(Beyond Pesticides, August 26, 2024) In July, the U.S. Environmental Protection Agency (EPA) announced it was raising the allowable levels of the highly toxic weed killer atrazine in the nation’s waterways from the 2016 level of 3.4 to 9.7 micrograms per liter (µg/L), which scientists and environmental advocates say is a serious threat to aquatic plants, fish, invertebrates, and amphibians, in addition to people who recreate in waterways or eat food from them. With EPA’s August 7 decision to ban the weed killer Dacthal (or DCPA–dimethyl tetrachloroterephthalate), Beyond Pesticides is rallying public support for the removal of atrazine from the market under the same standards of harm, inability to mitigate hazards, and the availability of alternatives.

As Beyond Pesticides points out in its 2022 atrazine comments (2020 and 2016 comments included) to EPA, the agency in November 2021 released the final Biological Evaluation (BE) assessing risks to listed species from labeled uses of atrazine (in the triazine chemical family). The agency made “likely to adversely affect (LAA) determinations” for 1,013 species and 328 critical habitats, which it is now rejecting, while using a “community-equivalent level of concern (CE-LOC)” measure that is filled with uncertainty and lacks any sense of precaution with a chemical like atrazine—known to disrupt the endocrine system at miniscule doses. Meanwhile, the agency asserts mitigation measures associated with uncertain conservation practices and alleged benefits that outweigh risks. While calling for additional study of atrazine’s benefits, the Northern New York Agricultural Development Program’s Field Crops IPM [Integrated Pest Management] coordinator, Mike Hunter, said in July, “The results of this limited-scope, preliminary trial demonstrated that excellent corn weed control was achievable regardless of the atrazine rate used and without inclusion of atrazine in the herbicide treatment.” Beyond Pesticides points to the efficacy and profitability of organic practices and products for all crops, turf (see also), and vegetation use for which atrazine is registered by EPA.

Exposure to atrazine, manufactured by Syngenta, is widespread in the environment. According to EPA, “Pesticide products containing atrazine are registered for use on several agricultural crops, [including] field corn, sweet corn, sorghum, and sugarcane, []wheat, macadamia nuts, and guava, as well as non-agricultural uses such as nursery/ornamental and turf.” It is the second most widely used herbicide in the U.S. after glyphosate (found in Roundup), but banned in the European Union in 2004 and in over 40 countries worldwide. Many organizations have called for the chemical to be banned in the U.S. and have joined in litigation against EPA. 

In the case of Dacthal, EPA used the “imminent hazard” clause of the federal pesticide law to immediately suspend the chemical’s use. At the same time, the agency is exercising its authority to prohibit the continued use of Dacthal’s existing stocks, a power that EPA rarely uses. 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). The chemical manufacturer of Dacthal, AMVAC Chemical Corporation, can challenge the agency’s findings under the law 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 must apply the standard of the Dacthal decision to atrazine and issue an emergency suspension and prohibit use of existing stocks.

The timeline for review and action on individual pesticides has taken decades since the 1972 overhaul of nation’s pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The law’s risk-benefit standard allows for high levels of harm, especially to farmworkers and those handling pesticides, as well as public exposure through residues in food, water, and air. EPA’s decisions are based on agency risk assessments that use flawed assumptions and ignore 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 FIFRA in 1996, in the Food Quality Protection Act (FQPA), 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 as 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 current mechanism that EPA uses to restrict pesticides—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. 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, 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.) 

In making its decision to ban Dacthal, EPA states that it considered: 
1. The seriousness of the threatened harm; 
2. The immediacy of the threatened harm; 
3. The probability that the threatened harm will occur; 
4. The benefits to the public of the continued use of the pesticide; and 
5. The nature and extent of the information before the Agency at the time it makes a decision. 

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. 

Atrazine poses immediate serious harms to people and the environment. 
Registration of the endocrine-disrupting herbicide propazine (in the triazine family of frog-deforming endocrine disruptors) was canceled by EPA, eliminating use of the hazardous herbicide by the end of 2022. However, all pesticides in the triazine class, including atrazine and simazine, have similar properties and should be eliminated from use. 

Under an Endangered Species Act review, initiated by EPA only after a lawsuit from health and environmental groups, the triazine chemicals were found to adversely affect a range of species. Propazine was found to harm 64 endangered species, while simazine and atrazine were both likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds, “aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates.” In addition, evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine. 

The triazine class of chemicals also poses significant threats to human health and is particularly concerning in the context of the range of chemicals one may be exposed to in today’s world. As Tyrone Hayes, PhD, University of California, Berkeley professor, noted at a presentation at Beyond Pesticides’ National Pesticide Forum, “Children in utero may be exposed to over 300 synthetic chemicals before they leave the womb… I would argue that a human fetus trapped in contaminated amniotic fluid is no different than one of my tadpoles trapped in a contaminated pond.”   

Atrazine has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia (where nasal passages are blocked at birth), and hypospadias (where the opening of a male’s urethra is not located at the tip of the penis). The mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH), which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset. 

Despite these endocrine-disrupting effects, EPA reduces the margin of safety and underestimates exposure to children. 

>> EPA must apply the standard of the Dacthal decision to atrazine and issue an emergency suspension and prohibit use of existing stocks. 

Mitigation measures have not eliminated the harm. 
In November 2020, Beyond Pesticides and allied environmental groups launched a lawsuit against EPA for its intent to reregister the triazine family of chemicals. The agency’s interim approval of the herbicides, conducted under the Trump administration, eliminates important safeguards for children’s health and a monitoring program intended to protect groundwater from contamination. As is typical with EPA, the agency merely proposed minor label changes in attempts to mitigate risks identified in its registration review. According to a release from EPA, it made the decision not out of concerns relating to human health and environmental protection, but in order to provide “regulatory certainty” for farmers and local officials. 

Although a hefty 200,000 lbs. of propazine were used each year, mainly on sorghum in Texas, Oklahoma, and Kansas, this amount pales in comparison to the over 70 million lbs. of atrazine used throughout the United States. Under an Endangered Species Act review, initiated by EPA only after a lawsuit from health and environmental groups, the triazine chemicals were found adversely affect a range of species. Propazine was found to harm 64 endangered species, while simazine and atrazine were both likely to harm over 50% of all endangered species and 40% of their critical habitats. 

The public does not benefit from continued registration of atrazine. 
While industry consistently lines up local Congressmembers, former EPA officials, and agrichemical lobbyists to pressure EPA to keep triazines in the market, there is no evidence that the herbicides benefit the farmers these officials claim to represent. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would provide an economic benefit to farmers. “The winners,” the research concludes, “in an atrazine free future would include farm workers, farmers and their families, and others who are exposed to atrazine either directly from field uses or indirectly from contaminated tap water along with natural ecosystem that are currently damaged by atrazine.”  

EPA has sufficient information to cancel atrazine. 
EPA has long known about triazine’s threats to wildlife, including its ability to chemically castrate male frogs. However, the agency has consistently defended the chemical, and sat by while independent researchers like Dr, Hayes, who conducted seminal research on atrazine’s endocrine disrupting properties, are pilloried by chemical industry propaganda. In a Critical Perspectives piece published in Environmental Toxicology and Chemistry, Jason Rohr, PhD, provides an in-depth investigation of the atrazine controversy. 

“I argue that the atrazine controversy must be more than just a true story of cover-ups, bias, and vengeance,” he writes in the piece. “It must be used as an example of how manufacturing uncertainty and bending science can be exploited to delay undesired regulatory decisions and how greed and conflicts of interest—situations where personal or organizational considerations have compromised or biased professional judgment and objectivity—can affect environmental and public health and erode trust in the discipline of toxicology, science in general, and the honorable functioning of societies.” 

The Draft Ecological Risk Assessments for the Registration Review of Atrazine, Simazine, and Propazine, dated October 5, 2016, found high risks that were supported by EPA’s assessments. EPA states, “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates in these same locations. In the terrestrial environment, there are risk concerns for mammals, birds, reptiles, plants and plant communities across the country for many of the atrazine uses. EPA levels of concern for chronic risk are exceeded by as much as 22, 198, and 62 times for birds, mammals, and fish, respectively. For aquatic phase [stage] amphibians, a weight of evidence analysis concluded there is potential for chronic risks to amphibians based on multiple effects endpoint concentrations compared to measured and predicted surface water concentrations. The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift. Average atrazine concentrations in water at or above 5 μg/L for several weeks are predicted to lead to reproductive effects in fish, while a 60-day average of 3.4 μg/L has a high probability of impacting aquatic plant community primary productivity, structure and function.”

The agency acknowledges many risks of concern associated with the uses of atrazine, but asserts the serious worker and ecological risks remaining after adoption of all proposed mitigation measures are outweighed by the benefits of atrazine use. EPA has determined that the chlorotriazines (triazines) and their three chlorinated metabolites share a common mechanism of toxicity, and as such, human health risks were assessed together through a triazine cumulative risk assessment. The mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH), which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset. Importantly, this perturbation manifests after a short duration exposure with long-term life-cycle consequences, so it establishes both acute and chronic toxicity levels of concern (LOCs). 

Toxicity and exposure data available to EPA are sufficient to demonstrate that several atrazine uses exceed risk levels of concern. Exposures to children 1-2 years old playing on turf sprayed with atrazine exceed a risk estimate of concern for combined dermal and incidental oral exposures when assuming the maximum labeled rate for spray applications (2.0 lb ai/A). However, a screening aggregate assessment without the FQPA required safety factor was performed assuming that the application rate for turf is reduced to 1.0 lb ai/A, which would not be of concern for 4-day aggregate exposures. Even with this rate reduction, it can be presumed children are still at serious risk. For occupational handlers, EPA identified use scenarios that exceed risk concerns even with the maximum available personal protective equipment and/or engineering controls (proposed mitigation measures). 

Here is how EPA describes its truncated process for DCPA: 
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. 

As society and the global community struggle with petrochemical pesticides and their contribution to health threats, biodiversity collapse, and the climate emergency, EPA must acknowledge that Dacthal is one active ingredient among over 1,000 in 56,000 pesticide products whose uses can be eliminated by the use of organic systems that have now been shown to be effective.  

*** For more information on the dangers of atrazine and its chemical cousins, read Beyond Pesticides’ comments to EPA, and watch Dr. Tyrone Hayes’ presentations from former National Pesticide Forum events on YouTube. 

>> EPA must apply the standard of the Dacthal decision to atrazine and issue an emergency suspension and prohibit use of existing stocks.

Letter to EPA Administrator Michael Regan
I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. The weed killer atrazine fits the criteria used to ban Dacthal and it too should be banned immediately. 

In deciding to ban Dacthal, EPA says it considered the seriousness, immediacy, and likelihood of the threatened harm; benefits to the public of continued use; and nature and extent of the information before EPA.

Atrazine poses immediate serious harms to people and the environment. Under an Endangered Species Act review, the triazines were found to adversely affect many species. Atrazine is likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds impacts on aquatic and terrestrial ecology. Evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine.

Atrazine also poses significant threats to human health. It has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia and hypospadias. The mechanism of toxicity—perturbation of the neuroendocrine system—results in reproductive and developmental alterations. 

Mitigation measures have not eliminated harm. In typical fashion, EPA proposed minor label changes to mitigate risks identified in its registration review, deciding not out of concerns relating to human health and environmental protection, but to provide “regulatory certainty” for farmers and local officials. Environmental and health harms continue.

The public does not benefit from continued use of atrazine. There is no evidence that atrazine benefits farmers. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would economically benefit farmers. Claims that losing atrazine will lead to reduced corn yields and increased prices have been refuted by these researchers. Because much of the corn grown in the U.S. is intended for ethanol producers and livestock feed, corn prices are heavily determined by the demand from these two sectors, compared to production costs. 

Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.”

EPA has sufficient information to ban atrazine.
EPA has long known about atrazine’s threats to wildlife, including its ability to chemically castrate male frogs. EPA’s ecological risk assessment found high risks: “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates. . . The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift.” 

EPA has determined that the triazines and their chlorinated metabolites share a common mechanism of toxicity—perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary—leading to a disturbance in the ovulatory surge of luteinizing hormone, resulting in reproductive and developmental alterations. These risks exceed levels of concern, including children and workers. 

Please apply the standard of the Dacthal decision to atrazine. Issue an emergency suspension and prohibit use of existing stocks.

Thank you.

Letter to U.S. Representative and Senators
I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks.  The weed killer atrazine fits the criteria used to ban Dacthal and it too should be banned immediately. 

In deciding to ban Dacthal, EPA says it considered the seriousness, immediacy, and likelihood of the threatened harm; benefits to the public of continued use; and nature and extent of the information before EPA.

Atrazine poses immediate serious harms to people and the environment. Under an Endangered Species Act review, the triazines were found to adversely affect many species. Atrazine is likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds impacts on aquatic and terrestrial ecology. Evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine.

Atrazine also poses significant threats to human health. It has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia and hypospadias. The mechanism of toxicity—perturbation of the neuroendocrine system—results in reproductive and developmental alterations. 

Mitigation measures have not eliminated harm. In typical fashion, EPA proposed minor label changes to mitigate risks identified in its registration review, deciding not out of concerns relating to human health and environmental protection, but to provide “regulatory certainty” for farmers and local officials. Environmental and health harms continue.

The public does not benefit from continued use of atrazine. There is no evidence that atrazine benefits farmers. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would economically benefit farmers. Claims that losing atrazine will lead to reduced corn yields and increased prices have been refuted by these researchers. Because much of the corn grown in the U.S. is intended for ethanol producers and livestock feed, corn prices are heavily determined by the demand from these two sectors, compared to production costs. 

Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.” 

EPA has sufficient information to ban atrazine. EPA has long known about atrazine’s threats to wildlife, including its ability to chemically castrate male frogs. EPA’s ecological risk assessment found high risks: “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates. … The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift.” 

EPA has determined that the triazines and their chlorinated metabolites share a common mechanism of toxicity—perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary—leading to a disturbance in the ovulatory surge of luteinizing hormone, resulting in reproductive and developmental alterations. Data available to EPA demonstrate that several atrazine uses exceed risk levels of concern, including children and workers. 

Tell EPA to apply the standard of the Dacthal decision consistently—to ban atrazine. 

Thank you.

Image: Art Page submission from Sara Grantham, “Sunflower Pollinators” 

(Beyond Pesticides, August 23, 2024) A study in Science of The Total Environment calculates and compares pesticide risk in 594 wild bee species associated with crops in North America. Current pesticide risk assessments that analyze effects on bees primarily focus on a limited subset of species and do not provide comprehensive protection of all wild bees. “Species commonly proposed as models for pesticide risk assessments may not accurately represent risk for those bee species facing the highest potential risk in agricultural contexts,” the authors postulate.

The researchers continue, “This study presents a novel approach to characterize and compare the relative potential pesticide risk among wild bee species of their association with crops in North America using suites of intrinsic bee traits to quantify species’ vulnerability and extrinsic factors based on the toxic load of crops for bees and the strength of each species’ association with those crops.” In considering multiple factors that vary by species and determining potential harm to each from pesticide exposure, this study highlights the inadequacies of the current risk assessment process used by the U.S. Environmental Protection Agency (EPA).   

The system for risk assessment for pesticides that impact bees includes a tiered process, with Tier I as a screening tool within the laboratory and Tiers II and III as field studies. According to EPA, Tier I uses “conservative assumptions regarding exposure (i.e., assumptions that are likely to overestimate exposure) and uses the most sensitive toxicity estimates from laboratory studies of individual bees to calculate risk estimates.” These studies, however, primarily focus on honey bees such as Apis mellifera and do not consider the varying sensitivity in other bee species.

As the authors point out, “the use of a very unusual and non-representative species, A. mellifera, as a model for all bee species in pesticide risk assessments [is] because of the ease with which the species can be maintained by humans, well developed risk assessment protocols for the species, and its cost effectiveness.” The use of this species is not due to its ability to well-represent all other bee species.

EPA’s process does not factor in the growing body of scientific evidence regarding the negative impacts of pesticide exposure on a wide range of bee species, as well as other vital pollinators. This study suggests that efforts should be focused “on the subset of wild bee species likely experiencing the highest potential pesticide risk as a starting point for protection and conservation goals” instead of a reliance on a single species where the majority of data collected is under laboratory settings that do not mirror real-world exposure. See more on EPA’s failure to protect bees here.

Over 20,000 known wild bee species exist worldwide, with about 3,600 native to North America. Of those, 739 species are known to be associated with agricultural crops. For their research, the authors of this study obtained complete information for all life history categories and size for 594 of those identified bee species to analyze. Since exposure to agricultural pesticides is one of the multiple interacting drivers of wild bee declines globally, representative risk assessments are imperative to protect biodiversity and ecosystem services and thus need to be thorough.

For proper risk assessments, “a comprehensive understanding of both the nature of the risk (risk = hazard x exposure) attributable to pesticide use on crops and the nature of the intrinsic vulnerability of bees to pesticides is required,” the researchers state. In chemical-intensive agriculture, each crop requires different pesticide use regimes, each pesticide has varying toxicity, and bee species have different vulnerabilities that need to be considered. The authors continue in saying, “Across North America, the amount, type (active ingredient, systemicity, and toxicity), application method, and environmental persistence of pesticides used in agriculture vary by crop. The combination of these defines the bee toxic load unique to each crop.”

The main objectives of this study are to:

1. characterize and compare the relative potential risk experienced by wild bee species that are associated with agriculture in North America using (a) suites of bee traits to quantify species’ intrinsic vulnerability and (b) extrinsic factors based on the toxic load of crops to bees and the strength of each species’ association with those crops; and
2. describe the relative influence of extrinsic factors and intrinsic traits on calculated relative risk to bees from agricultural pesticides.

This was achieved by combining “both the Bee Vulnerability Score (BVS) and the Crop Association-Weighted Toxic Load for each bee species to calculate the relative potential risk experienced by that species from its association with agriculture” that then allows the researchers to rank the species by their potential risk score. Higher point values correspond to higher risk of exposure and/or susceptibility to agricultural pesticides.

The available data that was utilized in this study focus on crops for alfalfa, almond, apple, blueberry, cherry, corn, cotton, cucumber, eggplant, melon, pear, peppers, plum, potato, pumpkin, raspberry, soybean, strawberry, sunflower, tomato, and watermelon; these crops are known to be associated with 713 total bee species.

The authors find, “The highest BVS was shared by bee species that were small, ground nesting, solitary, and with crop specialization,” which includes the species Andrena melanochroa, Panurginus atramontensis, and Pseudopanurginus albitarsis. The lowest scores were found in Bombus species. Within the 90th percentile for the vulnerability scores, the researchers note that, “Five families (Andrenidae, Apidae, Colletidae, Halictidae, Megachilidae), 20 genera, and 60 bee species were represented.”

From the results, the authors point out that, “Importantly, species that are commonly used as models to assess the effects of pesticides on wild bees, like Bombus impatiens, Megachile rotundata, and Osmia species, all exhibited BVS below the median.”

The data also reveals that corn, peppers, potato, raspberry, and cherry have the highest toxic loads per crop for bees. As the authors say, “The high toxic loads of corn and peppers can be explained by the intensive use of bee toxic insecticides, including pyrethroids (e.g., cyfluthrin, zeta-cypermethrin, cypermethrin, bifenthrin) and organophosphates (chlorpyriphos) in corn, and neonicotinoids (e.g., imidacloprid, clothianidin, thiamethoxam, dinotefuran), pyrethroids (e.g., zeta-cypermethrin, cyfluthrin, permethrin, bifenthrin, lambda-cyhalothrin), and organophosphates (naled) in peppers… The intensive use of neonicotinoid (e.g., imidacloprid, thiamethoxam) and pyrethroid (e.g., zeta-cypermethrin, bifenthrin) insecticides in potato, raspberry, and cherry also contributes significantly to the high toxic loads of these crops.”

The researchers establish that extrinsic factors with environmental exposures are more strongly associated with risk to bees than intrinsic traits within the species. Extrinsic factors, such as bees not only foraging from crops but also nesting or overwintering in soils, can increase their pesticide exposure. Life history traits can vary greatly between species, “showing differences in phylogeny, nesting behaviour, sociality, size, reproductive strategies, phenology, larval provisioning strategies, diet breadth, and ability to detoxify pesticides.” All factors must be considered for risk assessments as studying a single species with a certain subset of traits is not representative of all bees.

Species that can detoxify pesticides more efficiently than others are less vulnerable to the effects of pesticides they are exposed to. For species that do not have this ability, such as “some species of the Megachile genus [that] lack important detoxification genes found commonly in other bee groups,” they have substantially higher sensitivity. This includes Megachile rotundata, which the authors identify in the top 10% for potential risk.

The authors highlight that, “Pesticide exposure for bees visiting treated perennial crops such as orchards may be higher than in annual crops because there is no crop rotation and no soil tillage, meaning that persistent pesticides are likely to accumulate in soil. Conversely, annual crops planted with pesticide-treated seeds may also bear higher risk to wild bees because some highly bee toxic neonicotinoid insecticides (e.g., imidacloprid, thiamethoxam) are often applied in this manner and because potential exposure of ground-dwelling bees to pesticide residues in the soil is high. Systemic pesticides can travel into nectar and pollen from their points of application, and persistent chemicals can accumulate in soil, causing an increase in toxic load over time that is especially relevant to bees that nest or overwinter in the ground.”

Pesticides used as seed coatings were not included in the data for this study, and as such the “reported toxic loads for alfalfa, corn, cotton, cucurbits, eggplant, pepper, potato, soybean and sunflower (i.e., crops that may be grown using treated seeds) may be well below their true toxic load and should be understood in that light,” the authors say.

This study helps to highlight relative potential risk, not absolute risk, for the varying bee species currently not considered by EPA when performing risk assessments even though hundreds of species are exposed to pesticides through foraging and nesting behaviors within North America. For a more representative risk assessment process, the authors “suggest an approach that combines information about intrinsic suites of bee traits that define a species’ vulnerability to pesticides with extrinsic factors such as the toxic load born by crops and the strength and breadth of a species’ association with those crops that define potential environmental risk for that species in agroecosystems.”

The researchers hope that this study “can empower stakeholders to (1) prioritize research efforts towards studying species or groups identified as being at highest risk, (2) address environmental factors contributing to risk generally, (3) tailor management practices in specific crops to mitigate risks effectively, (4) design conservation plans for agriculture, and (5) inform future risk assessment protocols, particularly by highlighting bee species or groups that exhibit the highest vulnerability based on their unique traits.”

While the risk assessment process for toxic pesticides is lacking and needs improvement, a better solution exists with organic land management. The holistic approach with organic practices provides a healthy alternative to the detrimental effects of chemicals that pollute the environment and all organisms within it. Protecting all bee species, as well as other pollinators, from pesticides is crucial to agricultural and economic productivity, as well as food security. Take action to advance organic, sustainable, and regenerative practices and policies and be part of the organic solution by becoming a member of Beyond Pesticides today.

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

Source:

Chan, D. and Rondeau, S. (2024) Understanding and comparing relative pesticide risk among North American wild bees from their association with agriculture, Science of The Total Environment. Available at: https://www.sciencedirect.com/science/article/pii/S0048969724055281?ref=pdf_download&fr=RR-2&rr=8b318d57dae85782.

(Beyond Pesticides, August 22, 2024) A screening and analysis of 36 pesticides finds traces of these chemicals in patients with “unexplained chronic kidney disease” from agricultural communities in the Indian province of Uttar Pradesh. Researchers conducting this study, published in the Journal of Toxicology and Environmental Health Sciences, identify organophosphates, organochlorines, and pyrethroids as the main culprits, building on years of existing research pointing to adverse health impacts originating from bioaccumulation of pesticides after acute and chronic exposure.

Chronic kidney disease (CKD) is a condition that afflicts one in ten adults internationally, based on a peer-reviewed analysis from The Lancet. The Centers for Disease Control and Prevention (CDC) estimate that one in seven U.S. adults (or roughly 35.5 million people) have CKD, with as many as nine in ten adults with the disease undiagnosed, based on 2023 data. The correlation between high rates of CKD and multigenerational use of and reliance on pesticides for food production, lawn care, and general land management reinforces the calls of advocates, farmers, and health professionals to adopt a new approach rooted in organic principles.

Methodology

This study was conducted by a group of researchers from the Department of Chemistry at Babu Banarasi Das University and the Biochemistry and Nephrology Departments at Dr. Ram Manohar Lohia Institute of Medical Sciences in Uttar Pradesh, India. As a prospective case-control study (enrolling study participants before symptoms occur), researchers declared no conflict of interest and followed both internal ethics guidelines and the World Medical Association (WMA) Declaration of Helsinki, the latter of which is a statement of ethical principles established in 1964 to guide human-centered medical research.

With the goal of identifying potential exposure pathways for patients with chronic kidney disease of unknown origin (CKDu), researchers enlisted patients from two health centers in Uttar Pradesh. This province is notable given that the majority of the population (approximately 237 million residents as of 2020) work in agriculture as their primary occupation, which means that roughly 23.7 million people are projected to have chronic kidney disease. Patients that had “episodes of acute kidney injury or any need for renal replacement therapy were excluded from the study.” The control group for this case-control population study consisted of participants from family members, spouses, or any others accompanying the selected patient. Further screening for geographical and age variation, as well as the exclusion of patients who met the CKDu criteria but had confounding health variables that would have disrupted the study, led to the final number of one hundred cases and one hundred corresponding control participants. See the methods section for further details.

Findings

Out of 150 commonly used pesticides, researchers identified 36 pesticides—15 organophosphates, eight organochlorines, and 13 pyrethroids—in the bloodstream of both groups of study participants. “The findings of the study indicate widespread exposure to pesticides among individuals in agricultural areas, with residues detected in both CKDu patients and controls,” as the authors report on the importance of further research to identify more links between CKDu patients and their accompanying control participants. Of the 36 pesticides, malathion, parathion, carbophenothion, azinphosmethyl, chloroneb, HCB, beta HCH, pp’-DDE (DDT metabolite), phenylphenol, transfluthrin, flucythrinate-1, and flucythrinate-2 were all found to be “significantly elevated” among CKD patients compared to the control group. The researchers emphasize “that CKD is associated with greater serum and lower urinary levels of several pesticides…indicating accumulation of various commonly used pesticides in CKD” because it suggests that afflicted patients discharge pesticides less efficiently, which in turn can exacerbate kidney damage and lead to spiraling health impacts.

Existing Research

This study builds on numerous reports that demonstrate the adverse health effects of pesticides on kidney health among various at-risk subpopulations, including women, pregnant women, and agricultural workers, as well as broader populations in various geographical contexts.

For example, a 2022 study published in International Journal of Environmental Research and Public Health found that acute kidney failure is the leading cause of death for agricultural workers in Brazil, based on mortality data from 1980 to 2014, with younger women in rural areas in southern regions of the nation at the highest levels of risk. Rates are also increasing in urban areas of Brazil in the target regions, but not as much as their rural counterparts – a trend consistent across high-, middle-, and low-income nations. A 2023 study in PLOS One corroborates the elevated risk of CKD and CKDu in female agricultural workers in Iran. Female agricultural workers in indoor settings face disproportionate risks, including among women who exhibit zero additional underlying health conditions such as diabetes mellitus and hypertension. More specifically, women face 2.6 times the prevalence of CKD than participating male subjects in this report.

A four-year investigation published in 2012, led by Channa Jayasumana, PhD and Sarath Guanatilake, MD from the Department of Medicine at Rajarata University in partnership with the World Health Organization, identifies pesticides and fertilizers (including cadmium and arsenic-based pesticides, as well as glyphosate) as dominating factors leading to CKD in agricultural communities across Sri Lanka. The two researchers won the 2019 Scientific Freedom and Responsibility Award (per the American Association for the Advancement of Science) for this research linking glyphosate-based herbicide use to elevated risk of CKD. A 2022 study published in npj Clean Water built on this investigation, identifying various insecticides (organochlorine insecticides DDT/DDE, propanil, and endosulfan, and the organophosphate diazinon—none of which are permitted for use in the United States or European Union) in well waters located in agricultural regions of the nation. Simply put, researchers attribute the prevalence of chronic kidney disease of unknown origin to rampant pesticide use.

The culmination of decades of scientific studies, data, and analysis points to what advocates would describe as the need to take transformative action for food production and land management systems. See Daily News sections on kidney failure and CKD for more information.

Take Action

Agricultural justice is a keystone example of ongoing environmental justice concerns among farmworker and farming communities within and outside the United States. See the Pesticide-Induced Disease Database entry on kidney function and disease to delve into dozens of peer-reviewed scientific literature on the connections between kidney health and toxic pesticide exposure. See the Gateway on Pesticide Hazards and Safe Pest Management sections on malathion, parathion, and other toxic pesticides in this study to find additional information and resources on their adverse health effects. For more information on moving beyond toxic pesticides in your local park or playing fields, see the Parks for a Sustainable Future program.

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

Source: Toxicology and Environmental Health Sciences

(Beyond Pesticides, August 21, 2024) A literature review, published this month in the Journal of Agricultural and Food Chemistry, explores levels of pesticide residues found in samples of human urine with environmental exposure and dietary intake and confirms prior findings about the benefits of an organic diet. Similar to past findings, lower concentrations of chemicals are detected in the urine of participants who report eating an organic diet. By analyzing 72 scientific research studies published between 2001 to 2023, the review assesses routes of exposure and “explores urinary concentrations and detection frequency of metabolites of organophosphates and pyrethroids, as well as herbicides such as 2,4-D and glyphosate,” the authors say.

While “exposure to pesticide residues is influenced by a variety of demographic factors, including occupation, agricultural practices, seasonal variations, residence, diet, age, and gender,” the authors say, the concentrations of pesticides and their metabolites in human urine highlights the disproportionate risk to certain groups as well as the overall threat to the health of humans and the environment. Pesticide exposure can occur from dermal/skin contact or inhalation, through residence or work, and with dietary intake.

“Pesticides in urine can be detected as parent compounds, specific metabolites corresponding to a specific pesticide, and nonspecific metabolites corresponding to pesticides chemical class, e.g., organophosphates,” the authors state. They continue, “Nonspecific metabolites are often targeted, as the aim in some cases is not solely to check exposure to a single pesticide but rather a range of pesticides. Parent pesticides may not always be observed due to metabolization.” The research that the authors review use levels of pesticides or their metabolites as biomarkers detected in urine samples, as it is minimally invasive and easy to collect, to gauge human exposure. Other biomarkers have been utilized to detect pesticides in hair.

While this review covers studies as far back as 2001, the authors highlight that from “2020 onward, there has been a significant increase in research output, with a total of 38 research papers [out of the 72 analyzed] published during the period 2020−2023.” The studies that were reviewed originate mostly from the United States, Spain, China, Thailand, and various European countries. The majority of studies focused on 50−200 participants (22 studies) or 200−1000 participants (24 studies) and targeted a range of ages (children only, adults only, and both adults and children).

Analyzing the results of the 72 studies reveals that 3-Phenoxybenzoid acid (3-PBA) is the primary metabolite detected in urine samples, as it is included in 34% of the studies. 3-PBA is a nonspecific metabolite of pyrethroid insecticides like deltamethrin, cypermethrin, and permethrin. A specific metabolite for the pyrethroid cypermethrin, known as DCCA (cis- and trans-(2,2-dichlorovinyl)-2,2-dimethylcyclopropane-1-carboxylic acid), was also commonly detected. Pyrethroids have been associated with cancer, endocrine disruption, reproductive effects, neurotoxicity, skin irritation, kidney and liver damage, and birth/developmental effects.

Diethyl phosphate and dimethyl phosphates, nonspecific metabolites of organophosphate insecticides, are detected in 32% of the studies. 3,5,6-Trichloro-2-pyridinol (TCPy), a specific metabolite of the organophosphate chlorpyrifos and chlorpyrifos-methyl, is included in 31% of the studies. Chlorpyrifos, and many other pesticides within the organophosphate class, are also linked to cancer, endocrine disruption, reproductive effects, neurotoxicity, skin irritation, kidney and liver damage, and birth/developmental effects. Studies highlight the impact of chlorpyrifos exposure to brain function damage, respiratory diseases and diabetes, and depression and suicide.

A study conducted in the Czech Republic finds that elevated levels of metabolites in urine, particularly DCCA and TCPy, have been linked to increased oxidative stress. The effect of pesticide residues on oxidative stress is also demonstrated by a study conducted in Thailand where organophosphate metabolites were proven to cause oxidative stress. Oxidative stress can play a role in many conditions like cancer, Alzheimer’s disease, and heart disease.

Glyphosate and its metabolite aminomethylphosphonic acid (AMPA), as well as 2,4-D, are additionally included in several studies. These chemicals are also well-documented for causing oxidative stress and cancer, as well as many other detrimental effects. Beyond Pesticides has reported on these health impacts extensively here and here.

Higher concentrations of metabolites, such as 2-Isopropyl-6-methyl-4-pyrimidol (IMPy), TCPy, and ethylene thiourea (ETU), “were significantly associated with a higher incidence of behavioral issues, such as social difficulties, thought-related problems, and rule-breaking symptoms,” the authors share. “These findings suggest a potential relationship between pesticide exposure and epigenetic changes, as well as behavioral and neurobiological impacts.” See more studies on these health effects here and here.

Much of the scientific research that is included “analyzed occupational exposure in farmworkers, farmworkers and their families, spray applicants, and florists’ exposure to pesticides,” the authors state, who are shown to be “vulnerable group[s] due to their direct contact and their routine respiratory exposure to pesticides.” While farmworkers generally have higher pesticide exposure, many of the studies within this literature review find that adopting organic farming practices can reduce the levels of pesticides detected in their urine. It should be noted that the requirement In the Food Quality Protection Act (amendments to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act) does not require occupational exposure to be included in a cumulative risk analysis for exposure through food, air, water, and land. As a result, when calculating the effect(s) of exposures that have a common mechanism of toxicity, the body burden of overall exposure, including dietary exposure, is not calculated by the U.S. Environmental Protection Agency (EPA).

Organic agricultural practices and eating an organic diet reveals evidence of reduced concentrations of metabolites, notably with 3-PBA, in urine samples. In comparing conventional and organic diets, the authors find, “a noticeable decrease in concentration is observed for phenols and phosphonate herbicides, with a 41−100% decrease, pyrethroid metabolites (16−100%), organophosphate metabolites (41−75%), and quaternary ammonium growth regulators (74−93%).” They continue, saying, “Detection frequencies of pesticides/metabolites significantly dropped from 10−100% to 0−50% when switching to an organic diet.”

The path forward to protect human health, for not only disproportionately affected groups like farmworkers and their families, is organic. Under the Organic Foods Production Act (OFPA), organic agriculture embodies an ecological approach to farming that does not rely on or permit toxic pesticides, chemical fertilizers, genetically modified organisms, antibiotics, sewage sludge, or irradiation. Beyond Pesticides supports organic agriculture because it implements good land stewardship and achieves reductions in hazardous chemical exposures.

Choose organic to protect health and the environment by buying organic products or growing your own organic food. Beyond Pesticides suggests a complete switch from chemical-intensive agriculture to regenerative organic agriculture to sustain human, animal, and environmental health. Become a member to add your voice to the movement and take action each week to be part of the organic solution.

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

Source:

Hakme, E., Poulsen, M. and Lassen, A. (2024) A Comprehensive Review on Pesticide Residues in Human Urine, Journal of Agricultural and Food Chemistry. Available at: https://pubs.acs.org/doi/abs/10.1021/acs.jafc.4c02705.

(Beyond Pesticides, August 20, 2024) A study published online in the journal Environmental Toxicology and Pharmacology raises continuing concern about residual exposure to organochlorine pesticides (OCPs) and the disruption that they and their metabolites and isomers cause to biological systems. For the most part, OCPs, including dichlorodiphenyltrichloroethane (DDT), are no longer used worldwide, but the legacy of their poisoning and contamination persists. A 2022 article in Environmental Science & Technology cites California condors and marine mammals along California’s coast contaminated with several dozen different halogenated organic compounds (hazardous, often-chlorinated chemicals) related to DDT, chlordane, and other now-banned legacy chemicals. Other research finds DDT in deep ocean sediment and biota. And, more research finds multigeneration effects from DDT exposure with grandmothers’ exposure to DDT increasing granddaughters’ breast cancer and cardiometabolic disorder risk.

This study may be the first compilation of research regarding the modes of action for distinct types of organochlorine pesticides (OCPs). The findings raise the significant danger of legacy chemicals that persist for generations and call for a precautionary regulatory standard that is focused on preventing harm and advancing alternative nontoxic practices and products. In tracking the ongoing scientific literature on a broad spectrum of adverse effects daily, Beyond Pesticides has urged the U.S. Environmental Protection Agency (EPA) to recognize that under the “unreasonable adverse effects” standard of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the viability, productivity, efficacy, and profitability of organic practices and organic-compatible products, make the current use of toxic pesticides violative of the statutory standard.  (See Pesticides and You.)

The authors aim to highlight differences and common behavioral reactions for three groups of OCPs—dichlorodiphenyltrichloroethane (DDT), hexachlorocyclohexane (HCH), and chlordecone (CLD)—in humans and animals by collecting data on their modes of action. A ‘mode of action’ is the chemical mechanism by which a chemical causes changes to an organism. Relevant studies from 1970 to 2024 on the mode of action for various classes of OCPs are compiled in the research, then translated into a series of detailed graphic flow charts.

Each pesticide, as well as its metabolites and isomers, exhibit different abilities to disrupt natural biological processes in mammals, according to the authors. In addition, each OCP differs in where they accumulate in the body and which types of protein they bind with most effectively. For example, DDT and HCH tend to accumulate in fat cells while CLD is most prevalent in the liver. However, DDT is more likely to bind to high-density lipoproteins (HDLs), while one of its metabolites DDE binds more readily to low-density lipoproteins (LDL). Furthermore, certain OCPs disrupt biological processes by mimicking hormones and filling a cell’s hormone receptor sites so that the cell is no longer able to receive natural signals from the body. Other compounds change the permeability of cell walls by binding with calcium or sodium, thereby changing the ability of cells to function properly. In some cases, the exact mode of action still has not been determined.

However, although each OCP has different modes of action, their biological impacts are mostly the same. For example, all compounds were found to be endocrine disruptors. The endocrine system creates and releases the hormones that regulate body function, such as metabolism, growth and development, and sexual function. Each of the OCPs mimics different hormones, creating different methods for disrupting the natural hormone systems. Similarly, all OCPs tested were found to disrupt the nervous system. The nervous system is responsible for blood pressure, heart rate, and breathing, as well as all sensation, movement, emotions, communication, thought processing, and memory among many other biological functions. In addition, each compound was found to contribute to oxidative stress—an imbalance of oxidants causes cell death and is linked to cancer, Alzheimer’s disease, heart disease, and many other diseases.

What are organochlorine pesticides?

OCPs are primarily made up of chlorine atoms, classified as persistent organic pollutants (POPs) due to their toxic longevity in the environment. The study notes that chemicals enter the environment through (1) their employment in farming as pest control, (2) the release of contaminated waste into landfills and dumpsites, and (3) emissions from industrial plants synthesizing these compounds. 

Although many countries ban most organochlorine compounds, OCPs remain in soils, water (solid and liquid), and the surrounding air at levels exceeding EPA standards. While EPA has ended pesticide registration for virtually all of the original POPs, the United States has not joined over 150 countries in ratifying a 2001 United Nations treaty known as the Stockholm Convention on Persistent Organic Pollutants, which requires the elimination of persistent organic pollutants’ (POPs) production, use, and/or release. (See here and here for Beyond Pesticides coverage).

OCPs are largely insoluble in water but easily dissolve in fats and oils, which makes them exceptionally persistent in the environment by binding readily to soils, plants, and animals. When OCPs enter an animal through ingestion or dermal absorption, the organochlorine pesticides may break down into metabolites or transform into isomers. Together, this affinity enables OCPs to move around the body with ease by attaching to lipoproteins and passing through the bloodstream. Additionally, as the study documents, prior epidemiological research clearly focuses on “the carcinogenicity of OCPs with a significant occurrence of acute myeloid leukaemia [leukemia], multiple myeloma, myelodysplastic syndrome, and hematopoietic bone marrow cancer (Bassil et al., 2007)” and their neurotoxicity “due to their toxicity towards insect nervous systems (Casida, 2009, Costa et al., 2008).” For Beyond Pesticides’ latest reporting on OCPs, see here.

This research highlights the complexity of the interactions associated with the adverse impacts of OCPs on biological systems. In her groundbreaking book, Silent Spring, Rachel Carson illuminated the severe and systemic collateral damage to wildlife, soil health, and water quality from the widespread use of pesticides, particularly DDT, but also organophosphate pesticides. Four decades after pesticides entered the scene, scientists are still only scratching the surface of the tangled web of interactions, reactions, and counteractions that can result from their use.

The evidence is clear: OCPs pose serious health and environmental risks, and the U.S. regulatory system has repeatedly failed to address these threats preventively or in a timely manner (see here and here). The continued persistence and use of fossil fuel-based pesticides and fertilizers is contributing to a trifecta of existential crises: human illness exacerbated by pesticide exposure, the collapse of biodiversity, and the accelerating climate emergency. We must take urgent action to eliminate their continued use. To learn more about the negative health effects of OCPs and other pesticides, please see the Gateway on Pesticide Hazards and Safe Pest Management and the Pesticide-Induced Disease Database.  

Organic practices offer a viable and necessary alternative. Grounded in the preservation of healthy ecosystems, these practices not only ensure food productivity and resilient land management but also safeguard our food, air, and water. The data supporting organic agriculture creates a compelling case for phasing out pesticides within the next decade. [Meeting Existential Challenges, the latest issue of Pesticides and You, underscores this stark reality.]  To learn more about why organic is the best choice for both consumers, farmworkers who grow our food, and those living in ‘fence-line communities’ near farms, visit the Beyond Pesticides webpages on the Health Benefits of Organic Agriculture and Agricultural Justice.

Now is the time to act. The work being done by Beyond Pesticides, along with our network and allies, demonstrates the potential for change through community-based efforts and initiatives See Beyond Pesticides’ Action of the Week and join your voice in the call for action. To become an advocate in your local community for organic public parks, learn more about our Parks for a Sustainable Future program. Together, we can build a future where organic solutions can thrive, protecting our health and the environment from unnecessary toxicants for generations to come.

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

Sources:

The mode of action of different organochlorine pesticides families in mammalians, Environmental Toxicology and Pharmacology, September 2024 (print release)

(Beyond Pesticides, August 19, 2024) As a local news outlet in Virginia covers a local farm receiving organic certification, Beyond Pesticides launches an action this week to “take back organic” —in response to prominent agricultural forces and industry interests attempting to weaken organic standards and blur the line between certified organic and “regenerative” practices that are not organic-certified. In an article, VMRC’s Farm at Willow Run is certified organic [VMRC is the Virginia Mennonite Retirement Community], Rocktown Now quotes the farm manager in Harrisonburg, VA, Nate Clark, saying, “This milestone demonstrates our dedication to providing high-quality, healthy food to our residents and community while also prioritizing environmental sustainability.” The article reports that as a certified organic farm with detailed records of the farm’s field and harvest activities and materials, subject to annual inspections, “VMRC is committed to regenerative farming practices that promote soil health, energy conservation and fair working conditions.”

“Regenerative” agriculture or land management that is not certified organic raises a series of questions about its lack of a standard definition that is enforceable under a compliance system. Beyond Pesticides’ piece on the subject, “Regenerative” Agriculture Still Misses the Mark in Defining a Path to a Livable Future,“ explores the departure from the underlying principles, standards, allowable substances, and enforcement of certified organic practices. As a result, organic practitioners and advocates have taken the position that to make regenerative meaningful, it must require organic certification as a starting point.

Organic agriculture in the United States started in the 1940s as a movement of concerned citizens, environmentalists, and farmers. The organic movement in the U.S. was spearheaded by J.I. Rodale, founder of Rodale Press and Rodale Institute (originally Soil and Health Foundation), who was influenced by earlier pioneers including indigenous peoples, George Washington Carver, Lady Eve Balfour in England, Sir Albert Howard in India, and Rudolf Steiner of Austria.  Rodale’s interest in promoting a healthy and active lifestyle that emphasized organically grown foods led him to establish the Rodale Organic Gardening Experimental Farm in 1940 and start publishing Organic Farming and Gardening magazine in 1942.

>> Tell USDA that organic agriculture must require practices that build soil and raise animals on pasture, so hydroponics and concentrated animal feeding operations (CAFOs) should not be certified. Tell Congress to support increased funding for the Organic Certification Cost Share Program.

Interest in organic food and organic farming grew in the 1960s after the publication of Silent Spring increased public awareness of the dangers of toxic pesticides, promoted by Rodale’s belief that farming practices focused on cultivating healthy soil would lead to healthier foods, and ultimately, healthier people as well. Since then, organic practices have been shown to also have beneficial impacts on biodiversity and climate. The notion of building soil, which is foundational to organic and certified organic production to this day, replaced the reliance on toxic petrochemical pesticides and fertilizers.

During the 1980s, momentum grew toward codifying principles of organic to not only protect organic consumers but also reverse pesticide dependency and its resulting impacts from toxic chemical contamination. That momentum culminated in the passage of the Organic Foods Production Act of 1990 (OFPA). That “organic” belongs to the movement of organic farmers, consumers and public interest organizations, environmentalists, scientists, handlers, retailers, and certifiers, was recognized in the guiding role OFPA gives to the National Organic Standards Board (NOSB) consisting of representatives of those groups. While the foundation of organic is strong in rejecting materials and practices that are harmful to biological systems, there are ongoing efforts regarding organic standards and certification at the U.S. Department of Agriculture (USDA) and large agricultural interests that have the effect, whether intentional or not, of undermining public trust in the organic label.

National Organic Standards Board and key issues. Just as the NOSB shows that organic belongs to the organic community and is not just a premium brand, it is the disempowering of the NOSB that marks the theft of organic. Although members of the NOSB are meant to represent various sectors of the organic community, it is USDA, not the organic community, who selects members of the board. When USDA redefined the requirement to reevaluate allowed synthetic substances in organic production and processing—the “sunset” provision—it weakened the default assumption that synthetic substances (on a five-year review cycle) are removed from the National List of Allowed and Prohibited Substances unless a supermajority of the board agreed on its relisting. It redefined “sunset,” defying its common meaning, to retain a listing unless a supermajority votes to remove it. USDA denies the primary principle of organic agriculture—the critical importance of soil health—by allowing hydroponics to be certified organic. It has also allowed certified livestock producers to confine animals for extended periods of time, without showing necessity, in concentrated animal feeding operations (CAFOs).

Certification of organic practices. A less obvious way that organic is being stolen is the way certification is currently managed. OFPA allows USDA leeway in the structure of the certification system. USDA’s approach results in inconsistency and “certifier shopping.” Certifying agents are private businesses that collect fees for the service from the certified producer or handler and have an incentive to give their customers (producers) what they want—hence, some certifiers (but not all) certify “organic” hydroponic or CAFO operations. Other ways of structuring organic certification that have been suggested by the Northeast Organic Dairy Producers Association and André Leu of Regeneration International have not been adopted in the U.S. In the short-term, one way of offsetting the costs of certification is the Organic Certification Cost Share Program. In the long-term, it must be recognized that organic agriculture performs a social good in saving the earth and therefore certification must be subsidized.

Solving existential crises. Chemical-intensive agriculture is a major contributor to climate change and biodiversity loss. Its dependence on toxic pesticides and chemical fertilizers results in human disease and contamination of air, land, and water. Organic agriculture can reverse or mitigate all these problems—as long as it is the organic as originally conceived, embodying the four principles of organic agriculture, as stated by Regeneration International, that are essential in determining whether practices are regenerative or degenerative.

• Health: Organic agriculture should sustain and enhance the health of soil, plant, animal, human and planet as one and indivisible.
• Ecology: Organic agriculture should be based on living ecological systems and cycles, work with them, emulate them and help sustain them.
• Fairness: Organic agriculture should build on relationships that ensure fairness with regard to the common environment and life opportunities.
• Care: Organic agriculture should be managed in a precautionary and responsible manner to protect the health and well-being of current and future generations and the environment.

As organic is being attacked, it continues to help mitigate the crises in public health, climate, and biodiversity by providing:

• A definition of organic agriculture that defines health-biodiversity-climate friendly practices;
• A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests;
• A rigorous process for an allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
• A third-party certification and enforcement system;
• A process for public participation to ensure a feedback loop for continuous improvement;
• Funding to ensure elements are carried out in a robust way.

Taking Back Organic Principles and Practices. However, the problems identified above have prompted some in the organic community to “add-back” or “add-on” to current USDA standards by defining and certifying “real organic” or “regenerative organic.” And now, the same chemical-intensive agriculture interests are trying to hijack the term “regenerative,” which was coined by Robert Rodale “to describe a holistic approach to farming that encourages continuous innovation and improvement of environmental, social, and economic measures.” The word “regenerative” is now used loosely by many who promote minor improvements in agriculture, such as reduced tillage and cover crops. However, when confronted with a definition that allows use of pesticides and chemical fertilizers, it is important to keep in mind what Jeff Moyer, emeritus director of the Rodale Institute who introduced Regenerative Organic Certification (ROC), has aptly stated, “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.'” 

It is time to reclaim organic from the chemical interests that are in the process of stealing it—and prevent “regenerative,” integral to organic, from being stolen as well. Regenerative organic agriculture—and regenerative must always start with organic—is our hope for mitigating and reversing the damage inflicted on the Earth and her inhabitants by chemical-intensive agriculture.

For more information, on “regenerative” practices outside of an organic management system, see Herbicide Use in “Regenerative” No-Till Contaminates Waterbodies. Also, Mad Capital in March announced the growth of its Perennial Fund II (PFII), a loan fund “to provide farmers in the United States with tailored loans that help them transition to regenerative organic farmland while also increasing farmer profits.”

>> Tell USDA that organic agriculture must require practices that build soil and raise animals on pasture, so hydroponics and CAFOs should not be certified. Tell Congress to support increased funding for the Organic Certification Cost Share Program.

Letter to USDA Secretary Tom Vilsack and NOP Deputy Administrator Jennifer Tucker:
Organic agriculture in the United States began in the 1940s as a movement of concerned citizens, environmentalists, and farmers, spearheaded by J.I. Rodale, founder of Rodale Press and Rodale Institute (originally Soil and Health Foundation). Rodale’s interest in promoting a healthy lifestyle emphasizing organically grown foods led him to establish the Rodale Organic Gardening Experimental Farm in 1940 and start Organic Farming and Gardening magazine in 1942.

Interest in organic farming and food grew in the 1960s as the publication of Silent Spring increased awareness of the dangers of toxic pesticides, furthered by Rodale’s belief that farming practices focused on cultivating healthy soil lead to healthier foods and healthier people. Since then, organic practices have been shown to have beneficial impacts on biodiversity and climate.

During the 1980s, momentum grew towards codifying principles of organic to not only protect organic consumers, but also reverse pesticide dependency and its resulting impacts. That momentum culminated in the passage of the Organic Foods Production Act of 1990 (OFPA). That “organic” belongs to the movement of organic farmers, consumers and public interest organizations, environmentalists, scientists, handlers, retailers, and certifiers, was recognized in the guiding role OFPA gives to the National Organic Standards Board (NOSB) consisting of representatives of those groups.

Just as the NOSB shows that organic belongs to the organic community, the disempowering of the NOSB marks the theft of organic. Although members of the NOSB represent various sectors of the organic community, USDA, not the organic community, selects members of the board. USDA’s unilateral redefinition of “sunset”—so that, in re-evaluating synthetic materials allowed in organic, they are now presumed to be renewed, contrary to the meaning of “sunset” in every other legal setting.

USDA denies the primary principle of organic agriculture—the critical importance of soil health—by allowing hydroponics to be certified organic. It has also allowed certified livestock producers to confine animals for extended periods of time in concentrated animal feeding operations (CAFOs).

OFPA allows USDA leeway in the structure of the certification system, and USDA’s approach results in inconsistency and “certifier shopping.” Certifying agents are private businesses that collect fees for the service from the certified producer and have an incentive to give their customers what they want—hence, some certifiers (but not all) certify “organic” hydroponic or CAFO operations. Other ways of structuring organic certification should be considered. In the short-term, the Organic Certification Cost Share Program may offset costs.

Chemical-intensive agriculture is a major contributor to climate change and biodiversity loss. Its dependence on toxic pesticides and chemical fertilizers results in human disease and environmental contamination. Organic agriculture can reverse or mitigate all these problems—if it is organic as originally conceived.

As the problems identified above have prompted some in the organic community to separate themselves from USDA by defining and certifying “real organic” or “regenerative organic,” chemical-intensive agriculture interests try to hijack the term “regenerative,” which Robert Rodale used to prioritize soil health. The word “regenerative” is now used loosely by many who combine chemical-intensive practices with minor improvements in agriculture, such as reduced tillage and cover crops. However, such steps outside an organic system are not regenerative.

Please ensure that organic certification requires practices that build soil and animals on pasture, so hydroponics and CAFOs should not be certified.

Thank you.

Letter to U.S. Representative and Senators:
Organic agriculture in the United States began in the 1940s as a movement of concerned citizens, environmentalists, and farmers, spearheaded by J.I. Rodale, founder of Rodale Press and Rodale Institute (originally Soil and Health Foundation). Rodale’s interest in promoting a healthy lifestyle emphasizing organically grown foods led him to establish the Rodale Organic Gardening Experimental Farm in 1940 and start Organic Farming and Gardening magazine in 1942.

Interest in organic farming and food grew in the 1960s as the publication of Silent Spring increased awareness of the dangers of toxic pesticides, furthered by Rodale’s belief that farming practices focused on cultivating healthy soil lead to healthier foods and healthier people. Since then, organic practices have been shown to have beneficial impacts on biodiversity and climate.

During the 1980s, momentum grew towards codifying principles of organic to not only protect organic consumers, but also reverse pesticide dependency and its resulting impacts. That momentum culminated in the passage of the Organic Foods Production Act of 1990 (OFPA). That “organic” belongs to the movement of organic farmers, consumers and public interest organizations, environmentalists, scientists, handlers, retailers, and certifiers, was recognized in the guiding role OFPA gives to the National Organic Standards Board (NOSB) consisting of representatives of those groups.

Just as the NOSB shows that organic belongs to the organic community, the disempowering of the NOSB marks the theft of organic. Although members of the NOSB represent various sectors of the organic community, USDA, not the organic community, selects members of the board. Another step was USDA’s unilateral redefinition of “sunset”—so that, in re-evaluating synthetic materials allowed in organic, they are now presumed to be renewed, contrary to the meaning of “sunset” in every other legal setting.

USDA denies the primary principle of organic agriculture—the critical importance of soil health—by allowing hydroponics to be certified organic. It has also allowed certified livestock producers to confine animals for extended periods of time in concentrated animal feeding operations (CAFOs).

OFPA allows USDA leeway in the structure of the certification system, and USDA’s approach results in inconsistency and “certifier shopping.” Certifying agents are private businesses that collect fees for the service from the certified producer and have an incentive to give their customers what they want—hence, some certifiers (but not all) certify “organic” hydroponic or CAFO operations. Other ways of structuring organic certification should be considered. In the short-term, the Organic Certification Cost Share Program may offset costs.

Chemical-intensive agriculture is a major contributor to climate change and biodiversity loss. Its dependence on toxic pesticides and chemical fertilizers results in human disease and environmental contamination. Organic agriculture can reverse or mitigate all these problems—if it is organic as originally conceived.

As the problems identified above have prompted some in the organic community to separate themselves from USDA by defining and certifying “real organic” or “regenerative organic,” chemical-intensive agriculture interests try to hijack the term “regenerative,” which Robert Rodale used to prioritize soil health. The word “regenerative” is now used loosely by many who combine chemical-intensive practices with minor improvements in agriculture, such as reduced tillage and cover crops. However, such steps outside an organic system are not regenerative.

Please ensure that organic certification requires practices that build soil and animals on pasture, so hydroponics and CAFOs should not be certified. Please support the Organic Certification Cost Share Program in the Farm Bill.

Thank you.

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

Source: Rocktown Now

(Beyond Pesticides, August 16, 2024) The International Panel of Experts on Sustainable Food Systems (IPES-Food) released a report, Food from Somewhere: Building food security and resilience through territorial markets, in July identifying the importance of moving beyond toxic chemical dependent, industrialized agriculture and toward “sourcing local and organic food” through alternative models, such as farmer and consumer-owned cooperatives, alternative certification schemes, and fostering relationships between organic producers and consumers through territorial markets. “[T]erritorial markets are closely associated with agroecology, and in many cases help to provide market outlets for farmers using natural fertilizers and pesticides that work with nature, rather than the fossil-fuel based synthetic inputs associated with corporate value chains,” the authors state and go on to advocate for transformative action based on various case studies rooted in organic principles and practices.

Territorial markets are a nascent concept rooted in agroecology (“an integrated approach that simultaneously applies ecological and social concepts and principles to the design and management of food and agricultural systems”) and political ecology, which depending on the perspective may have differing definitions. However, there are several commonly held principles of territorial markets that include ideas of “closer to home,” “largely or fully outside of corporate chains,” and “spaces where relationships are built…particularly between food producers and consumer[s],” among other key trends. (p. 27, IPES-Food) Organic agriculture in the United States started in the 1960s as a movement of concerned citizens, environmentalists, and farmers looking to move beyond a food production framework that substitutes “safer” toxic pesticide and safety mitigation measures, which reinforce pesticide dependency to a cultural shift that undergirds public health, biodiversity, regeneration, and climate resilience. This recent report by IPES-Food reinforces the existing belief in the organic community to be creative in imagining a toxic-free reality today, enhancing biodiversity and health.

There are numerous examples of organic food systems in low- and middle-income countries, as well as high-income nations, exemplifying the universal appeal of organic certification and governance models to food supply chains. For example, worker-led and owned cooperatives that engage through Participatory Guarantee Systems (PGS), such as Ecovida Agroecology Network in Brazil, certify small-scale farmers following organic standards while simultaneously creating independent supply chains across 120 street markets covering 352 municipalities outside neoliberal, international trade structures. Since its formation in 1998, the Network has grown to a coalition of 436 groups representing 2,848 family farms that undergo the process of organic certification in compliance with Brazilian law, which was amended back in 2007 to recognize PGS certification to foster “the development of trust-based community guarantee/assurance systems that provide zero/low-cost alternatives to often costly and time-consuming third-party certification schemes.” (p. 46, IPES-Food)

The International Federation of Organic Agriculture Movements (IFOAM) defines PGS as “locally focused quality assurance systems. . .that certify producers based on active participation of stakeholders and are built on a foundation of trust, social networks and knowledge exchange.” (See 2018 IFOAM Policy Brief on PGS). There are various examples of PGS structures for certification in countries including India (nonprofit- and farmer-led PGS Organic Council) and Mexico (Participative Organic Certification facilitated by farmer- and peasant-led organizations such as MILPA Conscious Consumption Cooperative), as well as a pilot PGS structure in Yoro, Honduras for local seed certification to protect farmers from genetically-engineered and privately-patented seeds. Neither the U.S. Department of Agriculture (USDA) nor the National Organic Standards Board, past or present, have formally considered proposals that would incorporate PGS as a priority in the certification system.

The Organic Farming Territories (TVAB) model introduced in 2020 by Madagascar serves as another paradigm shift in organic certification and compliance to build capacity and “respond to challenges like reducing chemical pollution, tackling over-exploitation of natural resources, improving urban food supplies, and securing farmers’ incomes and access to lands,” according to a 2023 briefing published by the United Nations Food and Agriculture Organization (FAO). Each TVAB is dependent on the social, political, and economic contexts of the region, such as existing markets and supply chains that bring together farmers, government agencies, organic business community members, and international bodies such as the International Fund for Agricultural Development (IFAD) and IFOAM-International to establish a multi-governance approach. The four main components of the national organic strategy are institutional governance, support measures for farmers and naval operators, research and development, and awareness of consumers and economic operators. For further information, see this brief webinar developed by SYMABIO (The Malagasy Organic Agriculture Union).

“These are territories which will be intended to for all activities in the value chain of the organic agricultural sector starting with the production of seeds from the actual production of the products, from processing to marketing,” Marinà Rakotoniaina, director of support for producer organizations and agribusiness at Madagascar’s Ministry of Agriculture and Livestock (MINEA), shares on the significance of TVABs. Andriantsoa Tahiry Rabefarihy, former engineer at Group For Research and Technology Exchanges (GRET) and current UN-FAO researcher, confirms the link between biodiversity protection and expansion of certified organic in rural Madagascar, including the Anjozorobe protected area, “The establishment of TVABs on the outskirts of protected areas will contribute to the management of natural resources in these areas, but it will also generate income for residents around the protected areas.” As of April 2022, pilot TVABs are ongoing in three target zones: in buffer zones on the outskirts of protected areas, agricultural production zones intended for local markets, and outskirts of entrepreneurial organic production zones dedicated to export crops.

“So it will be territories where, for example, the use of pesticides, the use of mosquito nets, the entry of chemical products, is regulated and there it will be at the district level,” Heriniaina Ramboatiana, President of SYMABIO represents the growing interest of farmers in the Madagascan organic sector, and accompanying economic growth, in the past decade and a half. According to data gathered from Ecocert East Africa and third-party certifiers in a 2024 report by the Research Institute of Organic Agriculture, there are 278,349 acres of certified organic agricultural land in Madagascar up from 234,955 acres; between 2022 and 2012, certified organic farmland has more than tripled from just 74,787 acres.

This system appears to mirror the Transition to Organic Partnership Program (TOPP) launched in the United States under the Biden Administration’s Organic Transition Initiative (see Daily News here and comments to National Organic Standards Board here) in which regional partners representing organic farmers in different regions of the country lend technical assistance and support to aspiring organic farmers with the intention to cater to differentiated needs depending on the state and regional markets.

Another model example of organic food production and procurement is through the development of farmers’ markets that emphasize connections between urban and rural communities beyond supermarket chains. In Lome, the capitol city of the southeast African nation of Togo, Experta Toga facilitates an organic farm-to-community chain through various farmers’ markets as well as an online platform through its BIOLAMESSIN initiative. “With BIOALAMESSIN, farmers have been able to increase their production volume of organic food,” organizers with the Alliance for Food Sovereignty in Africa (AFSA) share in a 2021 case study brief: “The Togolese farmers producing under the initiative could very well be the nation’s first wave of agroecological entrepreneurs. They have also been able to expand their farms, employ workers at the farms and pay fair wages for the work.” In France, a network of organic farmers in the National Federation of Organic Agriculture supported the launch of the Positive Food Households (FAAP) challenge, a mobile grocery store in southeastern France, with the goal of “democratiz[ing] access to their produce” at just “an average increase in the food budget [of participating families] of only €0.04.”

Narrowing in on the United States context, there are plentiful opportunities and models to draw upon that defy the modern expectation of food systems maximizing efficiency at the cost of environmental and public health. At the Salinas USDA Agricultural Research Service Extension in Monterey County, California, a coalition of scientists, elected officials, farmers, and community members have become a force of political and ecological will, defying expectations of success in spite of subpar financial support. Organic Farming Research Foundation, a member of the National Organic Coalition (of which Beyond Pesticides is also a member organization), determined that these types of programs “generate an impressive $20 of benefits for every dollar invested in public agricultural research.” There are fundamental gaps to organic that advocates and organic farmers demand to be addressed in the policy process, including lack of organic certification for seafood and aquaculture, pesticide, plastic, and PFAS contamination in organic compost, and infiltration of hydroponics as organic, among other structural issues such as accessibility and cost for BIPOC consumers and farmers.

See Keeping Organic Strong to engage in the public consultation and hearing process outlined in the Organic Foods Production Act to demand and emphasize continuous improvement. See Daily News section on organic, as well as Why Organic, to learn more about the environmental justice, ecological, and public health benefits of a wholesale transition to organic. You can also demand the U.S. House of Representatives and Senate to establish regenerative agriculture provisions under existing organic standards and expand funding for the National Organic Program in the 2024 Farm Bill ahead of the fall election.

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

Sources: IPES-Food, Organic Farming Research Foundation

(Beyond Pesticides, August 15, 2024) Adding to research that has linked insecticide disruption of the gut microbial community to the progression of Parkinson’s Disease (PD) in the brain is a recently published study that further examines the gut-brain mechanism at work. A review by neuroscientist Nabanita Ghosh, PhD in Chemical Research in Toxicology—coauthored by Krishnendu Sinha, PhD, molecular toxicologist and applied pharmacologist, and molecular toxicologist Parames C. Sil, PhD—focuses on how pesticide-induced microbial community alterations specifically drive the initiation of PD and the precise mechanism. The study also explores microbiota changes at different stages of PD progression, offering recent findings.    

The researchers derive their data from the examination of PD patients, evaluating the “interaction between pesticides and gut bacteria in PD patients, summarizing how pesticides cause imbalances in gut bacteria, the resulting changes, and their overall effects on the PD prognosis.”  

The review “looks at how pesticides and gut bacteria separately influence PD development and progression, highlighting the harmful effects of pesticides and changes in gut bacteria.” The team concludes that pesticide exposure is connected to PD onset through “disturbances in gut function and alterations in intestinal microbiota.” However, the “exact role of microbial factors in this connection remains unclear.”  

The study also points out a rise in the presence and decline of specific bacterial families and genera in PD patients compared to those without PD. Additionally, the review compiles a list of differential abundances of gut bacteria that are associated with nonmotor and motor symptoms in PD patients, as each stage of the disease may correlate with a particular microbial profile. 

The team reports on recent research findings concerning variations in the gut microbial community among individuals with PD. Several studies show alterations in gut bacteria composition and “subsequent changes in products and metabolites in PD patients.” A recent systematic review reveals differences in 53 microbial families and 98 genera between people with PD and those without. Recent studies suggest gut bacteria could serve as markers for disease staging in PD and could be a possible indicator of chemical and pesticide exposure.  

This review highlights several studies that report altered abundances of specific gut bacterial families and genera upon exposure to different pesticides. 

It is proven that several classes of pesticides are damaging to gut homeostasis leading to gut dysbiosis (microbiome imbalance). Recent PD research has focused on the microbiome-gut-brain axis and vagus nerve, the nerve connecting the brain to the gut. However, the influence of pesticide exposure on gut microbiota has recently gained more attention. The gastrointestinal tract being the first exposure site, pesticides can cause alterations in the gut microbiota, possibly leading to the development of PD.  Pesticides and microbial community changes disrupt the intestinal barrier, thereby causing inflammation and alpha-synuclein (a-syn) accumulation (a 140 amino acid protein in multiple brain regions). Research indicates that PD could start in the gut under these conditions.  

It is critical to preserve the Gut-Brain Axis in the prevention and onset of neurodegenerative disease. The gut has an important relationship with the central nervous system (CNS) via the sympathetic and parasympathetic nervous system. This review explores the immediate effects of pesticide exposure on both the CNS and ENS (enteric nervous system regulating the gastrointestinal tract). 

Environmental pathogens, such as pesticides, entering the gut can disrupt the nervous system leading to abnormal accumulation of a-syn proteins that can disperse to different brain regions via the vagus nerve. Additionally, the review reports on recent research suggesting that gut bacteria are essential in forming the blood-brain barrier (BBB) and influencing microglia (central nervous system cell) and astrocyte (nervous system tissue) functions, as studies display shifts in the microbial profile and also products and metabolites in PD patients. 

Growing evidence suggests a strong link between the microbial profile and PD. An April 19 Daily News focuses on a recently proposed research paradigm that describes the entry of toxicants to the gut as one of the most common pathways for neurological harm in PD and Lewy Body Disease (LBD), another form of dementia. 

The strong evidence linking PD to pesticides does not stop global pesticide usage from continuing and even expanding. Specifically, paraquat (PQ) has been linked to PD and has been prohibited in over 60 nations, but remains in use in the United States, Australia, India, and Africa. Paraquat is highly acutely toxic to human health, through ingestion, inhalation, or even dermal administration. This herbicide can cause severe damage and chronic issues that can lead to death through respiratory failure. While glyphosate and other types of pesticides have been closely linked to depression in farmers, PQ is one of the most fatal pesticides on the market and is frequently involved in suicides and accidental exposures resulting in death. In September of 2022 the U.S. Environmental Protection Agency (EPA) asked the federal court to reconsider approval of PQ due to its detrimental risks to human health and the environment. Supporting this notion, evidence suggests that the elimination of PQ will prevent PQ-induced death and suicides without reducing agricultural productivity. This information is critical as advocates push for both EPA and the federal court to restrict the usage of PQ. 

The research team for the study states, “Usage of hazardous pesticides has to be minimized and must be altered with benign substitutes, and supplemented with protective equipment. Alternative medicinal or nutritional strategies need to be explored for individuals who cannot evade pesticide contact.” 

Despite the close link between pesticide exposure and PD onset through gut dysbiosis, the specific role of microbial factors remains elusive. While several studies suggest a link between the clinical features of PD and changed microbial compositions in PD patients, further research is needed to propose mechanistic explanations and better our understanding of the interactions between the gut microbiota and the brain. Additionally, the associations of several bacterial families and genera with pesticide-induced and PD-related gut dysbiosis indicate a potential link that requires further study. 

While the precise mechanisms of pesticides’ contribution to the onset and progression of PD remains unclear, the adverse effects to gut microbial community from PQ exposure justify forceful regulatory action to ban its use, according to health advocates. With the elimination of harmful pesticides and lifestyle adjustments, the nation can start to seriously address the epidemic of PD and neurodegeneration. Even though there is no existing cure for PD, the neuroprotective role of a healthy gut microbiome can be supported with probiotics that supply healthy microbes such as Lactobacillus, Blautia, Roseburia, Lachnospiraceae, Prevotellaceae, and Akkermansia. 

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

Sources: 

Ghosh, N., Sinha, K., & Sil, P. C. (2024). Pesticides and the Gut Microbiota: Implications for Parkinson’s Disease. Chemical Research in Toxicology. https://pubs.acs.org/doi/abs/10.1021/acs.chemrestox.4c00057 

Ryman, S., Vakhtin, A. A., Richardson, S. P., & Lin, H. C. (2023). Microbiome–gut–brain dysfunction in prodromal and symptomatic Lewy body diseases. Journal of neurology, 270(2), 746-758. https://link.springer.com/article/10.1007/s00415-022-11461-9  

Li, Z., Liang, H., Hu, Y., Lu, L., Zheng, C., Fan, Y., … & Xu, P. (2023). Gut bacterial profiles in Parkinson’s disease: A systematic review. CNS neuroscience & therapeutics, 29(1), 140-157. https://onlinelibrary.wiley.com/doi/full/10.1111/cns.13990 

Nair, A. T., Ramachandran, V., Joghee, N. M., Antony, S., & Ramalingam, G. (2018). Gut microbiota dysfunction as reliable non-invasive early diagnostic biomarkers in the pathophysiology of Parkinson’s disease: a critical review. Journal of Neurogastroenterology and Motility, 24(1), 30. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5753901/ 

Gama, J., Neves, B., & Pereira, A. (2022). Chronic effects of dietary pesticides on the gut microbiome and neurodevelopment. Frontiers in Microbiology, 13, 931440. https://www.frontiersin.org/journals/microbiology/articles/10.3389/fmicb.2022.931440/full 

Matsuzaki, R., Gunnigle, E., Geissen, V., Clarke, G., Nagpal, J., & Cryan, J. F. (2023). Pesticide exposure and the microbiota-gut-brain axis. The ISME Journal, 17(8), 1153-1166. https://academic.oup.com/ismej/article/17/8/1153/7505820 

Walker, W. A. (2017). Dysbiosis. In The microbiota in gastrointestinal pathophysiology (pp. 227-232). Academic Press. https://www.sciencedirect.com/science/article/pii/B9780128040249000252 

Yuan, X., Pan, Z., Jin, C., Ni, Y., Fu, Z., & Jin, Y. (2019). Gut microbiota: an underestimated and unintended recipient for pesticide-induced toxicity. Chemosphere, 227, 425-434. https://www.sciencedirect.com/science/article/pii/S0045653519307416 

Chen, Q. Q., Haikal, C., Li, W., & Li, J. Y. (2019). Gut inflammation in association with pathogenesis of Parkinson’s disease. Frontiers in molecular neuroscience, 12, 218. https://www.frontiersin.org/journals/molecular-neuroscience/articles/10.3389/fnmol.2019.00218/full  

Sarkar, S. R., & Banerjee, S. (2019). Gut microbiota in neurodegenerative disorders. Journal of neuroimmunology, 328, 98-104. https://www.sciencedirect.com/science/article/pii/S0165572818304545 

Daneman, R., & Prat, A. (2015). The blood–brain barrier. Cold Spring Harbor perspectives in biology, 7(1), a020412. https://cshperspectives.cshlp.org/content/7/1/a020412.short 

Tangamornsuksan, W., Lohitnavy, O., Sruamsiri, R., Chaiyakunapruk, N., Norman Scholfield, C., Reisfeld, B., & Lohitnavy, M. (2019). Paraquat exposure and Parkinson’s disease: A systematic review and meta-analysis. Archives of Environmental & Occupational Health, 74(5), 225-238. https://www.tandfonline.com/doi/abs/10.1080/19338244.2018.1492894 

Kim, J. W., & Kim, D. S. (2020). Paraquat: toxicology and impacts of its ban on human health and agriculture. Weed science, 68(3), 208-213. https://www.cambridge.org/core/journals/weed-science/article/abs/paraquat-toxicology-and-impacts-of-ban-on-human-health-and-agriculture/0E4589AEC0B5B84F5D46587C0640B235 

Stuart, A. M., Merfield, C. N., Horgan, F. G., Willis, S., Watts, M. A., Ramírez-Muñoz, F., … & Williamson, S. (2023). Agriculture without paraquat is feasible without loss of productivity—lessons learned from phasing out a highly hazardous herbicide. Environmental Science and Pollution Research, 30(7), 16984-17008. https://link.springer.com/article/10.1007/s11356-022-24951-0 

Marras, C., Canning, C. G., & Goldman, S. M. (2019). Environment, lifestyle, and Parkinson’s disease: implications for prevention in the next decade. Movement Disorders, 34(6), 801-811. https://movementdisorders.onlinelibrary.wiley.com/doi/abs/10.1002/mds.27720 

Rajawat, N. K., Bhardwaj, K., & Mathur, N. (2022). Risk of Parkinson disease associated with pesticide exposure and protection by probiotics. Materials Today: Proceedings, 69, A1-A11. https://www.sciencedirect.com/science/article/pii/S2214785322075253 

See Beyond Pesticides info: 

1. Research Links Parkinson’s and Lewy Body Disease with Chemical Effects on Brain and Gut. https://beyondpesticides.org/dailynewsblog/2024/04/research-links-parkinsons-and-lewy-body-disease-with-chemical-effects-on-brain-and-gut/
2. Recent Studies Continue To Highlight Connection Between Depression and Suicide in Pesticide-Exposed Farmers. https://beyondpesticides.org/dailynewsblog/2024/07/recent-studies-continue-in-highlighting-connection-between-depression-and-suicide-in-pesticide-exposed-farmers/
3. EPA Asks Federal Court to Allow Reconsideration of Its Decision to Permit Paraquat’s Continued Use. https://beyondpesticides.org/dailynewsblog/2022/10/epa-asks-federal-court-to-allow-reconsideration-of-its-decision-to-permit-paraquats-continued-use/ 

(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