmingly voted for the center-left Labour Party, which won an unprecedented margin of 291 seats, winning 412 seats out of the 650 total seats up for grabs. The Conservative Party won just 121 seats, a clear rejection of their nearly fifteen-year leadership position in UK politics. UK-based advocates welcome the news given the Labour Party platform to “ban neonicotinoid pesticides imidacloprid, clothianidin, and thiamethoxam due to their impact on bees,” according to reporting by Politico.

Neonicotinoids have long had adverse effects on wildlife and communities across the nation, including a 2018 study published in PLOS ONE that found despite a partial ban on neonicotinoid insecticides instituted in 2014 — 25% of British honey is still contaminated with residue of this class of insecticides as of the date of publication. Neonic-treated seeds are also of concern to researchers, as documented in a 2020 study published in Science of The Total Environment in which clothianidin was found in roughly half of individual blood plasma samples from 10 out of 11 species of farmland birds.

The issue extends to herbicide-based pesticides as well, with UK-based Sheffield University study published in Nature determining that rotational substitution of various herbicides is ineffective to combat weed resistance. The Food, Farming and Countryside Commission, a non-governmental commission within the Royal Society for Encouragement of Arts, Manufactures, and Commerce, released a landmark report in 2019 calling for the transformation of UK food systems by 2030, including steps to transition to local food production rooted in agroecological practices consistent with organic principles for land management and agriculture. See the Daily News article on reflections from advocates in the United Kingdom ahead of Brexit for a broader history of the United Kingdom’s inconsistent record on protecting the public from pesticides under the previous government.

France, meanwhile, faces an interesting future given the roller coaster of events that amounted to a win for advocates of transformational pesticide reform. While no party earned a clear majority to form a new government based on reporting from Reuters, there are opportunities advocates see to build on existing momentum with a broad coalition of elected officials. Before the snap election, the French government announced in May a new plan – Ecophyto 2030 – to cut pesticide use in half by 2030 rather than the original plan that was paused as a result of widespread farmer protests across the European Union. Analysts in AgencyIQ – a vertical of Politico – identified the biggest change in this new plan is the metric used to measure its progress toward the 2030 target. “It replaces the longstanding Number of Unit Doses (NODU) indicator with the EU’s Harmonized Risk Indicator 1 (HRI-1). The NODU indicator has been used exclusively in France; it uses pesticide sales data to generate information about the intensity of pesticide use based on the number of hectares treated with a given active substance,” the authors go on to share why various organizations preferred the NODU indicator. “While green NGOs have long lauded NODU for reflecting efficiencies inherent to organic farming, it has also drawn the ire of agricultural actors [aka farmers reliant on toxic pesticides].”

France has demonstrated leadership in protecting the public from exposure, being the first country to enforce a strict ban on use in public landscapes and private lawns routinely used by the public in 2022. These public and privately-owned public areas include, but are not limited to, hotels, community gardens, cemeteries, nursing homes and health centers, and sports facilities. There are only some exemptions to this law, including against invasive species and serious public health threats. France’s policy initiative set the tone for the European Union-wide target to cut in half the use of overall toxic pesticide use by 2030. Environmental and health advocates recognize the importance of EU member states in developing comprehensive policies given the U.S. deferment to corporate interests and U.S. Department of Agriculture (USDA) Secretary Tom Vilsack’s rejection of coordinating with EU Farm to Fork (F2F) initiative. Meanwhile, France was one of several nations to vote in favor of the EU ban on use of three neonicotinoid pesticides (clothianidin, imidacloprid, and thiamethoxam) on all field crops in 2017. Separate from the EU-wide policy, France set the tone by maintaining one of the strongest neonic bans in the EU back in 2018 amidst potential threats to relax the ban.

The European Union plays an integral leadership role in the production and distribution of toxic pesticides to nations around the world, including Global Majority nations that face the brunt of the climate crisis. As reported in a 2020 investigation led by Greenpeace, EU- and UK-based pesticide manufacturers are exporting exorbitant quantities of chemical products (approximately +89,000 pounds as of 2018) to low- and middle-income countries (LMICs). As a result of continuous imports of glyphosate-based herbicides and other products, farmworkers in South Africa organizing with the Women on Farms Project took to the streets last September to protest Bayer. The increasing frequency of public demonstrations against pesticide manufacturers should not be surprising given the decades of scientific literature that cite direct and acute exposure to pesticides with elevated risk of deadly diseases, including breast cancer. United States export policy allows the shipping of toxic pesticides and genetically engineered food products to Central and South American nations (and worldwide) that do not have the infrastructure to enforce the label restrictions required in the U.S.

To maintain what was perceived as threats to this status quo, earlier this year the U.S. Trade Representative filed a complaint against Mexico for its ban on the importation of genetically engineered corn. This is happening ahead of the 2026 review of the trilateral trade agreement known as the United States-Mexico-Canada Agreement (USMCA)—the agreement that replaced the North American Free Trade Agreement (NAFTA).

In a legal battle that began with the current administration under President Andrés Manuel López Obrador (AMLO), Mexico-based subsidiaries of Monsanto pulled their lawsuit against the 2020 Presidential decree proposing both a glyphosate ban and GE corn ban, according to reporting by Mexico News Daily. Environmental and health advocates are urging President-elect Claudia Sheinbaum to follow through on efforts to ban glyphosate and GE crops after her inauguration on October 1, 2024. A similar trend is occurring in South America, where the Peruvian Congress rejected President Ángel Manero’s proposal to permit the domestic production and importation of genetically engineered cotton and corn into the nation until 2036, citing preservation of biodiversity as one of the leading factors, according to reports by La República. Ecuador banned GE seeds and crops in its 2008 constitution and Venezuela maintains its ban on GE seeds through its 2015 law but does not ban GE food imports into the country.

Advocates and concerned members of the public are increasingly demanding robust leadership on protections from toxic chemicals and pesticides. Dozens of towns and cities across the European Union are banning pesticides in their jurisdictions, which provides opportunities for national governments to build on their leadership. For more information on the state of organic agriculture in the European Union, please see the Daily News article, Planting the Seeds of Change: Why the European Union Struggles to Meet 2030 Organic Farming Target. See Pesticide-Induced Disease Database to learn more about the adverse impacts of toxic pesticides on human and wildlife health. To learn more about the health, environmental justice, and economic benefits of organic agriculture, see Why Organic?

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

Sources: Politico, Reuters

(Beyond Pesticides, July 16, 2024) Yet another study in the August 2024 journal Ecotoxicology and Environmental Safety has found that exposure to organophosphorus pesticides (OPPs) is correlated with increased suicidal thoughts in some people. This study is just the latest in a long line of studies from around the world that have linked pesticide exposure to mental health conditions, including sleep disorders, depression, and suicidal ideation (SI). As the rate of suicide increased by 30% between 2000 and 2020, there is an urgent public health need to investigate and address all potential contributing factors. A 2019 study, covered in Daily News, found that teens and adolescents living in agricultural areas and exposed to organophosphate (OP) insecticides are at higher risk of depression, In July and January this year, other studies link farmer psychiatric episodes to pesticide exposure, adding to the body of science. Exposure to household pesticides is also linked to depression in a 2020 study.  

Study and Methodology 

The study entitled “Association between exposure to organophosphorus pesticide and suicidal ideation among U.S. adults: A population-based study,” analyzes information on the mental and physical health of over 5,000 individuals aged 20 and up in the United States. The study aims to provide key epidemiological insights about the relationship between single and mixed exposure to OPs and SI. The authors note that mixed exposure to OPs is “more commonplace than single exposures, yet there is limited understanding regarding mixed exposures…” This study models OP single and mixed exposures using, as the authors continue, “advanced statistical methodology emerging in environmental epidemiology to address the complex associations… of multi-pollutant mixtures with specific health outcomes.” 

The study examined covariates such as gender, age, body mass index, smoking status, hypertension, and diabetes. The data was collected through the National Health and Nutrition Examination Survey (NHANES), an in-depth survey started in 1971 by the Centers for Disease Control and Prevention (CDC) and conducted annually since 1999. Responses to the survey’s Patient Health Questionnaire correlate with data on the concentrations of six OP metabolites in urine samples used to model suicidal ideation and OP exposure.  

Results

The study finds that one OP metabolite alone (dimethylthiophosphate—DMTP) is associated with suicidal ideation, but also that mixtures of other organophosphate metabolites were associated with suicidal ideation. This study finds that men ages 20-40 and those over 60 are likely to experience a correlation between suicidal ideation and OP exposure. These results confirm previous studies cited by the authors which found people working with these chemicals or living in agricultural areas are more prone to mental health issues such as depression and anxiety, which are closely linked to suicidal thoughts.

The study finds that long-term exposure to OPs may lead to a decrease in certain protective substances in the brain, making older men who have had more long-term exposure than others more susceptible to the harmful effects of OPs. These factors combine to make older men particularly vulnerable to developing anxiety, depression, and cognitive problems when exposed to OP, also known as risk factors for suicidal thoughts.

Organophosphates and the Brain

Organophosphates are a family of insecticides derived from World War II nerve agents. They are cholinesterase inhibitors, meaning that they bind irreversibly to the active site of an essential enzyme for normal nerve impulse transmission, acetylcholinesterase (AChE), inactivating the enzyme. A decrease in AChE activity has links to higher depression scores observed in individuals with increased suicide risk. (See Beyond Pesticides reporting here).

Consistent with a 2022 study, the current study reports that OPs can harm the brain in several ways. They interfere with important chemical messengers in the brain, like acetylcholine, serotonin, and dopamine, which help regulate mood or may trigger a buildup of cortisol, which is associated with depression and suicide. OPs also can cause inflammation in the brain, which may lead to mood disorders and cognitive problems. They can damage mitochondria, the energy-producing parts of cells, leading to further brain dysfunction. Exposure to OPs might alter the brain’s reward and motivation systems, potentially contributing to depression. (See here for reporting in multiple Daily News pieces on studies linking pesticide exposure to depression and suicide).

The World Health Organization (WHO) reports that depression affects 322 million people globally, with the number of diagnosed patients increasing by 18.4% from 2005 to 2015. Although the etiology of depression—and many other psychiatric disorders—is often genetic, studies suggest that other etiological factors, like pesticide exposure, play a role in depression incidents. Poor mental health has a tangible influence on physical health (e.g., depression and cardiovascular disease); therefore, the combination of pesticide exposure and mental illness worsens the adverse effects on human health.

The results of this most recent study confirm prior research published in the WHO Bulletin, which found people storing organophosphate pesticides in their homes are more likely to have suicidal thoughts as the exposure rate is higher. The study found an association between suicidal thoughts and ease of household pesticide accessibility. Geographic areas with more frequent home storage of pesticides have higher rates of suicidal thoughts than the general population. WHO scientists recognize pesticide self-poisoning as one of the most significant global methods of suicide, as increases in pesticide toxicity make them potentially lethal substances. Robert Stewart, PhD, a researcher for the WHO Bulletin, stated, “Organophosphate pesticides are widely used around the world. They are particularly lethal chemicals in overdose and cause many suicides worldwide.”

Broader Implications

While Beyond Pesticides has been reporting on the mental health adverse effects of pesticides since its founding, this area of research is still limited. This research highlights yet again a significant public health concern, particularly for farmers, farm workers, and people living near agricultural land. Farmworkers, their families, and those living near farms or chemical plants are at elevated risk of exposure, causing disproportionate impacts. (See Beyond Pesticides Agricultural Justice and disproportionate risks web pages). Additionally, OPs are used in many settings, including urban areas, and their residues can be found in food and water, affecting the general population and contributing to cumulative exposures to organophosphate and other pesticides.

Despite pressure from public health scientists and professionals, organophosphate insecticides continue to be used in the United States. This study and others indicate that farmers and those in agricultural communities are at disproportionate risk of mental health problems due to pesticide use, in addition to the myriad of neurodevelopmental, reproductive, respiratory, and other health problems individuals risk from exposure to organophosphates. Beyond Pesticides’ Pesticide Induced Diseases Database (PIDD), tracks the most recent studies related to pesticide exposure. For more information on the multiple harms of pesticides, see PIDD pages on depression, suicide, brain and nervous system disorders, endocrine disruption, and cancer.

To help support the move away from these toxic petrochemical pesticides, see Beyond Pesticides’ webpage, Health Benefits of Organic Agriculture, and Tools for Change. For more about disproportionate harm to farmworkers from pesticide use in conventional agriculture and why organic certification should recognize agricultural justice issues, see Beyond Pesticides’ Keeping Organic Strong and Agricultural Justice web pages.

Purchasing organic products encourages the protection of the farmworkers and those who eat the bounty of their labor. See Eating With A Conscience to understand the risks of pesticide exposure through commonly eaten fruits and vegetables, while considering the health benefits of eating organic (even on a budget).

Suicide Prevention Resources

Suicide is the tenth leading cause of death among adults (3rd for adolescents) in the U.S., with more than 34,000 individuals succumbing to the disease annually. Suicidal thoughts and behaviors are dangerous and harmful and are therefore considered a psychiatric emergency. An individual experiencing these thoughts should seek immediate assistance from a health or mental health care provider. If you or someone you know is in an emergency, please call 988 or the National Suicide Prevention Lifeline at 1-800-273-TALK (8255) immediately.  If you are in a medical emergency or suicidal crisis and cannot connect, please call 911.

[988 Lifeline is a national network of local crisis centers that provides free and confidential emotional support to people in suicidal crisis or emotional distress 24 hours a day, 7 days a week in the United States. When calling 988, press 2 to connect to a trained Spanish-speaking crisis counselor. For people who speak languages other than English or Spanish, call 988 and translation will be provided in more than 240 additional languages through Language Line Solutions (available 24/7 through voice calling only.]

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

Sources:

Association between exposure to organophosphorus pesticide and suicidal ideation among U.S. adults: A population-based study, Ecotoxicology and Environmental Safety, August 2024

Depressive symptoms and suicide attempts among farmers exposed to pesticides, Environmental Toxicology and Pharmacology, June 2024

(Beyond Pesticides, July 15, 2024) It is hot. Really hot. A serious response to this climate emergency requires, according to environmental advocates, a dramatic transformation in land management and an end to the use of petrochemical pesticides and fertilizers. Beyond the real-world adverse effects of the climate crisis— more intense and frequent fires, floods, hurricanes and hail storms, as well as the harm to health and biodiversity—the rising insurance premiums imposed by the insurance industry speaks to the need for an urgent systemic response. According to the paper, Pricing of Climate Risk Insurance: Regulation and Cross-Subsidies, “The unprecedented rise in natural disasters has led to catastrophic losses of more than $600 billion in the United States over the last two decades, roughly twice the losses of the previous 40 years combined.” While the events associated with climate are more accurately described as “human-made” rather than “natural” disasters, a 2023 Washington Post article reports that, “U.S. insurers have paid out $295.8 billion in natural disaster losses from 2020 to 2022, a record for a three-year period.” This has led to dramatic changes in the cost of insurance coverage and the decision of many carriers to deny coverage.

The Washington Post writes, “At least five large U.S. property insurers — including Allstate, American Family, Nationwide, Erie Insurance Group and Berkshire Hathaway — have told regulators that extreme weather patterns caused by climate change have led them to stop writing coverages in some regions, exclude protections from various weather events and raise monthly premiums and deductibles.” In an analogous context of safety standards for automobiles and consumer protection, Ralph Nader has written for decades and most recently in a 2023 piece, Insurers Can Be Sentinels for  Health and Safety, saying: “Insurance executives began to view themselves more as heads of financial companies than as underwriting companies pressing for safer factories, automobiles, building codes, fire prevention and other ‘loss prevention’ attentiveness.” This is distinguished from insurers during the Industrial Revolution, as Mr. Nader describes: “As factories were being built in the 1800s with boilers prone to exploding and starting fires, the early property insurance companies hired engineers to develop upgrades in boiler design and construction. Insurers would only provide coverage to companies that met the new standards. That is how the industry defined ‘risk management.’ Dangerous factory boilers meant unacceptable insurance losses.” With prodding from Mr. Nader and allied advocates in the late 1980s, some insurers did embrace a “loss prevention” strategy like this for auto safety. 

Given the urgent need for transformational climate-sensitive practices, there is a role for homeowner insurance underwriters to join the campaign to transition all land management, including agricultural and nonagricultural lands, to organic practices. This will eliminate the very inputs that contribute to the climate crisis and at the same time recognize the extreme value of organic soil systems in drawing down atmospheric carbon—with companies insuring only those land management practices that effectively contribute to severe “loss prevention” or avoidance of climate disasters.

>> Regenerative agriculture must be organic.

Agriculture is a major contributor to climate change. In a recent article in Science, Clark et al. show that even if fossil fuel emissions were eliminated immediately, emissions from the global food system alone would make it impossible to limit warming to 1.5°C and difficult even to realize the 2°C target.

Why do homeowner insurers need to pick up the mantle of organic land management? The current patchwork of state insurance regulations means that either insurance companies leave the home insurance market in areas most directly affected by the climate crisis (e.g., coastal, floodplain, and fire-prone areas) or raise prices. As home purchasers know, mortgage lenders require homeowner insurance to obtain a loan. In the pricing paper cited above, the authors show that the entire country bears the brunt of high and rising insurance costs due to the climate crisis. In other words, one does not have to live in a high hazard area to face high and increasing insurance costs. The authors state: “In this paper, we provide evidence of decoupling of insurance rates from their underlying risks and identify regulation as a driving force behind this pattern. We identify two sources for this decoupling. First, rates have not adequately adjusted in response to the growth in losses in states we classify as “high friction”, i.e. states where regulation is most restrictive. Second, in low friction states rates increase both in response to local losses as well as to losses from high friction states. Importantly, these spillovers are asymmetric: they occur only from high to low friction states, consistent with insurers cross-subsidizing in response to rate regulation. Our results point to distortions in risk sharing across states, i.e. households in low friction states are in-part bearing the risks of households in high friction states.”

The insurance industry has already recognized the reality of the climate crisis and the threat that it represents. The question now is whether the insurance industry will join efforts that force a transition to organic practices and support policies that facilitate this transition. Currently, the focus is on amendments in the Farm Bill, among other legislation, that could either contribute to an escalating climate crisis or help to curtail it.

Climate change is a real crisis and requires serious action. Actually, climate change is one of multiple crises that are compounding one another. While climate change may be most apparent—128^o F in Death Valley, heat waves in India, the U.S., and globally, the earliest Category 5 hurricane on record, another wildfire season, etc.—the climate emergency intersects with crises in human disease and biodiversity collapse. 

Heat makes the health effects of pesticides more serious. Climate change is intensifying the impacts of habitat destruction and toxic chemicals on biodiversity. We cannot afford to let anyone capitalize on marketing schemes making false claims of climate change mitigation.  

>> Regenerative agriculture must be organic. 

Organic agriculture can mitigate climate change. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced greenhouse gas (GHG) emissions. The contribution of animal agriculture has been estimated at 14.5% to 87% or more of total GHG emissions. These estimates include emissions of carbon dioxide, methane, nitrous oxide, and ammonia. The carbon dioxide contribution largely comes from converting land from natural forest to pasture or cropland.  

“Regenerative” agriculture is widely considered to be a solution for reducing or even reversing these impacts. Unfortunately, a movement by promoters of chemical-intensive agriculture has misled some environmentalists into supporting toxic “regenerative” agriculture. While recognizing practices that sequester carbon in the soil—practices that are central to organic agriculture—the so-called “regenerative agriculture” promoted by these groups ignores the direct climate impacts of synthetic nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients as well as for the heat and energy driving chemical reactions. It is important to see through this deception.  

Organic practices preserve natural lands and biodiversity. Natural forests are more effective than tree plantations in sequestering carbon. Preserving natural land increases biodiversity, which also reduces dependence on petroleum-based pesticides. Organic farms are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife, as required by § 205.200 of the regulations and per the §205.2 definition of Natural resources of the operation.”  

Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers. In addition, studies have found organically grown plant foods and milk to be nutritionally superior to those produced by chemical-intensive agriculture.  

The National Organic Program provides for clarity and enforceability, while providing processes that are open and transparent to growers, consumers, and the public at large. As an established program, it also has its own funding mechanism. We must demand that any definition of “regenerative” must—at a minimum—meet organic standards.  

>> Regenerative agriculture must be organic. 

It is crucial, as we move forward with a plan to harness agriculture in the fight against the climate emergency, biodiversity collapse, and health threats, that we not be misled into promoting the same practices that have created the problem. As aptly stated by Jeff Moyer of the Rodale Institute, “We believe that in order to be regenerative, you have to start by being organic. It’s a little disingenuous to say you can regenerate soil health and sequester carbon and still use nitrogen fertilizers and synthetic pesticides. What you’re really saying is equivalent to saying ‘I want to be healthy as a person, but I still want to smoke cigarettes.'”  

The climate crisis and the devastating decline in biodiversity are escalating because of uncontrolled and unnecessary reliance on toxic chemicals. These threats to life require a meaningful holistic strategy to end our fossil fuel dependence and use of materials that release harmful levels of noxious gases (including greenhouse gases).   

Agriculture must—across the board and on an expedited five-year schedule—shift to organic practices. Organic practices both sequester carbon and eliminate petrochemical pesticides and synthetic fertilizers. Importantly, the data show that organic agriculture now operates without sacrificing productivity or profitability. While the vested economic interests in the petroleum and chemical industry cling to the status quo, there are good jobs and money to be made in a green economy.  

We need a national plan to shift to 100% organic farming. Organic land management is more effective at reducing emissions and sequestering carbon in the soil. There is already a national program for certifying farms that meet organic standards. Organic operations must “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.”   

Undefined and unenforceable “regenerative” agriculture falls short by ignoring the direct climate impacts of nitrogen fertilizers, the damage to soil health and ecosystem services caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients and for the heat and energy-driving chemical reactions.   

We need a national land management plan.  Preserving natural land increases biodiversity, reduces dependence on petroleum-based pesticides, and is more effective in sequestering carbon. Biodiversity buffers against damage from climate change by allowing systems to evolve with changing conditions. Preserving natural lands and transitioning farms to organic production should be the cornerstones of combating climate change.   

>> Regenerative agriculture must be organic. 

Letter to Congress:
As Congress considers elements of the next Farm Bill, climate change is an extremely urgent crisis to address. And while climate change may be most apparent—128o F in Death Valley, heat waves in India, the U.S., and globally, the earliest Category 5 hurricane on record, another wildfire season, etc.—we are also facing crises in human disease and biodiversity collapse.

Heat makes the health effects of pesticides more serious. Climate change is intensifying the impacts of habitat destruction and toxic chemicals on biodiversity. 

We cannot afford to let anyone capitalize on marketing schemes making false claims of climate change mitigation. Regenerative agriculture must be organic. 

Organic agriculture mitigates climate change and therefore must be dramatically expanded. Agriculture is a major contributor to the climate emergency. Research shows that even if fossil fuel emissions were eliminated immediately, emissions from the global food system alone would make it impossible to limit warming to 1.5°C and difficult even to realize the 2°C target. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced greenhouse gas (GHG) emissions. 

“Regenerative” agriculture is widely considered to be a solution for reducing or even reversing these impacts. Unfortunately, a movement by promoters of chemical-intensive agriculture has misled some environmentalists into supporting toxic “regenerative” agriculture. While recognizing practices that sequester carbon in the soil—practices that are central to organic agriculture—the so-called “regenerative agriculture” promoted by these groups ignores the direct climate impacts of synthetic nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients as well as for the heat and energy driving chemical reactions. It is important to see through this deception. 

Organic farms are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.” 

Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers. In addition, studies have found organically grown plant foods and milk to be nutritionally superior to those produced by chemical-intensive agriculture. 

The National Organic Program provides clarity and enforceability while providing processes that are open and transparent to growers, consumers, and the public at large. As an established program, it also has its own funding mechanism. Any definition of “regenerative” must—at a minimum—meet organic standards. 

The climate crisis and the devastating decline in biodiversity are escalating because of uncontrolled and unnecessary reliance on toxic chemicals. These threats to life require a meaningful holistic strategy to end our fossil fuel dependence and use of materials that release harmful levels of noxious gases (including greenhouse gases).  

We need a national plan to shift to 100% organic farming in the coming five years. Please support a shift to organic in the Farm Bill and reject language that (i) undermines, or preempts, local and state authority to enact more stringent land management policies protective of health and the environment, and (ii) establishes immunity from lawsuits for chemical companies that fail to warn farmers and consumers of pesticide hazards.  

Thank you.