(Beyond Pesticides, October 8, 2020) Research from the University of Wisconsin—Madison (UWM), suggests that fludioxonil—a commonly used agricultural fungicide—decreases the human body’s ability to defend itself against illnesses, like COVID-19, and promotes disease permanency. Tristan Brandhorst, a Ph.D. scientist at UWM, notes that a pesticide-induced reduction in the antioxidant glutathione could be responsible for this lack of bodily defense against disease. Although many studies examine how pesticides adversely affect the human body (i.e., cancer, respiratory issues, etc.), very few studies assess how pesticides reinforce chemical disruption patterns that reduce levels of vital chemicals needed for normal bodily function.

The steady rise in U.S. pesticide use, including disinfectants, threatens animals and humans, as exposure to indiscriminate dispersal of pesticides cause a whirlwind of health risks. As the total U.S. COVID-19 cases rise above 7.5 million, global leaders need to understand extensive pesticide spraying is not a viable solution to prevent illness and causes more chronic harm from exposure in the long run. Dr. Brandhorst stresses the need for proper reevaluation of pesticide risks stating, “The issue needs more study, [and] might also warrant a reworking of how [the U.S. Environmental Protection Agency] evaluates pesticides.”

Amidst the outbreak of SARS-CoV-2 (COVID-19), the global demand for pesticides, including disinfectants and sanitizers, has increased substantially as a means of preventing illness in domestic and community settings. Additionally, the increasing pervasiveness of moist environments from severe weather events like hurricanes increases the amount of mold and mosquito pests in some areas, causing higher inputs of fungicides and insecticides to combat the issue. However, exposure to these toxic pesticides can weaken the body’s immune response to illnesses, creating an environment for underlying condition (like respiratory issues such as asthma, or endocrine disruption problems like diabetes) to flourish among vulnerable individuals.

In 2019, Dr. Brandhorst (in the lab of Bruce Klein, Ph.D. at the University of Wisconsin–Madison and UW School of Medicine and Public Health) led a research study to discover the mode of action (or ability to cause harm) fludioxonil has on fungi. An initial 2018 analysis pointed to the uncertainty about how fludioxonil causes fungi cell death, claiming that this ambiguity merits a reevaluation by the U.S. Environmental Protection Agency (EPA) of its potential impacts on non-target organisms. However, Dr. Brandhorst recently discovered that the chemical causes metabolic shock to fungi, hindering glucose transport across the cell membrane. Additionally, further analysis finds that exposure to fludioxonil decreases glutathione levels in non-fungal cells, promoting “the ability of [the fungicide] fludioxonil to act on a sugar-metabolizing enzyme common to all cells, and to produce the damaging compound methylglyoxal.”

Although the U.S. Environmental Protection Agency (EPA) deems fludioxonil safe for use, claiming “no harm will result to the general population, including infants and children, from aggregate exposure to fludioxonil residues,” the previous findings suggest that the chemical can cause more potential to harm non-fungal cells than previously thought.

The solicitude over chemical exposure from pesticides and human health is hardly a new issue as a plethora of studies demonstrates the risks associated with toxic chemical exposure. Specific concerns arise over fungicides like fludioxonil as its ubiquitous use in agricultural and residential settings puts human and animal health at risk. Furthermore, studies regarding climate change note that changes to moisture and temperature conditions promote the spread of fungi as global warming may cause fungi to become significantly more heat-tolerant. Heat-tolerant fungi not only increase pesticides use to combat spread but also increases fungi’s ability to infect a host with higher body temperatures as the difference between environmental and body temperature will decrease. Additionally, extreme weather conditions associated with climate change like flooding from hurricanes, or drought, can promote fungus growth, specifically mold, resulting in more extensive fungicides use.

Exposure to fungicides can manifest various adverse health effects, including reproductive dysfunction, birth/developmental effects, kidney/liver damage, and cancer. Furthermore, some researchers suggest excessive use of fungicides can promote more drug-resistant fungal infections in humans as these fungicides are structurally similar to medical antifungal medications. In addition to containing potentially dangerous compounds, fungicide use in agriculture is often in conjunction with other chemical pesticides to increase potency. However, the synergy between fungicides and other pesticides can further worsen the adverse effect of chemical exposure has on human and animal health. Since humans and animals encounter these pesticides through a wide variety of applications, it is essential to understand how these chemicals work to cause toxicity in humans and animals.

Although previous studies report that fludioxonil disrupts hepatic (liver), endocrine, and neurological systems, the mode of action by which this fungicide causes these issues only recently came to light. According to research by Dr. Brandhorst, fludioxonil may impede the antioxidant glutathione from protecting the body from illnesses while prompting disease endurance. This research adds to previous reports which associate glutathione disruption and oxidation with fludioxonil exposure. Glutathione is a natural antioxidant important in blood pressure and glucose regulation, preventing the formation of free radicals which damage cells in hypertension and diabetes mellitus. However, the endocrine disruption properties of fludioxonil can cause intracellular glutathione deficiency resulting in oxidative stress that influences the development of diseases, including Alzheimer’s disease, liver disease, cancer, diabetes, and more. A decrease in glutathione biosynthesis and/or an increase in depletion of the intracellular glutathione pool can impair oxidation-reduction homeostasis and promote oxidative stress that may account for individual susceptibility to a disease like COVID-19.

An observational study of COVID-19 patients in Russia finds that many of the patients already have a glutathione deficiency that makes them susceptible to COVID-19. However, Dr. Brandhorst warns that the mechanism by which fludioxonil damages cells is not singular, but multifactorial, damaging cells in a variety of ways. Since fludioxonil decreases glutathione levels, world leaders must limit exposure to this fungicide to mitigate the severity of disease prevalence among vulnerable individuals.

The Environmental Protection Agency’s (EPA) registration of fludioxonil came with the assumption that the absence of an enzyme in one group of organisms protects the overall health of all other organisms. However, EPA mistakenly made a similar assumption in assessing glyphosate/Roundup, which caused it to ignore the impacts of that herbicide on the human gut microbiota. Although EPA considers a wide range of potential health risks from pesticides, there is no requirement to assess glutathione depletion from a pesticide since “it does not kill you” but “makes you weak,” according to Dr. Brandhorst. If these research results are replicated then, “all this work done [by EPA] to prove that fludioxonil is safe is invalid.”

As the U.S. COVID-19 cases continue to rise, world leaders must establish policies that manage viral and bacterial infections, without exacerbating the risk to both animals and humans in the process of avoiding or controlling the threat. In the case of COVID-19, we have measures of protection—both practices and products—that can prevent infection without using toxic products that increase risk factors. Additionally, the negative impacts on human and environmental health from pesticide use include the mounting resistance issues thatdemonstrate the ineffectiveness of pest management in chemical-intensive agriculture. Individuals and government officials alike should assess all risks associated with pesticide use, including chronic risk from chemical depletion in the body. Advocates maintain that EPA must have a complete understanding of the mode of action of any pesticide it registers and should include as a part of its registration review new information in the peer-reviewed scientific literature. EPA’s failure to respond to current science is viewed as a major shortcoming of its risk assessment process.

It is essential that when EPA weighs the risks and benefits of pesticide use it does not allow harm to those disproportionally affected by these chemicals—people of color, including essential workers and farm and landscape workers, who may suffer elevated exposure to the virus. An evaluation of the contribution of pesticide use and exposure to health outcomes of COVID-19 is urgently needed. To learn more about how the lack of adequate regulations of pesticide use, including fungicides, can impact human and environmental health, see Beyond Pesticides’ Pesticides and You article “Highly Destructive Pesticide Effects Unregulated.” Additionally, Beyond Pesticides advocates for a precautionary approach to pest management in land management and agriculture, with a transition to organic methods. Lastly, learn how to protect yourself from COVID-19 safely by visiting Beyond Pesticides’ webpage on Disinfectants and Sanitizers for more information. 

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

Source: E&E News

(Beyond Pesticides, October 7, 2020) This week the Baltimore, Maryland City Council passed an ordinance restricting the use of toxic pesticides on public and private property—including lawns, playing fields, playgrounds, children’s facility (except school system property [golf courses are exempt]—following an approach similar to legislation first spearheaded by Montgomery County, MD in 2015. While the legislation, 20-0495, An Ordinance Concerning Pesticide Control and Regulation, generally limits inputs to the allowed materials under federal organic law, it provides for allowances for glyphosate by the Department of  Recreation and Parks. If signed by the Mayor, as expected, Baltimore City will become the most recent Maryland jurisdiction to exercise its authority to regulate pesticide use on private property, after a ruling of the state’s highest court.

Language in the Baltimore ordinance tracks a similar framework to the Healthy Lawns Act passed in Montgomery County, Maryland. Any pesticide that is not compatible with organic land care—allowed under certified organic by the U.S. Department of Agriculture (USDA) or considered minimum risk by the U.S. Environmental Protection Agency (EPA)—is subject to the bill’s restrictions. Use can only occur under limited exceptions, such as to manage particularly invasive species, as well as health or economic threats. Bee-toxic neonicointoids are banned from landscape use, and only permitted in a completely enclosed environment, such as a greenhouse or indoor space. Application of the weed killer glyphosate requires prior authorization from the city’s Commissioner of Health, with a determination that its use is necessary to address a “threat.” The same is true for the insecticide chlorpyrifos, however no legal uses of this highly toxic neurotoxicant are affected by this legislation, since golf courses are exempt from the bill. The Parks Department exemption is subject to a “limited use and application” of glyphosate based on a “written integrated vegetation management plan.”

However, because of the exemption for the Parks Department, some advocates feel that the loophole in the legislation, especially for glyphosate (identified as a probable carcinogen by the International Agency for Research on Cancer), is unacceptable and encouraged a prohibition. Two groups, Maryland Pesticide Education Network and the Smart on Pesticide Coalition, withdrew support for the legislation after the language was amended with the glyphosate loophole for public property. Regarding the waiver for Parks, Bonnie Raindrop with Smart on Pesticides Maryland and Central Maryland Beekeepers Association said, “Instead of promoting an organic approach to protect our babies, bees and bay, this bill pushes us backwards, by continuing an outdated industry definition of Integrated Pest Management (IPM).” Restrictions on private property applications of toxic pesticides were generally left intact in the final legislation.

Although the legislation passed by the Council does require annual reporting and subjects violators to civil and criminal penalties, critical components for public education were removed from the original legislation.

Unlike language passed in Montgomery County, the Baltimore bill does not establish a citywide public education program, nor does it require retailers to provide signs and information at point of sale. However, after originally establishing a start date six months after passage, the version passed by council members does not take effect until mid-2022. Although this is a longer time frame than some advocates wished, it should provide additional time for the public to be made aware of the law’s requirements.

Baltimore’s ability to pass a law restricting toxic pesticide use to private property was upheld by the Maryland courts after the chemical and lawn care industry lost their legal challenge to Montgomery County’s Healthy Lawns Act. A 2017 ruling by Sixth Circuit Court of Montgomery County Judge Terrence McGann, now retired from the court, struck down that law, but it was quickly appealed by the County Council. Beyond Pesticides joined with local groups to file an Amicus brief defending the right of Montgomery County and other local jurisdictions in Maryland to enact laws that protect their unique local environments from toxic pesticides. After years of court proceedings the Maryland Court of Special Appeals reversed the Circuit Court decision and upheld Maryland localities right to restrict pesticides on all property in its jurisdiction. The industry appealed the decision but was met with a swift dismissal from the state’s highest court (the Maryland Court of Appeals).

Local communities in Maryland wishing to protect their residents, particularly sensitive populations such as children and pregnant mothers, and communities disproportionately harmed by pesticide use, are now empowered to do so under state law. Baltimore follows a recent opt-in to the Montgomery County law from the community of Gaithersburg, MD. The Prince Georges County Council is also currently considering passage of Ordinance CB-08-2020, which tracks closely these recently passed policies.

Advocates within the state of Maryland are strongly encouraged to engage with their local leaders to pass a strong pesticide policy. Beyond Pesticides has supported the efforts in Gaithersburg, Baltimore, and Prince George’s County through expert testimony and comments (1,2,3). For those outside of Maryland, even if you’re in a state with explicit preemption of local authority to restrict pesticides on private property, you can still pass meaningful laws that fight back against unnecessary pesticide use on public land. To get started, see Beyond Pesticides’ Lawn and Landscape Tools for Change.

As Beyond Pesticides’ Map of U.S. Pesticide Reform Policies shows, there is strong demand for local rights over pesticide enforcement. Over 150 communities in 23 states have enacted some form of pesticide reform. Help make your community the next: take the pledge that you’ll fight for a pesticide-free, organic community.

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

Source: Baltimore City Council

(Beyond Pesticides, October 6, 2020) Despite the rapid rise of antibiotic resistance in the United States and throughout the world, new documents find the Trump Administration worked on behalf of a chemical industry trade group to weaken international guidelines aimed at slowing the crisis. Emails obtained by the Center for Biological Diversity through the Freedom of Information Act show that officials at the U.S. Department of Agriculture (USDA) worked to downplay the role of industrial agriculture and pesticide use in drug-resistant infections.

“From everything we’ve seen, it’s clear that this administration believes rolling back regulations and protecting industry profits is more important than protecting public health,” said Nathan Donley, PhD, senior scientist with the Center for Biological Diversity, to the New York Times (NYT). “But what these emails show is that the Department of Agriculture isn’t just soliciting their input. They’re seeking their approval on what the government’s position should be.”

Ray McAllister, PhD, of the pesticide industry trade group Croplife America, sent an email in March of 2018 to U.S. officials, wanting to “make certain” that the United Nation’s (UN) Codex Alimentarius, a set of international guidelines and standards established to protect consumer health, made no mention of how fungicides contribute to antibiotic resistance. Neena Anandaraman, DVM, with USDA’s Office of the Chief Scientist, deferred to Dr. McAllister and allowed him to provide line edits to the document, saying “We aren’t crop experts,” rather than deferring to other experts in the federal government. Dr. McAllister further suggested changes that eliminate any connection between crop production and the transmission of human pathogens.

According to NYT, other countries on the Codex Intergovernmental Task Force on Antimicrobial Resistance were outraged by the industry-fueled changes, which resulted in significant delays. USDA told NYT, “It is the normal course of business for U.S.D.A. to solicit input from industry when developing a technical document in order to understand current practice in the United States.” While touching base with industry for their viewpoint is not in itself problematic, it becomes significantly different when that industry is allowed to establish U.S. policy.

There is overwhelming evidence that agricultural pesticide use is contributing to antibiotic resistance.

A 2015 study found that the herbicides glyphosate, 2,4-D, and dicamba all have the potential to induce antibiotic resistance in Salmonella and E.coli. In a 2014 study from the United Kingdom, strains of Aspergillus fungi resistant to azole fungicides were found primarily in rural, agricultural areas.

That is unsurprising, as many of the same antibiotics and fungicides used to manage infections on crops are the same used for human medicine. While overuse in the medical field remains a concern, agricultural applications, which likely occur more frequently and on a larger scale, are major contributors to the crisis.

A 2018 study published in Nature Sustainability found that Earth has surpassed “planetary boundaries” for pesticide and antimicrobial resistance. “Without new approaches, going to hospital in the future will increasingly become a gamble. More patients will get unlucky, and become infected with untreatable or hard to treat bacteria. This is an urgent risk to human society,” study coauthor Søgaard Jørgensen, PhD, said in a press release.

Yet, despite these concerning data, the U.S. government listened to those producing, profiting, and perpetuating toxic chemicals, rather than safety and reform-minded experts. It is a trend Beyond Pesticides has reported on very often as of late; last month a similar story found that the U.S. acted on behalf of Bayer to stop Thailand’s government from banning glyphosate.

Help stop the pesticide industry from running our federal agencies by contacting your federal elected officials. Start by telling your U.S. Senator to cosponsor the Farm System Reform Act, a bill introduced by Senator Cory Booker which would eliminate factory farming, and make important strides in combating antibiotic resistance. Follow up with a phone call to their offices, and mention Croplife’s iniquitous influence in U.S. decision making. Although the draft UN guidance contains blatant omissions relating fungicide and other crop pesticide use to antibiotic resistance, there may still be time to revise the document before it is finalized later this year.

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

Source: New York Times, Center Biological Diversity

(Beyond Pesticides, October 5, 2020)  Another example of trading health and environmental protection for the support of special interests, EPA announces the misleading and fraudulently named, “EPA Supports Technology to Benefit America’s Farmers.” This time, EPA announces plans to “streamline the regulation of certain plant-incorporated protectants (PIPs).” Named to sow confusion, PIPs are plants engineered with pesticides in them. PIPs are known in general for two problems arising from incorporating pesticidal ingredients into crops: residues that cannot be washed off and production of crop-eating insects that are resistant to the incorporated pesticide that blankets the agricultural landscape. 

Tell Congress that EPA needs to listen to science, not pesticide manufacturers and biotech companies that are causing problems for farmers and the environment.

This time, EPA is proposing to exempt from regulation certain PIPs created by biotechnological techniques that are cisgenic (using genes derived from sexually compatible species), such as CRISPR. The distinction that EPA seeks to make between cisgenic plants and transgenic plants (in which the gene of interest may come from any species) is not supported by science. In fact, cisgenic techniques make use of genetic material other than the targeted genes, and that may come from species that are not sexually compatible with the crop. The bottom line: these genetically engineered organisms introduce havoc into biological systems and the local ecology.

According to an analysis by Les Touart, PhD, Beyond Pesticides’ senior science and policy manager, ”Experiments confirm that cisgenesis can result in significant unanticipated changes to a plant. The results of these experiments show that a trait introduced via a cisgene can result in plants that differ in unanticipated and dramatic ways from their conventionally bred counterparts. The differences observed would have important implications relevant to health and ecological risk assessments.”

Two important confounding aspects that EPA ignores are the likely move by the biotech industry to use multiple genetic manipulations—EPA has never been good at assessing risks of multiple stressors—and pleiotropy. Pleiotropy is the fact that a single gene controls more than one trait, so that introduction of a genetic change may have unanticipated impacts.

The other important effect of the use of PIPs is the certain development of resistance in pest organisms. Resistance creates severe economic impacts on farmers and the food production system because it leads to crop failures and requests to use more toxic compounds on for so-called pest emergencies. These resistance events, of course, are predictable outcomes that should not qualify for emergency use of unregistered pesticides under a loophole in the federal pesticide law. Because PIPs present a constant exposure to the pesticide, they present a constant selection pressure for resistance. Resistance to Bacillus thuringiensis (Bt) arising from its incorporation as a PIP in corn has resulted in the loss of effectiveness of this biological insecticide and the use of more toxic insecticides as a replacement. (See Beyond Pesticides’ draft comment on PIPs to EPA.)

Simultaneous with this proposal, EPA has issued a proposal to address the development of resistance to Bacillus thuringiensis (Bt) in PIP corn and cotton. The proposal does not address or impact the biology of pest populations developing resistance, but only the recognition and identification of such resistance. Science shows that continued reliance on chemical or PIP insecticides only continues the cycle of pests developing resistance and continued need for new chemistry or technologies. Options not considered in EPA’s new resistance management framework include organic management practices, which uses crop rotation and the employment of biological control measures and enhancements. 

Even in chemical-intensive agriculture, crop rotation is a good management option because it reduces the possibility of existing pests developing resistance to a particular insecticide by breaking the cycle of continual exposure that causes selection pressure. Crop rotation is more advantageous than use of refuges (buffers where the insecticides are not used), which have failed results due to ongoing pesticide dependency. Likewise, a variety of biological controls as alternatives to reliance on insecticide treatments are available and can be encouraged with proper management for lepidopteran pests resistant to Bt crops. EPA’s resistance proposal, therefore, only serves as a façade while the agency allows the use of more genetically engineered crops. (See Beyond Pesticides’ draft comment on resistance management to EPA.)

Tell Congress that EPA needs to listen to science, not pesticide manufacturers and biotech companies that are causing problems for farmers and the environment.

Letter to Congress

I am writing to ask you to ask the U.S. Environmental Protection Agency (EPA) to stop harming farmers and the environment by ignoring the science of pest management and pesticide dependency. In another example of trading health and environmental protection for the support of special interests, EPA misleadingly announces, “EPA Supports Technology to Benefit America’s Farmers,” to “streamline the regulation of certain plant-incorporated protectants (PIPs).” PIPs are known for two problems arising from incorporating pesticidal ingredients into crops: residues that cannot be washed off and production of crop-eating insects that are resistant to the incorporated pesticide.

EPA proposes to exempt from regulation certain PIPs created by cisgenic biotech techniques such as CRISPR that use genes derived from sexually compatible species. The distinction that EPA seeks to make between cisgenic plants and transgenic plants (in which the gene of interest may come from any species) is not supported by science. In fact, cisgenic techniques make use of genetic material other than the targeted genes, which may come from species that are not sexually compatible with the crop.

According Beyond Pesticides’ senior science and policy manager, Les Touart, PhD, ”Experiments confirm that cisgenesis can result in significant unanticipated changes to a plant. The results of these experiments show that a trait introduced via a cisgene can result in plants that differ in unanticipated and dramatic ways from their conventionally bred counterparts. The differences observed would have important implications relevant to health and ecological risk assessments.”

Two important confounding aspects that EPA ignores are the likely move by the biotech industry to use multiple genetic manipulations—EPA has never been good at assessing risks of multiple stressors—and pleiotropy. Pleiotropy is the fact that a single gene controls more than one trait, so that introduction of a genetic change may have unanticipated impacts.

The other important effect of the use of PIPs is the certain development of resistance in pest organisms. Because PIPs present a continuous exposure to the pesticide, they present a constant selection pressure for resistance. Resistance to Bacillus thuringiensis (Bt) arising from its incorporation as a PIP in corn has resulted in the loss of effectiveness of this biological insecticide and the use of more toxic insecticides as a replacement—often through the use of a loophole in the pesticide law that identifies the predictable resulting insect resistance and population explosion as an emergency.

EPA has also issued a proposal to address the development of resistance to Bt in PIP corn and cotton. The proposal does not address or impact the biology of pest populations developing resistance, but only the recognition and identification of such resistance. Science shows that continued reliance on chemical or PIP insecticides only continues the cycle of pests developing resistance. EPA fails to consider agricultural practices used in organic agriculture, including crop rotation and biological control. Crop rotation is always a good management option because it reduces the possibility of existing pests developing resistance to a particular insecticide by breaking the cycle of continual exposure that causes selection pressure. Likewise, a variety of biological controls are available that can be encouraged to manage lepidopteran pests resistant to Bt crops. EPA’s resistance proposal, therefore, only serves as a façade while the agency allows the use of more genetically engineered crops.

Please tell EPA to listen to scientists, not the companies it is supposed to regulate. Ecology and toxicology support the need for incentives to adopt organic agriculture.

Thank you for your consideration of this request.

(Beyond Pesticides, October 2, 2020) The U.S. Environmental Protection Agency’s (EPA) September 22 announcement asserts that, “despite several years of study, the science addressing neurodevelopmental effects [of the insecticide chlorpyrifos] remains unresolved,” as reported in The New York Times. This conclusion contradicts both ample scientific evidence and the agency’s own findings. Beyond Pesticides has repeatedly advocated for a ban on the use of chlorpyrifos because of the grave risks it poses.

This organophosphate pesticide is used on approximately 60 different crops, including almonds, cotton, citrus fruits, grapes, corn, broccoli, sugar beets, peaches, and nectarines. It is also commonly employed for mosquito-borne disease control, and on some kinds of managed turf, including golf courses. Exposure to the pesticide has been identified repeatedly as problematic. Most residential uses were taken off the market in 2000, after the manufacturer, DowDupont (now Corteva) was faced with EPA action.

Chlorpyrifos is a cholinesterase inhibitor that binds irreversibly to the receptor sites of acetylcholinesterase (AChE), an enzyme that is critical to normal nerve impulse transmission. In so doing, chlorpyrifos inactivates the enzyme, damages the central and peripheral nervous systems, and disrupts neurological activity. The compound is associated with harmful reproductive, renal, hepatic, and endocrine disrupting effects, and most notably, with neurodevelopmental impacts, especially in children. It is a neurological toxicant that damages their brains and leads to compromised cognitive function, attention deficit disorder, developmental delays, lowered IQs, and a host of other developmental and learning anomalies.

Beyond Pesticides has long reported on the multitude of twists and turns in EPA’s actions on chlorpyrifos (see background and a timeline of developments here). The gist of the saga is that the agency has dragged its feet for years on stricter regulation of this pesticide. In 2015 the EPA proposed to revoke food residue tolerances for chlorpyrifos, which would effectively have banned use of the pesticide in agriculture (all residential uses having been proscribed in 2000). The agency took this step after its own studies demonstrated that exposure to the pesticide could harm brain development in children. In proposing the ban, EPA stated: “The agency is unable to conclude that the risk from aggregate exposure from the use of chlorpyrifos meets the safety standard of . . . the Federal Food, Drug, and Cosmetic Act (FFDCA). Accordingly, EPA is proposing to revoke all tolerances for chlorpyrifos.” 

EPA had not yet enacted this ban by 2017, at which point the Presidential election and change in administration had happened, and Trump’s EPA Administrator, Scott Pruitt, reversed that decision, resulting in a slew of legal challenges. In the Summer of 2019, those lawsuits culminated in a directive from the U.S. Court of Appeals for the Ninth Circuit ordering the agency to ban the pesticide within 60 days. Almost immediately, the Trump Department of Justice (DOJ) requested a rehearing before an en banc panel of the court’s 11 judges; the request was — unusually — granted. The en banc panel effectively vacated the earlier ruling.

Cue more legal challenges from environmental and public health groups, and in April of 2019, the Ninth Circuit Court again issued an order for EPA to take action on a ban, this time within 90 days. By then, Mr. Pruitt was out and Andrew Wheeler had become EPA Administrator. Pursuant to the court’s directive, the agency announced in July of that year that it would not ban the compound, thus allowing the continued use of the highly toxic pesticide.

This past July, following more lawsuits to try to force a chlorpyrifos ban, EPA argued before a three-judge panel in the Ninth Circuit Court that it understands that chlorpyrifos can have neurodevelopmental impacts, but that the level of exposure that is dangerous is unclear. It also claimed that lack of public access to the raw data for a pivotal study out of Columbia University (see more, below) prevented EPA scientists from assessing its findings on chlorpyrifos independently. It should be noted that the Columbia researchers have made offers to share the information privately with EPA, and the agency has rejected these.

This most-recent announcement — allowing continued use of chlorpyrifos because of what EPA calls “unresolved science” on the neurotoxicity of the chemical — needs to be understood, as The New York Times reports, in the context of the Trump EPA’s industry-friendly agenda and related machinations. In 2018 under Mr. Pruitt, and in process in 2020 under Administrator Wheeler, the agency has promulgated a new rule that limits the scientific research that can be used in decision making on pesticides. EPA claims that this brings greater transparency to what it likes to call “secret science” — research studies that cannot or do not make publicly available their underlying data. The so-called “secret science” rule, though not yet finalized, would guide EPA staff to give less weight or credence to, or to ignore outright, such research. The New York Times writes, “This controversial policy would eliminate many studies that track the effects of exposure to substances on people’s health over long periods of time, because the data often includes [sic] confidential medical records of the subjects.”

EPA’s announcement may be a first test of this new rule, used to rationalize EPA’s rejection of the Columbia study, the outcomes of which spurred EPA’s original move to ban the pesticide. That work, by the Center for Children’s Environmental Health at Columbia, was part of a series of prospective cohort studies of urban populations of color that linked chlorpyrifos to early childhood developmental delays, decreased mental and motor development, attentional and hyperactivity problems, and altered brain anatomy and lowered IQs, among other impacts.

In its review of chlorpyrifos, EPA asked, over a period of years, for access to the raw data that underlay the Columbia study. Herein lies the underbelly of this proposed rule: much good research happens only when participants can be assured of privacy protection. Critics of this EPA limitation on “acceptable” science note that it will undoubtedly make it even more difficult for researchers to recruit subjects; many people do not want their data shared publicly, however “depersonalized” it is promised to be. In addition, this change would have significant impact on longitudinal studies. Former EPA Administrator Gina McCarthy commented, “The best studies follow individuals over time, so that you can control all the factors except for the ones you’re measuring. . . . But it means following people’s personal history, their medical history. And nobody would want somebody to expose all of their private information.”

For all of EPA’s touting of transparency, in reality, this policy change responds to the pesticide industry’s desires by making it harder for EPA to use epidemiological studies based on confidential medical records, such as the work out of Columbia. E&E wrote in 2018 about the influence of the pesticide industry on the Trump EPA, noting that the agency’s rationale on the emerging new “secret science” rule echoed closely the arguments that officials from CropLife America, an industry trade group, had been making in their multiple closed-door meetings with then-Administrator Pruitt and current Administrator Wheeler.

In 2016, E&E reported, “CropLife America asked the Obama EPA to scrap its proposed [chlorpyrifos] ban and any other regulations that rely on Columbia’s chlorpyrifos research, which has produced several additional papers published in peer-reviewed journals. ‘Neither EPA nor interested stakeholders . . . have [sic] been granted access to the Columbia Study’s underlying data,’ CropLife said. ‘Thus, EPA could not have adequately evaluated the data to determine its validity, completeness, and reliability.’” DowDuPont, a manufacturer of a chlorpyrifos product branded as “Dursban,” is a CropLife America member.

E&E reported that in 2017, “Asked to elaborate on the ‘transparency reasons’ for EPA needing the [Columbia] data, [Jack] Housenger [former director of EPA’s Office of Pesticide Programs] acknowledged it was largely to address industry concerns. ‘If you’re taking action on a chemical company’s compound, they want to be able to say, “Hey, we looked at these data and our scientists say this,” he said. Companies often told Housenger ‘we want to be able to analyze these data and defend our chemical.’”

Erik Olson, a senior director with the Natural Resources Defense Council, noted that the EPA and the Department of Agriculture (USDA) have kept chlorpyrifos on the market for years past when it should have been removed. He said in 2018, “There has been a long history of EPA and other agencies using published, peer-reviewed scientific literature to make decisions. It’s really only been recently that the chemical industry has been pushing very hard to ask — or demand, frankly — that agencies request and reanalyze all of the data from all the studies. [EPA] line scientists have long been fine with — in fact, supported — banning chlorpyrifos. It’s been some of the people in management that have been pretty tight with the chemical industry and took on some of those arguments.”

Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA’s action to allow its continued use a failure of both its protective mission and ethics. Further, it is an environmental justice failure, given that risks of exposure fall disproportionately on low-income African American and Latino families, including farmworker families, who are at the greatest risk of harm. In light of EPA’s failures, states are taking action, and Corteva has announced it will cease production by the end of 2020 because of declining sales. Yet state efforts, which are to the good, are nevertheless uncoordinated, patchwork attempts to do what EPA refuses to do: protect the public from harm.

Beyond Pesticides advocates the adoption of organic agriculture and pest management practices that eliminate the use of toxic materials. See our organic program page and ManageSafe.

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

Source: https://www.nytimes.com/2020/09/23/climate/epa-pesticide-chlorpyrifos-children.html

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

(Beyond Pesticides, October 1, 2020) A federal judge on September 24, 2020 dismissed an  environmental lawsuit seeking to reinstate a U.S. Fish and Wildlife Service (FWS) rule, killed by the Trump Administration, which banned the use of neonicotinoid insecticides, genetically engineered (GE) crops, and adopted a precautionary approach to pest management. The decision comes on the heels of a Center for Biological Diversity (CBD) analysis that reports a 34% increase in the pesticide use on U.S. national wildlife refuge acres over a two year period from 2016-2018.

This analysis is an update to CBD’s 2018 report, No Refuge, which is the first of its kind to offer comprehensive details of agricultural pesticide spraying in national wildlife refuges. Wildlife refuges act as a sanctuary, providing habitat and protection essential for the survival and recovery of species nationwide. However, pesticide spraying in or around wildlife refuges threatens the survivability and recovery of species that reside there as many of these pesticides are highly toxic to human and animal health. Analyses like these are significant, especially since the globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk of extinction.

In 2012, Beyond Pesticides and other environmental groups, led by Public Employees for Environmental Responsibility and Center for Food Safety, won a court battle to halt genetically engineered crops, and related herbicide-tolerant herbicides, on wildlife refuges in the southeast. This led to a grassroots campaign and public pressure from advocates and environmental groups, resulting in a FWS decision to adopt a national phase out of GE crops and ban neonicotinoid (neonic) insecticide use on national wildlife refuges. However, in 2018, FWS reversed the prohibition of GE crops and neonicotinoids via a memorandum, which allows the refuge system to make decisions on the use of GE crops and neonics on a case-by-case basis in compliance with the National Environmental Policy Act (NEPA).

With the increasing rate of biodiversity loss, advocates say it is essential for government agencies to enforce policies that eliminate pesticide use in wildlife refuges, not only to protect the well-being of animals, but humans as well. Hannah Connor, J.S.D., senior attorney at CBD notes, “It’s beyond senseless that we’re spraying even larger areas of America’s cherished national wildlife refuges with dangerous pesticides known to harm wildlife. We’re in the midst of a wildlife extinction crisis, and these places were set aside specifically as safe sanctuaries for some of our most endangered animals. The last thing they need is to have these poisons dumped on them.”

The U.S. has 568 national wildlife refuges—from forests and wetlands to various waterways—all of which play a vital role in protecting thousands of species, including over 200 endangered species. The U.S. Fish and Wildlife Service (FWS) oversees refuge management and permits private farming on refuges to help prepare seedbeds to increase seed germination for native habitats and provide food for migratory birds and other species. However, the recent rise of industrial-scale commercial farming is now commonplace in wildlife refuges, exposing these sensitive habitats and its wildlife dependents to highly toxic pesticides that jeopardize abiding health.

To determine the extent of pesticide use in commercial agriculture on national wildlife refuge land, researchers examined pesticide use data in wildlife refuges obtained from U.S. Fish and Wildlife Service (FWS) public records via the Freedom of Information Act (FOIA).

U.S. FWS data demonstrate a 34% increase in the number of acres to which agricultural pesticides were applied from 2016-2018, encompassing 363,000 acres of refuge land treated with 350,000 pounds of pesticides. Furthermore, the data reveals an increase in aerial spraying of pesticides by 35%. Lastly, wildlife refuges have experienced an over 70% higher level of dangerous pesticide inputs, including an 89%, 74%, and 100% increase in the most harmful of the pesticides dicamba, 2,4-D, and paraquat, respectively. The five national wildlife refuges complexes with the most pesticide contamination from agricultural pesticide applications include the Klamath Basin National Wildlife Refuge Complex (California and Oregon), Central Arkansas Refuges Complex (Arkansas), Theodore Roosevelt National Wildlife Refuge Complex (Mississippi), West Tennessee Refuge Complex (Tennessee), and Tennessee National Wildlife Refuge Complex (Tennessee). 

The impact of pesticides on wildlife—including mammals, bees and other pollinators, fish and other aquatic organisms, birds, and the biota within the soil—is extensive. A plethora of studies document how exposure to these toxic chemicals cause reproductive, neurological, renal, hepatic, endocrine disruptive, and developmental anomalies, as well as cancers, in a wide range of species. There are policies in place to protect wildlife from harm, such as the Endangered Species Act (ESA) of 1973, which protects ecosystems on which threatened and endangered species depend. However, a 2013 report by the National Academy of Sciences detected shortcomings in the U.S. Environmental Protection Agency’s (EPA) evaluation and analysis of pesticides on endangered species, with the agency regularly  disregarding the ESA’s requirement to confer with federal wildlife agencies on how to take precaution to protect threatened and endangered species from pesticide harms. Therefore, EPA, and other federal government agencies, including FWS, reformed the pesticide review process to meet the pesticide approval requirements for the ESA. 

GE crops perpetuate the use of neonicotinoids and other harmful pesticides as many of these crops are resistant to the pesticides used on them, forcing farmers to use more chemicals to treat persistent pest issues.

Additionally, the U.S. Geological Survey (USGS) routinely finds widespread pesticide contamination of surface waters throughout the U.S. Scientists warn that neonicotinoids, and other pesticides, pose a direct threat to both insect and non-insect wildlife, including birds, aquatic animals, and other wildlife, which absorb pesticide sprays and vapors through respiration, as well as orally via food.

The reversal of the GE crop and neonicotinoid ban in national wildlife refuges are only a few of the many recent rollbacks on environmental regulations, which do little to protect ecosystem health that marine and terrestrial species, including humans, require. In March 2020, the Environmental Protection Agency (EPA) revised their methods for “biological evaluations” (BE) to assess pesticide risks to endangered plant and animal species. However, these newly revised methods allow extensive harm to many of the most endangered plants and animal species nationwide. Additionally, 2019 regulations for the ESA, set forth by the Trump administration, “weaken the consultation process designed to prevent harm to endangered animals and their habitats from federal agency activities, curtail the designation of critical habitat and weakens the listing process for imperiled species, and eliminate all protections for wildlife newly designated as ‘threatened’ under ESA.”

Two of the most widely used pesticides in the U.S. (chlorpyrifos and malathion) have harmful effects on 97 percent of all species listed for protection under the ESA. In light of this, advocates maintain that government agencies must adopt policies that protect the vulnerable species from pesticide exposure. 

Although pesticide-treated acres in wildlife refuges increased and the total pounds of pesticides used per acre declined, the data obtained from the FWS does not account for the full calendar year. This lack of accountability means the data certainly underestimates total pesticide use since most of the pesticide-use decline was at one refuge—the Klamath Basin National Wildlife Refuge Complex. Most concerning are the range of hazardous pesticides commonly used on wildlife refuges, including dicamba, 2,4-D, and paraquat. Although these three chemicals are highly toxic to fish, amphibians, crustaceans, and other animals—causing everything from birth and reproductive defects to cancer—they remain in use on wildlife refuges.

Additionally, a recent ruling by FWS allows an expansion of hunting and fishing in wildlife refuge areas. Not only does this expansion put extra stress on species already affected by pesticide exposure, but it also exposes hunters and anglers to pesticides that contaminate soils, waterways, and bioaccumulate inside of game animals. Hence, FWS must provide timely protection to the most critically imperiled species and their habitat by eliminating toxic pesticide use from chemical-intensive farming. CBD researchers concur with the organization’s previous 2016 analysis, maintaining that “continuing protection for species and their habitats are, therefore, crucial to preserving and maintaining the nation’s treasured natural heritage. By opening refuges to intensive farming that utilizes toxic pesticides, the Service has failed to carry out its primary purpose of protecting wildlife.”

The use of pesticides should be phased out and ultimately eliminated to protect the nation’s and world’s wildlife and reduce the number of dangerous pesticides exposed to species in wildlife refuges. Additionally, Beyond Pesticides has long fought against GE crops and pesticide use on refuges and has long advocated for federal regulations that consider all potential impacts of pesticides to ecosystems and organisms.Current administration regulations fail to consider the environment holistically, thus creating a blind spot that limits our ability to adopt widespread change that improves ecosystem health. With the Trump administration dismantling many environmental regulations, it is vital to understand how pesticide use on wildlife refuges can increase biodiversity loss, especially due to the increasing amount of dangerous pesticide use in these areas. The administration has now declined protection for more than 60 species and protected only 18 — the lowest of any president at this point in an administration. However, advocating for local and state pesticide reform policies can protect wildlife from pesticide-contamination. For more information on pesticide impacts on wildlife, visit Beyond Pesticides’ wildlife page. 

Furthermore, buying, growing, and supporting organic can help eliminate the extensive use of pesticides on crops located on wildlife refuges. Organic agriculture has many health and environmental benefits, which can eliminate the need for chemical-intensive agricultural practices in these sanctuaries. For more information on how organic is the right choice for both consumers and the farmworkers, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture.  

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

Source: Center for Biological Diversity Press Release, Center for Biological Diversity Analysis

(Beyond Pesticides, September 30, 2020) Low doses of neonicotinoid (neonic) insecticides are known to disrupt insect learning and behavior, but new science is providing a better understanding of how these effects manifest at a cellular level. Published in the Proceedings of the National Academy of Sciences, this study finds that the neonic imidacloprid binds to brain receptors, triggering oxidative stress, reducing energy levels, and causing neurodegeneration.

“Although many studies have shown that low doses of insecticides can affect insect behavior, they have not uncovered whether insecticides trigger changes at the cellular and molecular levels,” said lead author Felipe Martelli, PhD, of Monash University in Melbourne, Australia. “The goal of this work was to have a better understanding of the effects of low doses of the common insecticide imidacloprid at the cellular, physiological and behavioral levels.”

Researchers used the fruit fly Drosophilia melanogaster, a common experimental organism, as it contains a number of nicotinic acetylchloline receptors, the primary site of action for imidaclorpid. The neonic binds to these receptors, which regulate a number of physiological processes, such muscle contraction. Binding closes these channels, leading to the range of harm researchers observed through their study.

Larval fuit flies were exposed to imidacloprid for two hours at 2.5 parts per million (ppm), less than 3% of the application rate insects are likely to encounter in the field. At this rate, test-reared flies display reduced movement, but do not die. However, scientific observation found that, although the flies are not dying, the neonic exposure induce a sequence of compounding negative health effects.

“We discovered that imidacloprid did bind to the nicotinic receptors in the larvae’s nervous system, causing a long, enduring influx of calcium ions into the neurons. Having too much calcium inside the neurons damaged the mitochondria, the energy-producing structures of the cell. This led to the accumulation of significant amounts of reactive oxygen species (ROS), or free radicals inside the brain that triggered a cascade of damaging events that spread to many other tissues,” Dr. Martelli said.

ROS leads to an imbalance in the development of lipid droplets throughout the fly’s organ systems. “Lipids are much more than energy storage. They play many important roles in the body, from being a crucial part of the integrity of cell membranes to working as messenger molecules or in hormone synthesis,” said Phillip Battenham, PhD, of the University of Melbourne. “In addition to lipid alterations, we also observed that imidacloprid triggered changes in the activity of genes related to metabolism, energy production, detoxification and the immune response. The overall physiology of the larvae was systemically impaired.”

Scientists were able to confirm that imidacloprid is causing these impacts by successfully treating some larvae with an antioxidant known to mediate the effects being observed.

Harmful effects are also seen in adult fruit flies exposed to the neonic. A dose of 4 ppm, known to cause death in 50% of exposed flies within a month, was used, and researchers observed the flies for the first 10 days of exposure. Dosed flies performed poorly on tests assessing their climbing ability and recovery after disturbance – indications of neurodegeneration. Vision was significantly impacted, with damage to mitochontrial photoreceptors effectively rendering the flies blind.

“When we looked closer at the light-sensing cells in the adult fly’s retina, we found that glial cells, which provide support and protection to neurons, had progressively accumulated vacuoles and a significant number of defective mitochondria, indications that the glia were dying,” said Hugo Bellen, PhD, of Baylor University and Texas Children’s Hospital.

As with the larva, an antioxidant treatment was able to decrease the extent of damage caused by imidacloprid exposure. “It is concerning that even at low doses, insecticides can cause neurological damage, disrupt energy production and compromise the immune system of insects,” Dr. Batterham said. “Those problems can make it more challenging for insects to adapt to other stresses, such as climate change or infections. Our findings emphasize the importance of better understanding the mechanisms of action of insecticides, in particular on beneficial insects.”

Pollinators are perhaps the most well known victim of exposure to systemic neonicotinoid insecticides, but as the global Task Force on Systemic Insecticides shows the entire invertebrate world, and therefore the ecosystems that depend upon them, is at risk. Further evidence finds these chemicals are directly harming a range of other life, including amphibians, birds, and mammals, including humans, as indirect effects move up the food chain.

It is not too late to intervene and stop the use of these harmful substances. Call your member of Congress and urge them to cosponsor the Saving America’s Pollinator Act, which would eliminate neonic use in the United States. Become active in your community and state by gathering together with like minded friends and neighbors, and reaching out to your elected officials about this issue. Get familiar with the science through Beyond Pesticides past daily news posts as well as the Bee Protective webpage.

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

Source: PNAS, Baylor College of Medicine press release

(Beyond Pesticides, September 29, 2020) While the green revolution is often heralded in conventional agriculture circles as the key agricultural innovation of the last century, new research finds that biological controls likely had a bigger beneficial impact on world crop production. The study, Ecological Pest Control Fortifies Agricultural Growth in Asia–Pacific Economies, published in Nature Ecology and Evolution, makes the case that the introduction of predators to manage non-native pest species was just as important as the introduction of new cereal grain varieties.

“Our work constitutes an empirical demonstration of how insect biological control helped solidify the agrarian foundation of several Asia-Pacific economies and, in doing so, places biological control on an equal footing with other biological innovations such as Green Revolution germplasm,” said study co-author Michael Furlong, PhD, of the University of Queensland, Australia.

The study, focusing in on the Asia-Pacific region between 1918-2018, relied primarily on the BIOCAT database, a record cataloging “classical biological control” introductions. Of 252 unique interventions reviewed within individual countries, pest predators established themselves in 96. Of those roughly 4 in 10 introductions that were able to maintain populations over the long term, 48% achieved full or partial pest control.

The success of these programs had critically important implications for agricultural economies in the region. “Biological control delivered durable pest control in myriad Asia-Pacific agriculture sectors, permitting yield-loss recoveries up to 73%, 81% and 100% in cassava, banana and coconut crops respectively, said Dr. Furlong. “The ensuing economic dividends are substantial, as pest-induced losses up to US $6.8, $4.3 and $8.2 billion annually for the above crops were offset (at respective values of $5.4-6.8 billion, $1.4-2.2 billion and $3.8-5.5 billion/year, for a conservative to high impact scenario range). As many of the underlying programs were run on a shoestring, the rate of return on biological control science is extraordinary.” Overall, the authors indicate that biological controls have brought approximately $20 billion to Asia-Pacific economics on an annual basis.

While, for example, rice yields in Indonesia increased by 303% from its 1961 baseline, yields in banana and cassava grew 1,222% and 323% respectively. Cassava yields were saved in large part due to the introduction of Anagyrus lopezi, a parasitic wasp that preyed on the non-native cassava mealybug. In Papua New Guinea, the country’s banana crop was experiencing 30% yield loss due to the banana skipper Erionota thrax, but was able to reduce pest pressure below economically damaging levels through introduction of the parasitoid Cotesia erionotae.

“Not only does [our work] spotlight [biological control’s] transformative impacts – especially in light of increasing global reliance on chemical pesticides – but it also celebrates the century-long achievements of dedicated, yet often, unacclaimed insect explorers and biological control pioneers.”

Biological control is not without its detractors. Many point to introductions like the cane toad, released in the 1930s to manage Australia’s sugar cane beetles. The poisonous amphibian never established in cane fields and became an invasive pest in its own right. The authors acknowledge this history, noting how “a small number of ill-advised introductions” from the middle of the 20^th century led to “a more risk-adverse attitude,” which “eclipsed its myriad societal benefits.”

The present studies highlights the value of these past approaches, both in terms of economic and environmental benefits. Not only can biological interventions save agricultural sectors, their use can also supplant the industrial chemical approach that harms public health and adversely impacts ecological stability.

“By thus placing agro-ecological innovations on equal footing with input-intensive measures, our work provides lessons for future efforts to mitigate invasive species, restore ecological resilience and sustainably raise output of global agri-food systems,” said lead study author Kris Wyckhuys, PhD.

Biological approaches are needed now in many sectors. After years of testing, officials in California are beginning to release Tamarixia radiata wasps to manage Asian citrus psyllids, which cause citrus greening that has devastated the citrus industry. Past reports indicate many New Jersey communities have used copepod crustaceans, voracious predators of mosquito larvae, to control mosquito-borne disease. Goats have also been used across the country as biological weed management at airports, cemeteries, and to restore soil and improve land quality. These techniques provide a viable management approach that does not require the regular, repeated use of toxic pesticides.

Support an ecological approach to food production by purchasing organic whenever possible. Organic land management prioritizes mechanical, cultural, and biological means of managing pests before considering even least-toxic pesticide products. For more information, see Beyond Pesticides Daily News biological control archives.

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

Source: Centre for Agriculture and Bioscience International press release, Nature Ecology and Evolution

(Beyond Pesticides, September 28, 2020) These comments are due by October 5 at 11:59 pm EDT. Separate comments to the National Organic Standards Board are due October 1 at 11:59 EDT.

After hearing for years about inadequate enforcement of the rules governing organic production, USDA has issued a massive draft rule on strengthening organic enforcement (SOE). The draft rule presented to the public constitutes an impressive and far-reaching rewrite of the regulations implementing the Organic Foods Production Act (OFPA). However, unlike the process by which the initial regulations were established in 2002, the National Organic Standards Board (NOSB) was only consulted on a portion of the elements in this draft rule. Public engagement was, thus, also limited.

USDA’s National Organic Program (NOP) is accepting comments on its draft rule via Regulations.gov. Please use this opportunity to remind USDA of the proper public process while commenting on the proposed rule itself. Please join us in asking for an extension of the pubic comment to facilitate fuller public scrutiny.

Tell USDA that strengthening organic enforcement starts with the National Organic Standards Board.

USDA must involve the NOSB and public as required by law.

Section 2119 of OFPA states the Secretary shall establish the NOSB to advise the Secretary on “… the implementation of this title.” Furthermore, the law states, “The board shall provide recommendations to the Secretary regarding the implementation of this title.” [emphasis added]

The promulgation of the original rule was preceded by a thorough discussion by the NOSB, intended by Congress to be a diverse panel of expert stakeholders, with abundant opportunity for public input from the most knowledgeable and experienced community and industry participants. This process was clearly fulfilling the intent of Congress.

Although the current draft SOE rule includes many meritorious elements, a number of them have not been discussed publicly. Given the narrow time window for public comments, concurrent with stakeholders and public interest groups working on formal comments pursuant to the upcoming NOSB meeting, and taking into account the impact this pandemic has had on the productivity of many organizations, a wide discussion within the organic community has not been possible—although a number of separate stakeholder constituencies have been discussing this rule in isolation without benefit of widely sharing their knowledge and perspectives.

Thus, an extension of the comment deadline is necessary to allow an opportunity for the organic community to collaborate on this proposal prior to proceeding to final rulemaking. Such an industry-wide discussion must be orchestrated by the NOSB and we recommend scheduling a third meeting during 2021 for that purpose.

Improvements in Organic Enforcement are Needed

As a starting point, Beyond Pesticides and its investigative arm OrganicEye, in general, support the detailed comments submitted by the National Organic Coalition (NOC). Furthermore, we also support the comments related to strengthening oversight on imports submitted by the Organic Farmers Agency for Relationship Marketing (OFARM).

In addition, we would emphasize the following points:

1. There is no reason for a 10-day delay in communicating electronic certificates. They are electronic! They should be transmitted simultaneously with shipment. Twenty-four hours is more than adequate. 
2. This rule is massive and, despite many meritorious elements, adds, in the aggregate, tremendous additional regulatory burdens. As such, it deserves additional time to be thoroughly and thoughtfully evaluated, including through public discussions, before public comment closes. 
3. Regarding a recommendation on accreditation of organic certifiers by the NOSB in October 2018,  it is time to look at risk-based oversight of certified operations, rather than putting honest farmers through the ringer every year with inspections and audits while massive fraud is being simultaneously perpetrated by malefactors. Although OFPA requires annual inspections, farmers and small processors who have demonstrated a high level of compliance and low risk should be given the option of yearly virtual inspections, using artificial intelligence and a national database to compare acreage, production, and sales, along with more comprehensive, periodically staggered, full site inspection/audits. This will free up resources in the certification and inspection sector for a much more aggressive approach to unannounced inspections, testing, and full, comprehensive audits. It should be noted that the IRS does not audit every taxpayer every year. Holding the hammer of unexpected and comprehensive audits ensures a high level of compliance.
4. A new, more efficient, and focused approach to inspections and audits of certified organic operations must be coupled with more aggressive penalties, enforcement action, and monitoring. It has become standard practice for NOP to negotiate settlements with alleged perpetrators, leaving some in business without substantive penalties. For the current or proposed regulatory oversight to be effective, prosecution of willful violators to the full extent of the law is needed as an effective deterrent.
5. USDA should mandate strict criteria for residue testing and unannounced inspections, including assisting in the selection of audit targets based, in part, on complaints and other reports from the public. The draft rule allows for far too much discretion by certifiers. Given that certified entities hire their certifier, clear criteria are especially important. Establishing enforcement requirements for certifiers is also critical if USDA reduces the emphasis on annual inspections/audits and shifts to more random and risk-based auditing.

How to Submit Comments

1. Navigate to the gov comment page. 
2. Enter your comment and identifying information. You may copy, paste, and edit the points below. See our video tutorial for steps in doing this.
3. Press the “Submit” button.

Here are points you may want to include:

• This rule is massive and, despite many meritorious elements, adds, in the aggregate, tremendous additional regulatory burdens. As such, it deserves additional time to be thoroughly and thoughtfully evaluated, including through public discussions, before public comment closes. This should be facilitated by the National Organic Standards Board.
• I support the detailed comments submitted by the National Organic Coalition (NOC) and the comments related to strengthening oversight on imports submitted by the Organic Farmers Agency for Relationship Marketing (OFARM).
• There is no reason for a 10-day delay in communicating the electronic certificates. They are electronic! They should be transmitted simultaneously with shipment. Twenty-four hours would be more than adequate.
• Consider risk-based oversight of certified operations rather than putting honest farmers through the ringer every year with inspections and audits while massive fraud is simultaneously perpetrated by malefactors. Farmers and small processors who have demonstrated a high level of compliance and low risk should be given the option of yearly virtual inspections, using artificial intelligence and a national database to compare acreage, production, and sales, along with more comprehensive, periodically staggered, full site inspection/audits. This will free up resources in the certification and inspection sector for a much more aggressive approach to unannounced inspections, testing, and full, comprehensive audits. Note that although the IRS does not audit every taxpayer every year, the hammer of unexpected and comprehensive audits ensures a high level of compliance.
• A new, more efficient, and focused approach to inspections and audits must be coupled with more aggressive penalties, enforcement action, and monitoring. It has become standard practice for NOP to negotiate settlements with alleged perpetrators, leaving some in business without substantive penalties. Willful violators need to be prosecuted to the full extent of law, as a deterrent, for any current or proposed regulatory oversight to be effective.
• USDA should mandate strict criteria for residue testing and unannounced inspections, including assisting in the selection of audit targets based, in part, on complaints and other reports from the public. The draft rule allows for far too much discretion by certifiers. Given that certified entities hire their certifier, clear criteria are especially important. Establishing enforcement requirements for certifiers is also critical if USDA reduces the emphasis on annual inspections/audits and shifts to more random and risk-based auditing.

Tell USDA that strengthening organic enforcement starts with the National Organic Standards Board.

In separate comments, please don’t forget to submit comments on NOSB proposals by October 1 at 11:59 pm EDT. Click on the link below to see our analysis and suggested comments.

While you are visiting Regulations.gov, please remember to tell the National Organic Standards Board to support core organic values.

(Beyond Pesticides, September 25, 2020) An investigation has revealed that companies in the United Kingdom (UK), as well as in some European Union (EU) countries, are exporting massive amounts of pesticides — banned in their own jurisdictions — to poorer countries. More than 89,000 (U.S.) tons of such pesticides were exported in 2018, largely to countries where toxic pesticide use poses the greatest risks. The UK has been the largest exporter (15,000+ tons, or 40% of the total in 2018); other significant exporters include the Netherlands, France, Spain, German, Switzerland, and Belgium. Among the countries receiving the bulk of these dangerous pesticides are Brazil, South Africa, Mexico, Indonesia, and Ukraine. Despite a flurry of attention to this problem in the U.S. in the early 2000s, little has changed, worldwide, to stop this practice of selling domestically banned pesticide products to parts of the world that continue to allow their use. This is an unethical practice that compounds the risks to workers in developing countries, who already endure heighted threats to health and local ecosystems.

The investigation was conducted by Unearthed, a Greenpeace UK journalism arm, and Public Eye, a Swiss NGO (non-governmental organization) that investigates human rights abuses by Swiss companies. The collaborators discovered that in 2018, these exported pesticides were sold to 85 different countries, 75% of which were low- and middle-income countries — many in the global south. The report notes that, “Two-thirds of the . . . exports to richer nations were destined for one place: the U.S., which has some of the most permissive pesticide regulations among high-income countries and is itself a major exporter of banned agrochemicals to LMICs. . . . Swiss-based, Chinese-owned Syngenta was by far the biggest exporter of banned agrochemicals among manufacturers.”

The EU, with its 28 member states, has the most-protective and comprehensive pesticide regulations of any major agricultural producer. But as the EU moves ahead on increased regulation and bans of pesticide products it deems dangerous for human health and/or the environment in its member countries, it simultaneously is adding to the number of banned pesticide products it allows for export. Nina Holland, an advocate with the Brussels-based NGO Corporate Europe Observatory, said: “The fact that this practice is only set to increase, with new chemicals including pollinator-killing substances like fipronil being added to the list, is completely in contradiction with the new [European] Commission’s ambitions when it comes to reducing the harm done by pesticides.”

Unearthed notes that, “Loopholes in European law mean chemical companies like Bayer and Syngenta can continue making pesticides for export long after they have been banned from use in the EU to protect the environment or the health of its citizens.” The companies and countries that sell these banned products insist that countries have the right and ability to control what pesticides can be used in their jurisdictions.

But public health and environmental advocates, as well as U.N. officials, insist that sales of pesticides known to be so dangerous as to be banned by wealthier, generally Western countries, constitute a double standard based on placement of a “lower value on lives and ecosystems in poorer countries.” Spokesperson for the Permanent Campaign Against Pesticides and for Life, Alan Tygel, cut to the chase: “If a pesticide is banned for causing cancer in the EU it will cause the same problems in Brazilian people.”

Indeed, prior to the release of the Unearthed/Public Eye report, UN special rapporteur on toxics Baskut Tuncak said, in a statement endorsed by 35 other experts on the UN Human Rights Council: “Wealthier nations often create ‘double standards’ that allow the trade and use of banned chemicals in parts of the world where regulations are less strict.” [The statement] added that the “‘racialised nature of these standards cannot be ignored’ as the dangers were ‘externalised’ to ‘communities of African descent and other people of colour.’ This shifting of the dangers posed by toxic chemicals to communities of colour was a ‘grave concern’ that could also be found within rich countries, with ‘respect to the siting of polluting industries and the dumping of hazardous waste. In nearly every case there is no legitimate public interest justification. These loopholes are a political concession to industry, allowing their chemical manufacturers to profit from inevitably poisoned workers and communities abroad, all the while importing cheaper products through global supply chains and fueling unsustainable consumption and production patterns. It is long-overdue that states stop this exploitation.’”

Mr. Tuncak previously called out pesticide companies doing business in Switzerland during a review of the pesticide impacts in the country, saying that “pesticide companies’ behavior is ‘seriously deficient’ regarding human rights (especially those of children), and that the Swiss government should act more aggressively to phase out use of these hazardous chemicals.”

The preponderance of the 2018 UK exports were products containing paraquat, Syngenta’s herbicide that not only is acutely toxic — even the Environmental Protection Agency (EPA) acknowledges that a sip of this Restricted Use pesticide can be fatal — but also, is linked to numerous health problems, including reproductive, neurotoxic, and renal and hepatic impacts; is toxic to birds, fish, and bees; and is a likely carcinogen. Tragically, toxic pesticides have come to be a significant method of attempted suicide in poorer countries, such as China and India — and Sri Lanka, until the country acted in the 1990s to ban import of many of the most dangerous pesticides. The suicide rate in that country fell, after those bans, by 50% between 1995 and 2005, and after a second round of restrictions between 2008 and 2011 (including a ban on paraquat), fell again by another 21% between 2011 and 2015.

U.S. companies also participate in this export practice, as Beyond Pesticides began noting more than 15 years ago (see here and here). In the U.S. it is legal, even when dangerous pesticides have been banned or highly restricted by EPA, for companies to continue to sell them abroad.

Truthout captures the situation: “When the federal government bans a pesticide, pro-industry loopholes allow agrochemical companies to recoup lost profits by manufacturing the same pesticide for use abroad. . . . With no comprehensive global regulatory framework to guide policy for transport, storage and use, the U.S. consciously subjects vulnerable agricultural workers overseas to chemicals known to cause harm and death, and widens international dependence of agriculture on pesticides. Every registered pesticide has a ‘tolerance’ . . . how much residue can remain on a food product before it is deemed unsafe for human consumption. Pesticides deemed too dangerous or unregistered with the EPA cannot be sold in the U.S. . . . While the U.S. is required to inform countries when a pesticide is not registered in the U.S., there is no assurance that the receiving official will forward the data to the user of the chemical. Agrochemical companies can satisfy labeling requirements simply by placing labels on shipping containers rather than on the product container. . . . Given the reality of how these pesticides are actually used (without appropriate protective equipment, lack of proper disposal, etc.), halting exportation is critical.“

The pesticides that U.S. companies export can even end up in the U.S. food supply when pesticide manufacturers whose chemicals fail to maintain EPA approval and registration at home, continue to produce these dangerous products and sell them abroad. Many of these pesticides end up in the domestic food supply when crops grown in those countries are exported to the U.S., threatening public health and safety both at home and abroad. The bigger-scale problem is what these toxic exports do to people and ecosystems in recipient countries. More than a decade ago, Beyond Pesticides wrote about the dangers of pesticides to farmworkers in “developing” countries: “Each year, millions of developing world farmers are poisoned by pesticides, many of which are banned or strictly controlled in the West.”

Way back in 2002, an investigator for the U.N. Commission on Human Rights, Fatma Zora Ouchachi-Vesely, called the U.S. practice of exporting to other countries harmful pesticides that are banned in the U.S. “immoral.” Government officials told her that international free-trade agreements “allow for pesticides be exported without regulation to countries that demand them, whether or not they are banned within the United States.”

Such demand, some NGOs claim, is the result of promotional campaigns by companies that profit from pesticide sales. Ms. Vesely noted that users of these pesticide products are not well informed about them: not only do the recipient countries often not have the capacity to get appropriate information to users, but also, when these chemical products are sold “on the ground” in recipient countries, they often have no or insufficient labeling, or labels are not translated to local languages. Ms. Vesely added, “Even if something is marked ‘poison’ it tends to be shipped in large amounts, then transferred to smaller containers without proper labeling for local sale and use. And the people actually using the products often cannot read anyway.”

A 2015 documentary film, “Circle of Poison” (which features Beyond Pesticides Executive Director Jay Feldman and luminaries such as Vandana Shiva, Noam Chomsky, and President Jimmy Carter), focuses on this toxic export issue. Mr. Feldman identifies the crux of the issue here in the U.S.: “Pesticides, known toxicants, are registered by EPA with the understanding that they can be used only in compliance with label instructions; the label is the law. However, when pesticides are exported, neither EPA nor any other federal agencies make any effort to determine whether the destination countries have the infrastructure to ensure enforcement of restrictions. When I was in Haiti, I saw U.S.-banned pesticides being sold in bags with no product labeling, or accompanying instructions, precautions, restrictions, etc. This means that the risk calculations that EPA makes, as weak as they are, do not even apply to use of these chemicals that lack labeling information. Use of these highly toxic substances ought to be governed by an enforcement system that controls their use. The widespread use of such pesticides with so few controls has direct adverse effects on people and the environment in the recipient countries, and has dire global impacts.”

A recent Daily News Blog entry covered the phenomenon of toxic pesticides, both in current use and banned, being released from the surfaces of Arctic glaciers as those glaciers melt in a warming atmosphere. This represents another chapter in the chronicle of problems related to wanton pesticide use, and underscores the pressing need for better pesticide policies worldwide — especially when a toxic pesticide is banned for use in a given nation or jurisdiction, but not for production and export to other countries.

A related, global issue is the “chemical time bomb” problem of waste from banned pesticides in various countries, as Beyond Pesticides covered in 2018 (as well as in 2004 and again nearly a decade ago). “Stockpiles have accumulated because some products have been banned for health or environmental reasons, leaving stocks (aka waste) that are often stored inadequately, and which deteriorate and migrate to contaminate the environment and put people at risk. Those affected are very often in poor, rural communities that may be unaware of the threat in their midst.”

One might reasonably wonder: are any governments tackling this matter? Congress made an attempt — in 1991 — to address this issue with the Circle of Poison Prevention Act. Introduced by Senator Patrick Leahy of Vermont, the bill would have put strict controls on exports of hazardous chemicals, but was ultimately unsuccessful. Advocates maintain that the U.S. must revisit and remedy this dangerous problem, and must also cease the practice of pressuring other countries to weaken their own pesticide regulations. The most recent example of that was the collaboration of the U.S. government with the agrochemical giant Bayer in pressuring Thailand to abandon its plan to ban glyphosate. The country ultimately succumbed to pressure, and rather than banning glyphosate, chlorpyrifos, and paraquat, restricted glyphosate use and delayed enforcement of bans on the other two toxic pesticides.

France will, in 2022, become the first EU country to prohibit the export of banned pesticides. A spokesperson for the Dutch Ministry of Infrastructure and Water Management has said that the Netherlands plans to use an upcoming meeting with other European environment ministers to “explore a European export ban for these substances,” adding that global ban was needed because, absent that, manufacturers will just switch to other exporting countries in response to a patchwork of national bans. The point underscores Beyond Pesticides argument that stricter regulation and, ideally, bans of toxic pesticides need to happen at the highest governmental levels because industry, like water, will always find a path around obstacles such as state or local prohibitions.

Mr. Tuncak asserts a bolder approach for the countries included in the report, saying, “The European Union as a whole needs to demonstrate leadership to other countries around the world on this issue. From there I think we can move towards an even broader consensus on ending this abhorrent practice of discrimination and exploitation.”

Beyond Pesticides’ commitment to agricultural justice, as well as to human rights, protection of farmworkers, and public and ecosystem health includes the legal export of dangerous pesticide products to other countries. Advocacy for a far-less-toxic world must include action on this discriminatory and unethical practice, which endangers wealthier nations when tainted crops return to their shores, but critically, has disproportionate impacts on poor nations and the people of color who live in many of them. So-called “first world” nations must enact controls over this practice, and support stronger controls and better pesticide education in less-well-resourced countries.

Source: https://unearthed.greenpeace.org/2020/09/10/banned-pesticides-eu-export-poor-countries/

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

(Beyond Pesticides, September 24, 2020) A new report by the U.S. Geological Survey (USGS), National Water-Quality Assessment (NAWQA) Project, reveals the presence of pesticides is widespread in U.S. rivers and streams, with over almost 90 percent of water samples containing at least five or more different pesticides. Pesticide contamination in waterways is historically commonplace as a 1998 USGS analysis revealed pesticides are commonly found in all U.S. waterways, with at least one pesticide detectable. Thousands of tons of pesticides enter rivers and streams around the U.S. from agricultural and nonagricultural sources, which contaminate essential drinking water sources, such as surface water and groundwater. As the number of pesticides in waterways increases, it has detrimental impacts on aquatic ecosystem health, especially as some pesticides work synergistically with others to increase the severity of the effect. Reports like these are a significant tool in determining appropriate regulatory action to protect human, animal, and environmental health. USGS concludes, “Identification of primary contributors to toxicity could aid efforts to improve the quality of rivers and streams to support aquatic life.”

Water is the most abundant and important chemical compound on earth, essential to survival and the main component of all living things. Less than three percent of that water is freshwater, and only a fraction of that freshwater is groundwater (30.1%) or surface water (0.3%) readily available for consumption. However, ubiquitous pesticide use threatens to reduce the amount of available freshwater as pesticide runoff, recharge, and improper disposal tends to contaminate adjacent waterways, like rivers, streams, lakes, or underground watersheds. With rivers and streams only accounting for 2% of surface waters, it is essential to protect these vulnerable ecosystems from further degradation, including aquatic biodiversity loss, a decrease in water quality/drinkability. Researchers in the report note, “[The] primary objective of this study was to characterize pesticide mixtures found in stream water samples at 72 sites across the United States in watersheds with agricultural, developed, and mixed land uses during 2013–2017.” Additionally, researchers aim to understand the “potential toxicity to aquatic life from the pesticide mixtures and evaluate the occurrence of drivers of potential mixture toxicity.”

To assess national water quality, researchers collected water samples from watershed sampling sites established in 1992 by the National Water Quality Network (NWQN) – Rivers and Streams, based on land-use type (agricultural, developed/urban, and mixed). From 2013-2017, researchers collected water samples from each watershed site monthly, increasing collection frequency in months with greater pesticide runoff, like rainy seasons. Researchers assessed pesticide levels in water samples using direct-aqueous injection liquid chromatography with tandem mass spectrometry to analyze a total of 221 pesticide compounds in filtered (0.7 μm) water samples at the USGS National Water Quality Laboratory. To evaluate pesticide toxicity, researchers applied a Pesticide Toxicity Index (PTI) to measure the potential toxicity of pesticide mixtures to three taxonomic groups – fish, cladocerans (small freshwater crustaceans), and benthic invertebrates. PTI score classification encompasses three levels to represent approximate screening levels of predicted toxicity: low (PTI ≤ 0.1), chronic (0.1 < PTI ≤1), and acute (PTI > 1).

The results find that during 2013-2017 at least five or more pesticides present in 88% of water samples from NWQN sampling sites. Only 2.2% of the water samples have no pesticide concentrations above detectable levels. The median number of pesticides present per water samples from each land-use type is highest in agricultural settings with 24 pesticides, and lowest in mixed (both agricultural and developed land) settings with seven pesticides. Developed areas fall in the middle, amassing 18 pesticides per water sample. Pesticides in water samples are potentially acutely to chronically toxic to aquatic invertebrates and chronically toxic to fish. Of the 221 pesticide compounds analyzed, 17 (13 insecticides, two herbicides, one fungicide, and one synergist) are primary drivers of toxicity in aquatic taxonomic groups. According to the PTI analysis, one pesticide compound contributes to >50% of the sample toxicity, while other present pesticides only contribute minimally to toxicity. For cladocerans, the main pesticide compounds driving toxicity are the insecticides bifenthrin, carbaryl, chlorpyrifos, diazinon, dichlorvos, dicrotophos, diflubenzuron, flubendiamide, and tebupirimfos. The herbicide atrazine and the insecticides bifenthrin, carbaryl, carbofuran, chlorpyrifos, diazinon, dichlorvos, fipronil, imidacloprid, and methamidophos are the main drivers of potential pesticides toxicity for benthic invertebrates. Pesticides that have the most chronic impact on fish include the herbicide acetochlor, the fungicide degradant carbendazim, and the synergist piperonylbutoxide.

The U.S. Geological Survey (USGS) “assesses the occurrence and behavior of pesticides in streams, lakes, and groundwater and the potential for pesticides to contaminate our drinking-water supplies or harm aquatic ecosystems,” via its National Water-Quality Assessment (NAWQA) reports. Previous USGS reports demonstrate that pesticides are ubiquitous in the aquatic environment and a pervasive contaminant of freshwater ecosystems. Many of the most commonly used pesticides in the U.S. are detectable in both surface and groundwater, which serve as drinking water sources for half of the U.S. population. Furthermore, pesticide-contaminated rivers and streams can discharge polluted water into oceans and lagoons like the Great Barrier Reef (GBR), where a mixture of over 20 different pesticides are present in 99.8% of GBR samples. However, these chemicals can have adverse health impacts, not only on aquatic organisms but terrestrial organisms which rely on surface or groundwater. Many of these chemicals cause endocrine disruption, reproductive defects, neurotoxicity, and cancer in humans and animals, and most are highly toxic to aquatic species. Additionally, water quality surveys usually detect the presence of more than one pesticide compound in waterways and the possible toxicity on marine organisms. However, neither USGS-NAWQA nor EPA’s aquatic risk assessment evaluates the risks a mixture of pesticides can pose to the aquatic environment.

Pesticide contamination in surface and groundwater raises another issue of deficient waterway monitoring and regulations that allow pesticides to accumulate in waterways. One of the ways the U.S. Environmental Protection Agency (EPA) protects human and environmental health is by regulating pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and point source pollution in waterways as sanctioned by the Clean Water Act. However, EPA’s recent rollbacks on waterway regulations do little to protect aquatic ecosystem health, which marine, and terrestrial species, including humans, require. Previously, USGS-NAWQA has criticized EPA for not establishing sufficient water quality benchmarks for pesticides. According to NAWQA, “Current standards and guidelines do not completely eliminate risks posed by pesticides in waterways because: (1) values are not established for many pesticides, (2) mixtures and breakdown products are not considered, (3) the effects of seasonal exposure to high concentrations have not been evaluated, and (4) some types of potential effects, such as endocrine disruption and unique responses of sensitive individuals, have not yet been assessed.”

The results of the study demonstrate 17 different pesticides are primary drivers of aquatic toxicity. Organophosphate insecticides are most responsible for chronic cladoceran toxicity, while imidacloprid insecticides cause chronic toxicity in benthic invertebrates. Organophosphates are a class of insecticides know to have adverse effects on the nervous system, having the same mode of action as nerve agents for chemical warfare. Exposure to imidacloprid insecticides can have adverse effects on the reproductive system and are highly toxic to various aquatic species. Although dichlorvos, bifenthrin, and methamidophos are rarely present within samples, when these chemicals are present, they exceed chronic and acute toxicity thresholds for aquatic invertebrates. However, researchers state toxicity indexes could underestimate the potential impact on aquatic life as past research finds that “short-term, potentially toxic peaks in pesticides frequently are missed by weekly discrete sampling.”

Aquatic invertebrates, including benthic organisms and cladocerans, are an essential part of the food web, consuming excess nutrients in the water, as well as being a food source for larger predators. However, the effects of pesticide contamination in waterways can have a bottom-up influence on the aquatic invertebrates, killing off beneficial invertebrates whose nerve system is similar to the terrestrial insect targets. Additionally, many benthic invertebrates are larvae of terrestrial insects, which are not only indicators of waterway quality and biodiversity but provide various ecosystem services such as bio-irrigation, decomposition, and nutrition. It is essential to mitigate the impacts that potentially toxic pesticides have on aquatic organisms in rivers and streams by regulating pesticide inputs, especially in regions where agrochemical use is more widespread.

The report reveals the number of pesticides in samples varied annually by site, with agriculture sites bearing the highest levels of pesticide use, including herbicides, insecticides, and fungicides, with severe seasonal influxes from May-July. Midwestern and Southern regions have the highest median number of pesticides per water sample due to the abundance of agricultural land use. These findings are consistent, with previous research suggesting water sources near agricultural regions tend to have higher levels of contaminants, especially during springtime, when agrochemical runoff is more rampant. A February 2020 USGS reporting on a collaborative sampling project (conducted with EPA) for pesticides in waterways detected 141 pesticides in seven Midwest streams and 73 in seven streams in the Southeast. Already, the Trump Administration waives the requirement of the multinational chemical company Syngenta-ChemChina to continue monitoring Midwest waterways for the presence of the weedkiller atrazine through 2020. Additionally, the administration’s replacement of the 2015 Waters of the United States (WOTUS) rule with the Navigable Waters Protection Rule will significantly weaken the protection of several U.S. waterways and wetlands, and by forsaking prohibitions on activities that threaten waterways from a variety of pollution harms. As the implications of climate change worsen, increasing instances of rainfall, and thus runoff, as well as glacial ice melt, which entraps legacy pesticides no longer in production, lack of specific pesticide monitoring can cause toxic chemicals to accumulate and synergize in the aquatic environment, further polluting water sources.

The use of pesticides should be phased out and ultimately, eliminated to protect the nation’s and world’s waterways and reduce the number of pesticides that make their way into your drinking water. Additionally, Beyond Pesticides has long advocated for protective federal regulation that considers potential synergistic and additive threats, to ecosystems and organisms, from admixtures of pesticides — whether in formulated products or “de facto” in the environment. Unfortunately, current administration regulations fail to consider the environment holistically, thus creating a blind spot that limits our ability to enact widespread change that truly improves ecosystem health. However, advocating for local and state pesticide reform policies can protect you and your family from pesticide-contaminated water. Furthermore, organic/regenerative systems conserve water, nurtures fertility, reduces surface runoff and erosion, reduces the need for nutrient input, and critically, eliminates the toxic chemicals that threaten so many aspects of human and ecosystem life, including water resources. For more information about pesticide contamination in water, see the Threatened Waters program page and Beyond Pesticides’ article Pesticides in My Drinking Water? Individual Precautionary Measures and Community Action. Tell the U.S. Environmental Protection Agency that it must do its job to protect health and the environment.

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

Source: USGS Press Release, USGS Report

(Beyond Pesticides, September 23, 2020) Multinational agrichemical corporation Bayer coordinated with the U.S. government to pressure Thailand to drop plans to ban glyphosate use, according to documents obtained by the Center for Biological Diversity (CBD). CBD is now suing the Trump Administration after it refused to release additional documents pertaining to the pressure campaign. The incident is the latest example of an administration that has allowed corporate interests to dictate American governmental action on toxic pesticides.

The documents reveal that the October 2019 letter that U.S. Department of Agriculture (USDA) Undersecretary Ted McKinney sent to Thailand’s Prime Minister Prayuth Chan-ocha pushing back on the country’s plan to ban glyphosate came shortly after emails Bayer sent to U.S. officials. In September and October 2019, Bayer’s Jim Travis asked the U.S. to act on its behalf in defense of the company’s glyphosate products. Emails reveal that Mr. Travis also collected intelligence on the personal motivations of Thailand’s deputy agriculture minister, including whether she was “a diehard advocate of organic food; and/or staunch environmentalist who eschews all synthetic chemical applications.”

Reports indicate that the U.S. government brought up the issue of glyphosate during trade talks in the context of considerations to revoke Thailand’s trade preferences. The White House specifically created talking points to refute any “concern that action related to Thailand has another cause.”

A draft of a letter sent to USDA Secretary Sonny Purdue two days before Thailand’s reversal on glyphosate is part of CBD’s legal complaint, as it is was completely redacted by the U.S. government.

Bayer asserted to Reuters that its public sector engagements are “routine, professional, and consistent with all laws and regulations.” The paper reports that Thailand’s action would have prohibited US exports from reaching Thailand, a market worth roughly $1 billion dollars.

As Thailand reversed its decision on glyphosate, it continues to come under pressure for targeting two other highly toxic pesticides, chlorpyrifos and paraquat. In the case of those chemicals, the U.S. and Brazil each launched separate complaints to the World Trade Organization. Like the Trump administration, the Bolsonaro administration has been accused of corrupt practices in favor of the agrichemcial industry.

Using the weight of the US government to intervene in foreign countries on behalf of chemical companies would be a scandal even if taken by itself. But the Trump administration has made practices like these standard. The list of incidents is nauseating: from former U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt’s Dow Chemical inspired chlorpyrios reversal, delay of farmworker protections, cuts to EPA staff, reversal of bee-toxic pesticide restrictions on wildlife refuges, lack of EPA enforcement, allowance to let Bayer Monsanto write the rules on dicamba, the registration of new bee-toxic pesticides opposed by beekeepers, cuts to independent scientific research, weakening of pesticide protections for endangered species, weakening of pesticide protections for the nation’s waterways, and proposal to plant genetically engineered crops on National Wildlife Refuges. These are just a small sample of the actions the Trump Administration has taken over the last four years – all of them have the potential to increase the profits of the agrichemical industry. Yesterday, Beyond Pesticides reported that EPA will reregister the potent endocrine disruptor atrazine despite significant hazards from its use, and long-established bans in developed countries like the EU.

Opening up the government to act only for the most moneyed, and powerful corporate interests is a concern not only for our health and environment, but the future of our democracy. EPA received over 280,000 comments on its decision to reregister glyphosate, with the vast majority opposed. It is critical that those concerned about continued use of toxic chemicals in our environment continue to exercise their democratic right to petition their government. Beyond Pesticides is suing EPA over this decision.

Bayer knows the dangers its glyphosate products pose to its bottom line, and recently agreed to settle with cancer victims with the creation a $10 billion fund. It, alongside industry umbrella groups like Croplife America, will continue to do everything possible to leverage a pliant administration to protect its products. Meanwhile countries like Mexico show that glyphosate use can and should be eliminated. Keep up pressure on EPA and the federal government, but also advocate for protections from toxic pesticides in your own state and community. The more land under organic management and production, the more straightforward it will be to eliminate the use of toxic and unnecessary chemicals like glyphosate, both here at home and abroad. See Beyond Pesticides’ organic program page.

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

Source: Center Biological Diversity, Reuters

(Beyond Pesticides, September 22, 2020) Use of the highly hazardous, endocrine disrupting weed killer atrazine is likely to expand following a decision made earlier this month by the U.S. Environmental Protection Agency (EPA). Under the guise of “regulatory certainty,” the agency is reapproving use of this notorious herbicide, as well as its cousins simazine and propazine in the triazine family of chemicals, with fewer safeguards for public health, particularly young children. Advocates are incensed by the decision and vow to continue to put pressure on the agency. “Use of this extremely dangerous pesticide should be banned, not expanded,” Nathan Donley, PhD, a senior scientist at the Center for Biological Diversity said in a press release. “This disgusting decision directly endangers the health of millions of Americans.” Beyond Pesticides has long argued against the continued use of the triazine herbicides, which includes atrazine.

Triazines are well known to interfere with the body’s endocrine, or hormonal system. Disruptions within this delicately balanced process in the body can result in a range of ill health effects, including cancer, reproductive dysfunction, and developmental harm. These weedkillers interfere with the pituitary gland’s release of luteinizing hormones, which regulate the function of female ovaries and male gonads. In comments written by Beyond Pesticides to EPA, the organization notes, “Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset.”

Despite the serious concerns atrazine poses to young children, the agency brushed these issues aside. EPA maintains that because it has all the studies minimally required under law, it could remove uncertainty factors established to safeguard children’s health. Yet the agency ignored epidemiological literature that raises concerns and uncertainty around atrazine’s association with birth defects, preterm delivery, low birth weight, and other abnormalities.

Minor, nearly insignificant changes to triazine product labels finalized by EPA’s decision are outweighed by a risk analysis framework that is not only fundamentally flawed, but also subject to political interference on behalf of the pesticide industry.

The agency’s decision to reregister atrazine comes as it is already under fire for recent actions taken to protect the weed killer’s primary manufacturer, Syngenta-ChemChina. Earlier this year, using the Covid-19 crisis justification, the Administration provided the multinational company a waiver from a requirement that it monitor Midwestern waterways for atrazine contamination.

In a press release announcing the decision, EPA Administrator Wheeler was joined by representatives from the Missouri Farm Bureau, as well as the head of the Triazine Network, a chemical industry group dedicated to defending these toxic herbicides. “The benefits of atrazine in agriculture are high, so these new protections give our nation’s farmers more clarity and certainty concerning proper use,” Administrator Wheeler said.

According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would provide an economic benefit to farmers. “The winners,” the authors  conclude, “in an atrazine free future would include farm worker, farmers and their families, and others who are exposed to atrazine either directly from field uses or indirectly from contaminated tap water along with natural ecosystem that are currently damaged by atrazine.” Numerous other countries, including the European Union as far back as 2004, have banned atrazine and eliminated use without any damage to the farming economy.

The accumulated evidence inevitably brings many proponents of pesticide reform to the conclusion that the Trump EPA, under Administrator Andrew Wheeler, is willing to sacrifice American’s health for the profits corporate donors; not for farmers, or an ideological desire to “reduce regulatory burdens,” as one lawmaker put it.

In light of an EPA woefully captured by the industry it is charged with regulating, Beyond Pesticides encourages advocates continue to put pressure on every level of government. EPA and the agrichemical industry must not think that those fighting for a better future will give up. Over 4,000 individuals signed on to Beyond Pesticides’ petition urging EPA to ban atrazine. In light of the agency’s failure to protect the public, work to restrict use at the state and local level. But don’t limit your advocacy to one class of chemical – promote organic farming and land care, which eliminates atrazine as well as all other highly toxic pesticides.

For more information on the specific dangers of atrazine poses to our health and the environment, watch the keynote presentation from distinguished professor Tyrone Hayes, PhD of University California, Berkeley, at the 33rd National Pesticide Forum in Irvine, CA. Dr. Hayes one of the world’s foremost experts on atrazine, has been the subject of incessant attacks Syngenta-Chemchina. If you’re interested in supporting the research of scientists like Dr. Hayes, reach out to Beyond Pesticides about contributing to the Fund for Independent Science.

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

Source: Center for Biological Diversity press release, EPA press release.

(Beyond Pesticides, September 21, 2020) The National Organic Standards Board (NOSB) meets online October 28-30 to debate issues—after hearing public comment October 20 and 22—concerning how organic food is produced. Written comments are due October 1. They must be submitted through Regulations.gov.

Everywhere we look, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, organisms large and small entangled in plastic, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. As we focus on one of the most blatant examples of environmental abuse—the dispersal of toxic chemicals across the landscape—it is important to seek a solution. Organic can be a big part of the solution, but only if it doesn’t stray from its core values and practices.

Tell the National Organic Standards Board to support core organic values.

From its very beginnings, the organic sector has been driven by an alliance of farmers and consumers who defined the organic standards as a holistic approach to protecting health and the environment, with a deep conviction that food production could operate in sync with nature and be mindful of its interrelationship with the natural world—protecting and enhancing the quality of air, water, land, and food. Organic is not just an alternative for people seeking better food—though it is that—or a more profitable way of farming—though we hope it is that, too. It is a path to prevention of total ecological collapse. We constantly return to the foundations of organic for inspiration and guidance. When we comment on NOSB proposals, we are not interested in what is less harmful. We feel an urgency to prevent ecological disaster. 

As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong, our Fall 2020 NOSB web page which will be up within the week. Comment on all issues that interest you. 

We especially encourage comments on the topics below, keeping in mind this definition from the organic regulations: 

“Organic production. A production system that is managed in accordance with the [Organic Foods Production] Act and regulations…to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.”  Meeting these goals, essential to a sustainable future, requires strong adherence to these organic standards. To adopt practices and materials that weaken organic, undermines the future. In this spirit, we urge the following:

1. Do Not Allow Virgin Paper in Organic Crop Production Aids. The Crops Subcommittee proposes to allow planting aids—including paper pots, seed tape, and plant collars—made from virgin paper. To date, the National Organic Program has allowed only recycled paper to be used in crop production (as mulch and in compost). Virgin paper—especially virgin paper from wood pulp—results in much greater environmental impacts than recycled paper and does not foster cycling of resources. Use of virgin paper made from hemp reduces some of these impacts but adds the impacts of agricultural hemp production. Virgin paper from wood pulp should not be allowed as a crop input in organic production. 
2. Get Plastic Out of Organic. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—on a wide range of organisms. Although concerns were first raised about microplastics in the marine environment, impacts on terrestrial organisms are increasingly documented. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Biodegradable biobased mulch film (BBMF) has been allowed in organic production since 2014, but no products meeting the requirements set by the NOSB are produced, so the NOSB is considering loosening the requirements (annotation). Furthermore, use of BBMF results in bits of microplastic that are not fully degraded. Synthetic mulches should not replace natural mulches like hay, straw, and wood chips. The annotation of BBMF should not loosen up restrictions on the bioplastic film.
3. Protect Marine Life. Seaweeds (marine algae) and fish byproducts are used as inputs into organic crop production, but there is concern about the impacts of overharvesting and destructive harvesting methods, so the Materials Subcommittee proposes to allow marine algae to be used only when the harvest meets specific conditions. These requirements should be adopted by the NOSB, along with strong enforcement provisions. Separate action on fish products proposed by the Crops Subcommittee is too weak because it is unenforceable and allows the commercial use of bycatch. Only fish byproducts from postconsumer waste should be allowed as soil inputs.
4. Tell the National Organic Program to Finally Take Action on “Inert” Ingredients. After years of NOSB action and NOP inaction on “inerts,” the Crops Subcommittee proposes the only action it can to stimulate NOP into action—it proposes to remove List 4 from the National List. According to the Organic Foods Production Act, NOP cannot allow the use of synthetic materials that are not supported by the NOSB. “Inert” ingredients are neither chemically nor biologically inert. They make up the bulk of pesticide products—sometimes as much as 99%–and have not been subjected to the scrutiny by the NOSB that has been applied to the few active pesticidal ingredients allowed in organic production. The NOSB must approve the Crops Subcommittee motion to remove the listing of List 4 “Inerts” and implement prior NOSB recommendations.               

Submit comments now.

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the four comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)

(Beyond Pesticides, September 18, 2020) In late August, Consumer Reports magazine (CR) issued a report titled, “Stop Eating Pesticides,” which offers consumers a rating system CR developed and employed to help them “get the health benefits from fruits and vegetables while minimizing [the] risk from toxic chemicals.” In addition to providing its analysis and ratings of the pesticide risk of a variety of produce items, CR recommends eating organically grown and raised foods whenever possible. It also makes a host of recommendations on federal pesticide policies and emphasizes the importance of maintaining the integrity of the National Organic Standards (of the USDA-housed National Organic Program). Beyond Pesticides appreciates that this mainstream publication has arrived at many shared, science-based assessments of the risks of pesticides. That said, a wholesale transition to organic and regenerative agriculture — rather than making the public figure out which fruits and vegetables are “safer” or “less safe” — is the real answer to the health risks of pesticides in the food supply, according to Beyond Pesticides.

The CR analysis used data from the U.S. Department of Agriculture’s (USDA’s) Pesticide Data Program for 2014–2018. Those pesticide residue data were compiled from tests of approximately 450 pesticides across 24,000 samples of 35 different fruits and vegetables. The analysis evaluated both conventionally grown, meaning produce that’s typically been treated with pesticides and synthetic fertilizers, and organically grown produce; it also reviewed both U.S. produced and imported items. CR based its ratings on four criteria: the number of pesticides found on each item, the average amount of residue of each pesticide found on the items, the frequency with which pesticides were found on samples, and the toxicity of the pesticides detected.

Embedded in the ratings is consideration of the number of child-size servings (i.e., 2/3 of an adult serving) of a fruit or vegetable item that could be consumed before the exposures could represent potential harm. The analysis was normed for a 35-pound child (the weight of an average four-year-old); adults would likely consume more in a serving, but CR says the relative risk would remain the same. CR notes that “in some cases, those levels exceed what CR’s experts consider safe.” See more on CR’s rating methodology here.

Based on the criteria mentioned, CR assigned Excellent or Very Good ratings to the “cleanest” produce, and Fair or Poor to the items that scored as most risky. One of the consultants to CR’s project was Charles Benbrook, PhD, an agricultural economist, former executive director of the National Academy of Sciences board on agriculture, and former research professor at the Center for Sustaining Agriculture and Natural Resources at Washington State University. He notes that, in order to “minimize the chance that risks are underestimated,” CR used “EPA’s chronic reference dose for each pesticide (the amount it considers not likely to cause harm over a lifetime), then applied the FQPA [Food Quality Protection Act] safety factor to known neurological toxins or suspected endocrine disruptors — even when the EPA doesn’t.”

CR writes, “This means that fruits and vegetables with residue of many different pesticides can still receive a rating of Very Good or even Excellent if the amounts are low compared with the level we consider harmful, or if the pesticides have a low toxicity. But others rate poorly if they have even a very small amount of a more dangerous pesticide.” On the face of it, rating a produce item with residue of many different pesticides as Very Good or Excellent would seem to contravene CR’s acknowledgement of EPA’s inadequate regulatory attention to exposures to multiple pesticide compounds. (See more on EPA and multiple exposure risks, below.)

CR’s report rates, for example, U.S. grown, non-organic broccoli, cabbage, carrots, corn, bulb onions, tomatoes, cranberries, oranges, and a few other items as Excellent, and domestic green beans, potatoes, spinach, peaches, and cherries as Poor. Nearly all of the domestic organic items rated fell into the Excellent category, with organic spinach being a notable exception. The report says that 33 pesticides were found on 76% of those samples. However, CR explains that the probable reason is that pesticides banned in organic agriculture can drift from fields where non-organic crops are grown — a common and growing problem, especially with increasing use of pesticides that pair with genetically engineered commodity crops, such as soybeans, cotton, and corn. Senior CR scientist Michael Hansen, PhD, comments, “The vast majority of the USDA data show that while pesticides are sometimes found on organic foods, the levels are usually 10 percent or less of what’s found on nonorganic, which would be consistent with drift from a neighboring field. When levels on organic and nonorganic are similar, government agencies should take a closer look.” Notably, imported produce often, though not always, had poorer ratings than domestic items.

The CR article chronicles a number of health risks associated with pesticide exposures, even at low levels, including cardiovascular diseases, cancers, reproductive dysfunction, respiratory problems (e.g., asthma, bronchitis), neurological impacts (e.g., developmental effects and dementia/Alzheimer’s), and endocrine dysfunction, among others. To its credit, the report also includes a section on the shortcomings of federal pesticide policy, which notes that CR’s own “experts say the government hasn’t upheld its responsibility to protect consumers [and that] the research used to set [pesticide residue] tolerances is imperfect, and they’re often too high.” The report also calls out the Environmental Protection Agency (EPA), which is primarily responsible for pesticide regulation, for multiple failures.

One is the failure to use the mandated FQPA “safety factor” (which establishes more-protective limits on residues) 85% of the time, from 2011 through 2019, for non-organophosphate pesticides. Another is that, despite the requirement of the FQPA to review registered pesticides for endocrine-disrupting impacts, by 2020 EPA has done this for only 52 of the roughly 9,000 pesticide compounds approved for use in the U.S. Dr. Hansen comments, “The tests the EPA uses to approve pesticides don’t take into account new evidence on pesticide harms, and it hasn’t incorporated many new scientific techniques.”

CR also points to some of the failings of EPA’s pesticide regulation that Beyond Pesticides has long discussed: relative inattention to the impacts of so-called “inert” or adjuvant ingredients in pesticide products; and reviewing (and registering) pesticides as single entities or classes, when in real life, people are often exposed to multiple pesticides. Brenda Eskenazi, PhD, director of the Center for Environmental Research and Children’s Health at the University of California, Berkeley, comments, “What we should be looking at is the whole swimming pool of chemicals that we’re exposed to.”

In recognizing the risks of pesticide residue in food and the importance to health of consuming a wide variety of fruits and vegetables (the goal being 4½ cups daily for most adults), CR underscores the conundrum the public faces. If conventional produce is contaminated with pesticides, what are consumers to do? The CR report says that they “can minimize the risk by choosing fruits and vegetables grown with fewer and safer pesticides.” To that end, the analysis proposes to “help consumers identify which produce poses the biggest risk from pesticides,” and asserts that the “good news” is that nearly “half of the nonorganic fruits and vegetables pose little risk. But about 20 percent, such as fresh green beans, peaches, and potatoes, received our worst scores; those are the ones it’s most important to try to buy organic. . . . For the lowest-scoring items, eating a half of a serving or less per day poses long-term health risks to a young child.” Beyond Pesticides believes that warning is more than warranted.

Choosing organic for the “worst” produce items is an incremental approach that does yield somewhat lower risks to eaters. Indeed, Beyond Pesticides has often covered the annual Environmental Working Group’s “Dirty Dozen^TM” and “Clean 15” guides to avoiding pesticide residue in foods. The “simplest” answer is to consume organic fare as much as is practicable. Yet that is not necessarily easy for everyone, whether it’s a matter of availability or price. This is one reason that those who can purchase most or all of their food as organic, should: it helps scale up organic production and, as organics occupy increasing market share over time, potentially bring prices more in line with conventional pricing. This is a short-term, market-based strategy; the equitable and most-protective strategy is to transition to organic agricultural practices, which nearly eliminate the risks of chemical exposures through food.

A decade ago, Beyond Pesticides addressed the affordability issue in a comprehensive article in its journal, Pesticides and You, which spelled out the “invisible” aspects of affordability. The article noted that a simple comparison of retail prices is a misleading metric on the cost of organic vs. conventional produce because “it overlooks the glaring fact that conventional farm operations do not incur the total cost of their production. Chemical-intensive agriculture has countless negative effects on our health and natural resources, which are not accounted for in most traditional farm business models, but [which] are passed on to society nevertheless. Some researchers calculate the adverse impacts to health and the environment to be as much as $16.9 billion a year [as of 2011] . . . . We still pay these costs, just not at the grocery checkout counter. Instead, we see these costs in the forms of higher taxes and medical bills, and decreased quality of life due to environmental pollution. Conversely, organic farmers take steps to ensure that they do not create these effects, which result in external costs. Instead, they internalize them and take care not to damage and deplete natural resources or create public health problems.”

Beyond Pesticides would add to this personal and societal calculation the consideration that consumption of conventionally grown produce — even those items that score well in CR’s analysis — takes both environmental and social justice tolls at the sites of food production and processing. Farmworkers, ecosystems, and biodiversity are notoriously negatively impacted by the use of pesticides. Beyond Pesticides Executive Director Jay Feldman notes: “We contribute to environmental racism when we eat conventionally grown food because the regulation and risk assessments that support our chemical-intensive food system institutionalize disproportionate risk for black and brown people.” CR senior policy analyst Dr. Charlotte Vallaeys is quoted in the article: “The effects of pesticides on the people who grow and harvest our food is a big part of the reason CR recommends buying organic when you can.”

Beyond Pesticides’ 2020 Labor Day Daily News Blog article added, “Our work . . . will continue to seek changes in underlying policies that codify disproportionate harm, such as federal pesticide law that is built on a foundation that allows elevated and disproportionate risk to workers who are excluded from EPA’s cumulative risk assessment (under the Food Quality Protection Act, amendments to the Federal Food, Drug and Cosmetic Act, and the Federal Insecticide, Fungicide, and Rodenticide Act), which aggregates dietary and non-dietary, but explicitly not occupational, exposure to pesticides, while including a mandate to protect children. With this, the law effectively requires EPA to allow higher rates of harm for workers, particularly farmworkers [and] landscapers (who are disproportionately people of color), and others occupationally exposed to pesticides.”

The CR article acknowledges that there are big knowledge gaps about impacts of pesticides on human health, never mind on ecosystems, and says, “Laws governing the use of pesticides on produce in the U.S. are based, at least in theory, on a philosophy of avoiding potential risk in the absence of definitive proof of their harm.” The glaring failing in this EPA approach to regulation is the lack of a precautionary framework. As as Dr. Vallaeys notes in the article, “It makes sense that we should err on the side of caution and base decisions about pesticide use not just on what we know but also on what we don’t yet know.” EPA’s current policies and practices essentially allow chemical experimentation on the U.S. population without the public’s permission, and without benefit of understanding what the impacts of various pesticides will be, given multiple, chronic, and ubiquitous exposures.

Among CR’s recommendations are these:

• Ban the agricultural use of the riskiest pesticides, which would protect children, especially, as well as farmworkers and rural communities.
• EPA should, as it is mandated to do, apply the FQPA safety factor to all neurotoxins, suspected endocrine disruptors, and any pesticide whose safety is uncertain.
• EPA should make available a public, easily accessible and searchable database of currently registered pesticides, including information on whether the FQPA safety factor was applied when tolerance levels were set.
• Place an import alert on produce that tests positive for banned pesticides. (Pesticides banned in the U.S. sometimes show up on samples of imported produce in the Pesticide Data Program databases.) USDA should apprise the U.S. Food and Drug Administration, which is responsible for enacting and enforcing import alerts, when such residues are detected.

Beyond Pesticides hopes that the Consumer Reports article, given the vaunted independence of the publication, will make inroads in educating the public about the dangers of pesticides. Stay updated on the relationships between pesticides and health, as well as the many other impacts of their use, via the Daily News Blog and the quarterly journal Pesticides and You, and through supporting the mission of Beyond Pesticides: “protecting public health and the environment to lead the transition to a world free of toxic pesticides” by becoming a member. For more information, see Beyond Pesticides’ Eating with a Conscience.

Source: https://www.consumerreports.org/pesticides-in-food/stop-eating-pesticides/

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

(Beyond Pesticides, September 17, 2020) The apparel industry becomes the latest contributor to global biodiversity loss, directly linking soil degradation, natural ecosystems destruction, and environmental pollution with apparel supply chains, according to the report, “Biodiversity: The next frontier in sustainable fashion,” by McKinsey & Company. Although there are many studies on the fashion industry’s impact on climate change, much less research discusses the impact the industry has on biodiversity. The globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk of extinction. With the increasing rate of biodiversity loss, advocates say it is essential for government agencies to hold the fashion industry accountable for the direct (i.e., excessive agrochemical use, water consumption) and indirect (i.e., water pollution from run-off) impacts on the environment, not only to protect the well-being of animals, but humans, as well. Researchers in the study note, “We expect biodiversity to become an even greater concern for consumers and investors in the coming years. Covid-19, instead of slowing the trend, has accelerated it—perhaps because people now understand more deeply that human and animal ecosystems are interdependent. It’s time for the apparel industry, which to date has contributed heavily to biodiversity loss, to now make bold moves in the opposite direction.”

People now, more than ever, are changing their sentiment toward sustainability, with two-thirds of consumers stating the importance of limiting climate change impacts, and 88 percent maintaining that more attention should be given to pollution reduction. Although apparel companies are cognizant of climate change, initiating numerous projects for carbon neutrality, the relationship between climate change and biodiversity—a “distinct but related issue”— is less apparent in the apparel industry. Climate change and biodiversity loss are interdependent, and an adverse impact on one can bolster an adverse effect on the other. Biodiversity is intricate and affects all environmental ecosystems—from oceans and freshwater to forests and soils; it encompasses all life forms on earth. Furthermore, without biodiversity, global reliance on food, energy production, clean water, fertile soil, sustained air quality, and climate regulations will suffer. Researchers remark, “Through our analysis of quantitative impact indicators as well as industry-expert interviews, we have developed a good understanding of how each part of the apparel value chain affects biodiversity.”

To determine how the apparel industry contributes to biodiversity loss, researchers examined each stage of the apparel supply chain, including raw material production, material preparation and processing, production manufacturing, transportation and distribution, retailing, product-use life, and end-use. Researchers assess the negative impacts that each stage of the apparel supply chain has on biodiversity, analyzing land and water use patterns, chemical pollution, waste production, and energy consumption. Additionally, researchers developed a “biodiversity impact area” map using data from the International Union for Conservation of Nature (IUCN) to determine the severity (high, medium, low) of impact on biodiversity from each apparel chain sector on land and water use, pollution, climate change, and overexploitation.

The results of the report identify the apparel sector’s five largest contributors to biodiversity loss in order of overall value added to the apparel industry: cotton agriculture, wood-based natural fibers/synthetic manmade cellulose fibers (MMCFs), textile dyeing and treatment, microplastics, and waste. All five contributors come from three stages in the apparel sector: raw-material production, material preparation and processing, and end-use. Raw material and production have the highest levels of land, water, and energy use, with chemical pollution following close behind. Material preparation and processing have the highest levels of chemical pollution and energy consumption, preceding water use levels. The end-use sector has the most elevated waste levels of all apparel sectors. According to the “biodiversity impact area” map, most of the apparel industry sectors contribute to environmental pollution (i.e., chemical, physical, geological, biological) that impacts species biodiversity.

Many people, including regulators and corporations themselves, are aware of the adverse environmental impacts associated with the apparel industry, including the production of 10% of all global CO2 emissions, approximately 20% of all industrial water pollution, nearly 35% of oceanic microplastic pollution, and massive amounts of textile waste. Despite the environmental impacts, the fashion industry continues to grow and pollute due to the upsurge in “fast fashion,” which relies on cheap product manufacturing, frequent consumption of goods and services, and brief clothing use to meet consumer demands. Nowadays, the amount of material-use in fast fashion is increasing as clothing brands are generating nearly double the amount of clothing than in the early 2000s.

Just as regular apparel production and consumption, fast-apparel production and consumption increase CO2 emissions, uses an enormous amount of water (trillions of liters per year), and produces an immense quantity of textile waste, most of which companies burn or send to landfills/developing countries. Furthermore, the entire apparel manufacturing process uses countless chemicals that are hazardous to consumers, factory workers, and the environment, including chemicals that lead to ailments, like brain cancer. A few examples of chemical hazards also include pesticide use on crops that produce raw material, chemical contamination in soils from pesticides and synthetic fertilizers, and chemical run-off into waterways from textile dyes and microfibers. Additionally, some fabrics treatments involve the infusion of harmful antimicrobial agents, like titanium dioxide or silver nanoparticles (nanosilver), which can seep into a person’s sweat and absorb through the skin. 

The apparel industry’s dependence on natural resources for the production of goods from raw materials demonstrates a need for sustainable practices to mitigate the risks associated with natural resource deficiency, including biodiversity loss. These businesses rely on the benefits of biodiversity and ecosystem services, such as pollination of crops and access to clean water for financial and operational success. With the global population increasing rapidly, the subsequent need for apparel will increase and result in significant biodiversity loss if the industry’s supply chain practices remain unsustainable.

Of the largest contributors to biodiversity loss, cotton agriculture, textile dyeing and treatment, microplastics from washing, and pollutants from waste have the highest impact on species biodiversity due to the presence of toxic chemicals, some of which the European Union classifies as hazardous to human health or the environment. According to this report, cotton agriculture is the most vital part of the apparel value chain, as cotton is the most popular, nonsynthetic fiber globally. In addition to being a water-intensive crop, utilizing over 700 gallons of water to make one t-shirt, cotton only grows on 2.4% of farmland worldwide, is one of the most agrochemical intensive crops, applying 22.5% and 10% of the world’s insecticides and all pesticides, respectively. Additionally, chemical pollution from MMCFs manufacturing, which creates fibers from cellulose in wood, can impact soil and water quality in areas of logging and processing, resulting in habitat loss and endangering various species endemic to the region.

Textile dyeing and treatment, as well as microplastics, mainly impact the marine environment, with dyeing and treatment accounting for 25% of all industrial water pollution. Microfibers (a type of microplastic) pollute waterways, with 7.5 million tons of microfibers ending up in the oceans from standard washing (i.e., hand-wash, machine-wash) annually. These microfibers are often synthetic and contain toxic chemicals that poison marine wildlife and accumulate higher up the food chain. Lastly, a majority, 73%, of textile waste ends up in landfills or incinerators, yet, only 12% degrades overtime, and less than 1% gets recycled. Landfill development can account for a loss of nearly 30 to 300 species, and the remaining waste can release pollutants into the surrounding habitat and contribute to habitat loss. The authors of the report conclude, “For the apparel sector to slow broader global biodiversity loss, a radical shift from business, as usual, will be necessary.”

In this report, researchers offer four innovative intervention areas for companies to focus on to reduce the industry’s impact on biodiversity:

1. Scale-up innovative materials and processes
   • There is no perfect material. As discussed, each of the most commonly used materials in the apparel industry—cotton, MMCFs, and synthetics—has a negative impact on biodiversity. But each of these can be made more sustainable. Furthermore, better alternatives do exist and could dramatically improve with more investment and innovation.
2. Take an aggressive stance against waterway pollution.
   • In the absence of effective regulation, waterway pollution from textile dyeing and processing requires a tougher stance from apparel brands.
3. Lead the way in education and empowering consumers.
   • Brands can help further educate consumers about what they can do to minimize the impact of their actions on biodiversity loss. Simple behavioral adjustments and consumption choices can have substantive results. For example, just doing laundry differently—specifically, in the following three ways—can make a big impact: washing in cold water, filtering microfibers, and using water-efficient washing machines. 
4. Relentlessly pursue zero waste.
   • One of the most powerful changes the apparel sector can make in the interest of biodiversity is to simply stop making too many clothes. Average overproduction is estimated around 20 percent. Manufacturers recycle roughly 75 percent of pre-consumer textile waste. But the remaining 25 percent primarily ends up in landfills or is incinerated—without ever having been worn, though some of it may be donated.

Additionally, the authors suggest that companies lead the way in transforming the apparel industry into a more sustainable enterprise:

• Manage for biodiversity like you manage value creation [by] factor[ing] biodiversity impact into financial.
• Shift the model on supplier engagement to…define joint [quantity] standards for suppliers.
• Invest in the broader ecosystem to accelerate and scale innovation [by] team[ing] up with other apparel companies to invest in scaling and industrializing emerging, low-impact technologies, and substitutes for nonsynthetic fibers.
• Push for change in adjacent, relevant industries, [like] agricultural, livestock, and chemical industries, [which] all face similar challenges in addressing their biodiversity footprints.
• Engage with policymakers and welcome meaningful biodiversity regulation.

As the global population reaches eight billion people, the need for apparel will increase along with harmful chemical use, excessive landfill waste, and extensive pollution in terrestrial and aquatic environments. Although recycling used clothing can help alleviate waste management in the apparel industry, the industry still uses harmful chemicals to maintain crop yields  and manufacture/process materials that can have adverse impacts on human, animal, and environmental health.

With the Trump administration dismantling many environmental regulations, including waterway monitoring, it is vital to understand how chemical pollutants from textiles and pesticide use in croplands can increase the risk of biodiversity loss. 

Making sustainable apparel choices can aid in the reduction of biodiversity loss due to the lack of harmful impacts on the environment from chemical, waste, water, and land pollution. Additionally, buying, growing, and supporting organic can help eliminate the extensive use of pesticides in agriculture and the environment. Organic agriculture has many health and environmental benefits, which can eliminate the need for chemical-intensive agricultural practices in the apparel industry. For more information on how organic is the right choice for both consumers and the farmworkers who grow the crops for our clothing, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture. 

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

Source: McKinsey & Company

(Beyond Pesticides, September 16, 2020) Disease carrying mosquitoes are more likely to flourish in areas being altered by human activities, according to new research published by scientists at Oregon State University. With climate change facilitating the spread of mosquitoes into new regions throughout the world, it is critical to understand the drivers of mosquito-borne disease in order to establish effective mitigation measures. “People care a lot about what environment a lion needs to succeed in; we’ve researched that extensively. But people don’t do that with mosquitoes. We don’t understand them as a group of species and how their ecology differs between species,” said study co-author Brianna Beechler, PhD, a disease ecologist and assistant professor of research in Oregon State University’s Carlson College of Veterinary Medicine.

Authors of the study note that most mosquito collection occurs opportunistically, with samples taken at known mosquito breeding sites. To better understand mosquito spatial ecology, scientists conducted paired sampling at locations inside and outside South Africa’s Kruger National Park, the largest nature preserve in the country. Each sample location inside the park was paired with another sample from a similar location (in terms of landscape and climatic conditions) in developing areas outside of the park. Human disturbance was measured by five factors, including (i) pesticide use, (ii) nutrient loading, (iii) human population density, (iv) biomass of grazing animals, and (v) loss of vegetation.

While these factors are all well known hazards for wildlife, researchers determined that disease vector mosquitoes are one important exception. Unsurprisingly, each of these impacts are significantly higher, by orders of magnitude, outside the park than inside. It followed that mosquito abundance outside the part is determined to be an average 2.9 times (ranging between 1.5 and 10 times) greater than paired sites of similar layout inside the national park.

Sheer numbers are merely half the story. Scientists also observed changes in the relative abundance of certain species of mosquitoes. Disease carrying mosquitoe populations are much higher outside of the park than inside, consistently accounting for roughly 80% of the difference in community composition between paired sites.

Although this research took place in South Africa, the authors indicate their findings are broadly applicable. “Given the global extent and intensity of the investigated anthropogenic pressures, these results are likely relevant for a wide array of vector-borne pathogens and provides a mechanism for the association between ecosystem degradation and disease,” the study reads.

In light of the results, certain impacts are more easily explained than others. Pesticide use, for example, can disrupt the trophic food web, killing of mosquito predators. A study published last year found that in the context of incessant pesticide use mosquitoes were able to out-breed predator damselflies. Nutrient loading and eutrophication can likewise result in the die-off of important species of aquatic predators. “It seems to suggest that disease-carrying mosquito species certainly did better in human-altered environments,” Dr. Beechler notes in a press release. The author further indicates that more study is needed to ascertain the ecological conditions that benefit various mosquito species.

This study has critical implications for mosquito management in states and communities throughout America. It underscores the importance of a science-based, ecological mosquito management program that takes local ecology into consideration and places and emphasis on habitat manipulation, a practice that naturally reduces mosquito populations through alterations to the landscape or built environment.

The City of Boulder, Colorado has long led the way in mosquito management, and has recently taken its approach to the next level in a way that appears aligned with the results of the study, and should act as a model for communities throughout the country. In 2019, the city began working with an ecologist to conduct wetland surveys and assess local biodiversity in mosquito breeding habitats. Preliminary results have already found when habitat supports fish populations, mosquito larvae are usually absent. And when damselflies and dragonflies are present, adult mosquitoes are often absent.

A sound approach to mosquito management is science-based and prioritizes preventive measures. These measures include surveillance, monitoring, public education on eliminating breeding sites and personal protective actions, consideration of local ecology, habitat manipulation, and larviciding with biological materials. Any pesticide use should always be considered a last resort. Not only because of the threats these chemicals pose to human health, but as the present study shows, because pesticide use has the potential to shift mosquito species composition toward increased populations of disease carrying mosquitoes. Community leaders must focus what is truly effective for long term health and safety, and resist the propensity to spray toxic pesticides to assuage resident concerns, and make it seem as though something is being done.

If you’re concerned about spraying in your community, begin your education by reading Beyond Pesticides Public Health Mosquito Management Strategy for Decision Makers and Communities. See Beyond Pesticides Mosquito and Insect Borne Diseases program page for additional information. Reach out for additional assistance, and stay tuned for new resources aimed at encouraging safer mosquito management in local communities.

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

Source: Scientific Reports, Science Daily (press release)

(Beyond Pesticides, September 15, 2020) Both wild and captive primates are being exposed to hazardous pesticides and flame retardants, according to research published this month in the journal Environmental Science and Technology. This is the first study to look at the threat anthropogenic (man-made) chemicals may present for this important order of animals. “We think a lot about habitat disturbance, logging, and hunting as threats to these species, while pollution has been overlooked,” study co-author Michael Wasserman, told Environmental Health News (EHN).

Scientists conducted their research by first obtaining fecal samples from three distinct primate populations: captive baboons from an Indiana zoo, wild howler monkeys from a research station in Costa Rica, and wild chimpanzees, red-tailed monkeys, and red colobus monkeys from a Ugandan national park. Samples were then tested for a range of chemicals, including 50 pesticides, and nearly 70 flame retardants.

Scientists discovered legacy pesticides (such as heptachlor, DDT, hexachlorohexane, chlordane, and related compounds) in every species tested, with the highest levels found in red colobus and red-tailed monkeys. In particular, DDT and its related compounds (DDD and DDE) were found to be widespread, with red colobus monkeys registering a median of 260 ppb DDE in its waste. Current use pesticides were only detected in the feces of primates from the United States and Costa Rica. Over half of these animals have chlorpyrifos pass through their bodies. Baboons in the Indiana sanctuary are the only population exposed to synthetic pyrethroids. Flame retardant exposure is also widespread, with the chemical tris(2-butoxyethyl) phosphate the most widely detected.

“We were surprised both at the number of chemicals measured in the feces and the levels of some of these chemicals in animals, especially those that are wild,” Marta Venier, PhD, senior author of the study, told EHN.

To elucidate exposure patterns, scientists investigated food sources, air quality, and other ambient environmental factors. Many of the conventional food and commercial feed provided to the captive baboons contained some level of pesticide. And air quality recordings in Uganda appear to correspond with with the chemicals found in primate feces. “[L]evels of some of the chemicals in air were comparable to what we see in Chicago, which was really surprising,” Dr. Venier told EHN. Detections not explained by food or ambient air quality could be related to legacy exposure in surrounding vegetation, or geophagy, the eating of soil, for certain primates.

While no detection was found above minimum risk levels (MRL) set by the Agency for Toxic Substances and Disease Registry, the authors write, “MRLs for primates are expected to be different from those of humans used here; these estimates are based on numerous assumptions and simplifications; and MRLs rely on the single chemical approach, while feces revealed that primates are exposed to a complex mixture of chemicals.”

Thus, it is unclear what the health implications are for primates exposed to this mixture of toxic human-made chemicals—though the outlook is not rosy. Scientists are encouraging further research, indicating that the presence of these chemicals in protected areas, “warrants an evaluation of the possible biological effects resulting from exposure and a consideration of how exposure and susceptibility should influence conservation planning.”

In the mid-2010s, scientists discovered that roughly 1 in 10 chimpanzees in a Ugandan wildlife preserve (located nearby the current study) exhibited dysplasia and facial deformities. Although studies are ongoing, many are linking this phenomenon to the use chlorpyrifos and other insecticides in nearby farms. Although data on pesticide impacts to primates is scarce, research conducted on their marsupial cousins finds that pesticide exposure does have the potential to cause adverse effects in the wild. An Australian study published earlier this year found that the herbicide atrazine can impede the reproductive success of exposed wallabies.

While specific effects on more complex species such as humans and other primates are often difficult to ascertain, it is clear that human production and release of hazardous chemicals into the environment is having significant effects on wildlife. Most concerning, these impacts start at the bottom of the food chain, with massive insect die-offs, and are now collapsing the populations of higher trophic species like birds.

It is not too late to take action against toxic pesticides, begin to reverse declines, and improve humanity’s relationship with the natural world. Learn more about the damage pesticides cause to wildlife on Beyond Pesticides program page, and get active in your community to encourage safer methods of managing land and growing food.

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

Source: Environmental Health News, Environmental Science and Technology

(Beyond Pesticides, September 14, 2020) As Congress returns to Washington this week, it is overdue to pass critical pandemic aid for families and communities, including helping small and mid-scale farms and ranches, farmers markets, and local food businesses address the impacts of the Covid-19 pandemic.

The Local and Regional Farmer and Market Support Act (H.R. 8096), introduced by Rep. Alma Adams of North Carolina, will help meet the needs of farmers who have been left out. Please urge your Congressional Representative co-sponsor this bill.

While farmers struggle to feed their communities during the ongoing coronavirus pandemic, many have not received support for critical safety and technology needs. Billions in federal aid through the Coronavirus Food Assistance Program (CFAP) has gone out, but failed to reach all farmers—particularly direct marketing farmers and ranchers, diversified farmers, and folks who are Black, Indigenous, and people of color. Local and regional food enterprises have worked to supply food through farmers markets, food hubs, CSAs, and more, but have not received the support given to larger enterprises.

Tell Congress to Help Farmers of Color and Small and Medium-Sized Farms Selling in Local Food Markets.

The Local and Regional Farmer and Market Support Act:

• Creates an alternative coronavirus relief payment program for farmers who sell in local and regional markets based on their historic revenue, rather than price loss;
• Provides emergency response grants for farmers markets and local food enterprises to implement public health protections and coronavirus-smart marketing practices;
• Provides emergency response grants to direct marketing farmers to help them respond to shifting markets and adopt new socially distant practices and sales models;
• Supports equity and ensure access to these grants and relief payments by prioritizing assistance to Black, Indigenous, and people of color farmers and minority-owned farmers markets and local-food enterprises; and
• Provides robust outreach and technical assistance to Black, Indigenous, and people of color farmers and ranchers.

This bill will help farmers stay in business and keep feeding their communities, ensure equitable access to aid, and support our responsive, resilient local food supply chains. Ultimately, it will create a more resilient farm and food system for the long haul toward recovery. 

>>Tell Congress to Help Farmers of Color and Small and Medium-Sized Farms Selling in Local Food Markets.

As Congress returns to Washington this week, it is overdue to pass critical pandemic aid for families and communities, including helping small and mid-scale farms and ranches, farmers markets, and local food businesses address the impacts of the Covid-19 pandemic.

The Local and Regional Farmer and Market Support Act (H.R. 8096), introduced by Rep. Alma Adams of North Carolina, will help meet the needs of farmers who have been left out. Please urge your Congressional Representative co-sponsor this bill.

While farmers struggle to feed their communities during the ongoing coronavirus pandemic, many have not received support for critical safety and technology needs. Billions in federal aid through the Coronavirus Food Assistance Program (CFAP) has gone out, but failed to reach all farmers—particularly direct marketing farmers and ranchers, diversified farmers, and folks who are Black, Indigenous, and people of color. Local and regional food enterprises have worked to supply food through farmers markets, food hubs, CSAs, and more, but have not received the support given to larger enterprises.

Tell Congress to Help Farmers of Color and Small and Medium-Sized Farms Selling in Local Food Markets.

The Local and Regional Farmer and Market Support Act:

• Creates an alternative coronavirus relief payment program for farmers who sell in local and regional markets based on their historic revenue, rather than price loss;
• Provides emergency response grants for farmers markets and local food enterprises to implement public health protections and coronavirus-smart marketing practices;
• Provides emergency response grants to direct marketing farmers to help them respond to shifting markets and adopt new socially distant practices and sales models;
• Supports equity and ensure access to these grants and relief payments by prioritizing assistance to Black, Indigenous, and people of color farmers and minority-owned farmers markets and local-food enterprises; and
• Provides robust outreach and technical assistance to Black, Indigenous, and people of color farmers and ranchers.

This bill will help farmers stay in business and keep feeding their communities, ensure equitable access to aid, and support our responsive, resilient local food supply chains. Ultimately, it will create a more resilient farm and food system for the long haul toward recovery. 

Tell Congress to Help Farmers of Color and Small and Medium-Sized Farms Selling in Local Food Markets.

Letter to Congress

I am writing to ask you to co-sponsor the Local and Regional Farmer and Market Act (H.R. 8096), introduced by Rep. Alma Adams of North Carolina. It is critical for pandemic response and recovery for agriculture.

The bill:

*Provides direct support for producers selling into local and regional markets based on the income losses they have experienced.

*Prioritizes funding for Black, Indigenous, and people of color and low-income communities of color and include robust outreach, technical assistance, and data collection, to ensure that aid is distributed equitably.

*Provides emergency response grants for farmers markets and local food enterprises to allow those operations to adapt to new market conditions, implement public health and safety protections, and further support communities experiencing food insecurity.

Please fight for farmers in our state and support these provisions by co-sponsoring the Local and Regional Farmer and Market Support Act.

Thank you for your support.

(Beyond Pesticides, September 11, 2020) In late August, the National Black Farmers Association filed suit against the chemical company Bayer/Monsanto, seeking to stop the sale of its ubiquitous, glyphosate-based herbicide, Roundup. According to the Midwest Center for Investigative Reporting, the lawsuit argues that Black farmers are, essentially, forced to use Roundup and incur the risks of developing non-Hodgkin Lymphoma or other cancers (or health impacts) because of the exigencies of the pesticide and biotech industry “grip” on agriculture in the U.S. The suit maintains that Bayer (which owns Monsanto, the original manufacturer of Roundup) knowingly failed, and continues to fail, to warn farmers adequately about the dangers of the pesticide. In a Labor Day Daily News post, Beyond Pesticides noted that current pesticide laws result in disproportionate impacts on workers, including agricultural workers of color. Beyond Pesticides is committed to addressing the conditions that give rise to disproportionate harm and to working in broad coalitions to correct them.

Many countries have banned use of Roundup, largely because of glyphosate’s strong links to many health issues, including cancer, endocrine disruption, Parkinson’s Disease, and reproductive and immunological anomalies. The compound is regarded as carcinogenic by the International Agency for Research on Cancer and by many public health experts and researchers. The Environmental Protection Agency (EPA) has concluded otherwise in its May 2019 interim decision, asserting that glyphosate herbicides are “not likely to be carcinogenic to humans,” and again in January 2020, when it reinforced that position in a news release that said, “After a thorough review of the best available science, as required under the Federal Insecticide, Fungicide, and Rodenticide Act, EPA has concluded that there are no risks of concern to human health when glyphosate is used according to the label and that it is not a carcinogen.”

That 2019 announcement came, from an administration that has skewered, suppressed, and delegitimized science, despite an April 2019 report by the Agency for Toxic Substances and Disease Registry — an agency of the U.S. Department of Health and Human Services — that evidenced findings supporting glyphosate’s carcinogenicity. Bayer rejects claims that Roundup causes cancer, despite both the evidence to the contrary, and many successful decisions in litigation based on this claim.

In 2019, less than 2% of U.S. farmers were Black, according to Pacific Standard. Investigate Midwest puts that metric at 1.3%, and adds that “Black farmers own .52% of U.S. farmland. . . . Overall, Black people make up about 13.4% of the U.S. population, the U.S. Census reports.” In addition, Black farmers tend, on average, to operate smaller farms and have narrower profit margins than operations owned by white farmers.

The suit brought by the National Black Farmers Association (NBFA) is led by Ben Crump, a well-known civil rights lawyer who has represented the families of numerous Black people killed or injured by law enforcement. Mr. Crump, according to law.com, has said that although Bayer claims that it agreed to the June 2020 settlement of a multidistrict suit (see below) “without regard to race or any other demographics,” the company’s failures to warn users of the dangers of the herbicide Roundup fell more heavily on Black farmers.

The plaintiff’s arguments are several. The farmers contend that — in a landscape of Bayer Crop Science’s near-hegemony on some genetically engineered, Roundup-ready seeds, especially soy, corn, and cotton — they are essentially forced to buy Roundup-resistant seeds and, with burgeoning resistance issues, larger quantities of Roundup every year, putting them at significant, and disproportionate, risk of developing cancer. The suit also argues that Black farmers are, on average, less literate than the general population, and have disproportionately limited access to the Internet. Thus, they generally rely more heavily on local seed salespeople for guidance about seed and pesticide purchases. Salespeople, Beyond Pesticides notes, are in the business of selling products and making money, rather than protecting farmers’ health.

The NBFA litigation is the latest in a massive number of lawsuits involving Roundup — more than 125,000 on cancer claims alone — brought against the company by victims of glyphosate exposure. In an attempt to consolidate many of those suits under a single settlement, Bayer/Monsanto announced in June 2020 that it would “pay up to $10.9 billion to resolve current and potential future litigation. According to Bayer, the settlement will ‘bring closure’ to approximately 75% of current Roundup™ litigation.” U.S. District Judge Vince Chhabria (of the Northern District of California) issued a 60-day stay of the lawsuit to allow the settlement to proceed.

That deal, however, may be in trouble, according to Bloomberg and The New York Times. In July, the NYT reported that court approval of one strand of the complex agreement — a plan for handling claims in the future from those who develop glyphosate-related non-Hodgkin Lymphoma — appeared doubtful. At that time, Judge Chhabria spoke of his concerns: that the agreement puts unfair limits on the ability of future plaintiffs to sue, and worries about creation of a scientific panel tasked with a decision on the carcinogenicity of glyphosate. He said then that he was “skeptical of the propriety and fairness of the proposed settlement, and . . . tentatively inclined to deny the motion.”

In an August 27, 2020 status hearing on the case, counsel for the plaintiffs charged that Bayer appears to be going back on the terms of the deal; Judge Chhabria acknowledged his receipt of confidential letters from a number of plaintiffs’ counsel with cases pending in the MDL (multi-district litigation). The letters expressed concern about Bayer’s actions, and cited as evidence the company’s termination of settlement term sheets and refusal to execute master service agreements that would finalize settlements. The company did acknowledge that there were at that point no final agreements.

Judge Chhabria indicated that he had understood Bayer’s June 24 announcement of the settlement to mean that the company and plaintiffs’ counsel were agreed on settlement terms and process, stating that he had taken “‘all of that to mean the MDL is settled.’” According to Bloomberg, “Brent Wisner, one of the lead attorneys for consumers, told the judge ‘there is no settlement.’ He urged Judge Chhabria to lift a pause on the litigation because the process has hit a wall. . . . ‘At this point it’s become clear to me that when we were told we had an agreement, either they didn’t have authority to do that or they’ve reneged on it.’” Judge Chhabria said that he would not lift or extend the current stay.

Judge Chhabria is also considering making public those letters that set out plaintiffs’ concerns with the status of the settlement, calling them “matters of significant public concern.” Bayer wants badly to be done with this settlement, but is also adamant that it resolve the issue of future litigation, so Judge Chhabria’s reticence on these matters could threaten the conclusion of the settlement. Another such “status conference” is set for September 24; if the settlement is not finalized by then, it is possible that the lawsuit would be restarted.

Two plaintiffs in the NBFA suit are also plaintiffs in the MDL glyphosate suit, who have refused to participate in the pending $10.9 billion settlement, according to Bayer spokesperson Susan Luke. She added, in a statement to the Midwest Center for Investigative Reporting: “Racism has no place in our society or at Bayer. This lawsuit is brought by two law firms that are holdouts in the Roundup product liability litigation and people should see this action for what it is — an attempt by plaintiffs’ lawyers to use media and more litigation to further their own financial interests. There is no basis in fact or law for the health claims in this suit, as Roundup has been assessed and approved by independent health regulators worldwide, including the EPA, which have found that Roundup can be used safely as directed.”

Referencing the MDL suit, the NBFA litigation notes that “conspicuously absent from these damages, actions, and purported settlements is any effort to get Roundup® off the shelf and protect farmers from the harm that it causes,” and that if the herbicide is going to continue to be sold, it should at the very least have a warning label. In the summer of 2019, EPA quashed California’s effort to label glyphosate products with a cancer warning; Beyond Pesticides wrote then, “The move comes after the state of California listed glyphosate on its Prop 65 list of chemicals known to cause cancer, birth defects or other reproductive harm. Health advocates are condemning the decision as the latest in a long string of EPA actions aimed at benefiting industry at the expense of consumer and public health. Many are concerned that the incessant stream of industry-friendly decisions is eroding public trust in the agency and its ability to act as an independent regulator.”

Beyond Pesticides will continue to monitor this suit and others that aim to constrain or remove glyphosate products from the market. We remain committed to equity in the protection of human health and the environment from the dangers of toxic pesticides, and to ending disproportionate impacts of their use, as well as other environmental injustices, in the lives of Black and Indigenous people, and other people of color. Please see Beyond Pesticides’ statement on Black Lives Matter.

Source: https://investigatemidwest.org/2020/08/28/as-questions-mount-about-roundup-settlement-black-farmers-sue-monsanto-to-stop-herbicides-sales/

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

(Beyond Pesticides, September 10, 2020) A new analysis by Science of Cannabis Laboratories Inc. (SC Labs) finds detectable concentrations of pesticides and heavy metals in rolling papers, with hemp/blunt wraps and cellulose-based rolling papers containing the highest levels of contaminants. The analysis follows a SC Labs’ finding of high levels of chlorpyrifos—a neurotoxic, organophosphate insecticide—in the rolling paper of pre-rolled cannabis, which was undergoing compliance testing. Although the rolling paper regulations generally track standards for toxic tobacco products (which means there is very little meaningful regulation), the rolling paper use with cannabis may add an addition layer of scrutiny since some statewide cannabis regulations and independent certifications adhere to stricter guidelines similar to organic practices. Researchers note the goals of the experiment “were to assess the exposure risks to the consumer as well as identify any potential liabilities for cannabis producers who use these products to make their pre-roll products.”

This report, and others like it, are significant as cannabis use expands in in the U.S. and around the world, and given that one of the most popular ways to consume cannabis product is as a rolled cigarette. Study author and president of SC Labs Josh Wurzer, Ph.D., said, “This [issue] is something that cannabis and paper manufacturers should be aware of. If those paper manufacturers are selling to people in the cannabis industry who use their papers, then they need to pay more attention to their quality control.”

The use of rolling paper products has been around since the early 1500s, with the foremost commercial producer of rolling papers, Pay-Pay, forming in 1703. In the U.S., the 20th century saw an increase in rolling paper sales as rolling paper products presented an inexpensive, convenient way to consume increasingly popular vices, such as tobacco cigarettes and cannabis. However, rolling paper regulations are sparse compared to other areas of the tobacco and cannabis industry. The U.S. Food and Drug Administration (FDA) regulates tobacco by evaluating “new tobacco products based on a public health standard that considers the risks and benefits of the tobacco product to the population as a whole, including users and nonusers.” Additionally, local governments in states where cannabis is legal, such as California, monitor and inspect hemp-based products before retail distribution. FDA regulates rolling papers as “tobacco products,” only requiring companies to disclose all ingredients to gain agency approval. However, cannabis presents a growing market for rolling papers that advocates say must be regulated on par with that of lab-tested cannabis.

In response to previous lab findings of pesticide contamination in rolling papers, researchers investigated chemical contamination frequency and concentration level in 118 rolling paper products, including rolling papers, cone papers, and blunt wraps made of rice, hemp, or cellulose, in Santa Cruz, California. Further classification of rolling paper products distinguished four different categories: standard rolling paper, pre-rolled cone paper, hemp or blunt wrap, or cellulose-based paper. To detect the presence of chemical contamination in rolling paper samples, researchers used gas and liquid chromatography, testing for 66 pesticides, five mycotoxins, and four heavy metals (lead, cadmium, arsenic, and mercury). All completed tests were within the scope of the laboratory’s accreditation and followed specific mandates set by the California Bureau of Cannabis Control (BCC), requiring lab-testing for all cannabis products.

According to the study, 90 percent of all rolling paper products contain at least one heavy metal, with eight percent containing heavy metal concentrations above California’s legal allowable limits for inhalable cannabis products. Lead detection surpasses all other metals present in the samples by a substantial perimeter. Furthermore, 16 percent of all tested rolling paper samples are positive for pesticides, with five percent above California’s legal allowable limits for inhalable cannabis products. Although only 11 percent of all rolling paper samples test positive for chemical contaminations levels above the California legal limits, 44 percent of those positives contain levels at least double, or several folds higher than the California legal limit. Regarding rolling paper categories, standard rolling papers have the lowest level of contaminants, overall, with blunt wraps and cellulose-based paper having the highest level of pesticide and heavy metal contamination, respectively.

Rolling papers, such as blunt wraps, cellulose-based paper, hemp paper, and other plant-derived smoking products, have various uses—from controlling the burn and ash rate of smokable herbs and plants to acting as combustible cartridges in rifles and revolvers for warfare reenactments. However, only 2-4% of American smokers currently use rolling papers to roll tobacco cigarettes, with many opting to buy factory-rolled or “tailormade” cigarettes for convenience. Instead, rolling paper use is more closely associated with the cannabis industry as one of the most popular ways to consume cannabis for several decades. As more states legalize cannabis across the U.S., many implement chemical restrictions or residue enforcement levels.  However, EPA has not evaluated the safety of any pesticide for cannabis production, nor has it set pesticide tolerances (allowed residues)—thus rendering pesticide use on cannabis crops illegal. Instead, states like California set their own residue enforcement levels and are shifting the cannabis industry toward organic-like practices, examining the use of pesticides and solvents via laboratory testing, and permitting mostly minimum risk pesticides.

More recently, organic cannabis has been growing in popularity, especially for its environmental and health benefits associated with excluding pesticide use. Rolling papers, on the other hand, do not undergo the same laboratory testing as cannabis. As statewide legalization of cannabis continues, and state-specific programs require cannabis industry regulations to align with federal organic requirements, advocates say that it is essential to ensure that the integrity of the finish cannabis products that are consumed are not compromised.  

Of the rolling paper products tested in the study, blunt wraps and cellulose-based papers have the highest level of contamination. Standard rolling papers have the lowest levels of contamination. Cellulose-based rolling papers are translucent paper made of water, glycerin, and cellophane from naturally derived cellulose from plant material, and results from the study show that these papers contain high levels of lead. Some cellulose papers have lead levels 100-fold higher than allowable levels. Although contamination levels are lowest for standard rolling paper made from wood pulp, there are still detectable levels of lead. Lead exposure can lead to nervous system and brain damage, psychological disorders, reproductive dysfunction, with children under six years more vulnerable to lead poisoning, causing severe mental and physical developmental delays. The study notes, “it is not surprising to find a prevalence of heavy metals detected in the rolling paper products,” as materials commonly used to manufacture rolling papers naturally accumulate metals contaminants. However, pesticides’ presence in rolling papers raises some alarm due to their growing ubiquitous use in agriculture compared to heavy metals.

Most blunt wraps, like cigars, incorporate tobacco grounds wrapped in a tobacco leaf. However, manufacturers of these tobacco products usually use chemical fertilizers and toxic pesticides in their production and processing. This fact is evident as researchers detect the presence of both cypermethrin, a synthetic pyrethroid insecticide, and chlorpyrifos, an organophosphate insecticide, in the blunt wrap samples. Cypermethrin has a plethora of adverse health impacts, including endocrine disruption, reproductive dysfunction, neurotoxicity, kidney/liver damage, birth defects, learning disabilities, possible cancer, and is toxic to bees and aquatic organisms. Chlorpyrifos is concerning as it is neurotoxic to children and has links to other adverse effects, such as endocrine disruption, kidney/liver damage, and lung cancer. Additional chlorpyrifos concerns include various environmental impacts, like groundwater contamination and toxicity to birds, bees, and aquatic organisms. Although U.S. pesticide manufacturer Corteva (formerly DowDupont) will stop chlorpyrifos production at the end of 2020, generic manufacturing of the chemical will continue. Cypermethrin remains available for commercial use in industrial, agricultural, and residential settings. With both chemicals commercially available for use, especially in agriculture, it is essential to monitor chemical treatments on crops, including those that produce rolling papers.

Although organic alternatives to blunt wraps exist, like organic cigarettes, organic blunts contain tobacco, which has nicotine, an addictive and potentially cancer-causing chemical. Even organic cigarette brands like American Spirit, which pride themselves on containing no additives, may have higher levels of nicotine than chemical-intensive brands. Regardless of the absence of pesticides and tobacco, high concentrations of nitrosamines, carcinogenic toxins created during the fermentation process, and other toxins can remain. Additionally, blunt wrappers are more porous than standard rolling papers, resulting in smoke inhalation with higher concentrations of toxins. Although detectable levels of contaminants in rolling paper products are not frequenting alarming levels yet, legalization will increase demand for products like pre-rolled joints and blunts, which are convenient for the many cannabis consumers. Lack of proper contaminant monitoring of rolling paper products can put consumers at risk, especially those who consume cannabis for medicinal purposes.

Rolling paper products have a long history in the U.S., most closely associated with tobacco use and regulations. However, as the market expands for rolling paper products, new uses develop, signifying a need for updated rolling paper regulations. Although laboratory testing on par with that of cannabis can help ensure quality rolling paper products, the current scheme of spot testing is not a long-term solution to problems of pesticide contamination in cannabis production. A comprehensive solution is need to ensure that rolling paper manufacturers do not replace some toxic ingredients with equally hazardous compounds.

Beyond Pesticides maintains that consumers, workers, and the environment would benefit from universal organic standards for the cannabis industry, including products used in conjunction with cannabis. Most cannabis products that many individuals are using are for medicinal purposes, and consumers are typically inhaling without any filtration. States must promote rigorous production standards and Beyond Pesticides recommends that states establish laws and/or regulations that mandate an organic systems approach to produce cannabis and cannabis consuming products. While “organic” labeling is welcome, states should require all cannabis and rolling paper product manufacturers to follow Ocal production standards, or follow the dictates of national organic soil management standards. Organic agriculture has many health and environmental benefits, which eliminate the need for chemical-intensive agricultural practices. Furthermore, buying, growing, and supporting organic can help eliminate the extensive use of pesticides in agriculture and the environment. For more information on how organic is the right choice for both consumers and the farmworkers who grow our food, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture. Read more about Beyond Pesticides’ coverage of cannabis and pesticides here and at its Daily News archival page on the topic. For more background, see Pushing for Organic Cannabis as Industry Grows and Pesticide Use in Marijuana Production: Safety Issues and Sustainable Options. Also see Spotting the Hackers of Hemp.

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

Source: SC Labs, Leafly

(Beyond Pesticides, September 9, 2020) Late last month the California legislature voted to ban, with limited exceptions, the use of highly toxic rat poisons. The California Ecosystems Protection Act of 2020, AB 1788, was passed after over a year of advocacy by groups and individuals concerned about the impact of second-generation anticoagulant rodenticides (SGAR) on state and local wildlife. Proponents of the legislation are advocating that lawmakers in other states follow California’s lead by passing similar legislation. The bill must be signed by Governor Gavin Newsom or allow the bill to become a law without his signature by September 30, 2020.

The legislation hones in on the use of SGARs, specifically the chemicals brodifacoum, bromadiolone, difenacoum, and difethialone, which present significant hazards to non-target wildlife. Unlike the first generation of blood thinning rodenticides on the market (such as chlorophacinone, warfarin, and diphacinone, which present their own hazards), SGARs cannot be quickly excreted by the body and can deal a lethal dose to rodents in a single feeding. However, SGAR-poisoned rodents do not die immediately, and are often left lethargic and exposed to the elements. This makes them easy prey for birds and mammals. In California, SGARs gained considerable attention for ongoing reports of poisoning within state’s iconic mountain lion population.

Kian Schulman, a founding member of Poison Free Malibu, said, “California has now recognized the harm done to wildlife, pets, and children from rat poisons. This example will motivate other states, the U.S. nationally, and other countries to follow suit.” Poison Free Malibu works to protect local wildlife in the Santa Monica Mountains and throughout California by educating about the dangers associated with the use of rodent poisons. As to the future, Ms. Schulman continues, “The next target to concentrate on is reversing “preemption” which prevents local regulation of pesticides.”

This chokehold law created by the pesticide industry must END, and give  communities the choice to be FREE from all pesticides!”

AB 1788 bans the use of SGARs within any state park, wildlife refuge, or state conservancy. It further prohibits use until the California Department of Pesticide Regulation conducts a reevaluation and develops a plan to stop the poisoning of non-target wildlife. Exemptions are provided only in limited circumstances, primarily for public health, agriculture, and use on non-native species inhabiting off-shore islands.

Although the bill was opposed by pest control companies, and some business and apartment associations, the legislation provides needed, timely protections for California’s mountain lions. A poisoning event in 2019 led to the death of a young lion dubbed P-47, which because it had not yet mated, represented a significant blow to the Santa Monica Mountains lion population. In 2018, another young mountain lion, P-55, infamous for its ability to crisscross California’s 101 Freeway, died of suspected rodenticide poisonings, shortly after another cougar, P-41, was found dead with six different pesticides detected in its liver. A similar rodenticide poisoning nearly killed mountain lion P-22, which, for a time, roamed the Hollywood Hills along Griffith Park’s Hollywood sign.

In fact, shortly after the passage of AB1788, the National Park Service reported the death of two big cats due to anticoagulant rodenticide poisoning: B-372, a female bobcat, and P-76, a young male mountain lion.

As recent scientific studies indicate, populations in Southern California’s Santa Ana and Santa Monica Mountains are at risk of local extinction within 50 years without intervention.

Earlier this year, the California Fish and Game Commission voted unanimously to provide temporary protected status to state mountain lion populations , and conduct a year-long study on permanent safety provisions. The drive to protect mountain lions also led lawmakers in Malibu, CA to implement an inventive ban on SGARs, despite preemption threats from the state.

Apart from the significant hazards these chemicals pose to non-target charismatic megafauna like bobcats, fishers, mountain lions, owls, hawks, and other critically important species lies the fact SGARs are unnecessary to effectively manage rodent populations. See Beyond Pesticides’ ManageSafe page on least-toxic control of mice for strategies that can be used that do not include the use of highly hazardous baits. For more information on the dangers pesticides pose to wildlife, see Beyond Pesticides’ Wildlife program page.

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

Source: AB 1788, The Sacramento Bee

(Beyond Pesticides, September 8, 2020) Canada should be in accordance with international treaty to eliminate persistent pollutants. 

Canada is considering the elimination of one of the worst persistent pollutants—pentachlorophenol (penta)—that dot our landscape in utility poles and railroad ties. This wood preservative—a cancer-causing chemical with dioxin, furans, and hexachlorobenzene that causes health and environmental degradation—has no place in society as we struggle with shared global challenges of public and worker health threats, the climate crisis, and biodiversity decline. We have a chance to urge Canada to move ahead with a pentachlorophenol ban, joining with Mexico to show leadership in the protection of health and the environment—something the U.S. has not done.

Tell Canada to ban pentachlorophenol.

Canada’s Pest Management Regulatory Agency (PMRA) is accepting comments on a proposal to ban the all uses of penta in Canada. Comments are due September 13. Canada is a signatory to the Stockholm Convention on Persistent Organic Pollutants, which voted 90-2 to ban penta in 2015. The United States is not a signatory to the Stockholm Convention and still allows the use of penta on utility poles and other “wood that is subject to decay or insect infestation, including supporting structures in contact with the soil in barns, stables, and similar sites.”

Despite the ban in force in 186 countries, the United States has continued to import and use this hazardous wood preservative on telephone poles and railroad ties throughout the country. With Mexico set to close one of the last production plants in the world, Gulbrandsen Chemicals Inc. tried to make Orangeburg, a majority black community in South Carolina, the new epicenter for penta manufacturing. Following protests by lawmakers and coverage in The State newspaper, the company dropped its plans.

Penta is used to pressure treat wood, with the aim of prolonging its use in utility poles and railroad ties. Beyond Pesticides has sounded the alarm on penta and other wood preservatives for over 20 years, starting with the reports Pole Pollution and Poison Poles, which outlined the science on the hazards and alternatives to preservative-coated utility poles. Penta is a particularly concerning wood preservative, as it is well known to be contaminated with hexachlorobenzene, polychlorinated dibenzo-p-dioxins, and furans. Acute contact exposure through contact or inhalation with penta-treated products can result in severe irritation. Chronic risks include damage to organ systems like the liver and kidney, as well as impacts on immune, nervous, and endocrine system functioning. EPA reviews previously classified penta as a probable carcinogen, however its Integrated Risk Information System recently classified it as “likely to be carcinogenic.” The U.S. Environmental Protection Agency (EPA) estimates that at least 1 in 1,000 workers are likely to develop cancer during their career at a penta production plant.

While EPA continues to drag its feet, an international treaty, called the Stockholm Convention on Persistent Organic Pollutants, was brought into force. Parties to the Stockholm Convention are bound to eliminate the use and production of hazardous chemicals voted on by member countries. The U.S. is glaringly absent from this treaty, signing it in 2001, yet never ratifying it through the Senate. Despite opposition from the U.S. and India, which is a minor producer of the chemical, the Stockholm Convention voted to impose the strictest ban possible on penta, beginning in 2016.  This set a clock ticking on the last North American penta plant, located in Matamoros, Mexico. Mexico was granted a five-year exemption from the treaty in order to provide time to shift production. With 2021 fast approaching, the plant’s owner, Cabot Microelectronics, announced it would stop manufacturing the chemical in order to comply with the Stockholm Convention. Around the same time, Gulbrandsen Chemicals Inc., a company that lists its headquarters in South Carolina, but appears to have ties to India, announced it would bring a production plant to Orangeburg.

The U.S. has long been the largest consumer of penta, and as a result has an intimate history with the chemical’s manufacturing process. Hundreds of Superfund sites throughout the country are designated as such because they were the location of previous penta production plants. According to research Beyond Pesticides conducted in Pole Pollution in the late 1990s, roughly 250 sites on the Superfund National Priorities list were contaminated with penta.

A ban by Canada will put added pressure on the U.S. EPA to finally ban penta.

The Canadian PMRA proposal summarizes the environmental and health hazards of penta. In the environment, concerns are persistence, mobility, and bioaccumulation (presence in all environmental compartments); potential risk to aquatic organisms; potential risk to terrestrial vertebrates; and release to the environment of polychlorodibenzodioxins, polychlorodibenzofurans, and hexachlorobenzene. Human health concerns include occupational exposure in wood treatment facilities and exposure to the general public from treated wood that could produce serious health effects. The long-term non-cancer risk was not shown to be acceptable. Based on the arithmetic mean exposure for all sites, all job groups and assuming 35 years of work per 78 year lifetime, cancer risk for workers in the treatment facilities is estimated as 1 × 10-3, compared to Health Canada’s generally acceptable level of 1.0 × 10-5 for occupational scenarios. PMRA concludes, “Evaluation of the available scientific information related to the human health aspects of concern indicated that under the current conditions of use of pentachlorophenol, potential risk to human health is not shown to be acceptable.”

Send this letter and sign the petition telling Canada to ban pentachlorophenol.

Please note: By sending this letter, you will also be adding your name to the petition that Beyond Pesticides will submit to Canada’s Pest Management Regulatory Agency. 

I am writing to support the proposal of the PMRA to ban all uses of pentachlorophenol. We share one global environmental that cannot tolerate continual contamination with persistent pollutions that travel the earth and contribute to public and worker health threats, the climate crisis, and biodiversity decline.

Canada is a signatory to the Stockholm Convention on Persistent Organic Pollutants, which voted 90-2 to ban penta in 2015. Penta is a particularly dangerous wood preservative, as it is well known to be contaminated with hexachlorobenzene, polychlorinated dibenzo-p-dioxins, and furans. Acute contact exposure through contact or inhalation with penta-treated products can result in severe irritation. Chronic risks include damage to organ systems like the liver and kidney, as well as impacts on immune, nervous, and endocrine system functioning. The U.S. Environmental Protection Agency (EPA) recently classified it as “likely to be carcinogenic.”

The Canadian PMRA proposal recognizes the environmental and health hazards of penta. In the environment, concerns are persistence, mobility, and bioaccumulation (presence in all environmental compartments); potential risk to aquatic organisms; potential risk to terrestrial vertebrates; and release to the environment of polychlorodibenzodioxins, polychlorodibenzofurans, and hexachlorobenzene.

Human health concerns include occupational exposure in wood treatment facilities and exposure to the general public from treated wood that could produce serious health effects. The long-term non-cancer risk was not shown to be acceptable. Based on the arithmetic mean exposure for all sites, all job groups and assuming 35 years of work per 78 year lifetime, cancer risk for workers in the treatment facilities is estimated as 1 × 10-3, compared to Health Canada’s generally acceptable level of 1.0 × 10-5 for occupational scenarios. PMRA concludes, “Evaluation of the available scientific information related to the human health aspects of concern indicated that under the current conditions of use of pentachlorophenol, potential risk to human health is not shown to be acceptable.”

Please ban all uses of pentachlorophenol in Canada, bringing the world closer to eliminating this highly toxic persistent organic pollutant.

Thank you for your consideration of my comments.

Sincerely,