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

Study and Methodology 

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

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

Results

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

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

Organophosphates and the Brain

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

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

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

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

Broader Implications

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

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

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

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

Suicide Prevention Resources

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

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

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

Sources:

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

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

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

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

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

>> Regenerative agriculture must be organic.

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

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

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

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

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

>> Regenerative agriculture must be organic. 

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

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

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

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

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

>> Regenerative agriculture must be organic. 

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

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

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

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

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

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

>> Regenerative agriculture must be organic. 

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

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

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

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

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

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

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

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

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

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

Thank you.

(Beyond Pesticides, July 12, 2024) No one can deny that the dominant agricultural system developed in the 20^th century is unsustainable, and indeed is in escalating crisis from the combined effects of pesticide resistance, climate change and resource overexploitation. The frontline members of this system are farmers, who must juggle numerous considerations to maintain their livelihoods. Any proposal for improvement that threatens their bottom lines is likely to encounter resistance, and any proposal that promises to improve the bottom line is more likely to be implemented. Thus there is a powerful incentive to accept suggestions from “crop advisors”—usually known as agronomists—a category that includes government extension agents, independent consultants usually paid directly by farmers, and those who work for agribusiness, particularly chemical companies.

A study published in the Journal of Rural Studies in April by Iowa State University sociologist Katherine Dentzman, PhD examines the relationships among agronomists, farmers and farming communities. Dr. Denzman conducted focus groups with agronomists in in Mid-Atlantic, Midwest, Northwest, and Southwest states to determine what pressures limit the types of advice they give farmers.

When it comes to pesticides and resistance to them, the advice provided by typical agronomists has generally led to more pesticide use, despite the policy known as Integrated Pest Management (IPM), which purports to handle resistance by judiciously and efficiently using pesticides rather than eliminating them. Pesticide resistance is portrayed as something that is too complex to be addressed by combining approaches such as no-till soil conservation, protection of beneficial insects, and regenerative agriculture in general. EPA continues to endorse IPM despite its ineffectiveness.

Dr. Dentzman’s study findings show that agronomists must balance scientific and economic factors along with the cultural preferences of farmers. Farmers and their communities feel more sense of mutual responsibility and trust when they know their advisors personally and feel engaged with them, and the advisors are intimately familiar with the local environment. Crop advisors “significantly influence” farmers’ behaviors and understanding of nutrient use, water and soil management, climate and nonpoint-source pollution. But if agronomists are perceived as presenting “modern,” top-down, expert-to-student attitudes, farmers are less likely to trust them. Dentzman found that many agronomists would prefer to provide more diverse and sustainable options for farmers by blending science and expertise with more traditional and experiential knowledge, but feel constrained by “structures based in the capitalist industrialized US agricultural system.”

In agriculture, recommended best management practices to combat pesticide resistance by reducing pesticide use, such as hand-pulling weeds and changing row widths, are impractical, Dentzman writes, in part because they are almost impossible to implement in the current system. For example, labor availability and the requirements of farm equipment restrict the applicability of such suggestions. This illustrates the problem that the agricultural system assumes pesticide resistance is something that must be handled at the farm level, rather than by changes in economic, political and governance policies nationally and globally, which is where much of the problem lies. According to Dr. Dentzman, “[N]etworks of communication and dominant ideologies, including techno-optimism and individualism…place limitations on what kinds of management approaches can be imagined as practicable.”

Not all agronomists are alike, however. Independent agronomists tend to make more varied recommendations than those working for corporate interests. On the other hand, government extension agents usually take a top-down approach, causing farmers to feel patronized, according to Dr. Dentzman. And corporate agronomists have an obvious motivation to encourage the use of more corporate products, especially petrochemical pesticides and fertilizers.

The aggressive investment in outreach and promotion by chemical companies creates the impression that pesticides remain the best way to deal with pesticide resistance. This ignores the fact that pesticide resistance is an inevitable result of natural selection and thus can never be conquered; pesticide companies rely on serial development of products that will perforce have only short-term effectiveness, driving up investment costs and passing those on to farmers in a vicious cycle, often called the “pesticide treadmill.”

Dr. Dentzman’s work complements a broader global push to implement the precepts of agroecology, which is an attempt to combine ecology and agronomy. It is related to concepts in organic farming, conservation agriculture, and regenerative agriculture, including alternatives to pesticides. A 2023 paper on agroecology in the Annual Review of Resource Economics by German scholar Frank Ewert, PhD and colleagues notes that to have “sustainable and resilient agri-food systems” there must be “integrated multiscale systems from farm to region to globe.” One of the field’s strongest advocates is University of California at Santa Cruz professor Stephen Gliessman, PhD. According to Dr. Gliessman, “The approach is grounded in ecological thinking where a holistic, systems-level understanding of food system sustainability is required” and “confronts the economic and political power structures of the current industrial food system with alternative social structures and policy action.”

Dr. Ewert and colleagues note that there have been numerous local solutions that have provided the desired ecological effects and “reduced injustice and inequality of the currently predominant conventional agricultural practices,” and that most of these have been introduced by small farmers and indigenous peoples. Gliessman estimates that about 30 percent of farmers globally have adopted some practices or redesigned their production systems on agroecologial principles.

But the question, Dr. Ewert and colleagues write, is whether these efforts can be scaled up. In a masterpiece of understatement, they note that “The related implications of such shifts for the economic and political system will likely be considerable.” The “agricultural research community and established knowledge systems” do not yet support agroecology. This is especially true in the U.S.

Nowhere is the sustainability problem more urgent and obvious than in pesticide use. A 2022 review in Agronomy for Sustainable Development by Florence Jacquet, PhD of France’s National Research Institute for Agriculture, Food and Environment discusses the goal of eliminating pesticides altogether rather than simply aiming to reduce their use. “By remaining in a framework in which pesticides are still a solution, it is difficult to initiate a paradigm shift for research, which is essential for radical innovations to emerge.”

Most agricultural research focuses on progressive reduction of pesticide use and finding substitutions. Dr. Jacquet and colleagues emphasize that “extension services remain dominated by approaches oriented to finding one solution to each problem, with little emphasis on systemic approaches that address a set of problems or propose changes in several aspects simultaneously.” This perpetuates a “fixation” effect, the authors write, “characterized by the development of common and conservative solutions to address a complex problem that should require breakthrough innovations.”

There are some encouraging signs. In the last 20 years, the number of peer-reviewed scientific publications on agroecology has gone from about zero to 600 articles per year. Related subjects like landscape ecology, plant health, microbiomes, and soil management have also increased. The United Nations Food and Agricultural Organization has developed a set of strategic documents, and the EU has developed the Agroecology Partnership to encourage collaboration and experimentation.

Currently, farmers suffer under pressures from large economic and political structures that push them to follow advice from many consultants whose goal is simply to sell more pesticides, with the strong implication that staying in the pesticide system is the only way to remain financially viable. But the ideological position that sustainable methods are not economically viable is incorrect, according to many researchers and practitioners. Dr. Ewert and colleagues cite a series of studies indicating that agroecological practices result in significantly higher value added and higher profits in grassland and dairy farms.

 In the face of this pressure, agroecology faces the daunting challenge of supporting farmers’ individual autonomy, trust in institutions and communities, and social justice, while also encouraging agronomists to combine local wisdom with reliable scientific information independent of corporate interests. This can point to a way off the pesticide treadmill. Farmers—and good-faith advisors—cannot be left to depend on disingenuous sources of expertise. Agroecology, including the substitution of ecosystem benefits for pesticide use, will be strongest if developed from the bottom up.

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

Sources:

Reflexivity and certified crop advisors’ knowledge paradigms as related to pesticide resistance management
Katherine Dentzman, PhD
Journal of Rural Studies May 2024
https://www.sciencedirect.com/science/article/abs/pii/S0743016724000901?via%3Dihub

Agroecology for a Sustainable Agriculture and Food System: From Local Solutions to Large-Scale Adoption
Drs. Frank Ewert, Roland Baatz, and Robert Finger Annual Review of Resource Economics 2023 https://www.annualreviews.org/content/journals/10.1146/annurev-resource-102422-090105

Pesticide-free agriculture as a new paradigm for research
Florence Jacquet, PhD et al.

Agron. Sustain. Dev. 42, 8 (2022).
https://doi.org/10.1007/s13593-021-00742-8
https://link.springer.com/article/10.1007/s13593-021-00742-8#author-information

Chemical-Intensive Practices in Florida Citrus Lead to Harm and Collapse, as Organic Methods Offer Path Forward Beyond Pesticides April 11, 2024 https://beyondpesticides.org/dailynewsblog/2024/04/chemical-intensive-practices-in-florida-citrus-lead-to-harm-and-collapse-as-organic-methods-offer-path-forward/

Environmental and Trade Groups Successfully Call for End to Pesticide Company Alliance with UN-FAO
July 5, 2024 https://beyondpesticides.org/dailynewsblog/2024/07/environmental-and-trade-groups-successfully-call-for-end-to-pesticide-company-alliance-with-un-fao/

Research Shatters Myth of Pesticide Benefits
Documenting unreasonable risks: sustainable alternatives Beyond Pesticides
https://www.bp-dc.org/assets/media/documents/journal/VIII%20Research%20Shatters%20Myth%20of%20Pesticide%20Benefits.pdf

Comment Period Ends Today: Advocates Say USDA Needs Organic Certifier Information on Soil Fertility
Beyond Pesticides January 22, 2024
https://beyondpesticides.org/dailynewsblog/2024/01/comment-period-ends-today-advocates-say-usda-needs-certifier-information-on-soil-fertility/

(Beyond Pesticides, July 11, 2024) Can the health of pollinator hives serve as a nature-based indicator for pesticide residue drift? Researchers in a study published in Science of the Total Environment in June find this to be the case. Through the BeeNet Project, led by the Italian Ministry of Agriculture, Food Sovereignty, and Forestry (MAFSF), researchers detected the presence of 63 different pesticide residues in hives across northern Italy. Of these residues, 15 are not approved for use under European Union (EU) law. Environmental advocates observe the mounting scientific literature on pollinator decline, in part due to the inadequate regulation of toxic petrochemical-based pesticides, as a call to action to push forward land management, agricultural, and climate policy that aligns with organic principles centering on soil health, biodiversity, public health, worker protections, and economic security.

Methodology

The study is cowritten by a cohort of ten researchers working in the Research Center for Agriculture and Environment in Bologna, Italy—a research institution within the Council for Agricultural Research and Agricultural Economics Analysis (CREA) at MAFSF. Supported by the BeeNet Project (funded by Italian National Fund), BeeNet is a national monitoring project that tracks the health of honey bee and wild bee populations in agroecological systems across hundreds of stations nationwide. The National Bee Monitoring Network (a.k.a. Honey Bees Network) consists of over 350 stations, or 1,750 hives, to inform research on apiary growth and development and susceptibility to pathogens. The Wild Bee Biodiversity Network (a.k.a. Wild Bees Network), in partnership with local universities, tracks the health and wellbeing of over 1,000 known wild pollinators in 11 regions to better inform biodiversity policy across various Italian agroecosystems since there are existing significant gaps in scientific understanding of native pollinators. The study builds on the National Bee Monitoring Network data published online, with a print release date of October 1, 2024 in Volume 945 of Science of The Total Environment.

Researchers on the study team tested for 373 active ingredients, drawing data from 25 stations in the 2021-2022 period. Of the 373 pesticides screened for, researchers found residues of 63 pesticides in their study hives. Each BeeNet station contains five hives using “standard beekeeping practices” (which includes “controlling varroa mite infestation at least twice a year using only approved treatments.”) It is unclear what these treatments refer to and if they are in compliance with the National List of Allowed and Prohibited Substances pursuant to the organic certification standards in the U.S. and EU. Beebread, a mixture of pollen and nectar or honey found in any given hive, was gathered from each station by gathering it from across the five hives in each station. The samples were collected in March and June of 2021 and 2022, totaling 100 samples compiled at moments in the year with highest probability of pesticide applications.

Findings

Of the 373 active ingredients, 63 different compounds were found across all samples. The range in multiresidue presence at its lowest was 22 in March 2022 to 40 in June 2021. The vast majority—over 90 percent—were fungicides and insecticides. Just 16 of the 100 beebread samples were completely pesticide-free and all of those were gathered in 2022. The most commonly detected pesticides include six fungicides (captan, carbendazim, dimethomorph, folpet, metalaxyl, tebuconazole) and one herbicide (pendimethalin).

The other pesticide residues found in beebread samples include Acetamiprid, Acrinathrin, Azoxystrobin, Boscalid, Bromuconazole, Buprofezin, Carbaryl, Chlorantraniliprole, Chlorfenvinphos, Chlorpyriphos-ethyl, Chlorpyriphos-methyl, Cyazofamid, Cyprodinil, Dieldrin, Difenconazol, Etaconazole, Etofenprox, Fenbuconazole, Fenhexamid, Fipronil, Fluazinam, Fludioxonil (fludioxinil), Flupyradifurone, Imidacloprid, Indoxacarb, Iprovalicarb, Kresoxim-methyl, Lenacil, Mandipropamid, Metaflumizone, Methoxyfenozide, Metolachlor (sum of isomers), Metribuzin, Amitraz (DMF+DMPF), Oxadiazon, Paclobutrazol, Penconazole, Permethrin (sum of isomers), Phosmet, Propargite, Pyracarbolid, Pyraclostrobin,Pyrimethanil, Pyriproxyfen, Spinosad (sum of spinosyn A and spinosyn D), Spirotetramat (+Spirotetramat-enol + Spirotetramat_keto-OH), Spiroxamine, tau-Fluvalinate, Tebufenozide, Tebufenpyrad, Terbuthylazine, Tetraconazole, Thiamethoxam, Trifloxystrobin, Triflumuron, and Zoxamide. This alphabet soup of pesticides present in ecosystems nationwide underscores the infiltration of pesticides and their breakdown chemicals into the broader ecosystem.

Pollinator Health and Pesticide Residues

In the spirit of Pollinator Week (June 17 to 23), Beyond Pesticides highlighted existing scientific literature as it pertains to the threat of toxic petrochemical pesticide exposure. A different study published this year in Science of The Total Environment identified – at a molecular level – that bees exposed to synthetic pesticides (particularly pyrethroid and neonicotinoid insecticides) face adverse effects to their gut microbiota, ultimately impacting pollinator biodiversity and wellbeing over their lifespan. On the issue of neonic-treated seeds, a PLOS One study found that butterfly species, with a specific concentration on the beloved monarch butterfly, are facing a rapid decline in populations in the U.S. Midwest region between 1998 and 2014. While the documentation of scientific literature continues to build upon the existing consensus that the ongoing application of insecticides imposes toxic harms imposed on pollinators, a report from U.S. Right to Know demonstrates the continued effort of pesticide manufacturers to influence scientific research, including at the Academic Society of Entomologists. Health and environmental advocates demand action to prevent attacks on sound, independent science. See one of the latest Actions of the Week, EPA’s Failures Go Beyond Pollinators, to tell EPA that to meet its obligations under Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Endangered Species Act (ESA), the agency must facilitate a transition to organic practices and to tell Congress to ensure that EPA meets its statutory obligations.

Take Action

Science writer, historian, and author Elizabeth Kolbert reflected on the history of mass extinction events across Earth’s history and underscored – building on substantial from experts across various disciplines of study – that there is currently a sixth mass extinction event underway, and insects are a prime target. Advocates are steadfast in their belief that there must be a systems-change approach to land management and agriculture that prohibits the use of toxic pesticides that directly contribute to biodiversity collapse, destruction of ecosystem services, and the climate emergency. The efficacy of global food supply chains and agroecological systems depend upon the wellbeing of pollinators and recognition as keystone species. See Keeping Organic Strong to learn more about the ecological benefits of transitioning to organic food and land management systems. See Daily News sections on pollinators and biodiversity for additional analysis on the intersection pollinator health and biodiversity protections. See Pesticide-Induced Disease Database section on biodiversity to read the latest scientific literature on pesticide infiltration and subsequent deleterious impacts on ecosystem stability.

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

Source: Science of the Total Environment

(Beyond Pesticides, July 10, 2024) An article last month in Entomology Today, a publication of the Entomological Society of America, highlights the important findings of a study published earlier this year in the Journal of Insect Science. While there has been debate on whether neonicotinoid (neonic) insecticides or Varroa mites (Varroa destructor) are more detrimental to the survival of bees, evidence suggests that neonicotinoids are not only harmful individually but can increase vulnerability to parasitism from mites in western honey bees (Apis mellifera).

The Entomology Today article reads: “Some researchers and organizations have pointed to neonics as directly harming bees. Others have pointed to other issues, like Varroa mite infestation, as more hazardous to honey bee populations.” There is scientific evidence supporting each claim, as both cause stress to bee species that can lead to population decline. The study in the Journal of Science, however, is “the first experimental field demonstration of how neonicotinoid exposure can increase V. destructor populations in honey bees and also demonstrates that colony genetic diversity cannot mitigate the effects of neonicotinoid pesticides.” 

As the article states, “The researchers were not looking for impacts on Varroa mites at first. Instead, they were looking to understand how genetic diversity of a honey bee colony could buffer the bees from environmental toxins, says Lewis Bartlett, Ph.D., assistant professor of entomology at the University of Georgia and lead author of the study.” The study uses controlled honey bee colony exposure to field-relevant concentrations of clothianidin and thiamethoxam in pollen while also simultaneously manipulating intracolony genetic heterogeneity. 

Genetic diversity, as a result of queen polyandry (a queen bee mating with multiple drones), can improve colony function, health, and fitness. As the study shares, “A wealth of studies have linked increased queen polyandry to reduced parasite (including Varroa) pressure in colonies,” which led the researchers to study the effects on colony vitality with increased polyandry. 

“We used brood exchange (transplantation) treatments to simulate the effects of a higher degree of polyandry in a colony. We tested whether this induced period of genetic heterogeneity not only improved colony health (for example, better brood survivorship, greater pollen foraging, reduced parasitic Varroa pressure, and increased queen survival) but also whether it improved colony tolerance to exposure of a mix of 2 common agricultural neonicotinoids (clothianidin and thiamethoxam) fed to colonies in contaminated pollen,” the authors write. 

Data was collected across three sites at the University of Delaware, University of Georgia, and Auburn University in Alabama. The honey bee colonies were force-fed clean pollen patties or pollen patties dosed with the two neonicotinoid insecticides and were denied the importation of foraged pollen by pollen traps being placed at all colony entrances. “Neonicotinoid-dosed patties were supplemented with 4.5 ng g⁻¹ thiamethoxam (Sigma-Aldrich) and 1.5 ng g⁻¹ clothianidin (Sigma-Aldrich) at the mixing stage,” the researchers note. “These concentrations reflect those found in pollen from flowering crops and crop-adjacent wildflowers in agricultural systems using these neonicotinoids.” 

The colony responses assessed at all sites include “size (capped brood area), queen survival (whether marked queens were confirmed as still present), pollen (mass of corbicular pollen gathered in 24 h), aggression (recruitment of guard bees to colony entrance following alarm pheromone exposure), per-capita Varroa parasitism (phoretic mites washed using ethanol from 300 adult bees), Varroa mite drop (mite drop rate onto sticky screen colony bottom boards), comb construction (area of comb constructed onto undrawn frame inserted for 24 h), and brood survival (proportion of identified L1–L2 larvae that survived to capping),” the authors report.  

As a result, the researchers, “find evidence of a detrimental effect of neonicotinoid exposure on colonies, where both mite drop rates and mite wash counts were higher in colonies exposed to neonicotinoids; colonies exposed to neonicotinoids had on average 5.3 more mites drop in 24 h and 1.11 more phoretic mites per 100 bees.” They continue in saying, “We found that field-relevant neonicotinoid exposure increased the severity of Varroa parasitism rates in exposed colonies. We did not find evidence supporting the hypothesis that this negative effect could be mitigated by increased genetic diversity in the colony, as in no instance did we find a significant interaction between pesticide exposure and brood mixing. Additionally, we found no evidence that increased genetic diversity compensated for the negative effects of the neonicotinoids, as the 2 treatments did not overlap in which colony phenotypes they significantly affected. We did, however, confirm the beneficial effects of increased genetic diversity in the form of improved brood survival.” 

The Entomology Today article reiterates that the authors did not initially seek to find effects on Varroa mites with a quote from Dr. Bartlett: “‘We didn’t expect to find our main result at all…The only negative effect we observed was the increased severity of parasitism, presumably due to some immunosuppression,’ Bartlett says.” 

As the original study emphasizes, “Agrochemical exposure is a major contributor to ecological declines worldwide, including the loss of crucial pollinator species. In addition to direct toxicity, field-relevant doses of pesticides can increase species’ vulnerabilities to other stressors, including parasites… Both wild and managed bees are threatened by interacting combinations of stressors, including forage loss, parasite pressures, and exposure to agrochemicals, including pesticides.” 

Most notably, pollinators are severely impacted by neonicotinoids, a class of insecticides that share a common mode of action that affects the central nervous system of insects. Studies show that neonicotinoid residues accumulate in the pollen and nectar of treated plants and represent a risk to pollinators by causing paralysis and death upon exposure. While the U.S. Environmental Protection Agency (EPA) has a system in place for risk assessment pertaining to pesticides that impact bees that includes a tiered process, there are many flaws in place regarding the assessments and regulations of neonicotinoids. (See more on Beyond Pesticides’ coverage of EPA’s risk assessment shortcomings here.) 

As the study authors maintain, “Agricultural pesticides are known to interact in their toxicity, leading to suspicions that their dangers to bee pollinators are underestimated.” Not only are there synergistic effects between pesticides, but they also interact with other environmental pollutants and cause greater harm to organisms and the environment. As seen in the body of science that this study adds to, neonicotinoids and Varroa mites are interacting stressors for bees that also have synergy. Previous studies have shown how the interacting stressors of neonicotinoids and mites can cause 70% reductions in overwintering honey bee survival. 

Additional studies have found that bee-toxic neonics do not provide any benefits to agriculture, and only sow seeds of doubt. The impact of pesticides on bees is an unreasonable amount of harm, even with any potential benefits, according to environmental advocates. Populations of bees continue to decline, which threatens pollinator’s critical contribution to plant health, crop productivity, and the preservation of natural resources.   

The researchers remark, “There is no shortage of observational and experimental studies emphasizing the synergistic impacts of pesticide and parasite exposure on honey bee health, including neonicotinoid and Varroa pressure. Moreover, field observations have explicitly linked neonicotinoid exposure to vulnerability to Varroa, with crucial laboratory studies… demonstrating how the neonicotinoid clothianidin increases Varroa reproduction rates due to reducing honey bee hemolytic immune response. Our work completes this literature body by showing that the individual-level findings… are mirrored at the colony level with contaminated pollen and is the first (to our knowledge) demonstration of this link between neonicotinoid and Varroa parasitism using a manipulated field experiment.”  

These results, specific to honey bees, may not represent all bee species. As previously covered by Beyond Pesticides, pesticide sensitivity in different species can vary dramatically. The authors of this study confirm that notion in saying, “While our neonicotinoid treatments were at field-realistic doses, honey bees may be more resilient in the face of these pesticides compared to other bees.” This could leave other bee species even more vulnerable than the honey bees that experienced increased parasitism in this experiment. 

The authors conclude that, “The combination of pesticide exposure and parasitism has antagonistic, additive, or synergistic impacts on honeybee health compared to either effect in isolation… The impact of the neonicotinoid in increasing Varroa populations both in absolute terms and in per-capita parasitism is in agreement with laboratory and observational studies and with this present work has now been demonstrated in the field, contributing to a large body of literature on the multiple and interacting stressors on pollinators. It is a notable finding that we confirm in-field that neonicotinoids can exacerbate the abundance of the parasite Varroa, which is arguably the single most severe contributor to managed honey bee losses in the United States.” 

Given these interacting stressors, organic agriculture is understood to be the solution. Without the use of harmful pesticides like neonics, the threat to bees and other pollinator species can be diminished. Alternatives are available for sustainable agricultural practices and for reducing parasites in hives. Research suggests that growing sunflowers near honey bee colonies help in reducing mite problems. Organic beekeeping practices are proven successful, as is organic crop production. Worldwide adoption of organic land management practices continues to increase, with entire towns going pesticide free.    

Protecting honey bees and 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. Be part of the organic solution by becoming a member of Beyond Pesticides today and subscribe to the Daily News to see the latest information on the health and environmental hazards of pesticides, pesticide regulation and policy, pesticide alternatives, and cutting-edge science.  

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

Source: 

Bartlett, L.J. et al. (2024) Neonicotinoid exposure increases Varroa destructor (Mesostigmata: Varroidae) mite parasitism severity in honey bee colonies and is not mitigated by increased colony genetic diversity, Journal of Insect Science. Available at: https://academic.oup.com/jinsectscience/article/24/3/20/7683866.  

(Beyond Pesticides, July 9, 2024) Last month, California cannabis regulators recalled a pesticide-tainted vape, one of the contaminated products identified in a Los Angeles Times investigation. The report reveals that the California Department of Cannabis Control (DCC) has for months been aware of the presence of dangerous chemicals in legal cannabis sold to the public. Conducted by Los Angeles Times and WeedWeek, a cannabis industry newsletter, the investigation has uncovered alarming levels of the insecticide chlorfenapyr in legal cannabis products sold in state dispensaries. According to an article via the National Institutes of Health, “Although [chlorfenapyr] has been identified as a moderately toxic pesticide by the World Health Organization (WHO), the mortality rate of poisoned patients is extremely high. There is no specific antidote for chlorfenapyr poisoning.” The chemical is associated with adverse liver effects and is toxic to bees, birds, and aquatic organisms.

Despite claims that the state’s cannabis is safe and regulated, many popular brands of vapes and pre-rolled joints were found to contain dangerous pesticides at levels exceeding state limits and federal standards for tobacco. This investigation comes on the heels of the discovery of large amounts of illegal Chinese pesticides at cannabis grow operations around the state. The findings are the latest in a series of reports about high rates of pesticides and other chemicals found in cannabis around the country. (See here and here for prior Beyond Pesticides reporting). With an estimated five million Californians consuming legal cannabis products monthly, the potential health consequences are extreme.

One Recall—Extensive Pesticide Contamination and Testing Laboratory Failures

The integrity of California’s cannabis laboratory testing has come under scrutiny, as has the certifying company, Verity Analytics, which has since had its license suspended. The recalled product was among many tested by Infinite Chemical Analysis last fall and found to contain pesticide levels above state limits, despite having been previously certified as safe by other labs. Infinite Chemical Analysis lodged a complaint with the state in November 2023, noting that the now-recalled product contained paclobutrazol (a plant growth retardant and fungicide) and trifloxystrobin (a fungicide), chemicals found at levels deemed unsafe by California standards. Paclobutrazol is associated with genetic mutation and reproductive toxicity, is very toxic to aquatic life, and is a potential endocrine disruptor. Trifloxystrobin is toxic and associated with negative reproductive, birth, and developmental effects, as well as kidney and liver damage.

A significant issue within the California cannabis industry is the integrity of laboratory testing and its impact on regulatory oversight. Infinite Chemical Analysis Labs and Anresco Laboratories, testing labs for the cannabis industry filed a lawsuit on June 26 against 13 other laboratories for issuing false certificates of analysis (COAs). According to the complaint, this practice, known as “lab shopping,” involves cannabis producers selecting laboratories that are willing to overlook regulatory compliance, including: “fraudulent testing practices at the heart of this complaint involve the deliberate manipulation of testing results …to hide dangerous contaminants in the products. This manipulation is not a result of mere negligence or error but is a calculated effort to misrepresent the actual makeup of cannabis products. Such practices are alarmingly widespread.”

Los Angeles Times and WeedWeek Investigation

To conduct the recent study, the Los Angeles Times and WeedWeek purchased cannabis products from licensed dispensaries across California, using two accredited labs—Anresco Laboratories and SC Labs—to screen the samples for over 100 pesticides, more than the 66 chemicals required by the state. Many samples were tested by both labs, with some undergoing repeat testing. In total, 66 tests were conducted across 42 products. Results from a state agriculture lab showed 16 additional pesticides present that the private labs were not equipped to measure, suggesting contamination may be even more widespread than uncovered

Out of 42 legal cannabis products tested, 25 show pesticide concentrations above allowed levels, and contaminants include chemicals linked to cancer, liver failure, thyroid disease, and neurological harm. Vapes from five well-known brands had pesticide levels exceeding federal thresholds for harm from a single exposure. Some products contained as many as two dozen different pesticides. The findings corroborate complaints filed by other private cannabis testing labs over the past eight months, suggesting contamination in over 250,000 vapes and pre-roll packages currently on store shelves. While most pesticides found were in low concentrations, some products had over 20 different pesticides; some levels exceeded the U.S. Environmental Protection Agency’s (EPA) threshold for human health risk from a single exposure. The investigation identified 45 toxic chemicals in the products tested, with 29 products exceeding either state limits for cannabis or federal tobacco standards.  

For example, chlorfenapyr—an insecticide not permitted on any food products or on California cannabis—was discovered at over two thousand times a base limit of .03 part per million used to calculate exceedances for pesticides prohibited upon detection. Pymetrozine—an insecticide prohibited in the European Union, Canada, and Norway as a known reproductive toxicant and carcinogen—was found at levels 762 times the reference base level. Notably, pymetrozine is not one of the 66 pesticides that undergo residue screening in California. In fact, ten of the 29 chemicals found to exceed the permitted limit are not included on California’s list of required testing, so even if testing is performed correctly, these chemicals would not be identified. As a result, these products would then pass the certification process.  

California Pesticide Residue Tolerances

California’s Department of Pesticide Regulation (CA DPR) website and regulations state a pesticide product can be used on cannabis only if its active ingredient is exempt from federal residue tolerance requirements and either exempt from federal registration requirements or registered for a use that is broad enough to include use on cannabis plants. However, California has acknowledged the reality of pesticide use on cannabis, including potential overspray from neighboring farms and contamination of ingredients in cannabis edibles. As a result, the state has imposed limits on some pesticide residues in cannabis products instead of outright bans. As mentioned above, California has developed a list of 66 pesticides for screening by state-certified third-party labs. Twenty-one are Category I pesticides, banned for cannabis use due to their significant risks. Any detection of these results in a failed test. The other 45 are Category II pesticides, with specific action levels for ingestible and inhalable products. Growers can use these under certain conditions if residue levels remain below the prescribed limits. For example, bifenthrin, a possible human carcinogen, and acephate, which is neurotoxic and a potential endocrine disruptor, are allowed with controlled residue limits.

State toxicologists used pesticide reference doses from EPA for ingestible products, ensuring limits account for potential contamination of all ingredients. For inhalable products, due to a lack of toxicity data, CA DPR used values from the French agency CORESTA (Centre de Coopération pour les Recherches Scientifiques Relatives au Tabac). These levels do not incorporate toxicological considerations, as there are no specific data for smoked or vaped cannabis. As Beyond Pesticides executive director Jay Feldman noted in the 2019 article, ‘Into the Weeds: Regulating Pesticides in Cannabis,’ CA DPR “is establishing a false sense of security regarding the allowed residues, given that they have not looked at the aggregate cumulative risk of dietary and nondietary exposure in combination with cannabis residue,” he says. “If [the DPR] does not have this kind of data… then it should use its statutory authority to embrace a precautionary approach,” Mr. Feldman says.

A genuinely precautionary approach would go well beyond catching prohibited pesticides and other contaminants in cannabis, as Beyond Pesticides’ 2018 ‘Pushing for Organic Cannabis as the Industry Grows,’ argues. Since the federal government classifies cannabis as a Schedule 1 narcotic, and cannabis is not a legal agricultural crop under relevant federal law—the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—EPA has not evaluated the safety of any pesticide on cannabis plants. EPA has established no allowances for pesticide use in cannabis production, and no tolerances, nor any exemptions from tolerances, for pesticide residues on cannabis. The lack of a federal role in establishing which pesticides are allowed for use in the plant’s production raises critical concerns related to (i) exposure from inhalation, ingestion, or absorption of pesticide residues on the crop; (ii) exposure to workers cultivating the plant; and (iii) environmental contamination and wildlife effects.  

The illegal federal status of cannabis and, therefore, the inability of EPA to register pesticides for use in cannabis production, offers a window for state regulators to force the industry to embrace an organic approach to cannabis cultivation, including prohibiting synthetic pesticides and fertilizers. Beyond Pesticides has maintained that pesticide use on cannabis is therefore illegal and the best regulatory solution for states is to require the cannabis industry to adhere to an organic systems approach used in certified organic agriculture, which also prohibits synthetic pesticides and fertilizers. 

Health Risks

With an estimated five million Californians consuming cannabis products monthly, the potential health consequences are staggering. Medical users seeking relief from health conditions are at increased risk of harm from pesticide contaminants. Additionally, cannabinoids (active compounds in cannabis) have been shown to inhibit the activity of cytochrome P450 enzymes, which can make exposure to pesticides more toxic. In other words, pesticide contamination of cannabis can interfere with the detoxification of those pesticides, as well as pharmaceuticals (important for those undergoing medical treatment). Among the pesticides detoxified by cytochrome P450 enzymes are pyrethroids, organophosphates, and carbamates.

Organophosphates can combine with cannabinoids to pose developmental risks to offspring. Even at low concentrations, through repeated use pesticides can cause long-term harm, including neurological damage, an increased risk of Parkinson’s disease, thyroid and liver cancers, heart failure, endocrine disruption, reproductive harm, and birth defects and developmental delays in offspring. 

The Problem with Vapes

Young adults, who make up the largest market segment and often view vaping as a “healthier” alternative, face long-term health concerns from contaminated products. Pesticides in cannabis pose unique risks compared to other products because smoking and vaping deliver chemicals directly to the lungs, bloodstream, and brain. Up to 82% of pesticides in cannabis end up as smoke inhaled into the lungs. Some pesticides break down into toxic gasses like hydrogen cyanide when heated. Some of the most highly contaminated products include vape pens.

The exploding vape market has created a high demand for low-quality “biomass” to produce distillate, much of it contaminated with pesticides. Oils are often made from stems and leaves left after harvest, parts of the plant where pesticides can concentrate upon absorption from the environment. In addition, manufacturers dilute contaminated oils to meet state screening limits. Yet, one vape oil was found to have more than 60 times the amount allowed in cigarettes. Additionally, the state does not require testing for other toxic pesticides like pymetrozine or illegally used Chinese pesticides, so the product can pass the state certification tests and still be dangerously contaminated.

Vapes also have caused deaths and illness due to ‘e-cigarette, or vaping, product use-associated lung injury’ (EVALI). The Centers for Disease Control and Prevention (CDC), the U.S. Food and Drug Administration (FDA), state and local public health departments continue to be vigilant and CDC reported a total of 2,807 hospitalized EVALI cases or deaths reported nationally in February 2020. Laboratory data show that vitamin E acetate, an additive in some THC-containing e-cigarette, or vaping, products, is strongly linked to the EVALI outbreak.

However, as Beyond Pesticides reported in 2019, solvent vitamin E acetate is not the only source of harm. Many unregulated vaping products tested in an NBC news investigation contained the fungicide myclobutanil. Heating myclobutanil can cause it to break down into harmful products, including hydrogen cyanide – a known potent carcinogen. Other pesticides detected included mixtures of the following pesticide or pesticide formula ingredients: fipronil, piperonyl butoxide, permethrin, malathion, and others (see full test results here).

Chinese Pesticides and Regulatory Failures

The presence of so many toxic chemicals is no surprise given the recent findings of illegal Chinese pesticides at various grow operations—both legal and illegal—around the state. The Los Angeles Times found that over the last three years, the use of illegal Chinese pesticides has exploded in California. Some of the chemicals found in these pesticides are otherwise unknown in California and the state’s labs lack the proper equipment to test for them. Moreover, many of these chemicals are so toxic that a single exposure could be fatal. Law enforcement agencies at both the state and local levels have started requiring their officers to wear personal protective gear when working in these locations and to undergo routine blood analysis for pesticides. However, the state has not extended the same level of warnings and protection to the public.

According to the Los Angeles Times report, ‘The dirty secret of California’s legal weed’, California regulators have largely failed to address evidence of widespread contamination, including at least 85 complaints from private labs. The state’s pesticide testing requirements have not been updated since 2018, despite repeated requests from toxicologists. Regulators are not testing for many dangerous chemicals currently used in cultivation, including some that must be smuggled in because they are illegal in the United States. For example, in the case of Chinese pesticides, only six of over 20 chemicals found in those products are required to be screened. 

Contrary to best practices, there is no routine testing of products on store shelves. The state lacks a lab accredited to test for pesticides, leaving oversight largely to private labs financially tied to the companies they test. Legislation to require independent checks on testing accuracy has stalled in Sacramento for two years. In addition, when alerted to contamination by private labs, regulators were slow to act. It took 41 days to announce the state’s first-ever pesticide recall after receiving a complaint. Including last week’s recall of one vape product, there have been three pesticide-related recalls issued since recreational sales began in 2018. Many flagged products were left to sell out rather than being pulled from shelves.

Recently, California DCC put the industry on notice about its intention to step up testing and enforcement, explaining that the agency will use both voluntary and mandatory recalls when a product is “product is mislabeled, defective, or unsafe for consumption,” or “there is an immediate and serious threat to human life or health, and other remedies would cause an unreasonable delay.” DCC also warned of the potential for disciplinary actions against licensees. However, it is unclear if these actions will be effective. Advocates note that consumers remain at risk as regulatory and market failures continue.   

Market Pressures Leave Cannabis Consumers Exposed to Pesticide Contamination

Arriving full circle, Infinite Chemical Analysis Labs’ and Anresco Laboratories’ lawsuit charges deliberate manipulation of testing results. Such practices are alarmingly widespread and highlight a significant failure in regulatory oversight, which has been insufficient in deterring or detecting these fraudulent activities. The alleged fraudulent testing practices involve not only inflating THC potency but also concealing the presence of dangerous contaminants, which should render the products unsellable.

Moreover, the lawsuit points out that the labels displaying the defendants’ test results are misleading to consumers, who rely on these labels to make informed decisions. These labels claim compliance with DCC regulations and assure consumers that the THC content is within a 10% margin of what is stated. However, the reality is often a stark contrast, as the lawsuit documents.

Response and Calls for Reform

Cannabis companies whose products were found to be contaminated in the study offered various responses but primarily claimed to have no knowledge of how the contamination occurred or why it was not uncovered during testing. Some claimed to adhere to all state standards and limits. However, many dispensary owners and consumers are unaware of the contamination risks, believing that any product with a certificate of analysis is safe. The state has even launched a $5 million taxpayer-funded campaign promoting legal cannabis as tested and regulated to protect consumers.

Cannabis researchers, toxicologists, and industry veterans are calling for stronger oversight and updated regulations. Among their recommendations are expanding the list of prohibited pesticides to include chemicals currently used in cultivation and implementing routine testing of products on store shelves. In particular, safety advocates say that the state must take a more active role in monitoring weed cultivation, preparation, and sale including establishing an independent state lab to verify test results, investigating the sources of contamination, and collecting data on health impacts experienced by cannabis users.

Beyond Pesticides has advocated that states establish laws and/or regulations mandating an organic systems approach to cannabis production, a genuinely precautionary approach, even more critical as the Los Angeles Times report reveals.  Detecting and regulating prohibited pesticide contaminants in cannabis is not protecting consumers (0r cannabis workers, another important issue).  Instead, a framework mandating an organic systems approach to cannabis production—for example, a requirement that growers and processors follow the dictates of national organic soil management standards—would be prudent, precautionary, and a positive trajectory for the cannabis industry.

To learn more about the impacts of pesticide residues in marijuana products on your health, see our reports: Pushing for Organic Cannabis as Industry Grows and Pesticide Use in Marijuana Protection: Safety Issues and Sustainable Options. If you are concerned that you or a loved one was exposed to pesticides, see Pesticide Emergencies. Click to learn more about the impacts of herbicide, insecticide, rodenticide, or fungicide exposure on your health.

For additional information on crop production, see please Beyond Pesticides’ organic agriculture webpage. To get involved and ensure that organic standards comply with the principles, values, and letter of the Organic Foods Production Act, please see Keeping Organic Strong (KOS). Through KOS, Beyond Pesticides makes it easy for the public to comment on critical issues before the National Organic Standards Board and the National Organic Program, under the U.S. Department of Agriculture.

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

Sources:

How dirty is your weed? A joint investigation finds high levels of pesticides in products, Los Angeles Times, WeedWeek, June 14, 2024

Lawsuit Infinate Chemical Analysis Labs v. Pride Analytics and Consulting, LLC and 2 River Labs, Case No. 2:24-cv-5311, U.S. District Court Central District of California

California recalls cannabis vape many months after it was told of contamination, Los Angeles Times, June 26, 2024

California’s Cannabis Industry Faces Toxic Threat from Illegal Chinese Pesticides, Siskiyou News, June 23, 2024  

A new threat to cannabis users: Smuggled Chinese pesticides, Los Angeles Times, June 13, 2024

Pushing for Organic Cannabis as Industry Grows, Beyond Pesticides 

Pesticide Use in Marijuana Production: Safety Issues and Sustainable Options, Beyond Pesticides

Into the Weeds: Regulating Pesticides in Cannabis, Environmental Health Perspectives, April 25, 2019

(Beyond Pesticides, July 8, 2024) Please submit comments by Wednesday, July 31, 2024. Acephate, an insecticide and member of the highly toxic organophosphate (OP) family, is so toxic that EPA is proposing to ban all uses except the systemic injection into trees. A comment period is open, and EPA is accepting comments through Wednesday, July 31, after extending the earlier July deadline. With this remaining use, EPA is still not recognizing that systemic neonicotinoid pesticides can cause serious environmental harm to the ecosystem through indiscriminate poisoning of organisms.

>> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically. 

EPA proposes to cancel all uses of acephate other than tree injection to eliminate all risks of concern it has identified that exceed its level of concern for dietary/drinking water risk, residential and occupational risks, and risks to non-target organisms. As Beyond Pesticides points out, although the tree injection method does not pose excessive dietary or aggregate health risk and does not pose any untoward occupational or post-application human health risks of concern, there are significant ecological risks posed that the agency has neglected. Rather than assessing the ecological risks of tree injection uses, the agency assumes that the use does not pose significant risk to nontarget organisms. On the contrary, the tree injection uses do pose serious risks to pollinator and certain bird species that cannot be mitigated and should therefore be included in the acephate cancellations.

In tree injection, the pesticide is injected directly into a tree trunk where it is taken up quickly by the vascular system and distributed. Because acephate and its degradate methamidophos are very soluble and systemic insecticides, the chemical is transported to all parts of the tree—including pollen, sap, resin, leaves, etc. Honey bees and certain bird species such as hummingbirds, woodpeckers, sapsuckers, tree creepers, nuthatches, chickadees, etc. can be exposed to residues within acephate-injected trees. Honey bees are exposed not only by collecting contaminated pollen, but more so from collecting sap and resins used for producing hive-important propolis. Similarly, birds are exposed to toxic acephate/methamidophos residues when feeding on contaminated tree sap, wood-boring insects/larvae, and leaf-chewing insects/larvae. 

Although it has limited data, EPA has determined that acephate uses may present risks of concern to honey bees. However, the full suite of pollinator studies has not yet been submitted for acephate or methamidophos; therefore, no adult acute oral, chronic toxicity data or larval toxicity data are available for honey bees. These data gaps represent significant uncertainties for the assessment of the impact of acephate on pollinators as sensitivity may vary according to life stage and length of exposure (adult vs. larval and acute vs. chronic, respectively). Adverse incidents with probable and highly probable causality, including bee kills, have been associated with acephate and/or methamidophos exposure to honey bees. It is reasonable to presume that tree injection application of acephate does not attenuate the risk to honey bees compared to foliar treatment and, given the higher dosage per tree from injection, may actually increase exposure and therefore toxic risk. The agency proposes a pollinator hazard statement for the tree injection uses stating, “This product is highly toxic to bees.” This label statement is totally insufficient to protect bees and other organisms or to communicate the seriousness of the risk. 

The risks of acephate use and the tree injection method specifically have not yet been fully evaluated for threatened and endangered species. EPA must complete its listed species assessment and any necessary consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service before completing the acephate registration review, paying careful attention to listed avian and insect species using trees subject to injection use for feeding, forage, and nesting. 

The agency completed a weight-of-evidence endocrine disruptor analysis for acephate in 2015, which concluded that no further data to assess the potential for impacts on the estrogen, androgen, or thyroid pathways are needed for humans or wildlife. However, more recent information suggests the endocrine disrupting potential for acephate and its degradate methamidophos through non-receptor-mediated pathways may be of concern, so EPA should update its assessment on the endocrine disruption risks for acephate. 

Moreover, EPA concludes in its benefits assessment that the tree injection use of acephate generally provides low pest management benefits because several effective alternatives are available for most insect pests. Therefore, from a risk-benefit standpoint the high risk to bees and birds from acephate tree injection treatments are unreasonable.

> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically.

Despite prioritizing review of OP pesticides, EPA has failed to take action to protect those most exposed and most vulnerable to their neurotoxic effects—farmworkers and children. In 2021, Earthjustice and others petitioned EPA to cancel the registrations of these highly neurotoxic pesticides. This spring, Consumer Reports’ (CR) most comprehensive investigation ever of pesticides in produce found that exposure to two broad classes of chemicals—organophosphates and carbamates—are the most hazardous, linked to an increased risk of cancer, diabetes and cardiovascular disease. Based on those findings, CR petitioned EPA to “ban these classes of pesticides from use on fruit and vegetables.” 

In addition to the issues identified above, EPA fails to consider endocrine disruption. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife.  

Notably, USDA certified organic food products are not permitted to be produced with toxic pesticides. Pesticide residues found in organic products, with rare exception, are a result of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. Not only is the production of organic food better for human health and the environment than chemical-intensive production, but emerging science reveals also what organic advocates have been saying for a long time—in addition to lacking the toxic residues of conventional foods, organic food is more nutritious and it does not poison the people and contaminate the communities where the food is grown. 

A study published by The Organic Center reveals that organic food is higher in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally beneficial. Another study published in the Journal of Agricultural Food Chemistry looks specifically at the total phenolic content of marionberries, strawberries, and corn, and found that organically grown products contain higher total phenolics. Phenolics are important for plant health (defense against insects and diseases), and human health for their “potent antioxidant activity and wide range of pharmacologic properties, including anticancer, antioxidant, and platelet aggregation inhibition activity.”   

In view of the advantages of organic production, EPA must use organic production as the yardstick when weighing risks and benefits of pesticides. No pesticide should be allowed to be used if the crop can be produced organically. 

>> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically.

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

(Beyond Pesticides, July 5, 2024) After years of advocacy against corporate interference in global pesticide policy, the United Nations Food & Agriculture Organization (FAO) has ended its “strategic partnership” with petrochemical pesticide and fertilizer trade association CropLife International. This decision, which allows the expiration of a 2020 Letter of Intent (LoI), was announced in a June press release by a coalition of international public interest, environmental, and trade groups. The organizations objected to the partnership from the inception of the agreement and has issued objections, including in 2022 and covered by Daily News. The signatories to the release last month believe that this severing of ties with the chemical industry will contribute to building momentum from frontline communities for “sustainable, resilient and equitable production systems under the agroecological paradigm.” The groups say, however, “We remain concerned about the FAO’s continuing informal engagements with CropLife and call for greater transparency and accountability in this regard.”

Beyond Pesticides has urged that models for change, whether advanced by FAO or other international or national institutions, must embrace clear definitions and standards that are certified and enforceable in order to reverse the existential threats to health, biodiversity, and climate from petrochemical pesticides and fertilizers. In this context, the organization advocates the adoption of certified organic practices that eliminate immediately petrochemical pesticides and fertilizers. FAO’s formal severing of ties with the petrochemical industry signals to farmers, farmworkers, pesticide applicators, and the public that the status quo is unsustainable amidst cascading crises of public health fragility, biodiversity collapse, and climate emergency. Consider writing to USDA and the U.S. Congress calling for an organic national land management plan.

Groups that signed onto this statement represent Indigenous communities and organizations’ fighting against the status quo of reliance on petrochemical pesticides and fertilizers, including the Alliance for Food Sovereignty in Africa (AFSA), Center for International Environmental Law (CIEL), FIAN International, Friends of the Earth International, Institute for Agriculture and Trade Policy (IATP), International Indian Treaty Council (IITC), International Pollutants Elimination Network (IPEN), International Union of Food, Agricultural, Hotel, Restaurant, Catering, Pesticide Action Network (PAN) International, Tobacco and Allied Workers’ Associations (IUF). Public Eye, and Third World Network.

“On 15 May 2024, PAN International received written confirmation from FAO Deputy Director-General Beth Bechdol that the LoI between FAO and CropLife International signed on 2 October 2020 came to an end almost exactly three years after its agreement,” the press release says. “We have been informed that the FAO concluded its LoI with CropLife on 3 October 2023 in line with a review of all LoIs entered into prior to the development of FAO’s Strategy for Private Sector Engagement (2021-25) and the related new due diligence framework.” Advocates caution that FAO’s relationship with the pesticide industry may not be over, given that FAO officials did not elaborate on future parameters for potential informal relationships with CropLife. FAO’s decision to develop more safeguards against corporate interference aligns with their commitments to the newly adopted Global Framework on Chemicals in September 2023 at the Fifth International Conference on Chemicals Management in Bonn, Germany—in coordination with UN Environmental Program and World Health Organization—through the Global Alliance on Highly Hazardous Pesticides (HHPs). Organic farmers and public interest advocates alike believe that this Framework is a welcome step in the right direction, and that there are opportunities to develop stricter targets for 2030 and beyond.

This important announcement builds on years of advocacy and campaigning through the Stop FAO-CropLife #ToxicAlliance campaign. According to a 2021 letter directed to FAO Director-General Qu Dongyu—who originally signed the 2020 LoI with CropLife International President and CEO Giulia Di Tommaso—200,000 individuals from over 107 countries, over 430 civil society and Indigenous Peoples’ organizations (including Beyond Pesticides), nearly 300 academics and scientists, and nearly 50 philanthropic groups, as well as the Special Rapporteur on the Right to Food, raised concerns in a report addressed to 49th session of the UN Human Rights Council. This coordinated effort was partially successful in that it prevented the LoI from moving forward into a more formal Memorandum of Understanding in 2022, however the agreement remained in place without a set expiration date (until October 2023), which would have continued to undermine the agency’s support for alternatives to generate agroecological systems without toxic pesticides. Throughout FAO’s agreement with industry, PAN International and the coalition partners remained resolute in calling for an end to this partnership. Letters on the subject were sent to Director-General Qu Dongyu on November 2020, February 2021, June 2022, and November 2022.

CropLife International (CLI) consists of 11 subsidiary national associations and six member companies (BASF, Bayer, Corteva, FMC, Sumitomo Chemical, and Syngenta). As an international trade association for the petrochemical pesticide and fertilizer industries, CLI has a vested interest in maintaining the status quo argument that pesticides are fundamentally necessary for global and national food security. While claiming to champion the role of agricultural innovation in crop protection to advance sustainable agriculture, instead, the pesticide industry is leveraging “agricultural innovation and digital technology” to expand market opportunities and increase their profits in the Global South. While CLI has not made any direct financial contributions to FAO since 2011, private sector investments are actively being brokered through the FAO’s Hand-In-Hand Initiative; for example, in October 2020, the Director General actively appealed to CropLife for investments in low and middle-income countries in his speech to the CLI Board of Directors. 

There is longstanding evidence of pesticide manufacturers influencing pesticide regulation in the United States, European Union, Thailand, Mexico, and Sri Lanka, among other nations. A 2022 briefing by PAN titled, Addressing the Conflict of Interest and Incompatibility of FAO’s Partnership with CropLife International, are various instances of this interference:

• “Bayer played a key role in Thailand’s decision to overturn its ban on the cancer-causing glyphosate. Communications between U.S. government officials and Thailand were largely scripted and pushed by Bayer, which lobbied support from USDA [U.S. Department of Agriculture], warning of trade impacts to U.S. commodity exports.
• Syngenta consistently refused to modify its deadly weedkiller formula of paraquat, claiming it was safe. It manipulated scientific data to circumvent a ban and keep paraquat on the market for 40 years. As a result, hundreds of people, especially in rural communities in the Global South, continue to use it and die from paraquat poisoning.
• Bayer exerted enormous pressure against Mexico upon the Presidential decree to phase out glyphosate and GMOs. CropLife lobbied the USTR [U.S. Trade Representative] and U.S. EPA [Environmental Protection Agency] which then took up industry’s concerns against Mexico to pressure them to drop the ban.”

The third point is particularly relevant given Mexico’s sudden and indefinite pause of the glyphosate ban that was slated to go into effect on April 1, 2024. This change in national policy comes as the USTR submitted a formal complaint to the United States-Mexico-Canada Agreement (USMCA) regarding Mexico’s policy of import bans on genetically engineered (GE) corn for human consumption that went into effect earlier in the President Andrés Manuel López Obrador (AMLO) administration.

See Action of The Week to call on U.S. Secretary of State Anthony Blinken and U.S. Trade Representative Katherine Thai to end its opposition to Mexico’s GE corn import ban. With the recent election of Claudia Sheinbaum, PhD, climate scientist and former mayor of Mexico City, to the presidency, advocates are optimistic and eager to see the makeup of the impending administration—particularly the Ministers of Agriculture, Environment, and Health—as these appointed cabinet members will decide the course of future policy regarding toxic pesticide use and GE commodities in Mexico through 2030.

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

Source: PAN International

(Beyond Pesticides, July 4, 2024) In reflecting on recent U.S. Supreme Court decisions that reduce federal government powers to restrict hazardous chemicals, including pesticides (see Clean Water Act decision and federal restrictions of toxic hazards under the reversal of Chevron decision), two remaining authorities in state and local governments and in the courts have become the next battleground to protect health and the environment. What is at stake are two major backstops to weak federal controls and chemical company disregard for safety: the critical importance of state and local governments’ exercise of authority to restrict toxic chemicals, and the ability of people to sue corporations for their failure to warn about their products’ hazards. 

The attack on state and local authority in the Farm Bill

The Farm Bill in the U.S. House of Representatives:

Prohibits the rights of states and local governments to restrict pesticides and protect public health and the environment. The language says the Farm Bill will “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).

In addition, the language includes: “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 Daily News for further analysis.) 

The attack on the right to sue companies that fail to warn on the hazards of their products

The Farm Bill in the U.S. House of Representatives: 

Takes away the right to sue for failure to warn when harmed by pesticides. The language states that this bill will “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.” (SEC. 10204. UNIFORMITY OF PESTICIDE LABELING REQUIREMENTS).

This language shields (gives immunity to) the producers and users of toxic pesticides from liability lawsuits associated with the harm that their products cause. The provision will block lawsuits like those successfully advanced against Bayer/Monsanto for adverse health effects, including cancer, associated with exposure to their products and companies’ failure to warn about these effects on product labels approved by the U.S. Environmental Agency (EPA). 

If you have not already, TAKE ACTION to protect the backstop of state/local democratic authority to restrict toxic chemicals and the right to sue chemical companies for their failure to warn the public about their products’ hazards. 

Here is what the Supreme Court did to limit the ability of the federal government to restrict pesticides and protect health and the environment. 

The U.S. Supreme Court decision on June 28 reverses a 40-year-old decision in Chevron v. Natural Resources Defense Council, which created a deference to federal agencies in the rulemaking process. In the dissent to this 6-3 decision of the court, the dissenters focus on the role of executive branch agencies: “Congress has conferred on that expert, experienced, and politically accountable agency the authority to administer—to make rules about and otherwise implement—the statute giving rise to the ambiguity or gap.” Agencies, the dissenters say, are intended to have “subject-matter expertise.” 

The court majority finds that Chevron conflicts with the Administrative Practices Act (APA), saying, “Chevron defies the command of the APA that ‘the reviewing court’—not the agency whose action it reviews—is to ‘decide all relevant questions of law’ and ‘interpret . . . statutory provisions.’” The dissent continues: “In recent years, this Court has too often taken for itself decision-making authority Congress assigned to agencies. The Court has substituted its own judgment on workplace health for that of the Occupational Safety and Health Administration; its own judgment on climate change for that of the Environmental Protection Agency; and its own judgment on student loans for that of the Department of Education.” The dissent sees the decision of the court’s majority as turning the judicial institution into the “country’s administrative czar,” and violating the court’s key principle of stare decisis, which establishes precedent as requiring an extraordinary set of circumstances to reverse—a tenet this Supreme Court has appeared comfortable in rejecting, including in Dobbs v. Jackson Women’s Health Organization (2022) and in reversing the court’s 1973 decision in Roe v. Wade. 

The expectation going forward is that the chemical industry will challenge EPA as relying on a “statutory ambiguity,” or the discretionary authority given to it by Congress. Whether affected parties or public interest organizations concur with their decisions, agencies are supposed to have the expertise to implement laws and bring the facts to the rulemaking process. But, of course, there are facts and there are “alternative facts.” And, in the realm of pesticide regulation, many times it is the lack of facts, data gaps, uncertainties, and limited reviews that support regulations that are not adequately protective—even though much data in the scientific literature suggests there is more science than is being considered by the regulators (e.g., endocrine disruption, pollinators, disproportionate harm and vulnerable population groups, comprehensive ecosystem effects, etc.). The fact is that there has been a swing from the Reagan to Biden Administrations, with conservatives and chemical company interests embracing the Chevron decision and then rejecting Chevron, as agencies took stronger positions on climate and environmental justice, along with others (even though many environmental and public health groups see them as inadequate to meet current existential threats). 

This Independence Day, make your voice heard with your elected representatives by (1) urging them to protect principles of democratic decision making that protect health and the environment, and (2) engage with local decisions that restrict pesticides in your community. Join Beyond Pesticides’ Parks for a Sustainable Future program through which we will assist you and your community in the transition to organic land management.  

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

(Beyond Pesticides, July 3, 2024) In June, the Vermont legislature officially passed H.706 into law – a bill that narrows and reduces the use of neonicotinoid insecticides and neonicotinoid-treated seeds. The legislature came together to override a veto of the bill issued by Governor Phil Scott (R). Gov. Scott said the bill’s language had “the potential to produce severe unintended environmental and economic consequences–—particularly for Vermont’s dairy farmers.” The advocacy in support of the legislation called for a holistic, systems change approach to legislative priorities that considers economic, ecological, public health, and climate resilience. The Vermont legislation builds on New York legislation, which in turn is inspired by Quebec’s “verification of need” prescription model (a.k.a. emergency exemptions) that has proven to dramatically reduce the use of certain neonicotinoids, yet enables the continued use of toxic pesticides and a legacy of pesticide dependency in land management and crop production.

Vermont Bill Building on New York

The Vermont Bill (See pages 29 to 44 for final text) mirrors the language of New York’s Birds and Bees Protection Act (S. 1856-A and A. 7640) and adopts New York’s language on timing regarding when critical sections go into effect. The Vermont language contains trigger language that relies on the New York law. “States will frame legislation this way to avoid the perception that the bill will cause economic disadvantage to their markets, and accompanying political fallout, relative to neighboring states,” says Max Sano, organic program associate at Beyond Pesticides. The trigger language reads as follows:

“Sec. 4 (prohibited use; neonicotinoid pesticides) shall take effect on July 1, 2025, provided that the prohibition on the use of neonicotinoid pesticides on ornamental plants in New York under N.Y. Environmental Conservation Law § 33-1301(13)(a) is in effect on July 1, 2025. If N.Y. Environmental Conservation Law § 33-1301(13)(a) is not in effect on July 1, 2025, Sec. 4 of this act shall not take effect until the effective date of N.Y. Environmental Conservation Law § 33-1301(13)(a).”

Vermont’s prohibition of neonic pesticides goes into effect July 1, 2025 if New York’s “prohibition on the use of neonicotinoid pesticides on ornamental plants” goes into effect as of the same date; if it does not go into effect, Vermont will have to wait for NY regulators to approve their rules (NY Environmental Conservation Law § 37-1101). The same is true on the matter of neonic treated seeds. VT’s treated seed provision goes into effect on January 1, 2029, as long as NY has implemented its identical provision by this date; otherwise, VT will wait for NY. (See page 43, Sec. 8. CONTINGENT REPEAL)

Given that Vermont’s deadline for proposed rules was due for review in the state legislature by July 1, 2024 (See pages 42-43, Sec. 4. IMPLEMENTATION; REPORT; RULEMAKING), there are still major questions regarding best management practices for how this regulation applies to the use of treated seeds before January 1, 2023, neonic pesticide use through written exemption under sections 1105b and 1105c, and agricultural use restrictions for neonic pesticides after July 1, 2025 that go into effect (see pages 40-41, Sec. 6. 6 V.S.A. § 1105a(c)) only if regulators make the following findings through rulemaking:

1. establishment of threshold levels of pest pressures required prior to use of neonicotinoid treated article seeds or neonicotinoid pesticides;
2. availability of untreated seeds that are not neonicotinoid treated seeds;
3. economic impact assessment of crop loss under the policy compared to crop yield when neonicotinoid treated article seeds or neonicotinoid pesticides are used;
4. relative toxicities of different neonicotinoid treated seeds or neonicotinoid pesticides and the effects of neonicotinoid treated seeds or neonicotinoid pesticides on human health and the environment;
5. surveillance and monitoring techniques for in-field pest pressures;
6. ways to reduce pest harborage from conservation tillage practices; and
7. criteria for a system of approval of neonicotinoid treated article seeds or neonicotinoid pesticides.

Advocates are concerned about the lack of definition for “environmental emergency” and “agricultural emergency,” not to mention the regulatory deference given to the New York Commissioner of Agriculture, Food and Markets in authorizing exemptions—an environmental concern given the influence of the pesticide industry and their allies.

Despite these issues, the New York bill has been lauded by some as model law for other states on the East Coast and across the nation. Beginning on January 1, 2027, New York will join Nevada, New Jersey, and Maine with the most stringent state laws that eliminate all nonagricultural outdoor uses of neonics, except for outdoor uses around structures. In a previous Daily News, Beyond Pesticides analyzed the benefits and pitfalls of legislation that defers to regulatory discretion on rulemaking given the degree to which New York Farm Bureau and other pesticide allies lobbied New York Governor Kathy Hochul, even after legislature passed the bill before Christmas.

In what environmental advocates describe as an undemocratic maneuver, the bill was amended through a “chapter amendment” process in which legislation can be changed without public debate if the leaders of the legislature agree with the governor’s changes to avoid a veto. In the case of S. 1856-A and A. 7640, the governor removed what would have been major legislative advances and crafted a negotiation process for determining the status of coated seed use that runs through 2029. [Note: The alterations can be seen in the linked  line-edited version of the new law—green text is law and red text is the originally enacted legislation.]

As more states in the northeast region of the U.S. and beyond look to states like New York for guidance, and if they follow the Vermont model of deferring to New York (which, at least in the case of this bill, capitulated to pesticide lobbyists and allies in amending the legislative text itself), Beyond Pesticides is advocating that new legislation calls for the replacement of neonic insecticides and all toxic petrochemical pesticides with organic land management systems, including organic compatible inputs.

Quebec, Canada Model

Quebec originally passed restrictions on certain treated seeds back in 2019, with the requirement that farmers must receive written permission from a certified agronomist (“verification of need” model) on the following pesticides: atrazine, chlorpyrifos, and three neonicotinoids (clothianidin, imidacloprid, and thiamethoxam). In delivering testimony in support of NY’s Birds and Bees Protection Act, Louis Robert, retired agronomist who worked for the Quebec Agriculture Ministry, and Genevieve Labrie, PhD, researcher at Mirabel Agri-Food Research Center, pointed to findings in a 2022 report, “Summary of pesticide sales in Quebec,” which concluded that: “Whereas nearly 100% of corn grown in Québec was grown with neonic-treated seeds prior to 2019, today, less than 0.5% is grown from neonic-treated seed. After neonic seed treatments disappeared, crop yields remained constant, and no crop failures have been attributed to the lack of neonic-treated seeds.” It is important to note that there has been an increase in the use of diamides class of insecticides (cyantraniliprole and chlorantraniliprole), in which at least 60% of Quebec corn fields used these pesticides in 2021. However, Mr. Robert says, “[T]his still marks a considerable decrease in the total use of insecticide-treated seeds from the period before the neonicotinoid restrictions took effect.”

It is unclear to what degree this policy has contributed to the expansion of biologique (organic) agriculture in Quebec since it was originally passed, but there are some interesting indicators that suggest a possible correlation. According to a report by Organic Biz, Quebec increased its organic acreage by 65% between 2017 and 2019 based on Canada’s 2021 Census of Agriculture. From 2020 to 2021, Quebec had a 16% gain in total organic producers according to the same 2021 census. Additionally, in a 2021-2025 implementation report for Quebec’s 2020-2030 Sustainable Agriculture Plan, Quebec Organic Grain Producers Union (SPGBQ) indicated that they are on track for a 2025 target of having “at least 60% of the 600 organic production companies…adopt[ing] practices recognized as the most beneficial for soil health and conservation.” In kind, Quebec Organic Milk Producers’ Union (SPLBQ) is on track to “disseminate technical sheets to 80% of traditional companies by 2025” to “[d]evelop tools on buffer zones in organic agriculture as a way to reduce the use of pesticides and improve biodiversity.”

What Now?

Environmental and public health advocates continue to call for a wholesale agricultural transition to organic standards and the National List of Allowed and Prohibited rather than substitution models that rely on state regulators who have a history of bending to pesticide industry influence. See Keeping Organic Strong to learn about the environmental justice, public health, and ecological benefits of organic agriculture and how to engage in strengthening organic standards. See Parks for a Sustainable Future and consider subscribing to Action of The Week to stay informed of opportunities to engage on future policy on neonic insecticides and expanding organic land management principles.

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

Source: NRDC

(Beyond Pesticides, July 2, 2024) Men’s Mental Health Awareness Month, which took place last month, evokes concern about the growing body of science linking pesticide exposure to neurological effects linked to depression. Recent studies reveal elevated rates of psychiatric disorders, including suicide, among farmers, with problems more common for males. 

Through systematic reviews, meta-analyses, surveys and interviews, and blood sampling, these three studies add to the growing body of science linking pesticide exposure to neurological impacts. First, in the Journal of Agromedicine, researchers from Greece and the United Kingdom review eight studies and find a significant positive association between pesticide poisoning and depression in agricultural populations.¹ Second, a study in Toxicology shows a link between depression in Brazilian farmers and pesticide exposure, most notably with glyphosate usage.² Third, the latest study in Environmental Toxicology and Pharmacology focuses on work by researchers from Spain in identifying farmers exposed to chlorpyrifos, mancozeb, and malathion that have higher rates of depressive symptoms and suicide attempts.³ 

Through a meta-analysis of published research, the authors of the Agromedicine journal article identify pesticide poisoning as a risk factor of depression. With depression affecting more than 264 million individuals worldwide, this is a field of interest with increasing importance. The authors conclude that “farm workers represent a high-risk population for the development of depression.”¹ The studies they analyze are throughout the United States, Korea, United Kingdom, and France with a focus on acute effects. While previous “epidemiological studies have reported higher prevalence of depression in particular occupational groups of individuals,” such as farmers, this review “confirmed a positive association between both pesticide exposure and pesticide poisoning and depression… [with] male agricultural workers [having] the highest incidence of depression compared to non-agricultural workers.”¹      

Depression can have harmful effects on physical, mental, and cognitive functioning and increases suicidal risk. As the researchers state, “Disturbances in neurotransmitter functioning and genetic factors have been implicated in the etiology of anxiety disorders and depression.”¹ They continue, saying, “High level acute poisoning involves inhibition of the enzyme acetylcholinesterase (AChE), causing neurotoxic effects and disturbances in peripheral, autonomic and central nervous system function (the cholinergic crisis) and resulting in a constellation of physical, cognitive, and psychiatric symptoms. AChE is used as a biomarker for exposure to organophosphates (OPs). Many neurotransmitters, few of which are responsible for mood regulation such as serotonin, are disrupted by OPs, which indicates the link between pesticide exposure and mood disorder, becoming in fact stronger in cases of acute poisoning.”¹  

The researchers of the study in Toxicology link occupational pesticide exposure to depression among rural workers from Maravilha, Brazil by assessing “the mental health, oxidative, and inflammatory profiles of farmers exposed to pesticides and compared them to an urban control group without occupational exposure to pesticides.”² This was performed through blood sampling and interviews with over 50 survey participants. 

The rates of mental disorders are higher in Brazil than the world average, “with an estimated 5.8% of the population diagnosed with depression and 9.3% with anxiety disorders, ranking the country as having the highest rates in the Americas region,” according to the World Health Organization (WHO). Brazil is also one of the largest food producers in the world, which raises concerns about pesticide usage and exposure. Beyond Pesticides has previously covered a study that links neurotoxic effects of the herbicides 2,4-D and glyphosate to the impairment of behavioral performance (i.e., attention/inhibitory control, memory/learning, language, visuospatial processing, and social perception). Another study links glyphosate to adverse impacts on the gut microbiome, which plays a pivotal role in regulating both physical and mental health. Exposure to glyphosate is widespread, as “glyphosate-based products have consistently maintained their dominance in the market, representing more than half of the total volume of pesticides sold in the country,” the authors say.² Glyphosate is the predominant pesticide used by the farmers in the study in Toxicology, with 100% of them having reported using the herbicide, as well as other commonly used chemicals such as atrazine, simazine, paraquat, and permethrin. 

This study finds that farmers exhibit more severe cases of depression than non-farmers. “Our findings revealed an elevated prevalence of depressive disorders among farmers exposed to pesticides, along with an increased self-reported prevalence of depression in this population,” the researchers state.² They also find that suicide rates are higher in regions dedicated to agriculture with intensive pesticide usage. The data reveals that of their participants, 57% of the farmers exhibit depressive symptoms. Of those, “7% presented severe symptoms, carrying a potential risk of suicidal behavior. Conversely, within the control group comprised of individuals from urban region of Maravilha, a substantial 80% showed no signs of depressive symptoms, with only 20% experiencing just mild indications of depression.”² 

The blood sampling reveals that, “Oxidative stress markers, such as increased lipid peroxidation and superoxide dismutase (SOD) activity, along with decreased catalase (CAT) activity and ascorbic acid levels, were noted in the pesticide-exposed group compared to controls.”² The authors also determine that, “Redox imbalance, mitochondrial dysfunction and neuroinflammation were described as key factors on the mechanism underlying the neurotoxic impacts of pesticides… In addition, inflammatory processes were ascribed as one of the putative biological pathways associated with the neurobiology of both depressive mood and suicidal behavior.”² With these findings, the authors conclude that inflammation and oxidative stress may be associated with depression in pesticide-exposed farmers and warrants further study, and that  “occupational exposure to pesticides, especially glyphosate, compromises antioxidant defense mechanisms and induces inflammatory processes that may compromise neural circuits and may be associated with the pathophysiology of anxiety and/or depression disorders in pesticide-exposed farmers.”² 

The third study, in Environmental Toxicology and Pharmacology, adds to the findings of pesticide exposure correlating with depressive symptoms as 453 participants in Almería, Spain were surveyed and sampled. Of those participants, 225 were pesticide-exposed farmers that showed “significantly increased risk of moderate/severe depression and suicide attempts compared to non-farmers” with risks particularly observed with chlorpyrifos, mancozeb, and malathion exposure.³ 33.3% of the farmers had made a suicide attempt compared to only 18.4% of non-farmer participants.  

All participants in this study were males, and all farmers reported having direct and indirect means of pesticide exposure. Blood samples were collected, and enzyme markers such as erythrocyte AChE and butyrylcholinesterase (BChE) were analyzed in the blood samples. The authors find that, “The AChE activity was lower in farmers than in non-farmers, as was BChE activity. When comparing AChE and BChE activity in farmers and non-farmers, according to the level of depression and whether they had had any suicide attempts, a significant decrease in AChE activity was observed in farmers with moderate/severe depression with respect to those with minimal/mild depression symptoms… Farmers who had had a suicide attempt showed significantly lower AChE and BChE activity relative to those who had not had suicidal attempts.”³ 

This study is focused in Spain, where “approximately 10% of the surveyed population acknowledges experiencing psychiatric disorders, with depression (6.7%) being a prominent factor.”³ The importance of highlighting the connection between depression and pesticides in this country is particularly important since Spain led pesticide sales in the European Union in 2021, with transactions of “approximately 76,448 tons. Of these, 10,091 tonnes (13.2 percent) were used in the southern Spanish region of Almería, recognized for its intensive agricultural practices, both in greenhouses and outdoors,” the authors share.³ 

Worldwide agricultural dependence on petrochemical pesticides and fertilizers puts everyone at risk. “This widespread application of pesticides has come at a considerable cost, impacting both environmental and human health, particularly among farmers occupationally involved in pesticide application,” the researchers say. “The adverse effects of pesticides can manifest acutely through high-concentration pesticide intoxication or chronically as a result of repeated exposure to lower concentrations… While factors like physical injuries and chemical exposures often take center stage, it’s crucial to recognize that mental health is an equally significant concern.”² 

These studies, proving a connection between pesticide exposure and mental health disorders in various parts of the world, highlight the lack of extensive research on the neurological impacts of pesticide exposure, specifically for those with disproportionate risk, as well as the need for alternative agricultural methods that do not cause unreasonable harm. “These findings,” the researchers conclude, “underscore the importance of investigating the neurotoxic effects of pesticides and their relationship with mental disorders, emphasizing the need to implement appropriate preventive and protective measures in agriculture to preserve the mental health of farmers.”³  

While Beyond Pesticides has been reporting on mental health effects of pesticides since its founding, this area of research is still limited. In recent years, more studies have emerged that highlight the link between acute and chronic pesticide exposure and the prevalence of depression, especially in farmworkers. (See further previous coverage here, here, and here.) Additional research still needs to be conducted, though, to assess variations in types of exposure regarding time, amount, and type of pesticides, as well as how they correlate to mental health symptoms. The researchers comment that, “ongoing research efforts to safeguard the health of those who play a vital role in our agricultural communities” are still needed.²  

As the scientists share, “Suicide is a serious global public health issue that takes the lives of more than 700,000 people each year… Furthermore, since suicide in the agricultural population is widespread and constitutes a significant public health issue, it is imperative to comprehend the risk and protective factors associated with it to design and implement specific interventions targeting those with higher vulnerability.”³ 

Farmworkers that are exposed to pesticides through the application process, as well as through direct or indirect contact with any targeted crops, are among those with a higher risk. According to the latest survey from the National Center for Farmworker Health (NCFH) for 2019-2020, 66% of crop workers are male. Based on the science presented in these studies, as well as many others, this leaves males more likely to experience depressive symptoms resulting from occupational pesticide exposure. 

The solution to these harmful effects is the transition to organic agriculture. By eliminating the need for petrochemical pesticides and fertilizers, the disproportionate risk to agricultural workers, especially males, for neurological impacts will be reduced. The Safer Choice, for all individuals, is to avoid hazardous home, garden, community, and food use pesticides. There are many health benefits to organic agriculture, specifically for farmworkers and their children, as well as environmental benefits. To learn more, see Beyond Pesticides’ Resources and subscribe to the Daily News Blog.      

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

Sources: 

[1] Frengidou, E., Galanis, P. and Malesios, C. (2024) Pesticide Exposure or Pesticide Poisoning and the Risk of Depression in Agricultural Populations: A Systematic Review and Meta-Analysis, Journal of Agromedicine. Available at: https://www.tandfonline.com/doi/full/10.1080/1059924X.2023.2278801. 

[2] Zanchi, M.M. (2024) Redox imbalance and inflammation: A link to depression risk in Brazilian pesticide-exposed farmers, Toxicology. Available at: https://www.sciencedirect.com/science/article/abs/pii/S0300483X23002937?via%3Dihub.  

[3] Zheng, R. et al. (2024) Depressive symptoms and suicide attempts among farmers exposed to pesticides, Environmental Toxicology and Pharmacology. Available at: https://www.sciencedirect.com/science/article/pii/S1382668924001017?via%3Dihub.

(Beyond Pesticides, July 1, 2024) Comments on proposed new dicamba uses are due Friday, July 5
The U.S. Environmental Protection Agency (EPA) is accepting public comments until July 5 on whether it should allow the expanded use of the weed killer dicamba, which has been associated with adverse impacts related to its propensity to drift off of the target application site. The comment period addresses a BASF chemical company proposal for additional food use of a dicamba product on dicamba-tolerant cotton and dicamba-tolerant soybeans. (See Beyond Pesticides’ comments.) This application is similar to Bayer CropScience’s application for XtendiMax®, for which Beyond Pesticides submitted comments in June. The proposed label for BASF’s Engenia® allows for application preplant, at-planting, preemergence, and postemergence (in-crop) for broadleaf weeds.

>> Tell EPA to ban use of dicamba and other drift-prone pesticides.

The U.S. Supreme Court Reversal

This proposal is under consideration on the heels of a U.S. Supreme Court decision on June 28 that reverses a 40-year old decision in Chevron v. Natural Resources Defense Council, which created a deference to federal agencies in the rulemaking process. In the dissent to this 6-3 decision of the court, the dissenters focus on the role of executive branch agencies: “Congress has conferred on that expert, experienced, and politically accountable agency the authority to administer—to make rules about and otherwise implement—the statute giving rise to the ambiguity or gap.” Agencies, the dissenters say, are intended to have “subject-matter expertise.”

The court majority finds that Chevron conflicts with the Administrative Practices Act (APA), saying, “Chevron defies the command of the APA that “’the reviewing court”—not the agency whose action it reviews—is to “decide all relevant questions of law” and “interpret . . . statutory provisions.’” The dissent continues: “In recent years, this Court has too often taken for itself decision-making authority Congress assigned to agencies. The Court has substituted its own judgment on workplace health for that of the Occupational Safety and Health Administration; its own judgment on climate change for that of the Environmental Protection Agency; and its own judgment on student loans for that of the Department of Education.” The dissent sees the decision of the court’s majority as turning the judicial institution into the “country’s administrative czar,” and violating the court’s key principle of stare decisis, which establishes precedent as requiring a extraordinary set of circumstances to reverse—a tenet this Supreme Court has appeared comfortable in rejecting, including in Dobbs v. Jackson Women’s Health Organization (2022), reversing the court’s 1973 decision in Roe v. Wade.

If public comments pour into EPA, urging the agency to look carefully at both the science on dicamba’s adverse effects and decides to deny the registration, as Beyond Pesticides advocates, will the chemical industry challenge the agency as relying on a “statutory ambiguity,” or the discretionary authority given to it by Congress? Whether affected parties or public interest organizations concur with their decisions, agencies are supposed to have the expertise to implement laws and bring the facts to the rulemaking process. But, of course, there are facts and there are “alternative facts.” And, in the realm of pesticide regulation, many times it is the lack of facts, data gaps, uncertainties, and limited reviews that support regulations that are not adequately protective even though there is much data in the scientific literature that suggests there is more science than is being considered by the regulators (e.g., endocrine disruption, pollinators, disproportionate harm and vulnerable population groups, comprehensive ecosystem effects, etc.). The fact is that there has been a swing from the Reagan to Biden Administrations, with conservatives and chemical company interests embracing the Chevron decision and then rejecting Chevron, as agencies took stronger positions on climate, environmental justice, etc. (even though many environmental and public health groups see them as inadequate to meet current existential threats).

What EPA Needs to Consider with Dicamba

Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. EPA is now considering two new dicamba registrations that continue use of the chemical in its most drift-prone application uses.

>> Tell EPA to ban use of dicamba and other drift-prone pesticides.

Pesticide drift harms people, crops, and wildlife. The term “drift” applies to airborne movement off the target site—though pesticides may also move as runoff and in soil carried by water or wind. Drift may consist of particles or droplets of pesticide as it is applied or vapors that evaporate and are carried in the air. Farmers and applicators may take steps to avoid drift—including buffer zones, thickening agents, and attention to wind direction—but drift-prone pesticides like dicamba are not always controlled by these actions. Those harmed by the drift are generally not those whose crops are sprayed, so the risk-benefit analysis pits farmer against farmer, neighbor against neighbor, even resulting in a murder.

The manufacturers of dicamba-based herbicides—who also sell seeds of crops engineered to tolerate dicamba—benefit from this conflict, as farmers buy the engineered seeds in an effort to defend themselves against drift damage, a strategy encouraged by pesticide manufacturers.

Despite a finding of dicamba’s harm and EPA’s failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA’s 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. And now proposed registrations would allow those uses to continue. The comment period on the Bayer application has closed, but comments on the virtually-identical application for BASF’s Engenia® are open until July 5. (See Beyond Pesticides’ comments.)

The proposed label for Engenia® allows for application preplant, at-planting, preemergent, and postemergent (in-crop) for broadleaf weeds. In dicamba-tolerant soybeans, there is a June 12 cutoff date with applications allowed before, during, and after planting, including over-the-top. In dicamba-tolerant cotton, similar conditions apply but with a cutoff date of July 30. This is different from the Bayer CropScience proposal where no over-the-top application was specified for soybeans. The new proposed uses, since they increase use of dicamba and subsequent harm from pesticide drift, should be denied for failure to meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirement of no unreasonable adverse effects on the environment.

Increasing global temperatures need also to be factored into the decision-making process. All dicamba formulations have the potential to volatilize since dicamba has a high vapor pressure. Increases in air temperature can cause dicamba to turn into a gas even after successful application on target surfaces. Since volatilization increases as temperatures increase, this is more and more concerning as temperatures are rising higher each year. The length, intensity, and onset of seasons have changed, which can be attributed to climate change. The longer and hotter summers will exacerbate dicamba volatilization, therefore any proposal that allows dicamba application in late Spring and Summer will lead to more drift–especially for postemergent and over-the-top applications.

Although pesticides are by definition harmful, what makes these adverse effects “unreasonable” is the existence 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 is successful. This includes the proposed uses.

Proposed submission to EPA (please submit by 5 PM ET on July 5, 2024):

Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. EPA is now considering two new dicamba registrations that continue use of the chemical in its most drift-prone application uses.

Pesticide drift harms people, crops, and wildlife. The term “drift” applies to airborne movement off the target site—though pesticides may also move as runoff and in soil carried by water or wind. Drift may consist of particles or droplets of pesticide as it is applied or vapors that evaporate and are carried in the air. Farmers and applicators may take steps to avoid drift—including buffer zones, thickening agents, and attention to wind direction—but drift-prone pesticides like dicamba are not always controlled by these actions. Those harmed by the drift are generally not those whose crops are sprayed, so the risk-benefit analysis pits farmer against farmer, neighbor against neighbor, even resulting in a murder.

The manufacturers of dicamba-based herbicides—who also sell seeds of crops engineered to tolerate dicamba—benefit from this conflict, as farmers buy the engineered seeds in an effort to defend themselves against drift damage, a strategy encouraged by pesticide manufacturers.

Despite a finding of dicamba’s harm and EPA’s failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA’s 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. And now proposed registrations would allow those uses to continue.

The proposed label for Engenia® allows for application preplant, at-planting, preemergent, and postemergent (in-crop) for broadleaf weeds. In dicamba-tolerant soybeans, there is a June 12 cutoff date with applications allowed before, during, and after planting, including over-the-top. In dicamba-tolerant cotton, similar conditions apply but with a cutoff date of July 30. This is different from the Bayer CropScience proposal where no over-the-top application was specified for soybeans. The new proposed uses, since they increase use of dicamba and subsequent harm from pesticide drift, should be denied for failure to meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirement of no unreasonable adverse effects on the environment.

Although pesticides are by definition harmful, what makes these adverse effects “unreasonable” is the existence 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 is successful. This includes the proposed uses.

Increasing global temperatures also need to be considered. All dicamba formulations have the potential to volatilize since dicamba has a high vapor pressure. Increases in air temperature can cause dicamba to turn into a gas even after successful application on target surfaces. Since volatilization increases as temperatures increase, this is more and more concerning as temperatures are rising higher each year. The length, intensity, and onset of seasons has changed, which can be attributed to climate change. The longer and hotter summers will exacerbate dicamba volatilization, therefore any proposal that allows dicamba application in late Spring and Summer will lead to more drift–especially for postemergent and over-the-top applications.

EPA must not approve the proposed expanded use of dicamba and must cancel uses of all drift-prone pesticides.

Thank you.

*Note: Due to updates to the Regulations website, we are now able to offer a “click-and-submit” form to the Regulations docket, linked above!

(Beyond Pesticides, July 28, 2024) Most people don’t like bugs, but the fact is that insects form the foundation of human flourishing, both for their ecosystems services, like pollination of food crops, and for their aesthetic joys. But insect populations globally are declining two to four percent a year, with total losses over 20 years of 30-50 percent, according to a new study of the interacting effects of pesticides, climate, and land use changes on insects’ status in the Midwest. Teasing out the relative influence of these stressors has been a major obstacle in determining the causes of the declines and ways to mitigate them.

The icon of insect beauty in the U.S. is the monarch butterfly, whose vibrant coloring, elegant form, and spectacular migrations inspire everyone. Beyond Pesticides has covered the distressing decline of these creatures, most recently in the June 24 Daily News. Monarchs prefer milkweed plants, but also visit many other flowers. Milkweed often grows along the margins of fields, so monarchs are widely exposed to pesticides and habitat disturbances associated with agriculture.

The new study was published in PLoS One by a team of scientists from the Washington Department of Fish and Wildlife, Michigan State University, Iowa State University, and Georgetown University. Of the three drivers of insect loss, the study confirmed unequivocally that insecticides lead the pack in causing the loss of richness and abundance in Midwest butterfly species, particularly monarchs. “Overall declines are overwhelmingly supported by the evidence,” they write. Monarchs, bumblebees, dragonflies and lowland butterflies all drop catastrophically in areas where pesticides are used.

In the pesticide category, the study considered weed control (herbicides including glyphosate), reactive insect control (the sprayed insecticides pyrethroids and organophosphates), and prophylactic insect control (neonicotinoid-treated and Bt genetically modified seeds). The researchers considered all of the highest-use pesticides including their main active ingredient, target organisms, application timing, and mode of application (preventive, as on seeds or in soils, or reactive, in response to pest outbreaks), whether the pesticide spills over into nontarget areas, and how persistent it is in the environment. And while the steep crash of monarch butterflies coincides neatly with the introduction of glyphosate, the authors note that while herbicides reduce habitat diversity sharply, they do not directly kill insects like pesticides do. The study’s end result was clear: seeds coated with neonicotinoids are causing the most damage.

Neonicotinoids are the most widely used insecticide type in the world. While generally considered less toxic to mammals than organochlorines and carbamates, but much more toxic to a wider variety of insects—not just pests but also beneficials and charismatic butterflies, their serious adverse impacts on human health are becoming increasingly defined. (See here and here.) Up to 85 percent of applied neonicotinoid insecticides, including on seeds, can leach into the environment. Thus, beyond exposure to neonicotinoids via plant tissue or direct spray, there is deep concern about the residues that remain in soil and water and are incorporated into non-target plants.

The study used advanced and innovative methods to overcome the difficulty of determining the relative influence of pesticides, climate and land use changes. In their target region of the Midwest, agriculture comprises 60 percent of land use in most counties, and corn and soybeans dominate the crop types. The Midwest also has the densest network of butterfly monitoring activities, which the researchers accessed for species and abundance data.

Large-scale climate and land use data are also publicly available, and changes in these factors can be sensed remotely. But acquiring reliable information about pesticides is frustrating because much of it is protected by the obscurantism of chemical companies and the shirking of responsibility by regulators. Granular data about pesticide use does exist, but this data is often proprietary. To get that data, the researchers acquired results of an annual survey called AgroTrak, conducted by Kynetec, Inc., a market research company. The survey draws from databases of growers who receive federal payments, membership lists of farmers’ associations, and subscribers to agricultural publications, correlated with USDA groupings of areas with similar climate, geography and cropping practices. Respondents to the survey provide information from the previous year about which seeds they use and the types and amounts of pesticides they have applied to individual fields.

Importantly, the data the researchers used included information about neonicotinoid usage only between 1998 and 2014, after which the market research company stopped asking its respondents about whether they used neonicotinoid-treated seeds. This was apparently because farmers are less knowledgeable about the pesticides in treated seeds, so the survey did not draw out accurate data.

This problem was also analyzed by a 2020 report, “Sowing Uncertainty: What We Do and Don’t Know about the Planting of Pesticide-Treated Seed.” To get around this data gap, Sowing Uncertainty collected information from other, publicly available sources, but these often have their own weaknesses. For example, the USDA conducts annual voluntary surveys of farmers growing major crops (corn, soybeans, wheat and cotton), but conclusions from this data are also problematic because the data is aggregated and does not provide field-level information. Europe is a patchwork of reporting requirements, some of which provide fairly detailed data, but again, seed treatments are either not reportable or are lumped in with other pesticide uses. The best source of pesticide use data is the State of California, because it requires commercial applicators to report. But seed treatment is not defined as a pesticide in California. Clearly the status of pesticide-treated seeds must be clarified by regulators and included in reporting requirements. Its omission from the reporting system is an example of policy dictated by economic interests.

This is despite the rising use of treated seeds. For example, according to Sowing Uncertainty, “Over the 2012–2014 period, approximately 90% of corn, 76% of soybean, 62% of cotton, and 56% of winter wheat acres in the United States were planted with treated seed.” Yet, the report stresses, government data gathering concentrates on field-applied pesticides.

Attempts to reduce the threat from neonicotinoids in general and seeds treated with them have had mixed success. In the U.S., the U.S. Environmental Protection Agency (EPA) amended the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in 1988 to allow manufacturers and sales companies not to register or label pesticide-treated articles including seeds, so they are not included in the pesticide use data the Food Quality Protection Act requires USDA to collect.

The European Union totally banned neonicotinoids for outdoor use in 2018, and in the U.S. the next year, neonicotinoid manufacturers caved to a lawsuit by beekeepers and environmental NGOs and asked EPA to cancel the registrations for a dozen of the 59 neonicotinoid products containing clothianidin and thiamethoxam. EPA has already found that three neonicotinoids—clothianidin, imidacloprid and thiamethoxam—are likely to adversely affect the vast majority of endangered species. Beyond Pesticides covered this issue here. Currently, EPA lists five neonicotinoids under registration review—including those three—which it optimistically plans to complete in 2024.

The PLoS study points directly to neonicotinoids as the leading culprit in monarch losses—but, the authors write, this “does not align with the relationship between neonicotinoids and monarch mortality in lab toxicology studies; indeed these lab studies show that neonicotinoids are among the least toxic agents.” This, Beyond Pesticides believes, highlights a severe problem with the methods used by regulators to assess harms to plants, animals, fungi and ecosystems from industrial chemicals: regulatory toxicology tests.

EPA, the Food and Drug Administration (FDA), and other agencies require chemical manufacturers to run batteries of antiquated tests on thousands of laboratory animals, usually culminating in calculating the LD50, or the dose at which half of the test animals die. The companies either conduct the tests and report the result to regulators themselves or outsource the tests to one of the many bespoke consultancies available to produce the desired results. Rarely do the tests include measures of cumulative health effects over time or at the animals’ most vulnerable life stages; nor do they often assess the combined effects of multiple chemicals.

Nor is there a requirement for chemical testing to be conducted together with other stressors such as those examined in the current study, namely climate and land use changes, especially habitat loss. Laboratory tests, the authors note, estimate “field-relevant exposure levels to be well below those expected to cause monarch mortality,” but this disregards the fact that seed treatments vastly increase the buildup of neonicotinoids in the environment. Nor can lab tests determine sub-lethal effects on monarchs in the environment. Laboratory results simply do not predict real-world consequences.

The authors emphasize that, because their dataset stopped in 2014, they were not able to consider the effects of climate change since then. The hottest years on record have occurred recently and surely must be affecting monarch abundance and survival more severely than they observed in their study. Even so, climate is unlikely to have outpaced pesticides as the most grievous harm being inflicted on these iconic butterflies and insects in general. Further, the glacial pace of regulatory action contrasts with the breakneck speed of pesticides’ accumulating consequences to insects and ecosystems. Insect loss means bird loss, estimated at 3 billion in the U.S. over the last 50 years. As the PLoS authors emphasize, there is an urgent risk of ecosystem collapse. Yet EPA and other federal agencies continue to give the worst culprits, neonicotinoid treated seeds, a free pass.

What you can do:

• Tell EPA to eliminate pesticides that threaten butterflies. Tell the U.S. Fish and Wildlife Service and Department of Interior to help bring back butterflies by eliminating the use of pesticides that threaten them. Tell Congress that EPA and other agencies need to do their job and protect our most charismatic insects.
• Join a monarch monitoring program to collect data in your area. Training is available.
• Create a monarch-friendly garden.
• Eliminate or reduce your own pesticide use; this will help not only monarchs, but yourself and all the plants, insects, fungi, and animals we depend on for life and joy.

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

Sources

Insecticides, more than herbicides, land use, and climate, are associated with declines in butterfly species richness and abundance in the American Midwest
Braeden Van Deynze, Scott M. Swinton, David A. Hennessy, Nick M. Haddad, Leslie Ries 
PLoS One June 20, 2024
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0304319

New ‘Detective Work’ on Butterfly Declines Reveals a Prime Suspect
The New York Times June 20, 2024
https://www.nytimes.com/2024/06/20/climate/butterfly-declines-insecticides-monarch.html

“Sowing Uncertainty: What We Do and Don’t Know about the Planting of Pesticide-Treated Seed”
Claudia Hitaj, David J. Smith, Aimée Code, Seth Wechsler, Paul D. Esker and Margaret R. Douglas
BioScience May 2020 / Vol. 70 No. 5
https://doi.org/10.1093/BIOSCI/BIAA019

[Blog post] “Sowing Uncertainty: What We Do And Don’t Know About The Planting Of Pesticide-Treated Seed”
By Aimée Code on 18. March 2020, Xerces Society
https://xerces.org/blog/sowing-uncertainty-pesticide-treated-seed

“Pollinator Week Ends; Pollinator Decline and Biodiversity Collapse Continue with Inadequate Restrictions”
https://beyondpesticides.org/dailynewsblog/2024/06/pollinator-week-ends-pollinator-decline-and-biodiversity-collapse-continue-with-inadequate-restrictions/

“More Evidence Shows Neonics Harm Butterflies”
https://beyondpesticides.org/dailynewsblog/2016/08/evidence-shows-neonics-harm-butterflies/

“Study Shows 50% Decline in Butterfly Population Across the European Union, 1990-2011”
https://beyondpesticides.org/dailynewsblog/2023/05/study-shows-almost-50-decline-in-butterfly-population-across-the-eu-1990-2011/

Take Action: With Butterfly Decline Mounting, EPA Allows Continued Pesticide Use that Causes Threat
https://beyondpesticides.org/dailynewsblog/2023/06/take-action-with-butterfly-decline-mounting-epa-allows-continued-pesicide-use-that-causes-threat/

“Vanishing: More Than 1 In 4 Birds Has Disappeared In The Last 50 Years”
By Gustave Axelson, Cornell Lab/All About Birds, September 19, 2019
https://www.allaboutbirds.org/news/vanishing-1-in-4-birds-gone/#

(Beyond Pesticides, June 27, 2024) Earlier this month, Public Employees for Environmental Responsibility (PEER) filed a lawsuit against the U.S. Environmental Protection Agency (EPA) on behalf of a group of ranchers and farmers in Texas harmed by biosolids contaminated with per- and polyfluoroalkyl substances (PFAS). The plaintiffs charge that their health and livelihoods were severely damaged due to contaminated biosolids leaching from neighboring properties onto their land. Despite EPA’s responsibility under the Clean Water Act (Section 405(d) and 40 CFR Part 503) to identify toxic pollutants in biosolids and regulate them to protect human health and the environment, the agency has not effectively addressed the dangers posed by PFAS in biosolid fertilizers. EPA’s failure has dramatic impacts on farmers as well as the public, who are eating or drinking PFAS-contaminated crops, dairy milk, beef, or other meat products. The shortcomings of federal regulations underscore the urgent need for a shift in how federal and state agencies approach these issues, prioritizing precaution to prevent future harm. The persistence of these legacy or “forever” chemicals in the environment illustrates the severe consequences of a historically lax regulatory framework in the U.S. 

The National Association of State Departments of Agriculture (NASDA) has identified PFAS as an “emerging risk” and a “major hazard” to American agriculture, affecting farmers and ranchers nationwide. Beyond Pesticides argues that ending the use of toxic petrochemical pesticides, fertilizers and biosolids in agriculture addresses environmental and health issues simultaneously, including biosolids, a known source of PFAS contamination in soil, groundwater, and drinking water. Organic regenerative agriculture is a viable solution, and under the Organic Foods Production Act (OFPA), which establishes the U.S. Department of Agriculture (USDA) organic seal and certification process, the use of biosolids or fertilizers containing biosolids, as well as toxic synthetic fertilizers and pesticides, is prohibited.

What are Biosolids or Biosludge?

EPA estimates more than 2.4 million tons of biosolids, or sewage sludge, are applied as fertilizers on farms, homes, parks, and other lands across the U.S. annually. Biosolids result from the wastewater treatment process, which collects wastewater and greywater, including anything flushed down the drain from homes, businesses, and industries. Some of the industries that discharge to wastewater treatment plants include metal plating, pulp and paper mills, fabric, and plastics manufacturing. Wastewater may even include the liquid waste or “leachate” that oozes from landfills.

Many persistent chemicals found in these waste streams are not removed during the treatment process. The Clean Water Act Section 405(d) requires EPA to review biosolids regulations every two years, identify any new pollutants found, and set regulations if there is the potential for harm to human health or the environment. As reported in Nature in 2022, EPA has identified 726 chemicals and “structure-based classes” in the biosolids it has tested, including pesticides and drugs (and their associated metabolites), cosmetics, flame retardants, polychlorinated biphenyls (PCBs), polybrominated biphenyl ethers (PBDEs), dioxins, and dibenzofurans. Some chemicals are sent as liquid waste into local waterways, while others settle into the remaining solids known as biosolids. PFAS chemicals are not broken down during sewage treatment and yet biosolids are not currently tested for the presence of PFAS or other chemicals, outside of some heavy metals and pathogens. EPA is in the process of determining next steps since this issue attracted public interest last year. According to the agency, “The EPA committed in the agency’s PFAS Strategic Roadmap to conduct a biosolids risk assessment for two PFAS, perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), in biosolids. . .The assessment is currently underway and is expected to be published by the end of 2024.” 

EPA allows biosolids to be applied to the land, incinerated, or landfilled, depending on the level of treatment. According to EPA’s 2002 ‘A Plain English Guide to the EPA Part 503 Biosolids Rule,’ biosolids can be applied on farms by conventional farmers, as long as they receive a permit from their EPA Region. EPA’s established standards on pollutant concentrations, pathogen density, and the attraction of potential pathogen vectors (e.g., insects, scavenging mammals, and birds) can be found in the Biosolids Rule (40 CFR Part 503). As Beyond Pesticides report, “Biosolids or Biohazards?,” noted in 2012, “While heavy metals, pathogens, and disease vectors are regulated, there are a myriad of chemicals, pesticides, and emerging contaminants, like PFAS in biosolids, that do not have any regulatory limits.”

The Problem with PFAS in Biosolids

Known as “forever chemicals,” PFAS do not break down in the environment. Instead, these chemicals leach into soil and groundwater where they are absorbed by plants and animals. Once absorbed by some plants and animals, they bioaccumulate up the food chain, posing significant risks to humans, livestock, and wildlife. PFAS are often found in very high concentrations in biosolids, due to their widespread use in residential and commercial applications. PFAS health risks include developmental, metabolic, cardiovascular, and reproductive harm, cancer, damage to the liver, kidneys, and respiratory system, as well as the potential to increase the chance of disease infection and severity. Gestational (during pregnancy) and childhood exposure to PFAS increases cardiometabolic risk, or the risk of heart diseases and metabolic disorders, later in life, according to a Brown University study published in Environment International in 2021. 

Concern over the high amount of PFAS in biosolids prompted EPA’s Office of Water, to work with the Environmental Council of the States (ECOS), and the National Association of State Departments of Agriculture (NASDA) to create Principles for Preventing and Managing PFAS in Biosolids. Ostensibly, the principles “define key areas for regulators and stakeholders to work collaboratively to ensure the fate and transportation of PFAS contaminated biosolids do not result in harm to human health or the environment.” Practically, these principles ignore the dramatic harms and reveal the lack of regulatory will necessary to address this crisis, despite EPA recognizing the grave impacts of PFAS on biological systems calling it an “urgent public health and environmental issue facing communities across the United States” in its 2021 PFAS. Roadmap.

While EPA has recently promulgated drinking water standards for a small subset of over 9,000 PFAS, regulations set limits for only a handful, including two of the most studied PFAS (PFOA and PFOE), for which EPA acknowledges there is no safe level of exposure for human health. Yet no federal agency has yet implemented a program to assist farmers plagued by PFAS on their land or to establish guidelines for PFAS in food.

Failure of EPA Regulation

The plaintiffs in the PEER case represent just a fraction of the farmers nationwide who face agricultural contamination due to EPA’s inaction on regulating toxic chemicals in biosolids. The lawsuit emphasizes that EPA has failed to use its authority under Section 405(d) of the Clean Water Act to regulate these toxic chemicals effectively and, based on PEER’s discussions with EPA before the lawsuit, the agency has no definitive timeline to take action. According to PEER, out of over 350 pollutants typically found in biosolids, EPA currently is only regulating nine heavy metals for land application, ignoring all others, including PFAS. 

In fact, EPA has been aware of hundreds of pollutants regularly found in biosolids, including 61 designated as acutely hazardous, hazardous, or priority pollutants in other programs. EPA’s failure to adequately regulate the use of biosolids prompted the EPA’s Office of the Inspector General (OIG) to investigate the situation in 2018. The OIG found that EPA’s management of biosolids was “incomplete” and “may not fully protect human health and the environment,” lacking the appropriate data or risk assessment tools. The OIG investigation also found that EPA reductions in staff and resources in the biosolids program have hamstrung the program. They lack the data necessary to determine which pollutants pose the greatest threats to humans and the environment. In addition, the OIG determined that EPA has not provided the public with sufficient information to understand the full spectrum of biosolids pollutants and their potential impacts.

Instead of developing regulations to prevent PFAS from entering the waste stream in the first place, in 2020 EPA provided “interim” guidance for destroying PFAS and PFAS-containing materials, which was updated in 2024 to provide information on methods to “remediate, dispose of, and destroy PFAS contamination.” This guidance is part of the EPA’s broader PFAS Strategic Roadmap, which outlines the agency’s strategies for addressing PFAS contamination. It identifies biosolids as a source of contamination to land, but states that alternative means of destroying PFAS in waste (incineration and landfill) also have contamination concerns and that further research is needed before additional guidance (or regulation) can be developed.  

Moreover, in 2022, EPA punted the responsibility for eliminating PFAS from biosolids to the states through the National Pollutant Discharge Elimination System (NPDES) program. Through NPDES permits, EPA says states may “choose” to monitor levels of PFAS in sewage sludge and include permit requirements to reduce PFAS contamination, where appropriate. Meanwhile, EPA says they will continue to “research, restrict, and remediate PFAS in the environment, including in biosolids.”

Several states are mandating the monitoring of wastewater at treatment facilities and by industries that utilize PFAS in their operations or contribute to contaminated stormwater. States such as Maine, Michigan, and Colorado have implemented regulations that require wastewater systems to assess the levels of contamination and control the entry of PFAS pollutants from major industrial sources into the wastewater system.

As a result of nearly absent federal regulation, contamination of US agricultural systems continues.

In a separate lawsuit in February 2024, five farmers from Johnson County, Texas, filed a lawsuit against Synagro Technologies, Inc., a major manufacturer of biosolids-based fertilizers. The lawsuit alleges that Synagro’s products contain high levels of PFAS, which poisoned their land, water, and livestock, thereby decimating their livelihoods. The concentrations of PFAS found in the soil, water, and tissue samples from these farms were alarmingly high and included several PFAS for which there are not safe levels of exposure. As PEER notes, this is “the first in what may be a tidal wave of product liability lawsuits … against a major manufacturer of biosolids-based fertilizer for damages caused by toxic chemicals they contain. Fertilizers produced from sewage sludge have dangerous levels of toxic PFAS (per- and polyfluoroalkyl substances), according to laboratory testing arranged by Public Employees for Environmental Responsibility (PEER), and thus present a major threat to American agriculture and public health.”

Synagro manages 6.5 million tons of biosolids each year, producing approximately 26,500 tons of fertilizer annually from sewage sludge purchased from water treatment plants. Despite marketing its fertilizers as safe and organic, the company faces accusations of failing to warn purchasers about the risks associated with PFAS exposure.

Beyond Pesticides has long warned unsuspecting consumers of deceptive labeling and PFAS dangers in fertilizers, calling out biosolid-based fertilizer products like Milorganite, often sold to consumers as “organic,” while contaminated with dangerous PFAS chemicals. A 2021 study published by Sierra Club and Ecology Center, identified biosolids containing residues of hazardous pesticides, heavy metals, antibiotics and other pharmaceuticals, personal care products, and a range of other toxicants. None of these risks are revealed on fertilizer packages. With fertilizer regulations failing the American consumer, it becomes more important than ever to seek out certified organic fertilizer products.

As the report notes, many of these products advertise themselves as “organic,” “natural,” or “eco-friendly.” But with these products, “organic” does not mean the same as certified organic products, which prohibit the use of fertilizers containing biosolids. The source of this discrepancy lies with the Association of American Plant Food Control Officials (AAPFCO). Fertilizer labeling is currently enacted on a state-by-state basis, and most states follow AAPFCO’s model language. The group defines organic fertilizer as a material containing carbon and one or more elements other than hydrogen and oxygen essential for plant growth. This definition permits fertilizers to be labeled as “organic” (containing carbon) even if they do not comply with the USDA National Organic Program (NOP) standards to produce organic food. 

State and Local Efforts

Lacking sufficient oversight at the federal level, action to protect health and the environment falls to the states and local jurisdictions. In 2022, the Environmental Council of the States (ECOS) conducted a survey of state efforts to regulate, test, and research PFAS in biosolids. Of the 34 states that responded, 23 allow for biosolids contaminated with PFAS to be used on agricultural feedstock, residential and commercial land, food crops, and/or other uses. Only Maine has a ban on land application of biosolids, with the exception of septage (sewage from septic systems). Michigan has also established PFAS limits for biosolids used in land applications. In addition, New Hampshire, Massachusetts, and Michigan each have some level of required monitoring for PFAS in biosolids. However, 27 states have no legislation regarding this matter.

Local agencies are also picking up the slack left by EPA in the regulation of these toxics. The ECOS survey found that nine states (Arizona, Colorado, Massachusetts, Michigan, Minnesota, New Hampshire, North Carolina, Tennessee, and Texas) have local municipalities that have established measures to regulate or ban biosolids disposal or land application. (To learn more about federal, state, and local legislation and regulations about PFAS, see Northeastern University’s PFAS Project Lab website and PFAS Governance Tracker).

Urgent Response Needed

Land application of biosolids to farms and landscapes is considered the standard means of “disposal.” As Beyond Pesticides reported, chemicals such as PFAS have been found to migrate into food when grown on farms using contaminated biosolids. Over 60% of biosolids are used in crops, and the contaminants in them make their way to our food and water. When biosolids are used in landscaping, the contaminants pose a hazard to landscapers and those using athletic fields. In view of EPA’s failure to provide comprehensive identification, regulation, and elimination of potential contaminants, the biosolids themselves must be tested to ensure safety; otherwise, they should not be used on farms, public lands, or landscapes.

Currently, USDA organic certification is the only regulatory safeguard from biosolids threats to human health, given their prohibition in the Organic Foods Production Act. Beyond Pesticides urges consumers to avoid the use of dried sewage sludge on their home yard and garden and encourages reading fertilizer labels carefully. To assist, Beyond Pesticides created a resource of Fertilizers Compatible with Organic Landscape Management. The resource focuses on companies that produce consumer-use fertilizers that bear the certified organic label, which never allows the inclusion of biosolid sewage sludge.

Fight back against sewage sludge on your food and in your agricultural community by urging local leaders to prohibit the use of these products on farm fields. Communities across the U.S. have begun to take on this fight. Additional information on the dangers of biosolids can be found in the report “Biosolids or Biohazards” and here. 

To raise your voice in support of two bills to fight PFAS contamination, see Beyond Pesticides’ Action:

Tell Congress to Take Action: The Farm Bill must include the Relief for Farmers Hit with PFAS Act and support the Healthy H2O Act to protect farmers and rural communities from PFAS contamination. Led by Chellie Pingree (D-ME), U.S. Senators Tammy Baldwin (D-WI), and Susan Collins (R-ME), a bipartisan and bicameral bill—the Relief for Farmers Hit with PFAS Act—has been introduced to provide assistance and relief to those affected by PFAS. A second bill, the Healthy H2O Act, introduced by Representatives Pingree and David Rouzer (R-NC) and Senators Baldwin and Collins, provides grants for water testing and treatment technology directly to individuals and non-profits in rural communities. Click here to tell your Congress member to act now.

Beyond Pesticides offers a variety of articles in the archives detailing the dangers and prevalence of PFAS in biosolids, pesticides, and drinking water, despite the standards EPA announced in April 2024. Click here to sign up for action alerts from Beyond Pesticides to take action on PFAS contamination and other environmental issues, and please take a moment to explore Beyond Pesticides’ Tools for Change webpage to begin your advocacy journey.

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

Sources:

EPA Sued to Remove PFAS from Biosolid Fertilizers: EPA Neglects Duty to Keep Toxic Forever Chemicals Out of Food and Water, Public Employees for Environmental Responsibility (PEER) press release, June 6, 2024

Lawsuit: James Farmer et al vs US EPA and Michael Reagan, Administrator US EPA, Civil Action No. 24-cv-1654, filed US District Court, District of Columbia, June 6, 2024

Senate Farm Bill draft raises hopes for PFAS-impacted farmers, The New Lede, May 25, 2024

Per- and Polyfluoroalkyl Substances (PFAS) in Biosolids, EPA website

Toxic PFAS in Sludge from Wastewater Treatment Plant Pollutes Tennessee Land and Water, Sierra Club Tennessee Chapter report, February 2024

Texas Farms Poisoned by PFAS-Laden Biosolid Fertilizers: Johnson County Holds Hearing to Warn Citizens About Synagro’s Biosolids, PEER press release, February 16, 2024

Case study of per-and polyfluoroalkyl substances (PFAS) from biosolids contaminating farmland in Johnson County, Texas, PEER analytical report to Johnson County, Texas, February 21, 2024

EPA accused of ‘egregious’ misconduct in PFAS testing of pesticides, The Guardian, May 28, 2024

PFAS in Biosolids: A Review of State Efforts & Opportunities for Action, The Environmental Council of the States paper, January 27, 2023

Biosolids or Biohazards? Pesticides and You, Beyond Pesticides, Fall 2012

Hidden Dangers of Biosolids, PEER website, December 7, 2022

PFAS Governance Tracker, maintained by The PFAS Project Lab from Northeastern University’s Social Science Environmental Health Research Institute

Image: Globetrotter19, CC BY-SA 3.0 <https://creativecommons.org/licenses/by-sa/3.0>, via Wikimedia Commons

(Beyond Pesticides, June 26, 2024) The Hungarian city of Törökbálint (featured above) is one of several dozen towns to join the European Pesticide Free Towns Network, an initiative of Pesticide Action Network (PAN) Europe, based on a recent blog post welcoming the city into its Network. With elections coming up in European Union Parliament and EU member state nations across the continent, advocates believe in the importance of proactive actions local governments and towns launch to address the cascading crises of climate change, biodiversity deterioration, and public health fragility. In the U.S., Beyond Pesticides is working with communities nationwide, providing hands-on technical assistance in the adoption of organic land management practices.

“In recent years, our municipality has begun to explore the possibility of tackling an increasing number of city management problems with environmentally friendly solutions,” says Sándor Elek, mayor of Törökbálint in a public statement announcing the city’s membership. “We are phasing out chemical treatments in public areas and working on the continuous information and awareness-raising of the public. We are also working to promote the public acceptance of environmentally friendly mosquito control.” In joining the European Pesticide Free Towns Network, each city must pledge to four primary objectives:

1. Ban the use of herbicides in public areas under city/town’s control
2. Ban the use of all pesticides in public areas under city/town’s control
3. Extend the ban of pesticides to private areas with public access and agricultural areas next to where citizens live
4. Step up greening efforts towards local biodiversity enhancement

There are three tiers or categories in which local governments can adhere to: “glyphosate free in public area”, “pesticide free in public area”, and “entire pesticide free.” According to the database as of the day of publication, currently there are over 100 cities and towns that fall into “pesticide free in public area,” with two Italian cities of Urbino and Loro Ciuffenna banning glyphosate use in public areas and just one city in Europe (Bolzano, Switzerland) banning all pesticide use. There is a legacy of EU member states leading the charge on pesticide regulations and bans, as laid out on the Policy & Strategies page. Germany, Italy, Belgium, Denmark, France, Spain, and Luxembourg are acknowledged as leaders. Italy banned glyphosate use as pre-harvest chemical treatment in 2016. Belgium has different rules depending on the province, but generally has banned the use of pesticides in most contexts in Flanders (northern half of Belgium) as of 2015 and in the capital and province of Wallonia as of 2019. See this separate map for a focus on pesticide-free and glyphosate-free towns in Belgium here. However, Brussels Times depicts a different story as Belgium is engaged in active litigation by Nature & Progrès (Nature and Progress), PAN Europe, and Bond Beter Leefmilieu (Association for a Better Environment) on the matter of permitting toxic pesticide use including with active ingredients of abamectin this year and a separate action against authorization of organophosphate insecticide indoxacarb last year.

In the U.S., Beyond Pesticides’ Map of U.S. Pesticide Reform Policies includes 18 pesticide free park policies, 47 with restrictions that protect pollinators, 103 that apply to public spaces, and 27 that extend restrictions to private land. Communities across the U.S. are working with Beyond Pesticides and its Parks for a Sustainable Future program to adopt organic land management practices on public and private land within local jurisdictions, eliminating pesticides, and adopting ecological methods and product inputs. See also Tools for Change with model policies, including provisions for pubic and private property.

With the growth of local practices and policies that restrict pesticide use, the chemical industry and its allies are advocating federal U.S policies that preempt local authority as more local officials seek to fill a gap in enhancing public health and environmental protection that falls short under U.S. Environmental Protection Agency’s (EPA) pesticide regulatory policies. The Farm Bill introduced by Republicans in the U.S. House of Representatives will eliminate the right of states and local governments to restrict pesticides and protect public health and the environment, and take away the right to sue for failure to warn when harmed by pesticides. A similar framework has been floated in by Republican Senators.

The European Union in recent years has taken the lead on toxic petrochemical pesticide regulations relative to the United States, although this may change given a series of critical elections in countries including France and Germany. Nathan Donley, PhD and Environmental Health Science Director for the Center for Biological Diversity in September 2022, published in a Brookings Institute article that over 4.37 million pounds of acephate are used annually in the U.S., while banned or being phased out in the European Union, Brazil, and India. Dr. Donley notes that the United States is unable to implement rational regulation of pesticides, as other parts of the world continue to eliminate agricultural use of many of the most toxic pesticides. For example, in 2019 the U.S. used 322 million pounds of 70 agricultural pesticides that are banned in the European Union. Similarly, the U.S. uses 40 million pounds of pesticides banned or phased out in Brazil.

In response to the introduction of pesticide bans and EU climate policies included in the European Green Deal, news outlets such as France24 have reported a groundswell of mass protests from farmers in France, Romania, and Germany who view these policies and the associated upfront costs of transitioning away from petrochemical pesticide use as a threat to their financial stability. France24 reports, “Frustration is…. mounting among farmers across Europe. They are unhappy about bans on pesticides cleared for use in other parts of the world and what they view as unfair competition from Ukrainian grain imports.” A recent analysis in Vox unpacks the current status of the Farm to Fork (F2F) strategy: “By the end of 2023, before most of Farm to Fork had even been implemented, many of its core initiatives were already watered down or abandoned, including pesticide reduction mandates and farm animal welfare improvements. Also declawed was the nature restoration law, which would require EU member states to restore 20 percent of degraded habitats to preserve biodiversity, by calling on farmers to plant tree and flower strips along the edges of fields, for example. Industrial beef and dairy operations were also granted an exemption from industrial emissions targets despite being among the food system’s biggest emitters, responsible for most agricultural methane emissions.”

France has taken a leading role in pesticide bans on public landscapes and private land that is frequently employed for public use, enforcing a strict ban on all pesticides in these areas in 2022. Under previous law, which is now the EU-wide regulation via F2F, France established the target of reducing overall pesticide use by 50 percent by 2030. According to reports by Associated Press, EU Commission President Ursula von der Leyen shelved this pesticide goal for all member states from moving forward in February 2024 amid farmer protests across Europe, including Spain, the Netherlands, and Bulgaria. This break between the interests of farmers and climate policy goals in the European Union demonstrates the significance of U.S. reluctance to commit to a full transition in coordination with F2F strategy in a broader organic farming framework, as Beyond Pesticides has recently reported. For context, USDA announced its Organic Transition Initiative (OTI) last year, providing $300 million USD in technical, insurance, and mentoring support for existing and transitional organic farms in the United States; however, the OTI did not establish an organic farming target similar to the EU approach.

Advocates welcome the growing leadership role of cities and local governments, be it in the United States or across the European Union, as national governments continue to abstain responsibility in preventing the biodiversity collapse, ongoing public health crises, and climate emergency. Subscribe to Action of the Week to learn how to take action in advancing organic land management practices and principles. See Keeping Organic Strong to learn more about the importance of shifting to an organic food system.

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

Source(s): Pesticide Action Network Europe

(Beyond Pesticides, June 25, 2024) It has been a couple of weeks since U.S. Senator John Boozman (R-AR), ranking GOP member on the Senate Agriculture Committee, released the Republican framework vision without statutory language for a Senate Farm Bill that would renew the law’s commitment to chemical-intensive agriculture and undermines efforts to curtail pesticide use and hold chemical company polluters accountable. In his press statement, Sen. Boozman issues an approach that largely mirrors the House-side text, passed by the House Agriculture Committee earlier this month in a 33-21 vote. On the same day that Sen. Boozman announced the framework, the House Agriculture Appropriations Subcommittee approved the federal food and agriculture budget for Fiscal Year 2025 with a $355 million cut from last year’s budget, affecting specific programs that support pollinator health, ecosystem health, and public health related to pesticide use and organic agriculture. The full House Appropriations Committee will vote on this budget on July 10 before moving to the House floor. Advocates are adamant in their resolve to demand more – not less – support from Congress to address the climate emergency, insect apocalypse, and public health implications borne from reliance on toxic petrochemical pesticides and fertilizers.

The Senate GOP framework alludes to federal preemption of state and local governance on pesticides, agriculture, and public health in Title X Horticulture title: “Restates and reaffirms U.S. Environmental Protection Agency’s (EPA) obligation with respect to the federal and state regulatory process.” Moreover, in Title XII Miscellaneous: “Protects the ability of livestock producers to raise and sell products into interstate commerce without interference from other states.” Environmental and health advocates believe that these two points refer to House-approved text carrying over from the Agricultural Labeling Uniformity Act and Ending Agricultural Trade Suppression (EATS) Act, respectively, and would effectively:

• Prohibit the right to sue for failure to warn when harmed by pesticides. In Section 10204 of the House Farm Bill, language shields (gives immunity to) the producers and users of toxic pesticides from liability lawsuits associated with the harm that their products cause. The provision will block lawsuits like those successfully advanced against Bayer/Monsanto for adverse health effects, like cancer, associated with exposure to their products and companies’ failure to warn about these effects on EPA approved product labels.
• Prohibit the rights of states and local governments to restrict pesticides and protect public health and the environment. In Sections 10204 and 10205, language would prevent local and state governments from passing pesticide ordinances or concentrated animal feeding operation (CAFO) regulations that conflict with (aka more stringent than) federal regulations and policy.

Advocates are also concerned about some of the provisions regarding organic agriculture funding. While there is mention of annual increases in National Organic Program funding over the next five years in Title VII Research, Extension, and Related Matters, there is also mention of the need to conduct an “efficacy study” on the Organic Certification Cost-Share program to ensure that it does “not unnecessarily and unreasonably increas[e] the cost of organic certification.” Organic farmers and gardeners have spoken favorably of this program given the upfront costs and barriers to certification that falls on farmers. Expanded funding through the launch of the Biden Administration’s Organic Transition Initiative in 2022 provided $300 million in additional funding to support transitional farmers, including through the cost-share program.

The Fiscal Year 2025 budget for agricultural and food programs that moved out of the House Appropriations subcommittee aligns with industry interests in selecting programs to defund and increase funding based on profits rather than human or ecological wellbeing. For example, according to the funding summary provided by the subcommittee, the Natural Resources Conservation (NRCS) budget is $11.9 million below last year’s enacted level and all funding for climate hubs was rejected. Additionally, the Risk Management Agency (RMS) and Agricultural Marketing Service (AMS)—in which National Organics Standards Board sits—falls $3.8 million and 30.7 million, respectively, below 2024 fiscal year levels. The budget also ignores the importance of centering environmental justice in USDA funding priorities, “Prohibiting the Biden Administration’s executive orders on diversity, equity, and inclusion (DEI); Prohibiting funds for the USDA’s new DEI Office; [and p]rohibiting the use of funds to promote or advance critical race theory.” Safety advocates view this proposed budget as a signal to undermine pesticide regulation and services that farmers rely on to transition to organic practices with the goal of acquiring and attaining certification.

Environmental and health advocates look no further than the substantial body of scientific literature that indicates the holistic benefits of a wholesale transition to organic agriculture and land management practices. A study published in World Journal of Microbiology and Biotechnology finds that organic farming systems have three times the proportion of beneficial fungi relative to chemical-intensive farms that rely on toxic pesticides. “Altogether, our results uncover that beyond differences in microbial community composition between the two farming systems, fungal keystone nodes are far more relevant in the organic farming system, thus suggesting that bacteria-fungi interactions are more frequent in organic farming systems, promoting a more functional microbial community,” according to an interdisciplinary team of Brazil-based researchers responsible for conducting the study. Various other studies corroborate this enhancement of soil health through microbial activity, including a study published this year in Agriculture, Ecosystems & Environment. Farmland managed with organic principles and practices have also been found to lead to a net decrease in greenhouse gas emissions while increase in total farmland (including chemical intensive farmland) leads to an increase in GHG emissions, according to a Journal of Cleaner Production study from 2023.

See Keeping Organic Strong to learn more about engaging with the National Organic Standards Board and the environmental justice, public health, and biodiversity benefits of transitioning to organic. See Action of the Week to demand Congress strengthen funding for organic agriculture and pesticide regulation in the Farm Bill, including this action to tell your U.S. Representative and Senators to support a Farm Bill that promotes a sustainable future.

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

Source: Office of Senator John Boozman

(Beyond Pesticides, June 24, 2024) National Pollinator Week ended last week, but the crisis associated with pollinator decline and biodiversity collapse continues. If there were not enough data to prove that regulators are woefully behind the curve in protecting pollinators, yet another study was published during Pollinator Week that reminded regulators, elected officials, farmers, gardeners, all eaters, and lovers of nature that federal, state, and local environmental laws in place have been an abject and unconscionable failure in protecting the biodiversity that supports all life. The study, “Insecticides, more than herbicides, land use, and climate, are associated with declines in butterfly species richness and abundance in the American Midwest,” published in PLOS ONE, cries out as a further warning that the U.S. Environmental Protection Agency’s (EPA) “mitigation measures,” which tinker with limited pesticide restrictions, represent a catastrophic disregard for the scientifically documented facts, according to environmental advocates.

Daily News will cover this study in more detail in a later piece, however, the abstract of the journal piece is worth reprinting here in reflecting on Pollinator Week:
“Mounting evidence shows overall insect abundances are in decline globally. Habitat loss, climate change, and pesticides have all been implicated, but their relative effects have never been evaluated in a comprehensive large-scale study. We harmonized 17 years of land use, climate, multiple classes of pesticides, and butterfly survey data across 81 counties in five states in the U.S. Midwest. We find community-wide declines in total butterfly abundance and species richness to be most strongly associated with insecticides in general, and for butterfly species richness the use of neonicotinoid-treated seeds in particular. This included the abundance of the migratory monarch (Danaus plexippus), whose decline is the focus of intensive debate and public concern. Insect declines cannot be understood without comprehensive data on all putative drivers, and the 2015 cessation of neonicotinoid data releases in the US will impede future research.”

These issues are not new to readers of Daily News and those who follow the scientific literature. The United Nations states that 80 percent of the 115 top global food crops depend on insect pollination, with one-third of all U.S. crops depending on pollinators, according to the U.S. Department of Agriculture (USDA). However, research finds that many insect populations are in decline, including managed and wild pollinators. Monarchs are near extinction, and commercial beekeepers continue to experience declines that are putting them out of business. The continued loss of mayflies and fireflies disrupts the foundation of many food chains. Additionally, the decline in many bird species has links to insect declines. Since the 1970s, three billion birds have vanished. The United Nations Development Programme in announcing its COP15 (Conference of the Parties) stated: “Despite ongoing efforts, biodiversity is deteriorating worldwide, and this decline is projected to worsen with business-as-usual. The loss of biodiversity comes at a great cost for human well-being and the global economy.” 

All species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA is required to register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.” Under ESA, EPA must, like all federal agencies, “seek to conserve endangered and threatened species and shall utilize their authorities in furtherance of the purposes” of the ESA—which are “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions” through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.”

>> Tell EPA that to meet its obligations under FIFRA and ESA, it must facilitate a transition to organic practices. Tell Congress to ensure that EPA meets its statutory obligations.

In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to FIFRA, whether those harms are “unreasonable” depends on a weighing of costs and benefits. Under a related law, the Federal Food, Drug, and Cosmetic Act, EPA sets allowable residue limits of pesticides in food (tolerances) utilizing risk assessments that have embedded in them the assumption that toxic pesticides are necessary for crop production. In fact, EPA starts with the position that farmers cannot farm without these toxic chemicals, an assumption that clouds and undermines the regulatory process and keeps farmers on the pesticide treadmill. In its Draft Herbicide Strategy Framework update, EPA says, “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” Not true. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured.

The only way to truly protect pollinators, insects, birds, and other species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Converting the world’s agricultural systems to organic would have a tremendously positive impact on threatened populations. Organic farming enhances biodiversity in the ecosystem and mitigates environmental degradation and climate change, all of which is necessary for recovery of threatened and endangered species.

By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. Organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world. Organic farming methods increase carbon sequestration in soils, reducing atmospheric carbon dioxide levels through practices that enhance soil organic carbon, such as using cover crops and organic soil amendments. Furthermore, organic farming reduces the reliance on fossil fuels by eliminating synthetic fertilizers and pesticides, which are energy-intensive to produce.

As part of its update to EPA’s ESA Workplan, EPA has created a “Mitigation Menu Website” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.” The strategy being employed by EPA has been characterized by commercial beekeeper Steve Ellis (more background), saying, “If it’s so complex that it’s impossible, then no one wins.”

Mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are entirely voluntary. There is no enforcement mechanism and no way to ensure that the pesticides are used as directed or that mitigation measures are implemented properly. In addition, EPA is making allowances for use of a pesticide when impacts cannot be avoided. Specifically, EPA plans to allow the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species.” How EPA will ensure that such offsets happen or that they successfully contribute to the conservation of a species of concern has not been described. It also does nothing to protect the habitat necessary for the long-term survival of the species in its ecosystem.

As mentioned above, the only way to truly protect endangered species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Instead of creating a complicated workaround that will not address the urgent health, biodiversity, and climate crises, Beyond Pesticides is urging EPA to cancel the registrations of pesticides that harm endangered species as part of an overall plan to end petrochemical pesticide and fertilizer and facilitate a society-wide conversion to organic practices.

>> Tell EPA that to meet its obligations under FIFRA and ESA, it must facilitate a transition to organic practices. Tell Congress to ensure that EPA meets its statutory obligations.

Letter to EPA:
At the close Pollinator Week, I want to remind you that all species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA may register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.” Under ESA, EPA must “seek to conserve endangered species and threatened species and . . . utilize their authorities in furtherance of the purposes” of the ESA—which are “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions” through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.”

In registering and reregistering pesticides, EPA allows uses that harm humans, other organisms, and ecosystems. EPA starts with the position that farmers cannot farm without these toxic chemicals, which fails to eliminate unreasonable risk. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured.

By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. By eliminating petrochemical pesticides and fertilizers, organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world.

As part of its update to EPA’s ESA Workplan, EPA created a “Mitigation Menu” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.” Farm groups that discussed possible mitigation measures in a series of workshops recognized the complexities in crafting restrictions and pesticide product label changes to protect endangered species. In the words of one participant, “If it’s so complex that it’s impossible, then no one wins.”

Even if EPA can address complications, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are voluntary, with no enforcement mechanism to ensure that the pesticides are used as directed or mitigation measures are implemented properly. Moreover, EPA makes allowances to use a pesticide when impacts cannot be avoided—allowing the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species,” with unknown effectiveness.

The only way to protect endangered species and the ecosystem is to stop the use of pesticides. Instead of creating a complicated work-around that fails to protect, EPA must cancel registrations of pesticides that harm endangered species and facilitate a widescale conversion to organic practices.

Thank you.

Letter to U.S. Representative and Senators:
At the close Pollinator Week, I want to remind you that all species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA may register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.” Under ESA, EPA must “seek to conserve endangered species and threatened species and . . . utilize their authorities in furtherance of the purposes” of the ESA—which are “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions” through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.”

In registering and reregistering pesticides, EPA allows uses that harm humans, other organisms, and ecosystems. EPA starts with the position that farmers cannot farm without these toxic chemicals, which fails to eliminate unreasonable risk. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured.

By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. By eliminating petrochemical pesticides and fertilizers, organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world.

As part of its update to EPA’s ESA Workplan, EPA created a “Mitigation Menu” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.” Farm groups that discussed possible mitigation measures in a series of workshops recognized the complexities in crafting restrictions and pesticide product label changes to protect endangered species. In the words of one participant, “If it’s so complex that it’s impossible, then no one wins.”

Even if EPA can address complications, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are voluntary, with no enforcement mechanism to ensure that the pesticides are used as directed or mitigation measures are implemented properly. Moreover, EPA makes allowances to use a pesticide when impacts cannot be avoided—allowing the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species,” with unknown effectiveness.

The only way to protect endangered species and the ecosystem is to stop the use of pesticides. Please ensure that instead of creating a complicated work-around that fails to protect, EPA cancels registrations of pesticides that harm endangered species and facilitates a widescale conversion to organic practices.

Thank you.

(Beyond Pesticides, June 21, 2024) A recent review of the scientific literature, published in Science of The Total Environment, analyzes multiple species of bees on a molecular level to better understand the poisoning mechanisms that could, as the authors see it, inform chemical risk assessments with more precision. The mechanisms “implicated in the tolerance of bees to specific pesticides, and thus as determinants of insecticide sensitivity, … include metabolic detoxification, insecticide target proteins, the insect cuticle and bee gut microbiota,” the authors write.

This review references more than 90 studies performed over the last 30+ years, with most being published in the last 5-10 years, as the understanding and importance of molecular determinants of bee sensitivity has emerged. Pollinators, such as bees, provide crucial ecosystem services by pollinating both wild plants and essential crops. The exposure these insects are subjected to threatens their existence, which occurs through pesticide contamination that can lead to impacts on growth and development or even colony collapse.   

“While bees have only been exposed to human-made pesticides over the recent past (last 80 years) they have co-evolved with plants and fungi which produce a range of xenobiotics, including plant allelochemicals and mycotoxins,” the authors state. “This has led to the evolution of sophisticated systems that allow bees to detoxify or circumvent the natural xenobiotics they encounter in their environment.” These complex systems are widely different between various insects and within individual species of bees. This review finds that, “Bees can exhibit profound variation in their sensitivity to different insecticides – including to compounds belonging to the same class” in the 20,000+ species throughout the world.

Honeybees (Apis mellifera) are the most widely studied and are the species that the U.S. Environmental Protection Agency (EPA) uses in laboratory testing for pesticide risk assessments. This species has “>1000-fold less sensitive to the neonicotinoid thiacloprid than the neonicotinoid imidacloprid in acute contact bioassays,” while the leaf-cutting bee (Megachile rotundata) is extremely sensitive to many insecticides that are labeled as “moderately and practically non-toxic to honeybees, such as the cyano-substituted neonicotinoid insecticides acetamiprid and thiacloprid and the synthetic pyrethroid insecticide tau-fluvalinate.” This raises the question as to why some bees have greater tolerance to certain insecticides but not others, and what underlying mechanisms create the differences in sensitivity.

In studying the metabolic detoxification within various bee species, cytochrome P450 monooxygenase (P450), an enzyme system that is crucial for detoxification and oxidative metabolism, was found to have the largest role in pesticide sensitivity. The authors find that, “P450s play an important role in bee sensitivity to pyrethroid and neonicotinoid insecticides and may be especially important in the detoxification of chemotypes that exhibit low toxicity to bees.” After identifying P450s as determinants of insecticide sensitivity in bee pollinators, specific genes were studied. “This revealed that P450s belonging to the CYP9Q subfamily, most notably CYP9Q3, metabolise thiacloprid (and acetamiprid) with high efficiency but have limited activity against imidacloprid, providing a molecular explanation for the profound difference in honeybee sensitivity to N-nitroguanidine and N-cyanoamidine neonicotinoids,” the authors share.

In a study of leaf-cutting bees without CYP9Q-type genes, they were up to >2500-fold more sensitive to insecticides after acute contact than honeybees, bumblebees, and red mason bees. This highlights the role of specific genes in metabolic detoxification that not all bee species have, leaving them more vulnerable to certain pesticides. Additional studies on honeybees, specifically Apis cerana, identified five P450 genes (referred to as Acc301A1, Acc303A1, Acc306A1, Acc315A1, and AccCYP6k1) that are altered by several insecticides. When expression of those genes was lower, the mortality rate of the honeybees after pesticide treatment was significantly higher.

The authors postulate that, “P450 genes may have important endogenous functions. Thus, silencing such genes can reduce the overall fitness of… bees, which may, in turn, result in increased sensitivity.” They continue in saying, “The sensitivity of bees to different insecticides within the same mode of action class can also reside in differences in the affinity of these insecticides for their target sites. An excellent example of this is for pyrethroid insecticides, which act on insect voltage-gated sodium channels.” A study on amino acid sequences of sodium channels from 11 bee species and 47 non-bee insect species identified three residues that were specific to bee species but were not present in any other species. This contributes to the low tolerance of certain bees, such as bumblebees, to pyrethroids.

The authors speculate that the role of P450-mediated detoxification across bee diversity also affects target-sites and the alignment of amino acid sequences within various species. They may also play a role in the ability of certain compounds to penetrate the cuticle, which makes up the exoskeleton of a bee. In a study of radio-labeled neonicotinoids, imidacloprid was shown to penetrate the honeybee cuticle much more readily than thiacloprid and acetamiprid. “This variation in penetration speed and internal body concentrations of different neonicotinoids suggest that a pharmacokinetic component contributes to the different acute contact toxicity of these insecticides,” the authors state. “The pharmacokinetics of neonicotinoids may differ for different bee species, and further work on the role of the insect cuticle in influencing bee sensitivity to members of this insecticide class and others is required.”

The last important mechanism identified are bee microbiota. The authors share that, “Emerging research is providing evidence that the sensitivity of bees to insecticides can also be influenced by their microbiome” through direct or indirect detoxification. Previous studies “demonstrate that microbiota derived from honeybee guts have the capacity to detoxify insecticides,” while more recent studies give a potential explanation as to why that occurs. It was found that the presence of several P450 genes played a role. In bees where lower levels of CYP6AS1, CYP6AS3, CYP6AS4, CYP6AS10, CYP9Q2 and CYP9Q3 were found in the midgut of bees, there was a lower tolerance to pesticides such as thiacloprid and tau-fluvalinate.

These results offer more in-depth tools for identifying pesticide sensitivity in insect species, while also highlighting the inadequacies of the current pesticide review process utilized by EPA, as well as the flawed regulations in place, given the complexities of these systems. Certain neonicotinoids have been banned in Europe after a review of their risk to bee health by the European Food Safety Authority (EFSA) and yet are still allowed in the U.S. today. The current system in place 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 II 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, only focus on honeybees and do not take into account the varying sensitivity in other bee species.

U.S. regulatory agencies have a history of ignoring science, as demonstrated with the U.S. Department of Agriculture (USDA) whistleblower case previously covered by Beyond Pesticides in 2016. This case involved a pollinator researcher who says his firing by the agency was retaliation for his cutting-edge research linking neonicotinoid insecticides to declining monarch butterfly populations. A more recent whistleblower case regarding EPA’s risk assessment for both new and existing chemicals occurred in 2021. Four scientists maintain that these assessments were improperly changed by agency managers during the Trump administration. Corruption within EPA has been an ongoing topic for years, with regulatory and statutory failures inflicting harm on health and the environment. Many citizens have expressed intense criticism of EPA’s scientific integrity, and say that the agency has lost sight of its health and environmental mission. Additional examples of EPA’s failure can be seen here, here, here, and here.      

This literature review offers the ability to inform with more specificity pesticide risk assessments, which are a regulatory requirement for pesticide registration. As the authors say, “Risk is defined as a function of hazard (intrinsic toxicity of a chemical) and exposure (expected concentration an organism is exposed to). The hazard assessment is currently largely based on experimental data collected from a handful of ‘model’ bee species such as honeybees and bumble bees. However, bees (Anthophila) are an exceptionally diverse clade of insects with broad differences in ecology and life history traits, and, as demonstrated by the studies reviewed here, can exhibit marked differences in sensitivity to pesticides.”

Leslie W. Touart, Ph.D., senior science and policy analyst for Beyond Pesticides, adds, “Although EPA has identified a full suite of pollinator data requirements, it’s not clear the agency has taken their pollinator protection policies seriously with appropriate data call-ins for existing registered products and ensuring these data are available before granting new or renewed registrations. Agency protective actions when toxicity data and exposure estimates indicate risk typically are limited to label statements such as ‘this product is highly toxic to bees’ or ‘foliar application of this product is prohibited to a crop from onset of flowering until flowering is complete’ as the only mitigation measures implemented.”

The current EPA review system 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 summarizes research with emerging tools that offer the ability to obtain specified data and insight into varied bee species sensitivity. Bees are only one group of insects that are at risk, and the diversity of all detoxification systems for all insects should be considered. While pesticides claim to target only certain types of insects, the variation of genetic and molecular intra- and inter-species mechanisms need to be considered.

The authors conclude, “Finally, bees are exceptionally diverse in their ecology and life history. The expanding data available on the ability of these species to detoxify or circumvent natural and synthetic insecticides offers an excellent opportunity to understand the ecological factors influencing the evolution of xenobiotic detoxification genes in one of the most diverse and ecologically important group of insects on the planet.”

While the authors recapitulate a multitude of studies with data that identify important mechanisms to consider in risk assessments for bee species, they also framed their article with bias. Two of the five authors report that they are employees of Bayer AG, Crop Science Division. Instead of using this scientific evidence to solely inform risk assessment or to provide evidence that supports the need for alternatives to harmful pesticides, the authors say that this should “facilitate the future development of pest-selective bee-safe insecticides.” This research, however, shows that a “bee-safe insecticide” is not possible when each bee species has varying sensitivity. What is considered low toxicity for one species can be highly lethal for another. Widely used systemic pesticides move through the vascular system of plants and are expressed through pollen, nectar, and guttation droplets causing indiscriminate poisoning to bees and other insects who forage the landscape.

To help protect these vital organisms, as well as all wildlife and the environment, the path forward is organic. Everything starts in the soil—healthy, resilient soil reduces any need for pesticides and promotes biodiversity. Terrain free from pesticides benefits wildlife and promotes natural predators that provide natural controls. Organic systems also save wildlife from the dangerous impacts of pesticides, which encourages them to flourish, and they restore the natural balance that is unable to exist in a conventional agricultural system. See Beyond Pesticides’ resources for going and supporting organic here and here.

In further support of bees, Beyond Pesticides has a week’s worth of actions that you can perform at any time in honor of Pollinator Week to help spread the buzz by informing others and eliciting change. In view of EPA’s failure to protect pollinators from pesticides, the lives of those essential insects, birds, and mammals are increasingly dependent on state and local laws that under threat of U.S. Congressional action in the upcoming Farm Bill. The Farm Bill covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—and one provision that the pesticide industry would like to include is preemption of local authority to restrict pesticide use. This attack on local governance would undercut the local democratic process to protect public health and safety, especially important without adequate federal protection of the ecosystems that sustain life. You can tell your U.S. Representative and Senators to support a Farm Bill that promotes a sustainable future.

You can also order a Pesticide-Free Zone sign to showcase your organic yard or garden, share resources with your community, and share photos of pollinators on social media with the hashtags #PollinatorWeek or #ProtectPollinators—then submit them to our Art Page!

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

Source:

Bass, C. et al (2024) The molecular determinants of pesticide sensitivity in bee pollinators, Science of The Total Environment. Available at: https://www.sciencedirect.com/science/article/pii/S0048969724003097.

(Beyond Pesticides, June 18, 2024) As part of its update to the proposed U.S. Environmental Protection Agency (EPA) Endangered Species Act (ESA) Workplan, the agency held a public webinar on June 18, 2024, which provided an overview of the agency’s “Mitigation Menu Website” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” [Check back to see webinar when posted by EPA.] After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Despite this acknowledgement, the agency said it would “provide flexibility to growers to choose mitigations that work best for their situation.” In this spirit, a range of people, including grower groups, gathered earlier in the year for a series of workshops in the Pacific Northwest to discuss possible mitigation measures. According to a report written by commercial beekeeper Steve Ellis (more background), concrete decisions were not reached at the workshops as participants recognized the complexities in crafting pesticide product label restrictions to protect endangered species. Mr. Ellis concluded: “If it’s so complex that it’s impossible, then no one wins.”

For years EPA has failed to comply with the Endangered Species Act (ESA) by not accounting for impacts to threatened and endangered species when approving pesticides for use under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). In 2021, as a result of multiple lawsuits aimed at holding EPA accountable, the agency acknowledged its failure to properly assess impacts on species. To comply with ESA (and compelled by court orders), EPA, working with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service, established a number of “Pesticide Use Limitation Areas” in endangered species’ known or needed habitat and imposed additional pesticide-use restrictions for certain pesticides in those areas. Thus began an effort to improve species assessments and pesticide mitigations to protect vulnerable species.

In July 2023, EPA released the Draft Herbicide Strategy Framework (updated in 2024), which it describes as “an efficient approach to determining the need for, the level of, and geographic extent of early mitigations for listed species from agricultural uses of conventional herbicides.” However, following public comments on these documents, EPA has backtracked on its proposals, introducing a degree of flexibility that critics say will undermine the protection of endangered species.

Beyond Pesticides’ comments on the policy stated the following: “EPA starts with the position that farmers cannot farm without these toxic chemicals, an assumption that clouds and undermines the regulatory process and keeps farmers on the pesticide treadmill. EPA says, ‘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’ Not true. Organic farmers are not reliant on these pesticides.” (See Beyond Pesticides’ comments.)

As EPA explains, the purpose of the webinar is to familiarize users with the “Mitigation Menu Website” and how to navigate it. At the meeting on July 18, EPA’s webinar will include:

1. A brief background on the goal and development of the mitigation menu,
2. A demonstration of how users would follow new label directions using the website,
3. An explanation of how to navigate the website,
4. Directions on how to access other resources associated with the website, and
5. An opportunity for questions and feedback on the proposed function of the menu, the website, and the use of the website for ESA strategies and additional types of mitigation (e.g., spray drift).

The Pacific Northwest workshops, held in Oregon and Washington, demonstrated that EPA is a long way from developing a usable mitigation program. The last in the series of workshops was held over two days in late May in Vancouver, Washington.  Approximately 40 stakeholders, including growers, pesticide manufacturers and applicators, state regulators, academics, and other interested parties, got together to perform a “test run” on the proposed mitigation strategy. What they found was a process so cumbersome and convoluted that it cannot be taught, implemented, or enforced.

Under the new protocol, pesticide labels will now direct users to an EPA website called Bulletins Live Two. The website is supposed to assist users in determining if a particular geographical area is subject to “Pesticide Use Limitations” and if so, which mitigation measures must be followed to protect threatened and endangered species that may be present at the site.

Restrictions are designed to reduce the risk of a pesticide moving from its targeted species into the ecosystem where it may have unintended harmful effects on threatened and endangered species. Applicators use a point system developed by EPA to determine if enough mitigation measures can be applied to allow for the use of the pesticide in a use limitation area.

To test this methodology, workshop participants were given hypothetical scenarios for pesticide application and asked to determine which, if any, mitigation measures should be applied. But the participants found stumbling blocks from the beginning. For starters, users found the point system to be complex and cumbersome. In addition to it being a mathematical challenge, points must be recalculated every six months when new bulletins are released with new instructions and restrictions for individual pesticides.

Even more problematic was the EPA website where participants were to reference both location and mitigation information. Pesticide labels referred people to differing EPA websites. The Bulletins Live website did not work properly on cell phones and determining the location of hypothetical application was “overly complicated.”

Once the appropriate bulletins were identified on EPA’s website for the location and type of pesticide, implementing the mitigation measures proved even harder with multiple sources of mitigation guidance, including the pesticide label and the latest EPA bulletin. Moreover, users were offered a choice of various mitigation measures that were reiterated with different wording, causing confusion and doubt. Essentially, users were left to determine on their own which measures were most appropriate and effective for their case. Ultimately, what the group found was that the guidance was not appropriate to real-world applications where users may be applying more than one pesticide at a time or where users were not fully versed in math or English.

Among the improvements recommended by the workshops were improved technology that would allow users to simply determine appropriate parameters for using pesticides under their specific conditions. Another suggestion was to move away from blanket, nationwide mitigation measures and rely on state or local agencies responsible for determining appropriate mitigation measures in their region.

Even if EPA is able to fix some of the technological problems with its website, mitigations only lessen the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are entirely voluntary. There is no enforcement mechanism and no way to ensure that the pesticides are used as directed or that mitigation measures are implemented properly.

Vulnerable Species Pilot Program

As Beyond Pesticides reported in February 2024, EPA appears to have put on hold its vulnerable species pilot projects after vociferous comments from the petrochemical pesticide industry, and instead opted to “create a narrow, tailored policy rather than a sweeping, burdensome one,” according to an op-ed in the Wall Street Journal. EPA has now announced it will not implement the VSP at least until its habitat maps are improved. Then in April 2024, Beyond Pesticides reported on rollbacks to the Draft Herbicide Strategy Framework that “simplified” EPA’s approach, increased growers’ “flexibility” when applying mitigation measures, and reduced the mitigation measures required in certain situations. Together these regulatory rollbacks will significantly reduce the success of EPA’s efforts to comply with the ESA and protect vulnerable plants and animals.

Throughout the herbicide strategy formulation process, EPA has repeatedly buckled to the interests of pesticide manufacturers. As described above, initial EPA proposals have repeatedly been weakened and it appears that EPA will consider further rollbacks. For example, in February 2024, EPA said they would “develop guidelines that the public can use to develop and submit refined maps for hundreds of other endangered species,” instead of basing such maps on academic studies of species locations. In the same announcement, EPA went on to say it was “considering which mitigations, if any, are needed on land that is dry or flat or both,” instead of basing mitigations on the specifics of the soil type, species of concern, and type of pesticide.

EPA is also making allowances for use of a pesticide when impacts cannot be avoided. Specifically, EPA plans to allow the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species.” How EPA will ensure that such offsets happen or that they successfully contribute to the conservation of a species of concern has not been described.

The only way to truly protect endangered species, as well as the ecosystem, is to stop the use of pesticides completely. Converting the world’s agricultural systems to organic would have a tremendous positive impact on endangered species populations. Organic farming enhances biodiversity in the ecosystem and mitigates environmental degradation and climate change, all of which is necessary for recovery of threatened and endangered species.

By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. This biodiversity is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. (See here, here, and here). Organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world. Organic farming methods increase carbon sequestration in soils, reducing atmospheric carbon dioxide levels through practices that enhance soil organic carbon, such as using cover crops and organic amendments. Furthermore, organic farming reduces the reliance on fossil fuels by eliminating synthetic fertilizers and pesticides, which are energy-intensive to produce.

Advocates of organic agriculture argue that instead of spending millions of dollars and many years creating mitigation programs that are unenforceable and ineffective, EPA should spend the same amount of time and money supporting transition to organic agriculture and supporting farmers in exiting the toxic pesticide treadmill. As Rodale Institute writes, “Organic farming is not simply the substitution of approved input materials. It is the replacement of a treatment approach with a process approach to create a balanced system of plant and animal interactions.” The European Union has already far surpassed the United States in this effort by setting ambitious targets to increase organic farmland and provide substantial funding to support organic farmers. Similar initiatives could help to overcome the barriers to adopting organic practices in the United States, contribute to the conservation of threatened and endangered species, and ensure a sustainable and healthy future for global agriculture.

Beyond Pesticides is calling for an end to all petrochemical pesticide and fertilizer use by 2032 and accelerate the adoption of organic farming and land use. While many observers of regulatory failure may be tempted to feel hopeless, change can be driven by market demand. Organic agriculture is growing, and consumers have created not just a market for organic produce and crops, but momentum for responsible food production provided by organic methods.

To appreciate the importance of consuming organic food, it is essential to recognize the benefits of eliminating pesticides throughout the food production process. This elimination protects farmworkers, air, water, land, and biodiversity, in addition to ensuring food safety. (Refer to Beyond Pesticides’ Eating with a Conscience database for a comprehensive overview of the benefits of organic food production.) The continued growth in organic sales and land use indicates a significant shift in the agricultural and food production sectors as more people become aware of the detrimental effects of agribusiness on ecosystems and human health. For more information on organic agriculture and its history, Beyond Pesticides’ website offers extensive resources. To learn about the health benefits of organic agriculture, visit Beyond Pesticides’ Organic Agriculture webpage.

Beyond Pesticides is a member of the National Organic Coalition (NOC). The coalition’s materials provide up-to-date information on organic agriculture policy in the U.S., including Farm Bill recommendations and discussions. Beyond Pesticides has strategically sought to transform our country’s approach to pest management, both agricultural and residential/structural, by eliminating reliance on pesticides and advancing organic management practices that do not rely on toxic inputs. In this context, EPA’s failure to protect endangered species from unnecessary pesticide exposure is yet an example of chemical industry influence resulting in inadequate underlying laws and regulations. We must teach that these chemicals are not only dangerous to environmental health but are unnecessary to prevent pests and achieve pest management goals. 

Please see the Daily News Blog and Take Action features on the Beyond Pesticides’ website homepage, and join Beyond Pesticides  to support our campaign to end the use of toxic pesticides. 

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And, as we celebrate national Pollinator Week, please visit Beyond Pesticides’ website for proactive pollinator-friendly actions you may take each day to support critical pollinator health. Together, our actions – small and large- can make a difference!

Today’s featured image: “New England Aster with Monarch Butterfly” by Julia from Manasses, VA!

Thursday—Identifying and Planting for Pollinators
With pollinators responsible for over 80% of the world’s flowering plants, it’s no wonder we are fighting to protect them. Pollinators are important members of various land ecosystems, therefore how we manage these ecosystems and landscapes plays a critical role in long-term pollinator health. The expansion of urban, suburban, and agricultural areas reduces pollinator habitat and access to food, while intensive chemical use harms these beneficial organisms. Pesticide applications expose bees, birds, butterflies, and more to acute and sublethal levels of pesticides, which can result in reproductive abnormalities, impaired foraging, and even death. Please see our brief introduction to pollinators here! 

What can we do? You can play a role in protecting pollinators simply by making an organic garden with colorful, bee-attractive flowering plants, pledging it as pollinator-friendly, or even organizing your community, schools, or local government to make choices that foster pollinators. Don’t have a garden? Windows and balconies are also great places to feature plants to encourage pollinators to stop by! Backyard trees, gardens, and beekeeping are great ways to support biodiversity and pollinators. Intentionally providing water, food, and forage to pollinators will encourage and boost pollinator populations in your community. 

It helps to review Organic Lawn Care 101 best practices and know your weeds—simple steps to convert your lawn to organic! Check out the BEE Protective Habitat Guide for more information; the Do-It-Yourself Biodiversity resource offers hints about increasing biodiversity; and the Pollinator-Friendly Seed Directory.

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

Sources:

Register for EPA’s Webinar on Mitigation Menu Website to Protect Nontarget Species from Pesticide Exposure, EPA announcement, June 4, 2024

Work Group Aims to Make New Endangered Species Rules Workable, Western Integrated Pest Management Center newsletter, June 2024

Implementing EPA’s Workplan to Protect Endangered and Threatened Species from Pesticides:

Pilot Projects Vulnerable Species Project, Herbicide Strategy Hawaii Strategy Insecticide Strategy

Endangered Species Act Workplan Update – Nontarget Species Mitigation for Registration Review and Other FIFRA Actions, EPA Workplan Update, November 2022

EPA 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, EPA Draft Plan, July 2023

Vulnerable Listed (Endangered and Threatened) Species Pilot Project: Proposed Mitigations, Implementation Plan, and Possible Expansion, EPA Draft Plan, June 2023

Calls for Holistic Environmental Justice and a Shift Away from Societal Dependence on Petrochemical Pesticides and Fertilizers

(Beyond Pesticides, June 18-19, 2024) Juneteenth (June 19) commemorates the date in 1865 when the enslavement of Black Americans ended in the westernmost Confederate state of Texas, over two and a half years after the Emancipation Proclamation of 1863 and the defeat of the Confederacy on April 9, 1865. On June 19, 1865, Union Major General Gordon Granger brought federal troops to Galveston, Texas and finally, and belatedly, implemented the Emancipation Proclamation, which proclaimed on January 1, 1863 freedom from slavery across the nation.

Carl Mack, PhD, a historian and former President of the Seattle-King County NAACP, reminds us that there were still 225,000 enslaved Black Americans in Kentucky and Delaware after June 19, 1865 and the end of the Civil War until December 6, 1865 when Georgia became the 27^th state to ratify the 13^th amendment. “That is the day in which Georgia ratified the 13^th amendment,” Dr. Mack goes on to discuss the remaining three former border states on their progress in adopting the 13^th amendment. “As it applies to Delaware and Kentucky, Delaware did not ratify the 13^th amendment until 1901. Kentucky ratified the 13^th amendment in 1976 and the state that I’m from—Mississippi—didn’t ratify the 13^th amendment until February 7, 2013 [the last eligible state to do so, according to Equal Justice Initiative and ABC News].”

These persisting lapses of freedom are emblematic of continued delays in equal protection under environmental statutes in the realm of pesticide and chemical exposure that persist today, as people of color and communities experience disproportionate harm from toxic chemicals.

A report released in January, US pesticide regulation is failing the hardest-hit communities. It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” 

As National Pollinator Week coincides with the Juneteenth commemoration, it is time to renew our commitment to environmental justice, while seeking the adoption of transformative solutions that recognize the urgency to address disproportionate harm caused by toxic pesticide production, transportation, use, storage, and disposal. We affirm on Juneteenth and Pollinator Week the urgent need to support healthy ecosystems that sustain lives that are being catastrophically harmed by escalating existential pesticide-induced health crises, biodiversity collapse, and the climate emergency—all disproportionately affecting people of color in the U.S. and worldwide.

From fenceline communities near chemical production plants to the hazardous and inhumane working conditions in agricultural fields, to the elevated risk factors for Black, Indigenous, and People of Color (BIPOC) from toxic pesticide exposure, the struggle for protection continues as society must shift away from a reliance on petrochemical pesticides and fertilizers and end their use.

Environmental Justice and Pesticides

In a 2022 interview with Southern Environmental Law Center, Robert Bullard, PhD—the father of environmental justice—defines environmental justice as the embracement of “the principle that all communities, all people, are entitled to equal protection of our environmental laws, housing laws, transportation laws…civil rights laws, human rights laws, and health laws and regulations.” In the January report co-written by Dr. Bullard and Nathan Donley, PhD, environmental health science director at the Center for Biological Diversity, the history of the U.S. Environmental Protection Agency’s (EPA) failure to live up to its environmental justice commitments are laid out. See here for additional coverage.

In April 2021, EPA Administrator Michael Regan directed all EPA offices to clearly integrate environmental justice considerations into their plans and actions, saying, “Too many communities whose residents are predominantly of color, Indigenous, or low-income continue to suffer from disproportionately high pollution levels and the resulting adverse health and environmental impacts. We must do better. This will be one of my top priorities as Administrator, and I expect it to be one of yours as well.” This effort follows President Biden’s Executive Order, Modernizing Regulatory Review (January 20, 2021), which mandates the adoption of agency policy across government to seriously and with urgency confront disproportionate harm to people of color communities (environmental racism) with the directive to “forward health, racial equity, and environmental stewardship.” Yet, the institutionalized protection of chemical companies that are marketing pesticides no longer needed to grow food and maintain our quality of life is integral to EPA’s Office of Pesticide Programs, which supports pesticide dependency through its pesticide registration program and continued insistence in putting forward “risk mitigation” measures that are unrealistic in calculating harm and ignoring the devastating effects caused by pesticides—from cancer, neurological effects, reproductive dysfunction, to respiratory disease and major public health threats like diabetes, Parkinson’s disease, and Alzheimer’s.

The Bullard/Donley review found that Black Americans are “more than twice as likely [as whites] to live within a mile of a hazardous chemical facility.” In spite of this higher likelihood of proximity to toxic petrochemical pesticides, there is an absence of equity and action by both EPA and Occupational Safety and Health Administration (OSHA). OSHA has virtually abandoned responsibility for occupational protection and redirected it to EPA. Bullard and Donley identify that the Food Quality Protection Act of 1996 (FQPA), which revised the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act, set a new safety standard of ” ‘reasonable certainty that no harm will result’ to people exposed to pesticides through food and all other non-occupational exposure routes,” explicitly excluding occupational exposure. This impacts not only BIPOC communities living near chemical facilities, but also those living near crop fields sprayed with these pesticides.

There is various documentation of disproportionate risks that BIPOC communities face due to generations of structural and institutional barriers. A 2022 study published in BMC Public Health documents evidence of disparities through existing literature and datasets, reaching the following conclusions:

“These disparities are being perpetuated by current laws and regulations through

1. a pesticide safety double standard,
2. inadequate worker protections, and
3. export of dangerous pesticides to developing countries.

Racial, ethnic, and income disparities are also maintained through policies and regulatory practices that

4. fail to implement environmental justice Executive Orders,
5. fail to account for unintended pesticide use or provide adequate training and support, fail to effectively monitor and follow-up with vulnerable communities’ post-approval, and fail to implement essential protections for children.”

A 2024 Consumer Reports analysis of pesticide residues corroborates decades of concerns from advocates regarding the failure of the existing risk assessment process to demonstrate heightened health risk levels for communities of color. Federal agencies typically point to acceptable or legal residues as an indication that they are taking responsibility—for example, the U.S. Department of Agriculture’s (USDA) 2022 Pesticide Data Program Annual Summary found that 99% of produce the agency tested “had residues below the established [EPA] tolerances,” despite potential adverse effects associated with inadequate assessment of health outcomes, such as endocrine disruption, vulnerable population groups, exposure to mixtures and synergistic interactions, and more.

The invisible threat of pesticides results in clearly visible consequences, as Beyond Pesticides sheds light on the hidden dangers of pesticide exposure and the disproportionate impact it has on marginalized communities. Communities of color and economically disadvantaged areas bear a heavier burden of pesticide exposure, leading to higher rates of health issues, including respiratory problems, developmental disorders, and certain cancers. From agricultural workers to residents of low-income neighborhoods, the adverse health effects of pesticides are not evenly distributed. The use of pesticides without adequate consideration for their health impacts constitutes a form of environmental injustice.

See Pesticide-Induced Diseases Database and Gateway on Pesticide Hazards and Safe Pest Management to follow the latest scientific literature on specific diseases and adverse health conditions linked to pesticide exposure—resources include fact sheets, uses, health and environmental effects, and alternatives.

Environmental Injustice on Farmland, Wood Treatment Facilities & CAFOs

Be it concentrated animal feeding operations (CAFOs) or wood treatment facilities, communities of color face the brunt of toxic petrochemical pesticide and chemical use.  

A recent EPA Inspector General Report in April echoes criticism over the course of the Biden Administration regarding the federal government’s inadequate response to the public’s risk to “residual contamination in the groundwater and soil.” The report emphasizes EPA’s weak response at the American Creosote Works Superfund site in Pensacola, FL, a problem that reflects the unending dangers of sites contaminated with persistent toxic chemicals associated with wood preservatives, which are felt disproportionately by majority Black communities nationwide. The Pensacola site was put on the Superfund priority list in 1983 and in 2017, it was estimated that the clean-up would cost $35.3 million. Just last year, EPA Administrator Michael Regan toured another Superfund Site contaminated with creosote and pledged the clean-up of that site, which affects a community of predominantly people of color. Advocates continue to urge EPA to cancel the registration of highly toxic wood preservatives, including creosote, chromated arsenicals, and copper compounds, and demand action from Congress to ensure the prevention of future site contaminations.

Rural communities and communities of color living in proximity to CAFOs tend to face heightened risk of chronic breathing issues like asthma and respiratory diseases such as chronic, obstructive pulmonary disease (COPD), based on a 2022 study published in Immunology and Allergy Clinics of North America. Going back to 2020, advocates continue to call for Congress to enact the Farm System Reform Act which would put a moratorium on factory farms by 2040 and hold operators accountable for associated health harms they impose on surrounding communities and their workers.

Take Action Today

What can we do? You can speak up for environmental justice and urge EPA and other federal agencies to adopt meaningful programs that take out of the pipeline of production, use, storage, and disposal hazardous chemicals that are having disproportionate adverse effects in people of color communities.

>> Take action by telling EPA that it needs to make environmental justice connections! 

Become an advocate for targeted support for small-scale organic farmers facing unprecedented uncertainty. See Agricultural Justice to learn more about Beyond Pesticides’ origins and commitment to organic land management principles after witnessing farmworker occupational and living conditions. See Keeping Organic Strong to learn about our priorities for equity and the environmental justice benefits of an organic food system.

• Consider supporting Sanctuary Farms in Detroit, Michigan—A message from jøn kent, co-founder:
  “Sanctuary Farms is a sustainable organization that focuses on closing the food loop through two main objectives: cultivating organic produce and creating nutritious compost. We cultivate the land through our composting and permaculture (no-till method) gardening practices. With these goals we want to foster a thriving community on the lower eastside of Detroit where people are safe, healthy and connected to their local environment and food by actively being involved in closing the food loop. We are practicing the tenets of food sovereignty and environmental justice by providing examples of the possibilities of what can be accomplished and reimagined in our communities from folks who live within the area. The long term goal is to put this land into a community land trust to provide folks in the Riverbend community with direct equity in the property with the purpose of ceasing potential displacement. If possible please consider supporting our cause here.”

• Consider supporting The Black Institute—The Black Institute (TBI) isn’t a think-tank, it’s an action-tank. Through a “head, heart, and feet strategy,” TBI injects new ideas for achieving racial equity and environmental justice into the policy realm. An Eco-Friendly Parks for All (EFPA) coalition partner, TBI is a leader in advancing organic land management legislation in NYC that bans toxic pesticides. [Poison Parks]

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

(Beyond Pesticides, June 17, 2024) Every year, Beyond Pesticides announces National Pollinator Week—this year beginning today, June 17—to remind eaters of food, gardeners, farmers, communities (including park districts to school districts), civic organizations, responsible corporations, policy makers, and legislators that there are actions that can be taken that are transformative. All the opportunities for action to protect pollinators, and the ecosystems that are critical to their survival, can collectively be transformational in eliminating toxic pesticides that are major contributors to the collapse of biodiversity. This is why Beyond Pesticides starts most discussions and strategic actions for meaningful pollinator and biodiversity protection with the transition to practicing and supporting organic.

In launching National Pollinator Week, Beyond Pesticides makes suggestions for individual actions to increase efforts to think and act holistically to protect the environment that supports pollinators. The impact that people have starts with grocery store purchases and the management of gardens, parks, playing fields, and pubic lands. The introduction of pesticides into our food supply and our managed lands has contributed to a downward spiral that is unsustainable. The good news is that it is now proven that we do not need toxic pesticides to grow food productively and profitably and that these chemicals are not required to manage ballfields, parks, and public spaces.

That is why in very realistic terms Beyond Pesticides says that pollinator protection starts with organic practices. Pollinators—bees, butterflies, birds, bats, and other organisms—make a critical contribution to plant health, crop productivity, and the preservation of natural resources, but their existence is threatened by their pesticide-contaminated habitat. Throughout the week, Beyond Pesticides will suggest actions that can be taken to promote the health of pollinators. Although these actions can include the establishment of pollinator-friendly plants, the first step is providing a safe place for pollinators to live, eat, reproduce, and take refuge from predators and adverse weather. In this context, pollinator conservation begins with organic management of their environment.

A great way to get grounded in Pollinator Week
See the keynote talk by David Goulson, PhD from Beyond Pesticides 40^th National Forum, Forging a Future with Nature. In his book, A Sting in the Tale (2013), Dr. Goulson writes, “We need worms to create soil; flies and beetles and fungi to break down dung; ladybirds and hoverflies to eat greenfly; bees and butterflies to pollinate plants to provide food, oxygen, fuel and medicines and hold the soil together; and bacteria to help plants fix nitrogen and to help cows to digest grass. . . [yet] we often choose to squander the irreplaceable, to discard those things that both keep us alive and make life worth living. Perhaps if we learn to save a bee today we can save the world tomorrow?” He is also the author of the Sunday Times bestseller The Garden Jungle: or Gardening to Save the Planet (2019).  And in his most recent book, Silent Earth: Averting the Insect Apocalypse (2021), he writes, “We have to learn to live in harmony with nature, seeing ourselves as part of it, not trying to rule and control it with an iron fist. Our survival depends on it, as does that of the glorious pageant of life with which we share out planet.”

More background
Pollinators––bees, butterflies, birds, bats, and other organisms––make a critical contribution to plant health, crop productivity, and the preservation of natural resources. However, pesticides consistently act as a key contributor to dramatic pollinator declines. Much research attributes the decline of insect pollinators over the last several decades to the interaction of multiple environmental stressors, from climate change to pesticide use, disease, habitat destruction, and other factors. Roughly a quarter of the global insect population has disappeared since 1990, according to research published in the journal Science. Monarchs are nearing extinction, and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies, the foundation of many food chains, and fireflies, the foundation of many childhood summer memories. The declines in many bird species likely have close links to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, have been lost since the 1970s. In a world where habitat loss and fragmentation show no sign of abating, scientists have concluded that the globe cannot afford to continue to subject its critically important wild insects to these combined threats. 

Toxic pesticide residues also threaten ecosystem functions needed to support life, frequently found in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. The scientific literature demonstrates pesticides’ long history of adverse environmental effects, especially on wildlife, biodiversity, and human health. Notably, pesticides are immensely harmful to pollinators. The pervasiveness of pesticide exposure combined with climate change threatens global species biodiversity. The globe is currently undergoing Earth’s sixth mass extinction, with one million species of plants and animals at risk. With the increasing rate of biodiversity loss, it is essential to provide protection from pesticides by adopting organic agriculture and land care methods. A study in the journal Nature found that, “The interaction between indices of historical climate warming and intensive agricultural land use is associated with reductions of almost 50% in abundance and 27% in the number of species within insect assemblages relative to those in less-disturbed habitats with lower rates of historical climate warming.”

Over the last decade and a half, increasing scientific evidence shows a clear connection between the role of pesticides in the decline of honey bees and wild pollinators. In the U.S., an increasing number of pollinators, including the American bumblebee and monarch butterfly, are being added or in consideration for listing under the Endangered Species Act, with specific chemical classes like systemic neonicotinoid insecticides putting 89% or more of U.S. endangered species at risk. Pesticides intensify pollinators’ vulnerability to health risks (such as pathogens and parasites), with pesticide-contaminated conditions limiting colony productivity, growth, and survival. Past research finds that notorious bee-killing neonicotinoid insecticides kill bees outright, resulting in a range of complex damage, including their ability to impede bees’ olfactory senses and adversely affects their vision and flying ability. Other chemicals like glyphosate weaken bees’ ability to distinguish between colors. A 2018 study found that commonly used neonicotinoid insecticides begin to kill off bumblebees during their nest-building phase, as exposure makes it more difficult for a queen to establish a nest. Exposure to neonicotinoids results in bumblebee colonies that are much smaller than colonies not exposed to these systemic insecticides. Spray applications of various agrichemicals affect the visitation patterns of pollinators through a range of different processes. Neonicotinoid exposure decreases pollination frequency, resulting in fewer social interactions as the chemical alters bumblebee feeding behavior and degrades the effectiveness of bumblebees’ classic “buzz pollination” process. A study published in 2017 determined that fungicides also play a significant role in bumblebee declines by increasing susceptibility to pathogens.

Organic practices require not only refraining from the use of synthetic pesticides and fertilizers, but also taking positive actions to promote biodiversity. Providing organic habitats can protect pollinators, and all species, including humans, that depend on their ecosystem services.

We launch Pollinator Week 2024 with our webpage of actions below. Everything here you can find on our webpage, National Pollinator Week Kicks Off with a Week of Actions!

Monday
Pollinator Protection Starts with Organic Practices
The week of June 17 is National Pollinator Week, which allows us to recognize—and take action to protect—these vital ecosystem members. >>Tell your Governor to adopt organic practices on state lands.

In addition, millions of miles of roads, utility lines, railroad corridors, and other types ofrights-of-way (ROWs) are treated with pesticides to control unwanted plants and insects. Some states have addressed the risk of using pesticides along ROWs by developing integrated pest management (IPM) programs, restricting when and where pesticides can be applied on ROWs and/or providing no-spray agreements. Planting native vegetation, using mechanical, biological, and least-toxic vegetation control methods are effective in reducing and eliminating toxic pesticide applications.

What can we do? Encourage your community to develop an integrated roadside vegetation management program for roadside management. Cut, girdle, mow or use grazing animals whenever possible as a mechanical means to eradicate unwanted vegetation. Establish a roadside wildflower program that plants native flower and grass species, especially those that are attractive to bees and other pollinators. Avoid pesticides such as 2,4-D, glyphosate (Roundup), dicamba, picloram, and triclopyr for roadside management. Look to our Pesticide Gateway page for more information! 

  Monday’s featured image: “Bumble and Lupine” by Barbara from Bend, OR!

 

Tuesday
Become an organic parks advocate in your community.

Envision an organic community where local parks, playing fields, and greenways are managed without unnecessary toxic pesticides, children and pets are safe to run around on the grass, and bees and other pollinators are safeguarded from toxic chemicals. At Beyond Pesticides, this is the future we envision and are working to achieve.

Our Parks for a Sustainable Future program is an in-depth training assists community land managers in transitioning two public green spaces to organic landscape management, while aiming to provide the knowledge and skills necessary to eventually transition all public areas in a locality to these safer practices.

Beyond Pesticides is interested in working with you to encourage your community to transition to organic. Our training program starts small, with two pilot sites, but often becomes the basis for broader change to land care practices throughout the entire community.

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.

Wednesday
Juneteenth and Environmental Justice
As Pollinator Week coincides with the Juneteenth celebration, the time is now to renew our commitment to environmental justice while seeking the adoption of transformational policies and practices that recognize the urgency to address disproportionate harm inflicted by toxic pesticide use.  Those fighting for environmental justice understand that the harms inflicted by toxic chemical production and use cause disproportionate adverse effects on people of color—from fenceline communities near chemical production plants to the hazardous and inhumane working conditions in agricultural fields, to the elevated risk factors for Black, Indigenous, and People of Color (BIPOC) from toxic pesticide exposure.  

In a 2022 interview with Southern Environmental Law Center, Robert Bullard, PhD – known as the father of environmental justice – defines environmental justice as the embracement of “the principle that all communities, all people, are entitled to equal protection of our environmental laws, housing laws, transportation laws…civil rights laws, human rights laws, and health laws and regulations.” Earlier this year, Dr. Bullard co-wrote a report for the Brookings Institute entitled, US pesticide regulation is failing the hardest-hit communities. It’s time to fix it, that describes U.S. Environmental Protection Agency’s (EPA) failure to live up to its environmental justice commitments as laid out in various presidential directives under the Biden Administration.

You can speak up for environmental justice and urge EPA and other federal agencies to adopt meaningful programs that take out of the pipeline of production, use, storage, and disposal hazardous chemicals that are having disproportionate adverse effects in people of color communities. >> Take action by telling EPA that it needs to make environmental justice connections.

Become an advocate for targeted support for small-scale organic farmers facing unprecedented uncertainty. See Agricultural Justice to learn more about the origins of Beyond Pesticides and a commitment to organic land management principles after witnessing farmworker occupational and living conditions. See Keeping Organic Strong to learn about our priorities for equity and the environmental justice benefits of an organic food system.

Two organizations you can support on Juneteenth:

• Consider supporting Sanctuary Farms in Detroit, Michigan. A message from jøn kent, co-founder of Sanctuary Farms: “Sanctuary Farms is a sustainable organization that focuses on closing the food loop through two main objectives: cultivating organic produce and creating nutritious compost. We cultivate the land through our composting and permaculture (no-till method) gardening practices. With these goals we want to foster a thriving community on the lower eastside of Detroit where people are safe, healthy and connected to their local environment and food by actively being involved in closing the food loop.
• Consider supporting the The Black Institute: The Black Institute (TBI) isn’t a think-tank, it’s an action-tank. Through a “head, heart, and feet strategy,” TBI injects new ideas for achieving racial equity and environmental justice into the policy realm. An Eco-Friendly Parks for All (EFPA) coalition partner, The Black Institute is a leader in advancing organic land management legislation in New York City that bans toxic pesticides. [Poison Parks] 

Thursday
Identifying and Planting for Pollinators
With pollinators responsible for over 80% of the world’s flowering plants, it’s no wonder we are fighting to protect them. Pollinators are important members of various land ecosystems, therefore how we manage these ecosystems and landscapes plays a critical role in long-term pollinator health. The expansion of urban, suburban, and agricultural areas reduces pollinator habitat and access to food, while intensive chemical use harms these beneficial organisms. Pesticide applications expose bees, birds, butterflies, and more to acute and sublethal levels of pesticides, which can result in reproductive abnormalities, impaired foraging, and even death. Please see our brief introduction to pollinators here! 

You can play a role in protecting pollinators simply by making an organic garden with colorful, bee-attractive flowering plants, pledging it as pollinator-friendly, or even organizing your community, schools, or local government to make choices that foster pollinators. Don’t have a garden? Windows and balconies are also great places to feature plants to encourage pollinators to stop by! Backyard trees, gardens and beekeeping are great ways to support biodiversity and pollinators. Intentionally providing water, food and forage to pollinators will encourage and boost pollinator populations in your community. 

It helps to review Organic Lawn Care 101 best practices and know your weeds—simple steps to convert your lawn to organic! Check out the BEE Protective Habitat Guide for more information; the Do-It-Yourself Biodiversity resource offers hints about increasing biodiversity; and the Pollinator-Friendly Seed Directory.

Additionally, check out the short film “The Seeds That Poison,” a Beyond Pesticides’ feature video highlighting the hazards associated with a major use of bee-toxic pesticides—seed coatings!  

Friday
Time to Spread the Buzz!
In view of EPA’s failure to protect pollinators from pesticides, the lives of those essential insects, birds, and mammals are increasingly dependent on state and local laws that under threat of U.S. Congressional action in the upcoming Farm Bill. The Farm Bill covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—and one provision that the pesticide industry would like to include is preemption of local authority to restrict pesticide use. This attack on local governance would undercut the local democratic process to protect public health and safety, especially important in the absence of adequate federal protection of the ecosystems that sustain life. >> Tell Your U.S. Representative and Senators to support a Farm Bill that promotes a sustainable future.

What else can we do? Order a Pesticide-Free Zone sign to showcase your organic yard or garden, share resources with your community, and share photos of pollinators on social media of with the hashtags #PollinatorWeek or #ProtectPollinators—then submit them to our Art Page! 

The banner highlights art submissions from members of the public to our Art Page! 🐝 Today’s featured image above: “Bumble and Lupine” by Barbara from Bend, OR!

(Beyond Pesticides, June 14, 2024) The influence of the chemical industry over public policy and regulation, especially in agriculture, is glaringly obvious and has little popular support, yet no one can seem to do anything about it. Numerous analyses have detailed the ways this influence is applied—through lobbying and political donations including dark money; industry experts named to regulatory agency scientific advisory boards; and the massive public relations machines that create and sustain public uncertainty using the tobacco industry playbook revealed by Naomi Oreskes and Erik Conway in their 2010 book Merchants of Doubt.

A more insidious tendril of industry influence is explained in U.S. Right to Know’s (USRTK) report, released this month, on pesticide manufacturers’ infiltration of the Entomological Society of America (ESA). The report, “Anatomy of a science meeting: How controversial pesticide research all but vanished from a major conference,” examines the ESA’s 2023 annual meeting—its program, sponsorships, presentations, panelists, poster sessions, meet-and-greets, budget, revenue sources, and other aspects of the event. What is revealed is a systematic and comprehensive industry presence throughout the society and its meeting. A direct consequence is the near-elimination of any scientific presentations addressing the effects of neonicotinoid pesticides on insects, particularly bees. Those effects are dire, as Beyond Pesticides has detailed in great detail here, here and here.

ESA, with nearly 7,000 members, is the largest organization dedicated to insect research in the world. It publishes eight scientific journals. According to USRTK, ESA has changed its approach to meeting sponsorships from the standard method employed by thousands of organizations, in which corporations and other organizations seeking to impress or recruit attendees organize “hospitality suites” and receptions—glorified cocktail parties replete with shrimp pyramids and artisanal alcohol. ESA adopted instead a “sponsorship program” that allows industry-backed scientists more chances to present during scientific sessions, publish in ESA journals and serve as officers in the organization. This makes the influence less obvious and more insidious.

An extra donation of $65,000 bought Corteva Agriscience an in-conference ad campaign featuring a photo of an unidentified man in a checked shirt attendees dubbed “Corteva guy,” who came to represent the face of ESA at the meeting. Corteva is a spinoff of the DowDuPont conglomerate (formerly Dow AgroSciences for Dow Chemical) selling Isoclast (sulfoxaflor), a seed treatment with similar action to neonicotinoids that, the company says, “when used according to the label…presents a low risk to honeybees and other pollinators.” (The Minnesota Department of Agriculture states that it is “highly toxic to bees.”) There is plentiful evidence from this research line that neonicotinoids are extremely toxic to a variety or organisms including vital beneficial species like bees. Neonicotinoids are banned for outdoor uses in the European Union and Quebec.

The top sponsors at ESA in 2023 were Corteva, Bayer (which absorbed Monsanto); and Syngenta, now owned by the China National Chemical Corp. Also sponsoring were BASF and SCJohnson. Corteva has extended connections deep into ESA. Two positions on ESA’s 18-member governing board are held by Corteva employees; two Corteva employees are editors on three of the ESA’s eight scientific journals; one edits two journals. In addition, three ESA journals include editors who work at Bayer. One ESA journal editor started the editing position as an academic and retained it after moving to FMC Corp, another major agribusiness entity.

ESA has allowed pesticide companies to sideline and minimize one of the most dire toxic consequences of those companies’ products. USRTK found that in the ESA program for 2023, nearly 100 papers, posters and symposia were devoted to bee science. But only four of the bee presentations addressed neonicotinoids, compared to 19 a decade earlier. All four of the neonicotinoid-bee presentations were by students, who do not enjoy the same level of prestige and credibility as professors and other PhD holders. The ESA spokesperson pointed out that there were 30 abstracts about neonicotinoids, and these included research on resistance to neonicotinoids in bedbugs and the Colorado potato beetle. But there were no discussions of neonicotinoids and bees.

This could be because industry-affiliated participants were organizing and populating the panel discussions. In 2023, 26 percent of the symposia, workshops and policy sessions were organized by corporate employees, mostly from agrochemical companies. Sixteen percent of the panelists were corporate employees.

Entomologists interviewed by USRTK who organized bee science sessions did not realize that neonicotinoids had disappeared from the program. Many believe neonicotinoids should be banned but said the field has shifted to concentrate on the effects of multiple stressors, such as mites and climate change. This approach, while sensible and productive, is also in line with and pushed by corporate interests, allowing them to hide behind a smoke screen. In traditional toxicology, which is still the gold standard for regulatory policy, each chemical is evaluated first individually; and the pesticide companies are very familiar with the direct effects of their products on target and nontarget organisms, which obviously must be included in any consideration of combined effects. Yet according to the USRTK report, ESA sessions about multiple stressors omitted any reference to pesticides, emphasizing for bees, for example, climate change and the Varroa mite.

The situation of ESA is not unique, nor are scientific societies. Many organizations whose mission is to advance the interests of particular groups by political action and public advocacy themselves are swallowed by chemical companies, which dominate their internal structures, budgets and actions, often to the detriment of the groups’ members. In 2019, the District of Columbia’s Environmental Film Festival featured the film “Ground War” (available on Hoopla), which details the domination of golf course policies and practices by chemical companies. The Golf Course Superintendents Association of America holds a massive annual trade show sponsored by many companies including Bayer, Syngenta, and the Australian chemical firm NuFarm. This financial influence makes it difficult for any organization to resist pressure from funders that is detrimental to members and society in general. After all, as “Ground War” shows, it is employees and patrons of golf courses who suffer the consequences, such as various lymphomas, of the companies’ profit-motivated control.

Tess Legg of the University of Bath and a researcher with its Tobacco Control Research Group told USRTK that corporations are able to influence science and “push out their preferred scientific messages by infiltrating professional organizations, including through funding and through speaking at their scientific and educational events, and publishing in their academic journals.”

In research published in 2023, Tess Legg and coauthors analyzed the Foundation for a Smoke-Free World, purportedly an “independent scientific organization” founded by Philip Morris in 2017. They concluded that the Foundation for a Smoke-Free World is “a new vehicle for agnogenesis….” The term agnogenesis means the manufacture of doubt, the study of which is now called agnotology in academia. In particular it is the study of the kind of ignorance that is “an active construct or strategic ploy…deliberately made and maintained to fulfill the interests of certain people,” in the words of philosopher Manuela Fernández Pinto, PhD of the University of Helsinki.

Nick Chartres, PhD, a senior research fellow at the University of Sydney, told USRTK, “Industry is afforded key positions/roles of influence throughout the [ESA], which allows them to shape the society’s scientific priorities, agenda, and public statements. Unless you dig, you do not realize there is this level of influence throughout the society.”

The USRTK report’s focus on neonicotinoids and bees reveals a stark contrast between the reality of neonicotinoid harms and blunt scientific acknowledgment of same on the one hand, and an insular professional society’s fiction that neonicotinoids are not responsible for devastation throughout not only European honeybee populations but also native bees and numerous other insects vital to our ecosystems.

Eliminating the self-interested influence of the chemical industry from scientific discourse and policymaking is a tall order. That influence inside professional societies seems especially cynical. These societies offer an entrée to a career for young scholars who want to be professional entomologists and face limited job prospects. Like many other agricultural scientists, they may be hitching their altruism to a doubtful star—convinced that the world cannot be fed without pesticides. With the help of charming industry colleagues, many may convince themselves that working for pesticide manufacturers can be an honorable profession. But this is a poison pill. A recent ProPublica investigation highlighted the personal cost that dedicated scientists can pay for staying loyal to a company that is knowingly distributing a toxic forever chemical in every part of the globe.

The manufacture of doubt also takes advantage of the scientific method’s own demand that every potential factor in a causal chain must be considered, and all evidence must be challenged to establish its validity. But we must no longer grant commerce an equal place at the scientific table. There is passion for truth and methodological integrity, and then there is venal manipulation of nebulous evidence. If we are to navigate the dire crises facing us, from the devastation of neonicotinoids and other pesticides, to the plague of plastics, to the juggernaut of climate change, both the scientific community and the regulatory system must choose.

To see more on regulatory corruption and collusion with the chemical industry, see Corruption Problems Persist at EPA.

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

Sources:

Anatomy of a science meeting: How controversial pesticide research all but vanished from a major conference 
https://usrtk.org/bees-neonics/entomological-society-america-corporate-partners/

Amid Damning Criticism of Its Scientific Integrity, EPA Takes Public Comments on Updated Policy
https://beyondpesticides.org/dailynewsblog/2024/02/amid-damning-criticism-of-its-scientific-integrity-epa-takes-public-comments-on-updated-policy/

Int’l Group of Scientists Calls for Restraints on Conflicts of Interest in Publications and Regulation
https://beyondpesticides.org/dailynewsblog/2023/12/an-international-group-of-scientists-calls-for-clear-restraints-on-conflicts-of-interest-in-publications-and-regulation/

Chemicals Implicated
https://www.beyondpesticides.org/programs/bee-protective-pollinators-and-pesticides/chemicals-implicated

Neonicotinoids Combined with Other Pesticides Elevate Hazards to Honey Bee
https://beyondpesticides.org/dailynewsblog/2023/02/neonicotinoids-combined-with-other-pesticides-elevate-hazards-to-honey-bee/

Maine Bans Consumer Use of Neonicotinoid Insecticides, with Some Exceptions
https://beyondpesticides.org/dailynewsblog/2021/06/maine-bans-consumer-use-of-neonicotinoid-insecticides-with-some-exceptions/

Seeds That Poison
Advocating for the removal of bee-toxic pesticides and the transition to organic policies and practices.
https://www.beyondpesticides.org/programs/bee-protective-pollinators-and-pesticides/seedsthatpoison

(Beyond Pesticides, June 13, 2024) A study published in Conservation Letters, a journal of the Society for Conservation Biology, exposes critical shortcomings in the U.S. Environmental Protection Agency’s (EPA) ecological risk assessment (ERA) process for modeling the risks that pesticides pose to bees and other pollinators. For the study, “Risk assessments underestimate threat of pesticides to wild bees,” researchers conducted a meta-analysis of toxicity data in EPA’s ECOTOX knowledgebase (ECOTOX), an EPA-hosted, publicly available resource with information on adverse effects of single chemical stressors to certain aquatic and terrestrial species. The meta-analysis found that the agency’s approach, which relies heavily on honey bee data from controlled laboratory studies, drastically underestimates the real-world threats from neonicotinoid insecticides (and likely other pesticides) to native bees and other pollinators. The study “challenges the reliability of surrogate species as predictors when extrapolating pesticide toxicity data to wild pollinators and recommends solutions to address the (a)biotic interactions occurring in nature that make such extrapolations unreliable in the ERA process.” Beyond Pesticides executive director Jay Feldman remarked, “EPA’s ecological risk assessment process is fundamentally flawed and puts thousands of bee species at risk of pesticide-caused population declines and extinctions.” Mr. Feldman continued, “This underscores the urgent need to expedite the transition to organic land management to better protect bees, butterflies, and other pollinators from the harms of toxic pesticides.”

Study Method and Results

ECOTOX, focused on acute effects, has been used for more than 20 years for a “rapid source for toxicity data to …inform ecological risk assessments for chemical registration and reregistration” among other assessment and regulatory decisions.  As EPA explains, the database includes 12,000 chemicals and ecological species with over one million test results from over 50,000 references,” as described in an article on the database in Environmental Toxicology and Chemistry. The study analysis includes a total of 252 assays from 49 studies. Data collected are for neonicotinoid insecticide exposure effects on both honey bees (Apis mellifera) and wild (non-Apis) bee species, including all reported LD50 values (lethal dose at which 50% of test population dies when exposed), routes of exposure (dietary vs topical), the neonicotinoid(s) tested, duration of study, and environmental parameters like temperature. Based on this information, researchers modeled the different effects of LD50 values across variables, highlighting the effects of genera, specific neonicotinoids, exposure routes, and study duration.

The researchers found:

• For both dietary and topical exposures to neonicotinoid insecticides, multiple non-Apis (wild) bee genera like Bombus, Megachile, Melipona, Nannotrigona, and Partamona exhibit significantly higher sensitivities and lower LD50 values compared to Apis (honey bees), in some cases up to six orders of magnitude more sensitive.
• Looking within just the Apis genus, LD50 values for the same neonicotinoid varied by up to seven orders of magnitude, likely due to factors like genetic diversity, temperature differences, nutrition levels, and other environmental parameters that were not adequately accounted for by the ERA process.
• The ECOTOX database is overwhelmingly populated (79.4%) by acute lethality data from studies lasting just one to five days on the western honeybee.
• Chronic, longer-term studies on diverse bee species and real-world conditions are lacking.

As the study finds, EPA’s reliance on honey bee data from lab studies focused on LD50 does not accurately capture the threats that pesticides pose in the real world to thousands of other bee species with diverse life histories, genetic compositions, and sensitivities to pesticides. This study demonstrates how estimating pesticide risks based predominantly on laboratory tests using a single surrogate species–the western honey bee–fundamentally fails to capture the range of differential sensitivities across thousands of other bee species. This failure jeopardizes the ability of the ERA process to accurately assess threats and develop appropriate mitigation measures to protect biodiversity and pollination services.

The study authors make specific recommendations for improving pollinator risk assessments:

• Develop toxicity assays for native bee species beyond just Apis mellifera, and integrate these into the assessment process
• Prioritize longer-term, chronic studies over short-term acute lethality studies on individual bees
• Account for factors like genetic diversity, climate conditions, nutritional status, and their interactions with pesticides

Other Studies Show EPA’s Ecological Risk Assessment Methods Flawed

Other studies highlight the need for a broader overhaul of the current regulatory review to address critical flaws in EPA’s current ecological risk assessment process. A November 2023 European study published in Nature demonstrates that relying on testing one active ingredient in a laboratory setting misses real-world impacts of pesticides on bees, nontarget pollinators, and, a “landscape-level” study finds that typical risk assessment reviews used by EPA and European regulators fail to “safeguard bees and other pollinators that support agricultural production and wild plant pollination.”

The Nature study, ”Pesticide use negatively affects bumble bees across European landscapes,“ evaluates the health of bumble bees (Bombus terrestris) as a sentinel species placed in 106 agricultural landscapes across Europe. The authors’ conclusions challenge “the current assumption of pesticide regulation—that chemicals that individually pass laboratory tests and semifield trials are considered environmentally benign” and call into question EPA’s current regulatory assessments based on the western honey bee and its failure to adequately regulate mixtures of chemicals to which organisms are exposed in the real world as well as the actual devastating impacts to pollinators from the ubiquitous neonicotinoids.

Neonicotinoids

Neonicotinoids (neonics) are insecticides similar to nicotine –that activate neuronal receptors and disrupt many sensory and cognitive processes in invertebrate organisms. The binding of neonicotinoids to the receptor is irreversible in arthropods.  Thus, they are highly toxic to insects and other invertebrates. (See Beyond Pesticides’ 2017 Factsheet). Neonics are linked with the dramatic decline of pollinators and other wildlife. U.S. beekeepers lost an unsustainable 33% of their hives between 2016 and 2017. Bees, butterflies, birds, and a range of soil and aquatic organisms essential to healthy ecological systems are imperiled by the use of these systemic and persistent pesticides. While several classes of pesticides introduced since the outset of the chemical-intensive agricultural era are systemic, neonicotinoids have attracted substantial scientific and public scrutiny because their appearance and proliferation in the market coincided with dramatic die-offs and decline of honey bees throughout the world. This decline has occurred, not only through immediate bee deaths, but also through sublethal exposure causing changes in bee reproduction, navigation, and foraging.

The Loss of Biodiversity Demands Better Pesticide Assessments

Bees and other insect pollinators play a vital role in fertilizing over 75% of flowering plants and nearly 35% of global food production. However, their populations have plummeted in recent decades due to multiple stressors including pesticide exposures, climate change, habitat loss, and diseases/pests. A 2020 study published in the journal Science reported that roughly a quarter of the global insect population has been wiped out since 1990 (see here for details). As Beyond Pesticides reports, a 2019 systematic review of insect population studies worldwide reported on “the dreadful state of insect biodiversity in the world, as almost half of the species are rapidly declining and a third are being threatened with extinction.” The study concluded with the dire prediction that insects will go extinct in the next few decades if patterns of intensive agriculture, in particular pesticide use, continue.

The science has become increasingly clear that pesticides, either acting individually, in mixtures, or synergistically, play a critical role in the ongoing decline of honey bees and wild pollinators, as Beyond Pesticides has extensively reported. While studies reveal wide-ranging adverse impacts from a multitude of agents, including poor nutrition, stress, fungicides, and pathogens, the neonicotinoid class of insecticides continues to receive the greatest attention from scientists, beekeepers, and advocacy groups. (See here, here, and Beyond Pesticides website here).

EPA Risk Assessment Process Ignores Potential Chemical Interactions or Synergistic Effects

With the limitations of the ERA process in assessing multiple pesticide exposure, Beyond Pesticides reported in February 2023 (see research published in Scientific Reports) that the synergistic effect of combining neonicotinoid insecticides with other commonly used pesticides can increase the overall toxic effect to honey bees. Under current regulations, EPA requires chemical manufacturers to submit data only on singular active ingredients. Yet, pesticide products may be packaged or ‘tank mixed’ with other equally toxic pesticides without any requirement to determine the toxicity of the material that is actually being applied. Independent research is left to fill in these gaps.

EPA’s Shortcomings Align with Beyond Pesticides’ Critique

The findings align with long-standing critiques by Beyond Pesticides and others about the inadequacy of EPA’s risk assessment process for evaluating threats posed by pesticides, particularly to critically important but understudied organisms like native bees.  (See here, here, and here for past comments and calls to action).

Beyond Pesticides has cited research showing neonicotinoids and other pesticides are key factors, alongside climate change, habitat loss, and pathogens, in driving unsustainable losses of bees, birds, butterflies, and other organisms essential to biodiversity and productive ecosystems. Beyond Pesticides argues that in addition to acute lethality, EPA risk assessments must comprehensively account for real-world exposure scenarios, the long-term effects of repeated exposure to various pesticides, sublethal effects on larval development and cognitive function, interactions with other stressors like climate change, and indirect effects on pollinators via impacts to food sources.

In addition to a faulty ERA process, the current registration procedures and risk assessment methods for pesticides has an over-reliance on industry-funded science that contradicts peer-reviewed studies. (See Beyond Pesticides website, Chemicals Implicated, for examples). Scientific fraud in support of regulatory decisions has plagued EPA’s Office of Pesticide Programs for decades (see here).

Ultimately, the only way to ensure the safety of pollinators and thereby the world’s agricultural systems as well as natural ecosystems, and protect human health, is to end the use of toxic petrochemical pesticides, including neonicotinoid insecticides. Beyond Pesticides advocates for the widespread adoption of organic management practices as key to protecting pollinators and the environment, and has long sought a broad-scale marketplace transition to organic practices that legally prohibits the use of toxic synthetic pesticides, and encourages a systems-based approach that is protective of health and the environment.

To move action forward on the pollinator crisis, Beyond Pesticides launched the BEE Protective campaign, a national public education effort that supports local actions to protect honey bees and other pollinators from pesticides and contaminated landscapes.   

BEE Protective includes a variety of educational materials to help encourage municipalities, campuses, and individual homeowners to adopt policies and practices that protect bees and other pollinators from harmful pesticide applications and create pesticide-free refuges for these beneficial organisms. In addition to scientific and regulatory information, BEE Protective also includes a model community pollinator resolution and a pollinator protection pledge.

Through Beyond Pesticides’ Parks for a Sustainable Future program, the organization works directly with communities to adopt organic land management in its parks, playing fields, school yards, and public spaces. It also teaches community members about managing their yards organically. Organic land management is effective, productive, economically viable, and sustainable and does not require yet another new toxic pesticide or genetically engineered plant, whether in agriculture or residential areas. By respecting the environment, and the complexity and benefits of interconnected ecosystems, organic agriculture protects pollinators and enhances the benefits we derive from the natural environment.

See Beyond Pesticides’ Eating With a Conscience database for more on why organic is the right choice and the Bee Protective webpage for additional resources you can use to go organic and safeguard pollinator populations. Join the effort to move your community to organic land management practices.

Things you can do:

• Plant pollinator habitat: Explore Beyond Pesticides’ resources to find ideas for native plantings or sources of untreated flowers and dig your pollinator-friendly garden today. Use the Bee Protective Habitat Guide and or Pollinator-Friendly Seed Directory to help! 
• Pledge to protect pollinators and produce in your garden by never using chemicals that harm beneficial insects and ladybugs and go organic! Display a Pesticide-Free Zone sign for your yard and show your neighbors that pesticide-free spaces are important for health and the environment.
• Protect the bees by using our organizing materials to aid in eliminating the use of bee-toxic pesticides in the community. Be sure to mark it on the Honey Bee Haven map! Additionally, demand justice and just conditions to stand in solidarity with farmworkers and the pollinators vital to our food supply!
• Become an Organic Parks Advocate! Send the municipal parks department links to Beyond Pesticides factsheets on Establishing New Lawns and Landscapes and Maintaining Sustainable Lawns and Landscapes. Or print them out and take them to the parks manager. For more support from Beyond Pesticides, sign up to become an organic parks advocate!

There is a lot more at Lawns and Landscapes on the Beyond Pesticides’ website. For more information about becoming an advocate for organic parks, see Parks for a Sustainable Future and Tools for Change.

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

Sources:

Risk assessments underestimate threat of pesticides to wild bees, Conservation Letters, a journal of the Society for Conservation Biology, May 15, 2024

BEE Protective: Pollinators and Pesticide: What the Science Shows and Chemicals Implicated, Beyond Pesticides website

Worldwide decline of the entomofauna: A review of its drivers, Biological Conservation, April 2019