(Beyond Pesticides, February 7, 2019) A new study, released in Environmental Science and Policy, systematically reviews all state-level pollinator protection acts passed since 2000 and makes a somewhat dim diagnosis: as a rule, state policies fall far below the mark for protecting invaluable ecosystem services and ensuring long-term, sustainable food production. Authors judge the legislation against a set of pollinator protection policy benchmarks established in 2016 by a group of scientists from the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES). Citing the ten policy recommendations laid out by IPBES experts, researchers point to the failure of all enacted state policies to address three main target areas – (1) to improve genetically modified crop risk assessment, (2) to incentivize farmers to make the switch from agrochemical dependence to sustainable benefits from ecosystem services, and, critically, (3) to support diversified farming systems. Beyond Pesticides notes one additional missed target: (4) funding for research on organic, diversified, and ecologically intensified farming.

The study includes a total of 109 state laws passed from 2000 to 2017, which authors tracked down by searching usa.gov and state legislative websites and by submitting requests to state librarians. To uncover common themes and patterns among these laws, researchers used NVivo text analysis software, coded to pull out words and phrases relating to the targeted policy areas. They find that policy targets shifted across the study span and seemed to track broad public awareness campaigns. In the mid-2000s, in response to mounting public attention around Colony Collapse Disorder, several states adopted policies aimed towards promoting honey bee health. In more recent years, a deeper appreciation for the importance of native pollinators has led to more broadly framed pollinator protection plans. Among these, researchers pointed to Minnesota, Vermont, Connecticut and California as models for crafting legislation designed to achieve comprehensive, programmatically supported pollinator protection plans.

Beyond Pesticides cautions against holding up existing pollinator protection plans (P3’s) as models for lawmakers interested in building substantive measures to support sustainable agriculture. P3’s are weakly construed and toothless, relying on “voluntary agreements” rather than substantive regulations to affect change. Moreover, along with almost every state-level pollinator policy on the books, P3’s have failed to address the foremost driver of pollinator losses: over-dependence on toxic agrochemicals.

There are a few states, however, that have adopted a stronger stance. In the face of growing awareness of the devastating impacts of bee-toxic pesticides, in particular the infamous neonicotinoids, Maryland and Connecticut passed policies for stricter pesticide regulation. Most recently, a piece of Maryland legislation passed in 2017 banned neonicotinoids from use on state-managed pollinator habitat, building off of the gains made in the state’s precedent-setting 2016 neonicotinoid consumer ban.

Overall, the researchers conclude that state-level policies have a long way to go to meet the standards of supporting sustainable agriculture. Among the major missed targets study authors identified are policies to incentivize and enforce, whenever possible, the transition from agrochemical dependence to ecosystem service farming. IPBES scientists have proposed adjusting insurance packages to provide incentives for farmers who move towards ecological intensification, including efforts to promote pollinators. In the long run, however, they say stricter pesticide regulations along with the naturally-enforced economic incentives of beneficial ecosystem feedback should replace the need for such methods and lead to broader adoption of organic and ecological farming methods.

According to an independent review of source documents by Beyond Pesticides, the policies studied failed yet another target: funding research on organic, diversified and ecologically intensified farming. Existing policies have supported research on managed honey bee health and adjustments to conventional agriculture and public land management. None have promoted research on improving yields to what IPBES scientists identified as “farming systems known to support pollinators”: organic, diversified, and ecologically intensified farming. Beyond Pesticides holds the position that research on modest modifications to conventional farming is inadequate to meet the needs of our growing global population, which is threatened by unsustainable and ecologically devastating reliance on fossil fuels, water and chemical inputs. A complete transition to organic farming practices is imperative and urgent, according to Beyond Pesticides, to protect, reestablish and sustainably benefit from vital ecosystem services before they are completely wiped out.

Beyond Pesticides is a resource for activists wishing to expand their engagement into the legislative realm. For those already involved in ongoing pollinator legislation, you can draw lessons from documented successes and failures to build stronger, more targeted pollinator protection laws that enforce pesticide regulation and build economic incentives and supports for organic, ecologically sustainable practices. Stay abreast of ongoing legislation to protect pollinators and our food system at the state and national level by following the Beyond Pesticides Daily News Blog.

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

Source: Environmental Policy Science and Policy

(Beyond Pesticides, February 6, 2019) The American Association for the Advancement of Science (AAAS) has awarded two researchers the group’s Scientific Freedom and Responsibility Award for their work uncovering the link between glyphosate and chronic kidney disease (CKD), which has killed at least 25,000 Sri Lankans and 20,000 Central Americans. Award recipients Sarath Guanatilake, MD, and Channa Jayasumana, PhD, faced death threats and claims of research misconduct as they went toe to toe with agrichemical industry giant Monsanto (now Bayer’s Monsanto), the major manufacturer of glyphosate-based products like Roundup.

“To right a wrong when significant financial interests are at stake and the power imbalance between industry and individual is at play takes the unique combination of scientific rigor, professional persistence and acceptance of personal risk demonstrated by the two scientists recognized by this year’s award,” says Jessica Wyndham, director of the Scientific Responsibility, Human Rights and Law Program at AAAS.

In the mid-90s, reports began to emerge of Sri Lankan rice farmers – many otherwise healthy, young adults, succumbing to CKD. Dr. Gunatilake, a researcher at California State University, Long Beach (CSULB), was hired by the Sri Lanka Ministry of Health to investigate the cause of the disease. Around the same time, Dr. Jayasumana was working on his doctoral degree, and was able to link up with Dr. Gunatilake’s efforts, and join CSULB. Dr. Jayasumana provided Dr. Gunatilake with rice, drinking water, and urine samples that were subsequently analyzed in the lab. Results found that drinking water was contaminated with glyphosate and heavy metals, and that these compounds were making their way to workers kidneys.

Evidence shows that glyphosate bonds with heavy metals like arsenic and cadmium, forming stable compounds in water that do not break down until reaching the kidneys. CKD is a disease that develops relatively slowly, impairing the kidney’s ability to filter excess waste and fluid from the blood. Outcomes are generally poor with CKD, ultimately resulting in the need for dialysis, kidney transplant, or death. The results were published in a major scientific report in the International Journal of Environmental Research and Public Health.

The study brought international attention to the CKD, with many other developing countries in Central America, North Africa, and Southeast Asia noting similar epidemics. The Drs. were subject to intense scrutiny and pressure for their research. In typical pesticide industry malfeasance, twelve industry-funded scientists filed research misconduct complaints against Dr. Gunatilake, who was unsurprisingly exonerated. More concerning, both scientists received death threats for simply reporting their discoveries.  This link shows the type of response Bayer’s Monsanto has posted to their website concerning the Drs.’ research.

A testament to the power of perseverance, the scientists work led a temporary important ban on glyphosate and lasting restrictions on its use in Sri Lanka. And Dr. Gunatilake has now raised more than $20,000 to help the families of victims.

“What started as a bold effort to provide a voice for the impoverished, powerless rice paddy farmers in Sri Lanka has now blossomed into a worldwide environmental movement through research, advocacy, networking and collaboration,” wrote public health professional Hanan Obeidi in the award nomination letter.

As the Drs.’ research shows, glyphosate’s link to cancer is only the tip of the iceberg when it comes to the range of chronic impacts resulting from exposure to the herbicide. Read more about the range of damage caused by this chemical in Beyond Pesticides fact sheets. Work to support a system that does not lead to rampant poisoning of farmworkers here and abroad by toxic synthetic pesticides by purchasing organic whenever possible.

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

Source: EurekAlert- AAAS Press Release

(Beyond Pesticides, February 5, 2019) Linuron, an herbicide registered for use by the U.S. Environmental Protection Agency (EPA), yet recently banned in Europe due to health concerns, appears to trigger inflammatory signals that have been linked to the onset of Multiple Sclerosis (MS). This new evidence, published in the journal Cell by researchers at Brigham and Women’s Hospital in Boston, MA, indicates that exposure to chemicals and pesticides in the environment may be a risk factor in the development of neurodegenerative diseases. “We created a platform to systematically investigate the understudied effects of environmental exposures,” said study coauthor Francisco Quintana, PhD. “The goal of our work is to return results that can guide future epidemiological studies and identify actionable targets.”

Researchers began their investigation with 976 chemicals identified by EPA’s ToxCast program, an inventory of compounds that have undergone screening for a battery of laboratory tests. Within that inventory, 75 chemicals, including linuron, were found to interfere with the signaling pathways linked to MS.

To confirm the adverse impacts, scientists used the embryos of zebrafish, animals often used as models in laboratory research. The zebrafish embryos were altered to contain low levels of myelin, a protein that protects nerve cells, as is similar in patients that have MS. The embyros were also engineered to produce a green fluorescent protein when damaged.

The zebrafish model revealed five compounds that increased inflammation in the central nervous system. These chemicals were then tested on mouse astrocytes, star shaped cells that occur in the brain and spinal cord and perform many functions, including the provision of nutrients to nervous tissue and repairing the brain after traumatic injury. Both the herbicide linuron and another chemical, methyl carbamate, used in textiles, polymers, and pharmaceuticals, caused inflammation in mouse astrocytes.

Scientists then analyzed brain tissue samples from patients with MS, and found that it contained higher levels of the inflammatory signaling pathways also seen as a result of linuron exposure. Although epidemiological studies are needed to further evaluate the impact of linuron, this research brings needed attention to the concept of the ‘exposome.’

“Our findings support the need for systematic investigation of the effects of the ‘exposome’—all of the environmental exposures people experience in their lifetime—on neurologic diseases and other conditions,” said Dr. Quintana. “Studies of the exposome have the potential to identify unknown origins of inflammation and key environmental factors that may contribute to risk.”

Scientists indicate their results were limited by number of chemicals within the ToxCast program, and a wider availability of chemicals for lab testing would likely yield additional candidates that cause inflammation in the central nervous system.
“When we study inflammation and neurodegeneration, we learn that the environment may play just as important of a role as genetics,” Dr. Quintana noted.

Evidence is increasingly showing that the probable carcinogen glyphosate is merely the posterchild for a litany of other toxic herbicides that can wreak havoc on human health. The herbicide paraquat has long been associated with the onset of Parkinson’s disease. Atrazine, another broadleaf herbicide, has been linked to a range of diseases, including birth defects, cancer, impaired neurodevelopment, and reproductive disorders. While these herbicides are EPA-registered and used widely in the U.S., France has banned glyphosate use, and the entire EU has banned atrazine, paraquat, and the topic of the current study, linuron, due to human health concerns.

Read up on the range of all too common diseases linked to pesticide exposure in Beyond Pesticides’ Pesticide Induced Diseases Database. And for information on avoiding the hazardous herbicides and pesticides on conventional food found in the grocery store, see the Eating with a Conscience database.

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

Source: Brigham and Women’s Hospital Press Release, Cell (peer-reviewed journal)

(Beyond Pesticides, February 4, 2019)  Although the rusty patched bumblebee was placed on the endangered species list in 2017, the Trump Administration has failed to put in place legally required safeguards for the species. The U.S. Department of the Interior (DOI) must designate locations where additional protections could help restore the endangered bumblebee’s population.

Tell Your U.S. Representative and U.S. Senators to Urge U.S. Department of Interior Acting Secretary David Bernhardt to protect the endangered rusty patched bumblebee as required by law.

DOI’s failure to comply with requirements under the Endangered Species Act (ESA) is consistent with the Trump Administration’s continued disregard for ongoing pollinator declines and environmental protections in general. Under ESA, DOI is required to determine “critical habitat” that contains physical and biological requirements a listed species needs in order to recover. That area must be designated within one year of placing a species on the endangered list, using best available scientific data. The Trump Administration’s DOI has failed to do so under either former Director Ryan Zinke or Acting Director David Bernhardt. Without determining critical habitat, the administration is in violation of the ESA, and the survival of a critical endangered species is threatened.

The rusty patched bumblebee has a historical range that included habitat throughout the Northeast and Midwest United States. The Washington Post notes that, “The rusty patched bumblebee was so prevalent 20 years ago that pedestrians in Midwestern cities had to shoo them away.” However, pesticide use, climate change, disease, and habitat loss led to significant declines over the last several decades. Since then, their populations have dwindled and their overall decline is estimated at 91 percent.

The Trump Administration has dragged its feet on protecting the rusty patched bumblebee since the beginning of its term. The species was proposed for ESA listing under the Obama Administration in 2016, and finalized in 2017 only a week before the new Administration took office. However, on his first day in office, President Trump directed federal agencies to postpone the effective date of any regulations that had been published to the federal register but not yet put into effect. This move effectively reversed the ESA listing of the rusty patched bumblebee. In March 2017, the species was finally placed onto the endangered list.

Unfortunately, the Trump Administration’s actions in this case are more of the norm rather than the exception. In August of last year, DOI reversed a long-standing policy that prohibited the use of systemic, bee-toxic neonicotinoid insecticides on National Wildlife Refuges. The Administration has also worked on the pesticide industry’s behalf to slow down the implementation of farmworker protections and continue the allowance of another highly toxic insecticide chlorpyrifos.

Tell Your U.S. Representative and U.S. Senators to Urge U.S. Department of Interior Acting Secretary David Bernhardt to protect the endangered rusty patched bumblebee as required by law.

Letter to Congress

Under the Endangered Species Act (ESA), the Department of the Interior (DOI) is required to determine “critical habitat” that contains physical and biological requirements a listed endangered species needs in order to recover. That area must be designated within one year of placing a species on the endangered list, using best available scientific data. DOI has failed to do so, in violation of the ESA. Without this action, survival of a critical endangered species is threatened.

The rusty patched bumblebee has a historical range that included habitat throughout the Northeast and Midwest United States. The Washington Post notes that, “The rusty patched bumblebee was so prevalent 20 years ago that pedestrians in Midwestern cities had to shoo them away.” However, pesticide use, climate change, disease, and habitat loss led to significant declines over the last several decades. Since then, their populations have dwindled and their overall decline is estimated at 91 percent.

DOI must ensure preservation of the rusty patched bumblebee by designating critical habitat, or the bee will become extinct.

Sincerely,

(Beyond Pesticides, February 1, 2019) Prior to a pesticide ban taking effect in Montgomery County Maryland Parks, the Department of Parks announced in mid-December 2018 that it would discontinue the use of glyphosate-based herbicides through March 2019. The agency has used these hazardous herbicides as part of its IPM (Integrated Pest Management) program for weed management. Montgomery Parks indicates it will release further information on the use of glyphosate in mid-March. In November last year, Montgomery County Council member Tom Hucker wrote to the head of Parks, supported by a community-wide petition, urging that glyphosate be banned immediately, pending implementation of the county ban. He cited the finding of the International Agency for Research on Cancer’s (World Health Organization) finding that the chemical probably causes cancer in humans and the $289 million jury verdict last year that the chemical caused a school groundskeeper’s non Hodgkin lymphoma.

In 2016, Montgomery Parks instituted a pesticide reduction program in compliance with Montgomery County, Maryland’s 2015 adoption of County Code 33B, which aimed to regulate use of pesticides on county-owned property, including parks, and on private property. In 2017, a Montgomery Circuit Court overturned the portion of the law pertaining to a ban on private land, saying that it would “conflict with federal and Maryland state regulations that allow the use of the pesticides.” At the time, Montgomery County Council member George Leventhal registered his disappointment in Judge Terrence McGann’s ruling, saying that it “sets a worrisome precedent for the ability of local governments to protect their residents on vital issues of health and safety.” The council has appealed that ruling, and in June 2018, an amicus brief was filed by 10 organizations, including Beyond Pesticides, in support of the 2015 regulation.

A number of localities (e.g., municipalities or counties) have ventured to regulate the use of pesticides (including fungicides and herbicides) on public or private property, or sometimes, both. Montgomery County  2015 ban limited allowable turf management pesticides (on public or private property within the county’s jurisdiction) to those permitted for use in organic production, or identified by the Environmental Protection Agency (EPA) as “minimum risk pesticides” under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

Takoma Park, a city within Montgomery County, passed a similar ordinance in 2013, as did Ogunquit, Maine in 2014. South Portland, Maine followed Ogunquit by roughly a year, as did Portland, Maine (2018) in passing an ordinance quite like Montgomery County’s 2015 “public and private” ban. In September 2018, Miami Beach instituted a ban on any use of glyphosate-based herbicides by city employees and contractors in landscaping and maintenance work on all city-owned properties.

Local governments have been constrained by “preemption” of their authority to restrict pesticides on private property by state law — even though these laws, similar to other local public health declarations, are protective of public health and safety. Even where states have not expressly preempted local jurisdictions, the pesticide industry and the chemical pest management industry and trade groups jump in to oppose and in some cases sue.

Preemption is the ability of one level of government to override laws of a lower level. As Beyond Pesticides has written, “The Supremacy Clause of the U.S. Constitution (Article VI, Clause 2) clearly establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the supreme law of the land. At the state level, things can become a bit less clear. Each state has its own Constitution . . . its own interpretive history of the document, and its own assignations of authority regarding the host of issues with which governments concern themselves.”

Beyond the reach of the Supremacy Clause, states and other litigants can claim that state statutes necessarily preempt local ordinances. It’s worth noting that pressure from the chemical industry led many states to pass legislation to prohibit localities from adopting local pesticide ordinances (affecting the use of pesticides on private property) that are more restrictive than state policy. But localities have more latitude in regulation of public lands under their jurisdiction. In part for this reason, counties and municipalities have more often tended to create regulations that pertain to pesticide use on public, rather than private, property.

In 1991, the U.S. Supreme Court (SCOTUS) upheld local governments’ authority to regulate pesticides in their jurisdictions under federal pesticide law. In the precedential Wisconsin Public Intervenor v. Mortier, the Court ruled that federal pesticide law does not prohibit, or preempt, local jurisdictions from restricting the use of pesticides more stringently than the federal government. That said, the case also resulted in the Court stating that states do have the authority to supersede local control.

Daily News for October 25, 2017 reported, “The pesticide industry has been very active in seeking federal legislation that preempts the ability of states to adopt more stringent standards, and has tried repeatedly to preempt the rights of states to adopt more-stringent regulations under FIFRA. After the SCOTUS Mortier decision, the Coalition for Sensible Pesticide Policy (comprising pesticide industry lobbyists) formed and drafted model legislation that would restrict municipalities from creating ordinances that would regulate use of pesticides on private property, and advocated for it methodically — and successfully — in many states.”

A 2017 National League of Cities report, City Rights in an Era of Preemption: A State-by-State Analysis, points out that,“State legislatures have gotten more aggressive in their use of preemption in recent years. Explanations for this increase include lobbying efforts by special interests, spatial sorting of political preferences between urban and rural areas, and single party dominance in most state governments. . . . This loss of local control means that cities cannot curtail laws to fit their needs.”

In the recent federal Farm Bill, which passed in December 2018, there had been alarming language that would have amended the federal pesticide law to prohibit local governments from restricting pesticide use on private property in their jurisdictions. Fortunately, that language did not make it into the final iteration of the bill, which became law, after dozens of local officials from across the country voiced their opposition.

Nevertheless, both globally and in the U.S., efforts to ban or restrict the use of glyphosate are on a steep rise; see a report on such initiatives here, and an interactive map identifying municipal ordinances restricting pesticide use, assembled by Beyond Pesticides and the Environmental Working Group, here. Recently, a federal judge in Brazil ordered the suspension of glyphosate use until the government reevaluates the herbicide’s toxicity. A French Court has just canceled the license for, and instituted an immediately effective ban on, Roundup Pro 360, one of Bayer’s (Monsanto’s) glyphosate-based herbicides.

Other efforts are ongoing in Washington State and California. In Hawaii — which is “ground zero” for chemical industry experimental testing of pesticides on cropland, enduring more of it than any other state — the state legislature fielded several bills to restrict pesticide use, including one that would regulate the use of glyphosate herbicides in land and road management. (Relatedly, Hawaii did institute a ban on the neurotoxic pesticide chlorpyrifos in May 2018.) Keep abreast of developments on initiatives related to glyphosate as Beyond Pesticides covers them in its Daily News.

Increasingly, people are voicing their concerns about the use of toxic chemicals in their communities. As noted in Beyond Pesticides’ factsheet on preemption, “As pesticide pollution mount[s], many are fighting to overturn preemption laws and return the power back to localities, enabling them to adopt more stringent protective standards throughout their communities.”

In 2017 Beyond Pesticides wrote that it “has long maintained the importance of the rights of local governments to protect public health and the environment — particularly when federal and state government are not adequately protective. State preemption often denies people their democratic right to better protection when a community decides that minimum standards set by state and federal law are insufficient. Localities across the country continue the work to pass statutes that would better protect residents and resources. A snapshot of the status of local policies on pesticide use is provided by the Beyond Pesticides and Organic Consumers Association in the map of U.S. Pesticide Reform Policies.”

Beyond Pesticides encourages communities to work to eliminate local use of glyphosate herbicides, and to advance the transition to organic land management. For resources on taking such actions, see our factsheet on glyphosate/Roundup, our report, “Glyphosate/Roundup Exposed,” and our Lawns and Landscapes page.

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

Source: https://www.montgomeryparks.org/montgomery-parks-will-discontinue-use-of-glyphosate-through-march-2019/

(Beyond Pesticides, January 31, 2019) On January 16, the Center for Food Safety (CFS) filed a new rulemaking petition demanding that USDA explicitly prohibit hydroponics from the organic label and revoke all existing organic certifications on hydroponic operations. CFS and more than a dozen co-signing organizations grounded their demands in the failure of hydroponic production to increase soil fertility, conserve biodiversity, and build soil organic matter, all legally required to achieve certification under the Organic Food Production Act (OFPA).

Hydroponic plants are grown without soil and fed entirely through manufactured nutrient solutions. Hydroponic operations rely on nutrient inputs that do not return to the system. Whether or not these inputs are organic products, the hydroponic practices themselves, CFS notes, fulfill zero out of the three core requirements that define “organic production” in OFPA: to “foster cycling of resources, promote ecological balance, and conserve biodiversity.” The central principle of the legal argument is that soil is integral to organic production. Citing OFPA, to be called organic, producers must engage in practices that actively support the rich, living biodiversity of the soil that sustains future production.

The prohibition of hydroponics from organic certification has been the position of organic regulators and the National Organic Standards Board (NOSB) for decades. A 1995 NOSB recommendation states, “Hydroponic production in soil-less media to be labeled organically produced shall be allowed if all provisions of the OFPA have been met.” However, when the NOSB proposed regulations for greenhouse standards in 2001, hydroponic production was rejected as not meeting all basic organic production principles. (See Got Organic? Grown in Nature in Soil or Factories in Water Solution?) In its 2010 recommendation, the NOSB clearly affirmed the long-standing hydroponics prohibition and other soilless methods in organic production.

In 2015, the Hydroponic Task Force (HTF), a committee of NOSB and agricultural experts formed by USDA, unearthed further evidence calling “organic” hydroponics to question. The reports of the Hydroponics Task Force (HTF) provide good evidence that hydroponics is not, and cannot be, organic. The task force “report” is actually two reports under one cover –two reports written by subcommittees with very different viewpoints– the 2010 NOSB Recommendation Subcommittee (2010 SC) and the Hydroponic and Aquaponic Subcommittee (HASC). The former represents the viewpoint that organic production must be in the soil, and the second promotes certification of “organic” hydroponics. Beyond Pesticides described in comments to the NOSB the clear consensus in the organic community. After more than a decade of inaction by regulatory agencies, the petition is elevating the urgency on the hydroponics ban.

Organic producers, consumers and advocates view the prohibition of hydroponics as vital in the fight to ensure that the organic label remains meaningful. “Mislabeling mega-hydroponic operations as ‘organic’ is contrary to the text and basic principles of the organic standard,” said George Kimbrell, CFS legal director. “Right now there is a pitched battle for the future of organic, and we stand with organic farmers and consumers who believe the label must retain its integrity.”

The U.S. is the only developed country still allowing hydroponics to fall under the organic label. Canada and Mexico prohibit hydroponics from organic, and the European Parliament voted to end the organic certification of hydroponic products in April 2018. With the U.S. regulatory gates open, industrial hydroponic operations have access to flood the organic market and, longtime organic producers warn, to push soil-based organic farmers out of business. “Hydroponic producers getting the benefit of the organic label without actually doing anything to benefit the soil undermines the standard and puts all soil-based organic farmers at an untenable economic disadvantage,” stated Kate Mendenhall of the Organic Farmers Association.

In The Omnivore’s Dilemma (2006), Michael Pollan offered some perspective on the importance of organic as envisioned by the pioneers of the practices and the drafters of the Organic Foods Production Act: “To reduce such a vast biological complexity to NPK represented the scientific method at its reductionist worst. Complex qualities are reduced to simple quantities; biology gives way to chemistry. As [Sir Albert] Howard was not the first to point out, that method can only deal with one or two variables at a time. The problem is that once science has reduced a complex phenomenon to a couple of variables, however important they may be, the natural tendency is to overlook everything else, to assume that wat you can measure is all there is, or at least all that really matters. When we mistake what we can know for all there is to know, a healthy appreciation of one’s ignorance in the face of a mystery like soil fertility gives way to the hubris that we can treat nature as a machine.”

Organic growers and advocates warn that without a serious effort to protect it, the organic label could become wholly misleading with respect to its central tenets: soil improvement and biodiversity conservation. As it stands now, with no additional labeling for “organic” hydroponics, consumers have no way of knowing whether the food they are buying follows the core principles they are trying to uphold. Jay Feldman, executive director of Beyond Pesticides and former NOSB members (2010-2015), wrote, “[B]ecause labeling [of hydroponically grown products] is not required, consumers are not able to distinguish between those products grown in soil and hydroponic products produced in a liquid solution.” He continued, “In a period of history when there is increasing awareness of the need to advance production systems that regenerate the earth, sequester carbon, and protect and enhance biodiversity, allowing hydroponics —which meets none of these critical needs—to be marketed as organic, and without full disclosure, undermines the basic principles, values, and legal standards that govern the commercial use of the word organic.”

The CFS petition represents the urgent demands of a growing number of organic farmers and consumers waking up to this invisible invasion and fighting to regain lost ground. Contribute to the movement to protect the organic label by staying abreast of new legal and regulatory developments through Beyond Pesticides’ Daily News Blog.  And stay engaged with the organic rulemaking process through Beyond Pesticides’ Keeping Organic Strong webpage.

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

Source:  CFS Press Release

(Beyond Pesticides, January, 30, 2019) Bug bombs are completely ineffective at reducing German cockroach infestations, according to new research published in the journal BMC Public Health.  Not only are they ineffective, research indicates that these products are putting people at unnecessary risk. “In a cost-benefit analysis, you’re getting all costs and no benefits,” said Zachary DeVries, PhD, co-author of the study. “Bug bombs are not killing cockroaches; they’re putting pesticides in places where the cockroaches aren’t; they’re not putting pesticides in places where cockroaches are and they’re increasing pesticide levels in the home.”

Scientists enrolled residents in 30 low-income apartments that had ongoing German cockroach infestations. Of the 30 homes, 20 were treated with a name-brand total release fogger (TRF), or bug bomb, and and 10 were treated only with gel baits. Baseline pesticide residue levels were recorded in all residences, and new data was collected after use of the bug bombs.

Bug bombs were set off in each infested apartment’s kitchen, according to EPA label precautions. Residents waited 4-6 hours before ventilating and returning to their homes. In apartments receiving baiting gel treatments, the products were applied three times on an as-needed basis during the course of a month. Traps were used to gauge baseline cockroach levels and the population response from the treatments.

“All the fogger products contained pyrethroids, a class of fast-acting insecticides, and some contained piperonyl butoxide, a chemical that prevents roaches from metabolizing, or breaking down, the insecticide,” said Coby Schal, PhD, Blanton J. Whitmire Distinguished Professor of Entomology at NC State and co-author of the paper.

While these products are marketed as effective against German cockroaches, researchers did not find that to be the case. The study indicates there was no significant difference between cockroach population levels before and after the use of any name brand bug bomb. “The bug-bomb products did absolutely nothing to control cockroach populations in these homes,” Dr. DeVries said.

To drive this point home, scientists vacuumed up German roaches found in residents’ kitchens and placed them in a greased trap (to prevent escape) alongside lab-reared German roaches known to be susceptible to pesticides. “The lab roaches, which are not hardy, had high mortality, as expected,” Dr. DeVries said. “The roaches captured in the homes and then brought back, however, had far lower mortality rates than you would expect from direct exposure to bug bombs, confirming the ineffectiveness of these products when used for German cockroach control.”

Not only did these products not work, but surface tests showed that resident kitchens increased their pesticide levels 600x over baseline results. “Baseline levels of insecticides in these homes makes sense, because residents with moderate to severe cockroach infestations are likely to use insecticides to attempt to eliminate roaches,” Dr. DeVries noted. “However, what was most disconcerting was that these swabs were collected from the middle of floors and kitchen surfaces, locations where roaches don’t generally congregate.”

Tests conducted one month after the bug bombs were released still showed pesticide residue levels 34% higher levels originally found in resident’s homes. This is unsurprising, as research finds that once applied, synthetic pyrethroids can persist in the home for over a year, putting individuals and families at risk of chronic exposure and subsequent health issues.

The U.S. Environmental Protection Agency made minor changes to the labels of bug bomb products in 2008 due to widespread reports of poisoning. Over 450 people had become sick after using a fogger between the years 2001-2005, and a 10 month old boy in Williamston, SC died after his mother used several bug bombs in their home. However, recent data shows EPA’s changes to be ineffective at even slightly reducing harm. Between the years 2007-2015 the U.S. Centers for Disease Control and Prevention indicates that 3,222 unique cases of illness and injury were reported from the use of bug bombs.

As the study shows, the only effective means of eliminating cockroach infestations in participants’ kitchens was through the use of baiting gels. Although not used in the present study, Beyond Pesticides encourages the use baiting gels containing boric acid as the active ingredient, as cockroaches are unable to develop resistance to this poison in the same way they may with many synthetic gel baits on the market.

Beyond Pesticides objects to research that exposes human subjects to high levels of pesticide residue. Although approved by an ethics board and participants provided informed consent, Beyond Pesticides objects to any study that would leave toxic pesticide residue in participant homes, and suggests this research could be adequately performed without human involvement and exposure.

That being said, it is an undeniable fact that every day individuals throughout the U.S. will use a bug bomb in their home in attempts to manage a German cockroach infestation.

There are a range of ways to take action against toxic, unnecessary, bug bombs. You can start by sending a letter to your state’s Governor urging them to ban bug bombs. Educate yourself on nontoxic methods of managing common household pests like the German cockroach through Beyond Pesticides’ ManageSafe webpage. That way, when a friend, family member, or workplace want to use a fogger, you will have the data you need to make the case for safer practices on your side.

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

Source: NC State University, BMC Public Health

(Beyond Pesticides, January 29, 2019) After eight months of deliberation and discussion, the European Parliament’s Special Committee (the PEST Committee) overwhelmingly approved its draft report in early December 2018 with recommendations to strengthen pesticide restrictions. PEST was established in January 2018 to assess the European Union’s authorization procedure for pesticides. The group’s charge was to review the European Union’s (EU’s) pesticide authorization process, identify its failures in evaluating and approving pesticides and their use (including any conflicts of interest impacting the process), and make recommendations to improve the protection of human, animal, and environmental health from pesticides. The 30-member committee concluded: improvement of the system will require changes in the entirety of the pesticide approval process — from the point of industry application for authorization of a pesticide, to the sale and use of any products containing the compound in EU Member States, to evaluation of impacts of its use once on the market.

The approval, sale, use, and regulation of what the EU calls “Plant Protection Products” [PPP] — active substances used to “1) to protect plants or plant products against pests/diseases, 2) to influence the life processes of plants (such as substances influencing their growth, excluding nutrients) and 3) to preserve plant products” — are controlled by the “PPP” Regulation. This regulations uses a two-step approach: active substances (the base chemical compounds) are approved at the EU level, and plant protection products, or formulations, are authorized at the national, or Member State, level.

The convening and charge of this committee by the European Parliament (EP) was a response, in large part, to widespread pressure and considerable clamor from more than a million European citizens, and a number of NGO (non-governmental organization) advocacy and anti-toxics groups. Complaints sparked many months of controversy related to the compound glyphosate, the active ingredient in multiple herbicide formulations — most notably, Monsanto’s (now Bayer’s) Roundup — and, pointedly, related to Monsanto’s undue and inappropriate influence on scientific studies that comprised the basis of much of the review process. The European Food Safety Authority (EFSA) reportedly copied dozens of pages from a Monsanto study in providing evidence for its conclusion that glyphosate is “unlikely to pose a carcinogenic hazard to humans.” (EFSA’s recommendation was supposed to provide an independent analysis for EU member states when deciding to renew approval of the compound.)

The coalition Citizens for Science in Pesticide Regulation, comprising 120+ groups and institutions, sent an open letter to EU regulators in Member States, calling for reform of the pesticide authorization process and increased levels of protection. The letter charged that the current model of pesticide risk assessment is failing to protect people and the environment from the harm caused by these chemicals, and must be reformed.

In May of 2017, the European Union proposed a 10-year extension on the approved use of glyphosate-based compounds. Member States of the European Commission (EC) came up short in the EC’s bids to approve 10- and 15-year extensions on the continued use of the compound, and in November issued a limited (five-year) extension for use. The EC was holding out for further information on carcinogenicity, which was assessed by the European Chemicals Agency (ECHA), whose report was issued in March 2017; that assessment found that glyphosate is “unlikely to be carcinogenic.” A chronicle of some of the activity on glyphosate use in Europe can be read here. Relatedly, Beyond Pesticides recently covered the disparity between the conclusions, on glyphosate’s potential carcinogenicity, of the International Agency for Research on Cancer (IARC) and the U.S. Environmental Protection Agency (EPA).

Among the many shortcomings of the EU’s current pesticide approval system identified in the PEST Committee draft report are: involvement of the pesticide industry in the toxicity assessments of pesticides, misuse of the academic scientific literature, a lack of sensitive testing for neurological and other serious diseases, the lack of post-market monitoring data to assess the real impact of pesticides, and poor transparency of, and access to, the process for the public. The report calls out a multitude of specific failures of the existing process, such as: “the decision-making process has been found to be lacking in transparency throughout the procedure, from lack of public access to the full studies and raw data through to the risk management stage”; “national competent authorities involved in the approval and authorisation process are in some cases understaffed and underfunded”; and “there is currently no legal obligation to test active substances for their developmental neurotoxicity.”

Recommendations by the PEST Committee are legion — 72 of them, in fact — and constellate around those shortcomings and other issues. Importantly, the committee’s product is a set of recommendations that are not binding. That said, they include calls for:

• heightened transparency across the entire pesticide assessment and approval process

• increased and “friendlier” public access to studies and data used in assessments
• equal weighting of scientific, peer-reviewed literature and lab-based studies
• use of data on final product formulations as part of assessment
• inclusion of key tests in risk assessment (e.g., current ecotoxicological tests for soil organisms, evaluation of environmental concentrations and residues in dust, wind, air, and water)
• a post-marketing monitoring system to enable assessment of the long-term effects on human and animal health, and the environment
• establishment of maximum residue levels for soils, using data collected through such post-market environmental monitoring
• completion and rapid implementation of cumulative risk assessments as part of the pesticide review process
• adoption of clear criteria for “unacceptable effects on the environment”
• inclusion of legally binding risk mitigation measures in approval of pesticides
• promotion of low-risk pesticides to help reduce adverse impacts of pest management
• use by risk managers of the Precautionary Principle in decision making on approvals of “active substances/plant protection products” (to include requisite conditions, and systematic communication about how this principle has been taken into account)

Embedded in one recommendation is this retrospective comment: The European Parliament “regrets that the derogation by confirmatory data procedure has led to certain plant protection products that would have otherwise been banned to remain on the market for an extended period of time.” This critique could readily be applied to the poor regulation of glyphosate — and any number of other pesticides — in the U.S. Beyond Pesticides has covered the domestic glyphosate saga for many years; see its most recent Daily News Blog on the matter here.

Europe has generally been more proactive, precautionary, and protective of human and environmental health than has the U.S. Regulators, particularly at the Environmental Protection Agency, might take a page from the European Parliament’s efforts; there is certainly overlap in concerns between the EP’s findings and critiques in the U.S. of the pesticide regulatory process. Beyond Pesticides and other advocates for human and environmental health have long pointed to a number of similar failings in this country’s regulatory processes, including transparency issues; “fox and henhouse” concerns (e.g., conflicts of interest in regulating bodies and processes), ecological and non-target harms, failure to evaluate impacts of final pesticide formulations, and inadequate environmental monitoring of pesticide use, not to mention repeated failures to follow the law.

In addition, EPA’s general failure to use more-precautionary approaches in its evaluation of pesticides stands in contrast to the PEST Committee’s recommendations. It likewise compares unfavorably with the recent decision of a French court to institute an immediate ban on the use of glyphosate, in which the court said that the French environment agency, ANSES, had not respected the precautionary principle in its consideration of the compound’s potential health risks.

Beyond Pesticides reports regularly on domestic and global developments on the understanding, impacts, and regulation of pesticides, herbicides, fungicides, and other chemicals of concern, through its Daily News Blog.

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

Sources: http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+COMPARL+PE-627.625+01+DOC+PDF+V0//EN&language=EN and https://www.pan-europe.info/press-releases/2018/12/eu-parliament-report-reveals-shortfalls-current-pesticide-authorization

(Beyond Pesticides, January 28, 2019) A  September 2018 report from the Office Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA) identified issues important to protecting health and the environment. The EPA’s response to the report left many of these problems unresolved.

Measures and Management Controls Needed to Improve EPA’s Pesticide Emergency Exemption Process (Report No. 18-P-0281, September 25, 2018), finds that the agency’s practice of routinely granting “emergency” approval for pesticides through its Section 18 program does not effectively measure risks to human health or the environment.

Tell Congress to Ask the EPA Administrator to Close the “Emergency” Pesticide Use Loophole, and Adopt All the Recommendations of the Office of the Inspector General.

Under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA has the authority to approve the temporary emergency use of unapproved pesticides if the agency determines the pesticide is needed to prevent the spread of an unexpected outbreak of crop-damaging insects, for example. But this provision has been widely abused.

The inspector general recommends EPA “develop and implement applicable outcome-based performance measures to demonstrate the human health and environmental effects of the EPA’s emergency exemption decisions.”

EPA disagreed and said, [T]he development of an outcome-based performance measure for the Section 18 emergency exemption process was neither appropriate nor feasible.” EPA’s response demonstrates that the current Section 18 program, which allows chronic overuse of emergency exemptions, is neither appropriate nor adequately protective of public health.

OIG’s report finds “significant deficiencies in the OPP’s [Office of Pesticide Programs] online database management, in its draft Section 18 emergency exemption standard operating procedure and application checklist, and in its reports to Congress and the Office of Management and Budget.” Specifically, the report notes EPA “does not have outcome measures in place to determine how well the emergency exemption process maintains human health and environmental safeguards. The program office also does not have comprehensive internal controls to manage the emergency exemption data it collects,” and “OPP does not consistently communicate emergency exemption information with its stakeholders.”

Beyond Pesticides has firmly opposed the current use of Section 18. Through the Section 18, or emergency exemption program, EPA allows the use of pesticides that are not registered for a particular crop, or in some cases not registered for use at all, but making progress toward registration. EPA can set tolerances for affected crops that are time-limited, usually for the season in which they are allowed or sometimes longer. For example, in March 2017 EPA announced it is allowing residues of antibiotics in Florida orange juice, after approving an emergency exemption for the antibiotics streptomycin and oxytetracycline –allowing their use for a bacterial disease, citrus greening (Candidatus Liberibacter asiaticus (CLas) bacterium that causes Huanglongbing), in Florida citrus crops through December of 2019, and further exacerbating bacterial resistance. Organic citrus growers use cultural practices, soil fertility focused on soil biology, and biological controls to manage the disease.

Beyond Pesticides has found a growing number of requests for Section 18 emergency exemptions from states over the last ten years for the use of pesticides to control various resistant weed and insect pests that do not meet the criteria for “non-routine” or “emergency” conditions set forth in FIFRA, and/or whose pesticide use would pose elevated risks to the environment. Additionally, a number of requests and subsequent, almost annual, issuance of Section 18 exemptions essentially replace one Section 18 exemption with another. Continuous exemptions for the same or similar pest problem over a number of years indicates that the case is not “non-routine” and undermines the intent of the program, which is to provide temporary relief from unforeseen problems.

A Center for Biological Diversity report finds as of 2017, EPA had granted 78 “emergency” exemptions for sulfoxaflor, a pesticide that the EPA itself concluded is highly toxic to bees. EPA has approved emergency exemptions to allow sulfoxaflor use on more than 17.5 million acres of U.S. cotton and sorghum farms – use sites where the pesticide is not currently registered. Other exemptions are given to states to combat herbicide-resistant weeds, which have proliferated across the U.S. over the last decade and should not be considered an “emergency” situation; resistance is a predictable consequence of pesticide use.

Reoccurring problems like weed resistance to herbicides should be a wake-up call for farmers and EPA to reevaluate and implement alternative biological and cultural management practices for the long-term prevention of diseases, ending the reliance on the “chemical fix” that will exacerbate the problem when pest resistance to the chemical inevitably occurs.

Tell Congress to Ask the EPA Administrator to Close the “Emergency” Pesticide Use Loophole, and Adopt All the Recommendations of the Office of the Inspector General,

Letter to Congress

When the Office Inspector General (OIG) of the U.S. Environmental Protection Agency issued its report in September, 2018 on emergency pesticide uses, the agency’s response left unresolved many issues important to the protection of health and the environment. The report, Measures and Management Controls Needed to Improve EPA’s Pesticide Emergency Exemption Process (Report No. 18-P-0281, September 25, 2018), concludes that the agency’s practice of routinely granting approval through its Section 18 emergency exemption program for pesticide use does not effectively measure risks to human health or the environment. Under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA has the authority to approve the temporary emergency use of unapproved pesticides if the agency determines the pesticide is needed to prevent the spread of an unexpected non-routine outbreak of crop-damaging insects, for example.

 The Inspector General recommends that EPA “develop and implement applicable outcome-based performance measures to demonstrate the human health and environmental effects of the EPA’s emergency exemption decisions.” EPA disagreed and said, “[T]he development of an outcome-based performance measure for the Section 18 emergency exemption process was neither appropriate nor feasible.” EPA’s response demonstrates that the current Section 18 program, which allows chronic overuse of emergency exemptions, is neither appropriate nor adequately protective of public health.

 OIG’s report finds “significant deficiencies in the OPP’s [Office of Pesticide Programs] online database management, in its draft Section 18 emergency exemption standard operating procedure and application checklist, and in its reports to Congress and the Office of Management and Budget.” Specifically, the report notes EPA “does not have outcome measures in place to determine how well the emergency exemption process maintains human health and environmental safeguards. The program office also does not have comprehensive internal controls to manage the emergency exemption data it collects,” and “OPP does not consistently communicate emergency exemption information with its stakeholders.”

 The ”emergency” use of unregistered pesticides under the current EPA program threatens public health and the environment. Please urge the EPA Administrator to comply with all the OIG recommendations immediately.

Thank you for your consideration of this request.
Sincerely

(Beyond Pesticides, January 25, 2019) The partial government shutdown–now in its second month–is disrupting federal oversight of food safety for various pathogens and pesticides. Labs are shuttered, many government agency employees are furloughed, and those still working are doing so without pay. The ongoing obstruction to government assessment of the food supply puts U.S. consumers at risk.

Workers from the Association of Public Health Laboratories (APHL) have expressed concerns about the U.S. Department of Agriculture’s (USDA) AMS Pesticide Data Program. This program samples, tests, and reports about pesticide residues in U.S. agricultural commodities, with a focus on chemicals that could cause problems for infants and children. Peter Kyriacopoulos, senior director of public policy at APHL, stated that only one of the ten public health laboratories is planning on continuing testing samples during the shutdown without compensation.

Additionally, APHA has reported issues regarding DNA analysis of food samples involved in foodborne outbreaks. DNA samples from sick patients are used to trace back the source of outbreaks and lead to assessment of food production facilities. While outbreak investigations are headed by the currently fully-operational Centers for Disease Control and Prevention (CDC), interdepartmental research involving the USDA and Food and Drug Administration (FDA) is delayed due to furloughed employees and lack of funding for laboratories.

A December news release from USDA outlined the list of inspection functions during the lapse of funding beginning January 1, 2019 to include: Meat, poultry, and processed egg inspection services, grain and other commodity inspections, as well as import/export inspections for pests.

A briefing held by the House Congressional Food Safety Caucus on Wednesday, January 16 named alarming realities of the impact of the shutdown. According to U.S. Representative Rosa DeLauro (D-CT), only about a third of FDA’s regular 160 weekly inspections are being carried out. 200 of the total 550 food investigators are tasked with working during the shutdown. They are doing so without pay, and are using personal funds for travel expenses. Overall, FDA has furloughed 41% of its workforce (~17,000 employees). Ninety percent of the USDA’s 9,500 Food Safety and Inspection Service employees are working without pay. Thomas Gremillion of the Consumer Federation of America stated, “Businesses know there aren’t any unannounced inspections happening now. The incentive structure is being eroded.”

FDA commissioner Scott Gottlieb, MD tweeted on January 22nd: “We’ve received multiple inquiries about which critical food operations continue during the shutdown. Examples of the work that we’re still doing include: 1) High-risk domestic food surveillance inspections; 2) foodborne illness surveillance and outbreak investigations; 3) Execution of high-risk food recalls; 4) Inspection of foreign food facilities; and 5) Sampling of imported food samples (including sampling for antibiotic residue contamination and decomposition analysis). These are among critical activities ongoing by dedicated, unpaid staff.”

The complicated, intertwined effects of the government shutdown are deeply concerning. The long-term consequences to the lack of oversight to food safety are yet unknown, and there does not seem to be a quick end to the shutdown within sight. NBC News reported on January 23 that the Trump administration has asked for a list of programs that could be affected if the shutdown continues for additional weeks, signaling preparation for an ongoing stalemate until, perhaps, March.

If you are concerned about what kinds of pesticides could be in your food, especially with lack of regulation, you can utilize Beyond Pesticides’ Eating with a Conscience database. The organization evaluates the impact of toxic chemicals allowed for use on individual fruits and vegetables grown domestically and internationally.

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

Sources: Food Safety News, Reuters, Contagion Live, NBC News

(Beyond Pesticides, January 24, 2019) A UK Study has concluded that the expansion of community gardens, identified as “pollinator hotspots” with “high pollinator diversity,” offer an important opportunity for assisting ailing pollinator species and improving community quality of life, particularly in low income neighborhoods. Consequently, researchers suggest towns and cities can be planned and managed more effectively to steward existing urban biodiversity to create essential havens for pollinators and people under stress.

The study finds that, “A high level of community robustness to species loss is increasingly recognized as an important goal in restoration ecology, since robust communities are better able to withstand perturbations.”

As previous research has shown that organic agriculture boosts local economies, researchers account for and compare a key socioeconomic factor; household income. Affluent neighborhoods have larger, more numerous, and more consistently maintained gardens and green spaces. To increase city-scale robustness, researchers suggest increasing community garden allotments, planting perennial flowering plants in cemeteries, and improving management of public parks. However, researchers explain that increasing the number of community gardens, particularly in communities of low-income, would be the best strategy per unit area, as it would expand viable habitat for pollinators throughout cities while providing much-needed green space and food sources for people.

To identify conservation opportunities, the study examined all major land uses and their impact on floral availability in the cities Bristol, Edinburgh, Leeds and Reading in the United Kingdom (UK). The nine major land use categories selected for sampling, include: (1) allotments (community gardens); (2) cemeteries; (3) residential gardens; (4) man-made impermeable surfaces; (5) urban nature reserves; (6) other green spaces (including school playing fields and yards); (7) public parks; (8) pavements; and (9) road verges (plant strips in-between roadways and sidewalks). For each city, ten sampling sites were chosen randomly. Every site was sampled three times between April and September of 2012 and 2013.

Results correlate floral abundance with pollinator abundance. Bees, hoverflies and non-syrphid Diptera (such as the common fly), represent 90% of flower visitors. For all four cities, residential and community gardens contain 54–83% of pollinators. Unsurprisingly, plant species commonly called “weeds” were shown to be critical for pollinator survival as they provide a varied array of nutrient resources.

Overall, Dandelion (Taraxacum), were visited most often, and common daisy least often. Other pollinator favorites are Creeping buttercup: Ranunculus repens, Hogweed, or cow parsnip (Heracleum sphondylium), and a perennial species, Creeping Thistle (Cirsium arvense).

In all four cities, residential gardens at houses with higher median income showed higher floral abundance, along with higher numbers of pollinators present.

“[Community gardens] are incredibly important at a city level, despite their small area,” said lead-author Katherine Baldock, PhD, School of Biological Sciences, at the University of Bristol, UK. “They are a good place for pollinators to hang out and provide a win-win situation, as they are also good for food growing and for people’s health.”

The influence of socioeconomic factors in constraining pollinator conservation cannot be discounted. Especially with climate change bringing stronger storms and heavy rains, building communities resilient to storm surges and food shortages can be the only measure of success. In this way, urban planning for sustainability will necessitate the expansion of community gardens and robust local food systems.

Take Action: In light of the shortcomings of federal action and industry groups working to weaken and derail any pesticide reforms at state and local levels, gardeners have an important role to play in pollinator conservation, quality of life, and availability of local organic food community-wide across all income groups. Organize with community leaders and arrange meetings with city officials to discuss expanding garden resources and training programs, such as arranging planting demonstrations.

For parks, advocate for organic land management with city officials. One simple strategy; reduced mowing, comes with immediate cost-savings, and with it, increased floral abundance for urban pollinators in distress. What more can you do? For comprehensive protection, ensure new pollinator habitat be kept pesticide-free, as designated pollinator habitat areas can still put pollinators at risk if pesticides are used.

Before you mow, consider allowing flowering plants, like clover and dandelions to bloom. Consider turning your yard into an organic, low-maintenance garden, or let a portion of your property re-wild altogether. Preserve biodiversity as if life depends on it. For more information and guidelines to get you started, read “Hedgerows for Biodiversity” by Terry Shistar, Ph.D. You can also visit “Managing Landscapes with Pollinators in Mind” for help deciding which plants are right for your region and the type of pollinators you want to attract.

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

Sources: The Guardian, Nature Ecology & Evolution

(Beyond Pesticides, January, 23, 2019) Individuals that have been acutely poisoned by pesticides at some time in their life may be more likely to lose their sense of smell, according to a recent study published in Environmental Health Perspectives.  Researchers focused on the effect of high pesticide exposure events (HPEE), such as a pesticide spill or other incident, on a farmers’ ability to smell later in life. This is the first study to indicate pesticide exposure may result in olfactory impairment.

Farmers from Iowa and North Carolina enrolled in an ongoing U.S. Agricultural Health Study have been asked about their pesticide use roughly every 5 to 6 years since 1993. In the most recent survey, taken from 2013-2015, farmers were asked additional questions about HPEE in their lifetime and whether they had a significantly decreased or impaired sense of smell.

“Studying farmers gives us more reliable data on pesticide exposures than if we had studied the general population,” says Honglei Chen, MD, PhD, lead author and professor of epidemiology at Michigan State University in a press release. “Because they use pesticides more and it’s part of their job, they’re more likely to remember what pesticides they used and in cases of high exposures, report the specific events.”

Of the roughly 10k farmers interviewed during the recent survey, nearly 1,200 reported some form of impairment to their sense of smell. Analyzing data from questions asked during the original 1993 survey, researchers found that farmers that reported a history of HPEE at the outset were 49% more likely to experience olfactory impairment than farmers that did not.

Evidently, those that delayed washing with soap and water after their exposure incident were roughly 1.5 times likelier to experience loss of smell than those that immediately worked to wash off the pesticide. But scientists found that the route of exposure mattered little, with farmers reporting roughly the same loss of smell whether the HPEE involved either internal or dermal impacts.  Significant associations were also found for particular pesticides. Specifically, two legacy organochlorine insecticides, DDT and lindane, as well as the herbicides alachlor, metolachlor, 2,4-D, and pendimethalin were all singled out within the study.

Scientists speculated on a range of ways pesticides may be disrupting olfactory senses. Exposure may damage the epithelium, or thin tissue inside the nose, impair the olfactory nerve, disrupt the immune system, the microbiome within the nose, and/or cause potentially persistent inflammation.

But very few major studies have been performed on the link between pesticide exposures and smell steadfastness. There is incidence in the literature of anosmia, or smell loss, after exposure to a pyrethrin based insecticide, and a 2015 study on farmworker smell difficulties found suggestive but inconclusive results. The authors indicate that although their results were strong, additional research on this issue is necessary to better understand the connection. In any case, it is another consideration for farmers working in chemical-intensive agriculture, alongside reports of increased rates of depression, asthma, and certain cancers.

“Olfactory impairment affects up to 25 percent of our older population, and our understanding of what the consequences are is still very limited,” Dr. Chen noted. “Studies have also suggested that older adults with a poor sense of smell are more likely to die earlier, so understanding the factors involved is very important.”

Farmers and residents alike should work to avoid any HPEE by forgoing the purchase, storage and use of toxic synthetic pesticides in the first place. By transitioning away from toxic chemicals in favor of alternative practices that work with, rather than against nature, farmers, farmworkers, consumers, and the planet will benefit from better health and long-term well-being. Organic represents the realization of this sustainable, alternative paradigm. By purchasing organic whenever possible, you support a system replaces toxic pesticides with safer practices.

Read more about the health effects linked to pesticide exposure through Beyond Pesticides’ Pesticide Induced Diseases Database.

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

Source: MSU Press Release, Environmental Health Perspectives

(Beyond Pesticides, January 22, 2019) Earlier this month, U.S. Representative Nydia Velásquez (D-NY) introduced The Ban Toxic Pesticides Act, H.R.230 which bans the insecticide chlorpyrifos from commerce.

Chlorpyrifos is a toxic chemical that has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children. As a result of a revised human health risk assessment, the Environmental Protection Agency (EPA) developed a regulation to ban chlorpyrifos in 2016. Under the Trump Administration, the EPA has taken steps to reverse the regulation.

“It’s unconscionable for EPA to turn a blind eye as children and workers are exposed to this poison,” Velázquez said.  “If the EPA won’t do its job when it comes to chlorpyrifos, then Congress needs to act – and do so quickly.”

Ask your U.S. Representative to Co-Sponsor H.R. 230 to Stop the Use of the Toxic Insecticide Chlorpyrifos, which Is Damaging Children’s Brains. 

Chlorypyrifos is a widely used pesticide. Agriculture companies annually spray 6 million pounds of the substance on crops like citrus, apples, and cherries.  In the same family as Sarin gas, the substance was initially developed prior to World War II as a chemical weapon. It can overstimulate the nervous system to cause nausea, dizziness, and confusion. With very high exposures (accidents or spills), it can cause respiratory paralysis and even death. When applying the chemical to fields, workers must wear protective garments such as respirators. Workers are then blocked from entering the fields from 24 hours up to 5 days after application due to the chemical exposure risk.

In August, the U.S. 9th Circuit Court of Appeals ordered the Environmental Protection Agency (EPA) to implement its previous proposed ban of the chemical in the U.S. However, the Administration is appealing the ruling, seeking to prevent implementation of the Obama-era ban.

Rep. Valázaquez states, “As long as there are efforts underway in the courts or administratively to undo the ban on this toxic pesticide, I’ll be working to see chlorypyrifos removed from commerce through the legislative process.”

There is a strong recent history of action of introducing legislation to remove chlorpyrifos from use. The same legislation being proposed by Valazquez was introduced in the last Congress as H.R. 3380, Pesticide Protection Act (2017). In the closing days of the 115th Congress, U.S. Senator Brian Schatz (D-Hawai‘i) introduced a bill to ban chlorpyrifos. The Prohibit Chlorpyrifos Poisoning Students Act (S. 3764) would elevate Hawai‘i’s state ban to the national level, banning the use of the chemical near (within 300 feet of) schools in 2019 and banning its sale and distribution altogether the following year. The legislation follows a 2017 bill introduced by Senator Tom Udall (D-NM), Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act, S. 1624, that deems any food with chlorpyrifos residues to be adulterated and therefore illegal.

EPA negotiated a cancellation of all residential uses (with the exception of golf courses and disease-carrying mosquitoes) in 2000 after finding significant neurotoxic effects on children. In June, 2018, Hawai‘i became the first state to ban chlorpyrifos, effective 2022.

Given the abundant research demonstrating deleterious effects of chlorpyrifos on human health –including a 2016 EPA human risk assessment that found the agency’s exposure threshold is exceeded for children, and citing concerns about chlorpyrifos levels in the air in schools, homes, and communities — it is critical to support a complete ban on the chemical.

H.R. 230 has 56 house representative co-sponsors. If your representative has already signed on, you will be prompted to send them a thank you note that encourages them to keep advocating for human and environmental health.

Ask your U.S. Representative to Co-Sponsor H.R. 230 to Stop the Use of the Toxic Insecticide Chlorpyrifos, which Is Damaging Children’s Brains. 

Letter to U.S. Representatives:

I am writing to request that you co-sponsor The Ban Toxic Pesticides Act, H.R.230. Introduced by Rep. Nydia Velásquez, the act bans the insecticide chlorpyrifos from commerce. Chlorpyrifos is a toxic chemical that has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children.

 EPA negotiated a cancellation of all residential (with the exception of golf courses and disease-carrying mosquitoes) uses in 2000, after determining that the neurotoxic effects to children exceeded reasonable levels. A 2016 revised EPA human health risk assessment of chlorpyrifos found that the agency’s exposure threshold is exceeded for children, citing concerns about levels in the air at schools, homes, and communities in agricultural areas. As a result, the EPA developed a regulation to ban chlorpyrifos. Under the Trump Administration, the EPA has taken steps to reverse the regulation despite clear human health hazards.

In June of 2018, Hawai‘i became the first state to ban chlorpyrifos (effective in 2022). The evidence of deleterious effects and momentum of policy change make it clear: there is an urgent need to extend protection from chlorpyrifos to children and others in all states.

Please confirm with me that you will co-sponsor H.R. 230, The Ban Toxic Pesticides Act.

Thank you.

Sincerely,

Co-sponsors in the last (115^th) Congress (56): Chairman Raúl M. Grijalva, Rep. David N. Cicilline, Rep. Debbie Wasserman Schultz, Rep. McNerney, Rep. Peter DeFazio, Rep. Blumenauer, Rep. Bonamici, Rep. Roybal-Allard, Rep. Quigley, Rep.
Lee, Rep. Chu, Rep. Eleanor H. Norton, Rep. Frederica S. Wilson, Rep. Gabbard, Rep. Jackson Lee, Rep. Peter Welch, Rep. Mark Pocan, Rep. Espaillat, Rep. Lipinski, Rep. Kathy Castor, Rep. Carolyn B. Maloney, Rep. Steve Cohen, Rep. Ro Khanna, Rep. Tim Ryan, Rep. Yvette D. Clarke, Rep. Chris Smith, Rep. Pramilia Jayapal, Rep. Carol Shea-Porter, Rep. Bonnie Watson Coleman, Rep. Gregory Meeks, Rep. Albio Sires, Rep. Nanette Diaz Barragán, Rep. Dwight Evans, Rep. Betty McCollum, Rep. Zoe Lofgren, Rep. Jerry Nadler, Rep. Jan Schakowsky, Rep. Raskin, Rep. McGovern, Rep. Ted W. Lieu, Rep. Bobby Rush, Rep. Pingree, Rep. Grace Meng, Rep. Adam Smith, Rep. Huffman, Rep. Fudge, Rep. Colleen Hanabusa, Rep. Donald M. Payne, Jr, Rep. Tony Cárdenas, Rep. Matt Cartwright, Rep. Pete Visclosky, Rep. Jimmy Gomez, Rep. Jackie Speier, Rep. Grace Napolitano, Rep. Seth Moulton, Rep. Katherine Clark.

(Beyond Pesticides, January 18, 2019) A new analysis by Charles Benbrook, PhD, published in the journal Environmental Sciences Europe, adds to the chronicle of the failures of the U.S. Environmental Protection Agency (EPA) to protect human health from toxic pesticides, and in this subject instance, from glyphosate. Meanwhile, a French Court has pulled the license for a Roundup product, citing the French government’s failure to protect public health.

In his paper, Dr. Benbrook examines the divergent positions on the carcinogenicity of glyphosate — the active ingredient in a number of herbicides, most notably Monsanto’s (now Bayer’s) Roundup — taken by the International Agency for Research on Cancer (IARC) and by EPA. The paper calls out EPA’s handling of science related to the safety of glyphosate, suggesting that the agency has discounted evidence of the compound’s association with genotoxicity — destructive effects on cellular genetic material that can cause mutations — which can result in cancer.

Dr. Benbrook is an American 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 has long studied pesticide use related to genetically engineered crops in the U.S., as well as their health impacts; see previous coverage by Beyond Pesticides here and here.

Publication of this paper follows the August 2018 San Francisco County Superior Court landmark decision for plaintiff DeWayne “Lee” Johnson, a former school groundskeeper exposed regularly to Roundup in the course of his job duties, who was diagnosed with Non-Hodgkins Lymphoma at age 42 and became terminally ill. The jury awarded Mr. Johnson $39 million in compensatory damages, and $250 million in punitive damages in his suit against Monsanto, then-maker of Roundup. (The judge later cut the total $289 million figure to $78 million.)

The analysis also precedes the first scheduled federal trial about whether glyphosate compounds can cause cancer. That suit, by California resident Edwin Hardeman, which will be heard in federal district court in San Francisco starting on February 25, will be the first to go to a jury among more than 620 cases pending in federal litigation. Dr. Benbrook testified as an expert witness in Mr. Johnson’s case, and is expected to testify for the plaintiff in Mr. Hardeman’s. Unsurprisingly, the defendant in the federal court case is seeking to have Dr. Benbrook’s testimony excluded.

The difference between the IARC and EPA positions on the carcinogenicity of glyphosate is this: in March 2015, IARC classified glyphosate (as well as malathion and diazinon) as “probably carcinogenic to humans.” (Upon IARC’s announcement, Beyond Pesticides called on EPA and the U.S. Department of Agriculture (USDA) to stop the use of the herbicide, given that ruling.) EPA, on the other hand, continues to classify glyphosate as “not likely to be carcinogenic to humans,” despite scientific evidence.

Dr. Benbrook’s analysis considered the number and nature of the glyphosate studies evaluated by IARC and EPA. His conclusion? “Clearly, compared to EPA’s genotoxicity review, the IARC review is grounded on more recent, more sensitive, and more sophisticated genotoxic studies, and more accurately reflects real-world exposures.” In addition, he noted that EPA has relied for its fundamental assessment of glyphosate on dozens of studies paid for by Monsanto (and other makers of glyphosate products) that found no evidence of association with the development of cancer in those exposed.

EPA has maintained that its review of glyphosate has been comprehensive and vigorous, that glyphosate represents a “low toxicity” risk for humans, and that glyphosate-based products are safe to use when label directions are followed. Dr. Benbrook, however, says that very little of the research EPA has used in its review of glyphosate actually evaluates the compound in the formulations that are sold in the marketplace and used “on the ground.” In its classification decision, IARC highlighted concerns about herbicide formulations that combine glyphosate with other ingredients to enhance weed killing effectiveness.

In fact, EPA began to collaborate only in 2016 — after glyphosate herbicides had been on the market for 42 years — with the U.S. National Toxicology Program (NTP) to assess the relative toxicity of the various glyphosate formulations. Early results of that assessment (released in 2018) point to evidence that Roundup and other formulations are potentially more toxic to human cells than is the active ingredient alone. Acting Chief of NTP Mike DeVito said that its early findings are clear on one key point. “We see the formulations are much more toxic. The formulations were killing the cells.”

Although Dr. Benbrook’s analysis is the first to do a deep dive on how and why the EPA and IARC drew such different conclusions, other scientists (including some from EPA’s Office of Research and Development, and from a panel of scientific experts convened by the EPA) have also identified problems with the agency’s classification of glyphosate as “not likely to be carcinogenic to humans.” He reviewed the citations for genotoxicity testing in EPA and IARC reports — both those that were published in peer-reviewed journals and the unpublished ones given to EPA by Monsanto (and other companies).

Environmental Health News reports that Dr. Benbrook’s analysis revealed that, within the body of available evidence, EPA relied on 151 studies; 115 showed no evidence of genotoxicity, and 36 that had positive results (i.e., showed evidence of genotoxicity). IARC cited 191 studies; 45 showed negative results (no evidence of genotoxicity), and 146 showed evidence of genotoxicity. On that basis, IARC reported that within these studies it found “strong evidence that exposure to glyphosate or glyphosate-based formulations is genotoxic.”

Dr. Benbrook’s analysis also found that at least 27 other studies published during the past three years have addressed potential mechanisms of genotoxic action for glyphosate and/or glyphosate-based herbicide formulations, and all but one reported one or more positive result. According to Dr. Benbrook, EPA’s failure to focus on these formulations is dangerous because they “account for all commercial uses and human exposures (no herbicide products contain just glyphosate),” and much more research is needed on real-world exposures.

Concerns about the safety of glyphosate-based herbicides is hardly confined to the U.S. After a great deal of “churn” about the issue in Western Europe, including a proposed 10-year extension of use approval, in early 2018, the European Parliament convened a Special Oversight Committee to review the European Union’s authorization procedure for pesticides, largely because of its controversial review of glyphosate.

Now comes news that a French court has canceled the license for, and instituted an immediately effective ban on, Roundup Pro 360, one of Bayer’s (Monsanto’s) glyphosate-based herbicides. A court in Lyon ruled that the 2017 approval of Roundup Pro 360 by French environment agency ANSES (Agence nationale de sécurité sanitaire de l’alimentation, de l’environnement et du travail) had not respected a “precautionary principle” in failing to consider potential health risks.

Concern was apparently great enough that the court took this step even in the context of President Emanuel Macron’s pledge to phase out glyphosate-based herbicides by 2021. In a summary, the court said, “Despite the European Union’s approval of the active substance (glyphosate), the court considered that scientific studies and animal experiments showed Roundup Pro 360 . . . is a potentially carcinogenic product for humans, suspected of being toxic for human reproduction and for aquatic organisms.” Bayer, of course, disagreed with the decision and is considering its legal options. It has cited regulatory rulings as well as scientific studies that “found glyphosate to be safe.”

With thousands of court cases pending in the U.S. alone, Bayer and other pesticide producers may have a rough road ahead, and judicial action may eventually force regulators to act more ambitiously on protection of human health from glyphosate-based products. Beyond Pesticides will monitor developments on the glyphosate frontier; keep informed through its Daily News Blog.

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

Sources: https://www.ehn.org/glyphosate-cancer-epa-2625974133.html and https://www.reuters.com/article/us-bayer-monsanto-france/french-court-cancels-monsanto-weedkiller-permit-on-safety-grounds-idUSKCN1P91F6

(Beyond Pesticides, January 17, 2019) Although the rusty patched bumblebee was placed on the endangered species list in 2017, the Trump Administration has failed to put in place legally required safeguards for the species. As a result, the Natural Resources Defense Council (NRDC) is suing the Administration’s Department of the Interior (DOI) for failing to designate locations where additional protections could help restore the endangered bumblebee’s population. Advocates say DOI’s failure to comply with requirements under the Endangered Species Act (ESA) is consistent with the Trump Administration’s continued disregard for ongoing pollinator declines and environmental protections in general.

Under ESA, DOI is required to determine “critical habitat” that contains physical and biological requirements a listed species needs in order to recover. That area must be designated within one year of placing a species on the endangered list, using best available scientific data. But the Trump Administration’s DOI, under both former Director Ryan Zinke and Acting Director David Bernhardt, has failed to do so, in violation of ESA. NRDC’s legal director Rebecca Riley notes that this lack of follow-through “leaves this highly endangered bee’s habitat at risk of destruction and decreases the species’ chance for survival.”

The rusty patched bumblebee has a historical range that included habitat throughout the Northeast and Midwest United States. The Washington Post notes that, “The rusty patched bumblebee was so prevalent 20 years ago that pedestrians in Midwestern cities had to shoo them away.” However, pesticide use, climate change, disease, and habitat loss led to significant declines over the last several decades. Since then, their populations have dwindled and their overall decline is estimated at 91 percent.

The Trump Administration has dragged its feet on protecting the rusty patched bumblebee since the beginning of its term. The species was proposed for ESA listing under the Obama Administration in 2016, and finalized in 2017 only a week before the new Administration took power. However, on his first day in office, President Trump directed federal agencies to postpone the effective date of any regulations that had been published to the federal register, but not yet put into effect. This move effectively reversed the ESA listing of the rusty patched. However, NRDC quickly launched at lawsuit to reinstate the designation, arguing that the delay in rulemaking illegally denied the species essential protections under the law.

In March 2017, the species was finally placed onto the endangered list, leading to NRDC dropping its initial lawsuit. This new court case responds to a lack of action after the initial designation. “Limiting [the rusty patched bumblebee] to just a tiny sliver of the habitat where they once thrived not only limits the likelihood that the bees persist,” said Daniel Raichel, a staff attorney for the Pollinator Initiative at NRDC. “It also fails to live up to the obligations of the Endangered Species Act.”

Unfortunately the Trump Administration’s actions in this case are more of the norm rather than the exception. In August of last year, DOI reversed a long-standing policy that prohibited the use of systemic, bee-toxic neonicotinoid insecticides on National Wildlife Refuges. The Administration has also worked on the pesticide industry’s behalf to slow down the implementation of farmworker protections and continue the allowance of another highly toxic insecticide chlorpyrifos.

Take action today by urging DOI to reinstate its ban on the use of bee-toxic pesticides in National Wildlife Refuges.  For more information on what you can do to protect pollinators in your backyard and community, visit Beyond Pesticides’ BEE Protective webpage.

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

Source: Natural Resources Defense Council

(Beyond Pesticides, January 16, 2019) Preliminary counts in California indicate the western monarch butterfly population dropped 86% from 2017 to 2018. The survey is a result of an annual effort by volunteer citizen scientists, organized by the nonprofit organization Xerces Society. If the trend from the initial sample (97 sites) holds true, the population of overwintering butterflies is estimated to be less than 30,000 – 0.05% of its historical size. Full and vetted results will be published in late January.

To get an accurate count of monarch populations, volunteers follow a monitoring guide, which recommends beginning a count on a still, cool, and dry morning so that monarchs are still clustered together. Volunteers count a small cluster of monarchs and then extrapolate that number to arrive at a total for the larger cluster they’re observing. Citizen science has been crucial to understanding the decline of monarchs and insects worldwide. As covered by The New York Times, the current “Insect Apocalypse” has largely been documented by volunteers.

The dismal numbers recorded this year are potentially disastrous, as the predicted extinction threshold for overwintering western monarchs is a population of 30,000. However this threshold, based on population densities needed for thermoregulation and mating during winter, will only be verified once the western monarch’s yearly migration patterns cease. And at that point it will likely be too late to save the wild population.

Using statistical analysis of citizen science data, a 2017 study posited the extinction risk of monarch butterflies in western North America to be ~50-70% within 20 years, and ~65-85% within 50 years. The precarious situation of the butterfly population can be attributed to both recent events and long-term stressors, including pesticide use.

To start, western monarch breeding populations in March and April were historically low. Art Shapiro, PhD, a distinguished professor of evolution and ecology at the University of California, Davis, noted in September 2018, “I have not seen a wild egg or caterpillar of the monarch this entire calendar year at low elevations. Not one.”

The weather in California was less than favorable, beginning with late rainy season storms in March. A severe and extended wildfire season – the most destructive on record – caused a smoky atmosphere and reduced habitat. The historic drought that established conditions for the massive wildfires had a negative impact on butterfly populations in its own right.

Overall, the western monarch population has declined by 95% since the 1980’s. Significant contributors to the dramatic decline are habitat loss, pesticide use (both insecticides and herbicides), and climate change.

As we confront the potential extinction of western monarchs, a swift and drastic response is necessary. In 2017, a number of environmental groups urged the Trump Administration to expand protections and efforts for monarch butterflies. The administration has not responded to this call to action, and continues to roll back federal protections.  Interior Department Deputy Secretary David Bernhardt has referred to the implementation of the Endangered Species Act (ESA) as an “unnecessary regulatory burden” on citizens and companies. Regardless, advocates say it is important to keep placing pressure on elected officials, especially those at the local level, to protect biodiversity.

The Xerces Society states, “Key areas to focus habitat protection and restoration efforts include overwintering sites and breeding habitat in California, particularly the Central Valley and foothills. Elsewhere in the western states, important breeding grounds for monarchs can be found in eastern Washington and parts of Oregon, as well as the Snake River Plain of Idaho, areas where habitat has likely been lost.”

Crucial to long-term recovery of monarchs and other pollinators is comprehensive adoption of organic land care practices. Agricultural lands comprise 77% of all prospective monarch habitat and are therefore critical to foster pesticide-free habitat for pollinator populations. As it stands, many agricultural fields employ a range of toxic pesticides, such as systemic neonicotinoid insecticides, which make the pollen and nectar of plants toxic to pollinators, or genetically engineered crops, which tolerate repeated glyphosate exposure and through drift indirectly lead to the loss of milkweed on which monarchs depend.

Beyond Pesticides has many resources that support monarchs and other declining pollinator populations on the individual level, including Managing Landscapes with Pollinators in Mind and Hedgerows for Biodiversity: Habitat is needed to protect pollinators, other beneficial organisms, and healthy ecosystems.  You can also visit the BEE Protective Habitat Guide and Do-It-Yourself Biodiversity.

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

Source: Xerces Society for Invertebrate Conservation

(Beyond Pesticides, January 14, 2019)  A petition submitted on January 7 by the Center for Biological Diversity calls on the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS) to initiate rulemaking to proscribe nearly all pesticide use in areas that are deemed critical habitat for endangered species. It asks these federal agencies to use the authority they have under the 1973 Endangered Species Act (ESA) to protect wildlife from the threats represented by pesticides — which threats both agencies have long recognized. The language of the ESA says its purpose is “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved.”

In its press release on the petition, the Center for Biological Diversity (CBD) notes that it comes “after decades of intransigence by the Environmental Protection Agency, which has refused to comply with the legal mandates of the Endangered Species Act to protect the nation’s most imperiled species from highly toxic pesticides like chlorpyrifos and atrazine that are known to harm wildlife.” CBD environmental health director Lori Ann Burd said, “Pesticides pose a devastating danger to endangered wildlife, from coast to coast. If the EPA isn’t going to do what’s needed to protect America’s endangered species from pesticides, federal wildlife agencies need to step in.”

In a more sensical world, federal agency enforcement would comport with the dictates of the ESA. But as the petition itself notes, such “rulemaking is necessary because the facts and history overwhelmingly demonstrate that the Environmental Protection Agency (‘EPA’) is both unwilling and unable to comply with the clear statutory requirements to address the harm caused by pesticides to threatened and endangered species by consulting with the Services prior to the approval of a pesticide, as well as failing to comply with the Endangered Species Act on other discretionary agency actions taken under the Federal Insecticide Fungicide and Rodenticide Act (‘FIFRA’).” (See more on the ESA role in pesticide regulation below.)

The protective standard of the ESA is stronger than the “unreasonable adverse effects” FIFRA standard. The ESA law requires federal agencies to ensure that “actions they authorize, fund, or carry out are not likely to jeopardize the continued existence of any listed species or result in the destruction or adverse modification of habitat of such species which is determined by the Secretary, after consultation as appropriate with affected States, to be critical, unless such agency has been granted an exemption for such action. . . . In fulfilling the requirements of this paragraph each agency shall use the best scientific and commercial data

available.”

The statute also prohibits any unauthorized “take” of any listed species of endangered fish or wildlife (“take” being defined as any harm, harassment, pursuit, hunting, shooting, wounding, killing, trapping, capture, or collection). It is worth noting that the economic impacts of protecting endangered species are not, by statute, supposed to play a role in regulatory decisions to restrict pesticides. However, the current federal administration seeks to change the way cost-benefit analysis of regulation is enacted in federal agencies such that “cost to industry” enjoys increased importance in determinations.

The current request by CBD is one in a long series of lawsuits and petitions aimed at getting EPA to follow the law, including compliance with the mandates of the Endangered Species Act. Petitioner and plaintiff organizations involved in these efforts have approached the task from a variety of angles, and have used the more-stringent language of the ESA to secure greater protection for both wildlife and ecosystems. (See a litany of such actions, below.)

Some back story is in order: When EPA registers pesticides for use under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) — the federal law under which EPA can enable and regulate use of pesticides — it must meet not only the requirements of FIFRA, but also, its legal responsibility to consult with the agencies charged with implementation of ESA to ensure that pesticide use patterns do not cause harm to endangered and threated species. Those agencies are the National Marine Fisheries Service, which operates under the aegis of the National Oceanic and Atmospheric Agency (NOAA), and the U.S. Fish and Wildlife Service, which operates out of the Department of the Interior.

[Fun fact: NOAA operates under the Department of Commerce, rather than the Department of the Interior, where it used to reside. This is a weird artifact of some administrative shenanigans on the part of President Nixon to punish then-Secretary of the Interior Wally Hickel for his criticism of Nixon’s Vietnam War policy.]

FWS and NMFS decide whether a species is either “threatened” or “endangered,” and should be listed under the ESA. (Generally, FWS has authority over terrestrial and freshwater species, and NMFS over marine species.) Once listed as “endangered” or “threatened” under ESA, a species is afforded certain legal protections. The required consultation process starts with the “action” agency’s (often EPA’s) request for information on whether any species listed (or proposed to be listed) under the ESA is present in the area of a proposed action. The agency then conducts a biological assessment to identify whether those species are likely to be affected by the proposed action. If there is a determination that any species may be present and is likely to be affected by the proposed action, consultation continues with FWS and/or NMFS.

The relevant Service then prepares a biological opinion that identifies impacts on the subject species. If it finds that the action would jeopardize the continued existence of the species or adversely affect critical habitat (a “jeopardy opinion”), the Service must suggest reasonable and prudent alternatives to avoid the adverse impacts. If there are no such alternatives, the agency may not proceed with the project unless the Endangered Species Act Committee grants an exception. If the Service does not issue a jeopardy opinion (a “non-jeopardy opinion”), it must inform the agency whether there are any “reasonable and prudent measures” that should be applied to the project.

The federal regulatory landscape for pesticides can be pretty complicated. Essentially, EPA regulates pesticides primarily under the dictates of two laws: FIFRA and the Federal Food, Drug, and Cosmetic Act (FFDCA), as well as by two amendments to them: the Food Quality Protection Act (FQPA) of 1996, and the Pesticide Registration Improvement Act (PRIA) of 2003. But the ESA is also active in this landscape. FIFRA requires all pesticides sold or distributed in the U.S. to be registered by EPA. Pesticides become legal for us (with some exceptions) when EPA completes its process for registering them. The role of the ESA in this process is outlined here.

The FFDCA mandates establishment of a maximum permissible level of pesticide residue in or on human food and animal feed (a so-called “tolerance”). The FQPA amends both FIFRA and FFDCA, and sets out that EPA must determine that a pesticide poses a “reasonable certainty of no harm” before it can be registered, and that such registration must be reviewed at least once every 15 years. The PRIA sets out administrative requirements related to fee payment for registration and meeting deadlines for decision making.

The litany of attempts to make EPA follow the law includes a 2002 suit involving impacts of 54 pesticides on Northwest salmon populations (EarthJustice offers a useful history), and a 2011 suit that claimed that EPA failed to consult with FWS and NMFS (a pattern identified in several such suits) on the impacts of one or more of 381 chemicals on 214 endangered and threatened species in violation of the Endangered Species Act (ESA). More recently, a long-standing case had a somewhat encouraging resolution: Beyond Pesticides, CBD, and fellow plaintiffs enjoyed a small victory when a settlement was reached in the case, the outcomes of which will include the eventual cancellation of registrations for 12 neonicotinoid-containing pesticides.

In a series of lawsuits beginning in 2014, plaintiffs have repeatedly acted to compel EPA to cancel approvals of a new pesticide, Dow AgroSciences’ Enlist Duo, which contains 2,4-D and glyphosate. After that, the Obama administration agreed to reanalyze some of the toxic new pesticide’s impacts, but EPA then reaffirmed its original approval and dramatically expanded it, allowing Enlist Duo to be sprayed in more than twice as many states and on cotton, in addition to corn and soybeans. The next suit, in 2015, in which Beyond Pesticides was a plaintiff, charged that EPA had inappropriately given the nod to use of the pesticide, and again failed to consult, as it legally must, with FWS about its impacts on two endangered species (the whooping crane and the Indiana bat). Later in the year, in response to that litigation, EPA announced that it would revoke its own approval of Enlist Duo.

The agency then went on to register Enlist Duo, triggering another lawsuit brought by Beyond Pesticides, CBD, and other groups, charging that approval of the compound “will lead to sharply increased spraying of toxic pesticides, harming farmers, neighboring crops, and wildlife . . . and will lead to as much as a seven-fold increase in its use in agriculture, significantly increasing exposure to farmers.” After EPA expanded approval for Enlist Duo use to 34 states and additional crops in 2017, environmental advocates (including Beyond Pesticides) once again sued EPA, in early 2018, seeking reversal of EPA approval of the compound.

Keep tabs on developments in the regulation of pesticides in the U.S., as well as other nation’s efforts to protect human and environmental health via Beyond Pesticides’ Daily News Blog.

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

Source: https://www.biologicaldiversity.org/news/press_releases/2019/pesticides-01-07-2019.php

(Beyond Pesticides, January 14, 2019) Tell Congress to stop the Trump administration from opening the floodgates to permit widespread use of antibiotics in citrus production (grapefruits, oranges and tangerines).

Despite the building national and international crisis of deadly bacterial resistance to antibiotics, this new allowance would expand on an emergency use decision the Environmental Protection Agency made in 2017. It permits up to 480,000 acres of citrus trees in Florida to be treated with more than 650,000 pounds of streptomycin per year; 23,000 citrus acres in California will likely be treated annually.

The World Health Organization has called bacterial resistance “one of the biggest threats to global health, food security, and development today.”

Tell your U.S. Senators and Representative to urge EPA to reject the use of antibiotics in food production, including citrus production.

The two approved antibacterial chemicals to be used as pesticides in citrus production are streptomycin and oxytetracycline. Their use was permitted by the U.S. Environmental Protection Agency (EPA) under an emergency exemption in May, 2017 for a citrus greening disease caused by the bacterium Candidatus Liberibacter asiaticus (CLas) in Florida citrus crops through December of 2019.

The Environmental Protection Agency announced March 15, “EPA is issuing these tolerances without notice and opportunity for public comment as provided in FFDCA [Federal Food, Drug and Cosmetic Act] section 408(l)(6).” EPA states, “[T]ime-limited tolerances are established for residues of streptomycin in or on fruit, citrus, group 10-10, at 2 ppm, and the dried pulp of these commodities at 6 ppm.” For oxytetracycline, EPA is allowing residues “in or on all commodities of fruit, citrus, group 10-10, at 0.4 ppm.” [See below; organic standards do not allow antibiotic use.] Now, EPA is moving forward with a permanent allowance of these chemicals.

In addition, both the active and inert ingredients in common herbicides advance antibiotic resistance. Learn more about the history of Resistance and Antibiotics by visiting Beyond Pesticides’ Antimicrobials and Antibacterials program page.  Pose the question to policy makers: Will we now see an “Antibiotics rebellion”?

Beyond Pesticides, with other organizations, led a successful effort to remove antibiotics from organic apple and pear production because of their contribution to antibiotic resistance and the availability of alternative practices and inputs.

As bacteria become resistant to the most commonly prescribed antibiotics, the results are longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. The development and spread of antibiotic resistance is the inevitable effect of antibiotic use. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance. Both antibiotics proposed for expanded use are important for fighting human disease. Tetracycline is used for many common infections of the respiratory tract, sinuses, middle ear, and urinary tract, as well as for anthrax, plague, cholera, and Legionnaire’s disease, though it is used less frequently because of resistance. Streptomycin is used for tuberculosis, tularemia, plague, bacterial endocarditis, brucellosis, and other diseases, but its usefulness is limited by widespread resistance (U.S. National Library of Medicine, 2006).

Exposure to antibiotics can disturb the microbiota in the gut. In addition to interfering with digestion, a disrupted gut microbiome can contribute to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. Furthermore, the human immune system is largely composed of microbiota.

Tell your U.S. Senators and Representative to urge EPA to reject the use of antibiotics in food production, including citrus production.

Letter to Congress:

Please stand up to EPA and insist that the agency does not permit the use of antibiotics, including streptomycin and oxytetracycline, in citrus production. This creates a public health threat that EPA must consider in real terms, as it relates to longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. Antibiotic resistance is a real and urgent public health threat and represents an existential threat to modern civilization. Antibiotic resistance kills over 23,000 people each year, according to the Centers for Disease Control and Prevention (CDC). In addition to the CDC, the World Health Organization has cited this escalating problem as one of the biggest public health challenges of our time.

“By 2050, resistance is estimated to add 10 million annual deaths globally with a cumulative cost to the world economy of US$100 trillion,” said Jack Heinemann, PhD, University Canterbury’s School of Biological Sciences.

In addition to interfering with digestion, exposure to antibiotics can disturb the gut microbiota, contributing to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. The human immune system is largely composed of microbiota. Treating all these diseases have real costs that must be calculated when the agency allows exposure to a pesticide, in this case an antibiotic used for non-medical uses.

Note that it may not be widely appreciated that use of antibiotics on fruit trees can contribute to resistance to the antibiotic in human pathogens. The human pathogenic organisms themselves do not need to be sprayed by the antibiotic because movement of genes in bacteria is not solely “vertical,” that is from parent to progeny—but can be “horizontal”— from one*/ bacterial species to another. So, a pool of resistant soil bacteria or commensal gut bacteria can provide the genetic material for resistance in human pathogens.

Consider the real cost to the American people and internationally and urge EPA to prohibit the use of streptomycin in citrus production by setting a tolerance or allowable residue of zero. Please let me know that you are able to voice your concern to EPA on this matter.

Sincerely,

(Beyond Pesticides, January 11, 2019) Plans to weaken farmworker protections from toxic pesticides were dropped by Acting U.S. Environmental Protection Agency (EPA) Administrator Andrew Wheeler, according to an undated letter sent to Senator Tom Carper (D-DE) late last year. Reports indicate the action was part of a deal cut by both parties that permitted confirmation of Alexandra Dunn to the EPA Office of Chemical Safety and Pollution Prevention in exchange for EPA concessions that would improve pesticide and chemical safety measures. While advocates are generally pleased with the outcome of the apparent deal, the irony that deals needed to be made for an agency with protection in its name to do its job is not lost.

Under former EPA Administrator Scott Pruitt, the agency backtracked on provisions put in place during the Obama administration that would update farmworker protections following decades of inaction. Pruitt determined to revisit rules put in place that would require farmworkers be 18 to spray highly toxic pesticides, implement 25 to 100 ft application exclusion zones (AEZ) after pesticide applications, and permit farmworkers to have a designated representative obtain health and safety information on their behalf. These simple, commonsense protections were strongly opposed by the agrichemical industry, which lobbied EPA to backtrack and revise the aforementioned provisions.

In March of last year, 28 Senators urged then-Administrator Pruitt to retain farmworker protections. But according to BNA news reports, Acting Administrator Wheeler had intended to move forward with the revisions as recent as October 2018. While the proposals were delayed as farm bill negotiations persisted, the agency had planned to send its changes to the White House Office of Management and Budget (OMB) this month.

In the agency’s letter to Senator Carper, EPA gave no reason for its decision to drop its revision plans. “Although the subject matter associated with these potential changes has been subject to wide ranging public stakeholder meetings and public comments, EPA will withdraw its OMB submission to propose revisions to these rules and will not make any changes to the designated representative and minimum age provision,” the letter reads.

EPA did not preclude changes to the application exclusion zone provisions, indicating that it would provide 90 days public comment should it proceed with further alterations to the rule.

Agrichemical industry groups, for their part, focused less on the indefensible position of encouraging minors to spray highly toxic restricted use pesticides, and more on how the designated representative provision could impact “confidential business information” and lead to “potential harassment and public criticisms for lawful use of EPA-approved pesticides,” according to previous statements. However without this provision, farmworkers may be poisoned by pesticides and have no route to get critical information to doctors and other medical staff that could help adequately treat poisoning symptoms. As the 28 Senators that wrote EPA indicated, “The designated representative provision is critically important because there are many reasons why a worker may be unable to access information about the chemicals they are exposed to. This commonsense safeguard has been denied to farmworkers while workers in other industries have had these protections for decades.”

Environmental justice advocates are hopeful that finally implementing these regulations will lead to better health and welfare for the countless individuals who help grow the nation’s food. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s, and represents a completely unacceptable data point for any industry today in a developed country.

Help promote a food production system that does not expose farmworkers and their families to toxic chemicals by purchasing organic whenever possible. Yes, organic uses pesticides, but those applied are only done so as a last resort, and the least-toxic pesticide products applied undergo several levels of evaluation by the NOSB, an independent stakeholder board consisting of a wide range of experts. To help better explain the benefits of organic food consumption, Beyond Pesticides invites readers to use the Eating with a Conscience database, which evaluates how toxic chemicals used used food items effect the environment and farmworkers.

To hear first-hand the experience farmworkers endure day in and day out, watch Beyond Pesticides’ National Pesticide Forum workshop on Farmworkers, Families and Health.

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

Source: AgriPluse (subscription required), EPA Letter to Sen. Carper

(Beyond Pesticides, January 10, 2019) The Trump administration is opening the floodgates to allow widespread use of antibiotics in citrus (grapefruits, oranges and tangerines) production, expanding on an emergency use decision it made in 2017. The public has an opportunity to comment on the widespread use of streptomycin by January 19, 2019. You can comment on the federal government’s public comment page (regulations.gov) by leaving a comment opposing any additional use of antibiotics in food production during a national and international crisis of deadly disease resistance to antibiotics. You can copy Beyond Pesticides’ prepared comment below and add your own concerns. Strikingly, the decision allows for up to 480,000 acres of citrus trees in Florida to be treated with more than 650,000 pounds of streptomycin per year, and 23,000 citrus acres in California will likely be treated annually.

The two approved antibacterial chemicals to be used as a pesticide in citrus production are streptomycin and oxytetracycline. These uses were permitted by the U.S. Environmental Protection Agency (EPA) under an emergency exemption in May, 2017, allowing residues of antibiotics in Florida orange juice, for the antibiotics streptomycin and oxytetracycline –allowing their use for a bacterial disease, citrus greening (Candidatus Liberibacter asiaticus (CLas) bacterium that causes Huanglongbing), in Florida citrus crops through December of 2019, and further exacerbating bacterial resistance. The World Health Organization has called bacterial resistance “one of the biggest threats to global health, food security, and development today.” The agency announced March 15, “EPA is issuing these tolerances without notice and opportunity for public comment as provided in FFDCA section 408(l)(6).” EPA states “time-limited tolerances are established for residues of streptomycin in or on fruit, citrus, group 10-10, at 2 ppm, and the dried pulp of these commodities at 6 ppm.” For oxytetracycline, EPA is allowing residues” in or on all commodities of fruit, citrus, group 10-10, at 0.4 ppm.” [See below; organic standards do not allow antibiotic use.]

Now, EPA is moving forward with a permanent allowance of these chemicals. While the comment period is closed on oxytetracycline, public comments on streptomycin are still open until January 19, 2019.

Antibiotic resistance is a real and urgent public health threat and represents an existential threat to modern civilization.  Antibiotic resistance kills over 23,000 people each year, according to the Centers for Disease Control and Prevention (CDC). In addition to the CDC, the World Health Organization has cited this escalating problem as among the biggest public health challenges of our time.

“By 2050, resistance is estimated to add 10 million annual deaths globally with a cumulative cost to the world economy of US$100 trillion,” said Jack Heinemann, PhD, University Canterbury’s School of Biological Sciences.

Antibiotics have a history of use in fruit production, but never at the scale that is being allowed by the Trump EPA. Advocates already working towards pesticide reform can add another reason for policymakers to shift away from toxic pesticides: stopping antibiotic resistance.

Beyond Pesticides, with other organizations, led a successful effort to remove antibiotics from organic apple and pear production because of their contribution to antibiotic resistance, and the availability of alternative practices and inputs.

Both the active and inert ingredients in common herbicides advance antibiotic resistance. Learn more about the history of Resistance and Antibiotics by visiting Beyond Pesticides’ Antimicrobials and Antibacterials program page.  Pose the question to policy makers: Will we now see an “Antibiotics rebellion”?

As bacteria becomes resistant to the most commonly prescribed antibiotics, it results in longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. The development and spread of antibiotic resistance is the inevitable effect of antibiotic use. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance. The principal traditional antibiotics used in plant agriculture to fight disease are both important for fighting human disease. Tetracycline is used for many common infections of the respiratory tract, sinuses, middle ear, and urinary tract, as well as for anthrax, plague, cholera, and Legionnaire’s disease, though it is used less frequently because of resistance. Streptomycin is used for tuberculosis, tularemia, plague, bacterial endocarditis, brucellosis, and other diseases, but its usefulness is limited by widespread resistance (U.S. National Library of Medicine, 2006).

It may not be widely appreciated that use of antibiotics on fruit trees can contribute to resistance to the antibiotic in human pathogens. The human pathogenic organisms themselves do not need to be sprayed by the antibiotic because movement of genes in bacteria is not solely “vertical,” that is from parent to progeny—but can be “horizontal”— from one*/ bacterial species to another. So, a pool of resistant soil bacteria or commensal gut bacteria can provide the genetic material for resistance in human pathogens. The basic mechanism is as follows. If bacteria on the plants and in the soil are sprayed with an antibiotic, those with genes for resistance to the chemical increase compared to those susceptible to the antibiotic. Resistance genes exist for both streptomycin and tetracycline, and spraying with these chemicals increases the frequency of resistant genotypes by killing those susceptible to the antibiotic and leaving the others. Those genes may be taken up by other bacteria through a number of mechanisms, collectively known as “horizontal gene transfer.”

The contribution of antibiotic use in fruit trees to resistance in human pathogens may not be nearly as important as the use of non-therapeutic antibiotics in livestock and farmed fish, but it does have an impact on the pool of antibiotic-resistant bacteria. Furthermore, residues of antibiotics in the soil may be taken up by treated or untreated plants and affect bacteria (Kumar et al., 2005). Disruption of human gut microbiota A human being contains more cells in and on the body that belong to microbes—and contain more microbial DNA—than those that originate from human genes. In fact, only 10% of human cells are genetically human, and only 1% of the DNA in the human is “human.” The 90% of human cells that are microbial in origin are not (mostly) pathogenic, nor are they (mostly) just along for the ride. They are (mostly) symbionts that help the body function as it should. The human body, rather than being a distinct organism, should be thought of as a biological community, or “superorganism,” truly the product of coevolution.

In addition to interfering with digestion, exposure to antibiotics can disturb the microbiota, contributing to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. The human immune system is largely composed of microbiota.

Help support organic agriculture, which eliminated the allowed use of antibiotics for fruit production due to concerns over resistance. Instead of “combatting” disease or unwanted insects, help policy makers identify the conditions that allow for their proliferation.

Take Action

Submit (and personalize) your comment to EPA to prohibit antibiotics in the food supply. You may use the general language below by cutting and pasting into the public comment page on this issue.

Post Your Comment by January 19:

Do not permit the use of antibiotics, including streptomycin, in citrus production. This creates a public health threat that EPA must consider in real terms, as it relates to longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. Antibiotic resistance is a real and urgent public health threat and represents an existential threat to modern civilization.  Antibiotic resistance kills over 23,000 people each year, according to the Centers for Disease Control and Prevention (CDC). In addition to the CDC, the World Health Organization has cited this escalating problem as one of the biggest public health challenges of our time.

“By 2050, resistance is estimated to add 10 million annual deaths globally with a cumulative cost to the world economy of US$100 trillion,” said Jack Heinemann, PhD, University Canterbury’s School of Biological Sciences.

 In addition to interfering with digestion, exposure to antibiotics can disturb the microbiota, contributing to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. The human immune system is largely composed of microbiota. Treating all these diseases have real costs that must be calculated when the agency allows exposure to a pesticide, in this case an antibiotic used for non-medical uses.

Consider the real cost to the American people and internationally and prohibit the use of streptomycin in citrus production by setting a tolerance or allowable residue of zero. Thank you for your consideration.

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

Source: Florida Phoenix, Center for Biological Diversity

(Beyond Pesticides, January 9, 2019) It is news to approximately no one that pollinators are in trouble worldwide. A series of papers by biologists at the University of Guelph, Ontario, posits that pesticide regulations aimed at protection of honey bees fall far short of the critical task of protecting the multitude of bee species that are important pollinators of human food crops. These recent papers arose from 2017 workshops that involved 40 bee researchers from various universities, and representatives from Canadian, U.S., and European regulatory agencies, and from the agrochemical industry.

Beset by shrinking habitat, pathogens, and toxic chemical exposures, bee pollinator populations are at great risk, even as “‘our dependency on insect-pollinated crops is increasing and will continue to do so as the global population rises,’ said [Professor Nigel] Raine, [PhD], [a] co-author of all three papers recently published in the journal Environmental Entomology. . . . Protecting wild pollinators is more important now than ever before. Honeybees alone simply cannot deliver the crop pollination services we need.” There are, in fact, more than 20,000 bee species worldwide, and 3,500–5,000 bee species in North America alone.

Although regulators across many countries have focused narrowly on assessing the risk of pesticides to honey bees, many of which are “managed” for commercial pollination services, Dr. Raine notes that wild bee species — including bumblebees, mason bees, solitary bees, and others — are likely more important for food crop pollination than managed honeybees, such as those used extensively in the American West. A significant portion of those wild species live in soils as larvae and/or adults. Exposure of those species through pesticide residues in soil or food sources is essentially unstudied by researchers. The University of Guelph biologists, in their papers, call for regulators to expand their purview regarding pollinator risks, perhaps by using solitary bees and bumblebees as models.

The abstract for the papers’ publication says, “Current pesticide risk assessment practices use the honey bee, Apis mellifera L., as a surrogate to characterize the likelihood of chemical exposure of a candidate pesticide for all bee species. Bees make up a diverse insect group that provides critical pollination services to both managed and wild ecosystems. Accordingly, they display a diversity of behaviors and vary greatly in their lifestyles and phenologies, such as their timing of emergence, degree of sociality, and foraging and nesting behaviors. Some of these factors may lead to disparate or variable routes of exposure when compared to honey bees.” Pesticide exposures for wild bees can happen through their food (nectar and pollen), via airborne molecules (from spraying or volatilized through abrasion of seed coatings), in nesting substrates (especially in soils, for ground-dwelling species), in water sources, via contact with contaminated plant foliage, and even through contact with residues in the wax they produce to protect their offspring.

Angela Gradish, PhD, lead author on one of the papers and a research associate in the University of Guelph School of Environmental Sciences, adds to the argument, saying, “Everybody is focused on honeybees. . . . What about these other bees? There are a lot of unknowns about how bumblebees are exposed to pesticides in agricultural environments.” She notes, for example, that the bumblebee queen life cycle, which differs from that of the honeybee queen, may increase those queens’ exposures to pesticides while they collect food and establish their colonies. Dr. Gradish notes, “That’s a critical difference because the loss of a single bumblebee queen translates into the loss of the colony that she would have produced. It’s one queen, but it’s a whole colony at risk.” Further, other non-honeybee species may vary in body size, food consumption rates, nesting habitats and substrates, overwintering strategies, and foraging times and behaviors, among other features.

The “crash” of pollinators is happening in a wider context of biological and biodiversity loss. The lack of attention to loss in insect populations broadly was identified in a dramatic November 18, 2018 New York Times article, “The Insect Apocalypse Is Here,” which called out the staggering attrition in insect populations during the last few decades. Here in the U.S., scientists discovered relatively recently that the population of monarch butterflies has fallen by 90% in the last 20 years, and that populations of the rusty-patched bumblebee (which used to be found in 28 states) dropped by 87% in the same period. Beyond Pesticides also noted the phenomenon in its coverage of a 2017 study by a German entomological society, which found a decline in total flying insect biomass in protected areas of the country of more than 75% over a 27-year period.

The New York Times piece also quoted North Carolina State University ecologist Rob Dunn, PhD, who searched for studies on the effects of pesticide spraying on insect populations living in nearby forests, only to find there were none: “We [have] ignored really basic questions. . . . It feels like we’ve dropped the ball in some giant collective way.” The New York Times also reported a shocking reality: “A 2013 paper in [the journal] Nature, which modeled both natural and computer-generated food webs, suggested that a loss of even 30 percent of a species’ abundance can be so destabilizing that other species start going fully, numerically extinct — in fact, 80 percent of the time it was a secondarily affected creature that was the first to disappear.”

These recent papers contribute to a growing body of work that points to inadequacies in regulation of (and research on) toxic pesticides, as regards their impacts on pollinators and on the insect universe. Not only are individual pesticides poorly evaluated at the federal level (see examples here and here), but also, there is wholly insufficient attention paid to the systemic and synergistic effects of toxic pesticides on ecosystems and organisms of all sorts. Beyond Pesticides wrote extensively, in the Summer 2018 issue of its journal, Pesticides and You, about an example of such systemic impacts — the ripples, up and down a food chain, that can happen when even one species in an ecosystem is harmed. Such a disturbance in functional ecosystem balance is often called a “trophic cascade”: a series of indirect ecosystem effects set off by a change in the status or abundance of a predator or prey organism. As The New York Times wrote, “One result of [insect] loss is what’s known as [a] trophic cascade, the unraveling of an ecosystem’s fabric as prey populations boom and crash and the various levels of the food web no longer keep each other in check. These places are emptier, impoverished in a thousand subtle ways.”

At this juncture, the multitude of studies that demonstrate the huge variety and complexity of harmful impacts of pesticide exposures to pollinators makes identifying the “most important” impacts — and how to protect pollinators from them — not only a Sisyphian task, but perhaps a bit beside the point. The many studies on which Beyond Pesticides has reported in its Daily News Blog, and in its databases (see Pesticide Induced Database, Gateway on Pesticide Hazards and Safe Pest Management, Eating with a Conscience database, and the Manage Safe database), demonstrate that pesticide exposures have consequences that amount to broad and indiscriminate poisoning of, and trophic effects on, organisms and the environment. The University of Guelph’s Professor Raine commented, “‘I hope we can address shortfalls in the pesticide regulatory process. . . . Given the great variability that we see in the behaviour, ecology and life history of over 20,000 species of bees in the world, there are some routes of pesticide exposure that are not adequately considered in risk assessments focusing only on honeybees.’”

Beyond Pesticides advocates for a rapid transition to organic management practices as key to protecting pollinators and the environment. Regulatory agencies should adopt this goal and legally prohibit the use of toxic synthetic pesticides, thereby establishing a systems approach that would protect environmental and organismic — pollinator, human, and all other — health. See the Beyond Pesticides website pages on its BEE Protective program for more information on pollinator health and how to advocate for it.

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

Source: https://www.eurekalert.org/pub_releases/2018-12/uog-spr121118.php

(Beyond Pesticides, January 8, 2019) At the end of December, the U.S. Department of Agriculture (USDA) finalized its rule regarding the disclosure of genetically engineered (GE) ingredients in consumer foods. After years of local, state and federal pressure to implement a clear, concise labeling requirement for GE foods, advocates say USDA’s rule is a failure, and a capitulation to agrichemical corporations that promote GE farming systems. According to U.S. Representative Chellie Pingree (D-ME), speaking with the Portland Press Herald, the new rule is “an insult to consumers.” She said, “These labels should give people the facts of whether ingredients in their food have been genetically altered, plain and simple.”

Rather than the plain and simple language urged by Rep Pingree and other GE labeling advocates, USDA determined to move forward with muddled verbiage that is certain to confuse consumers. GE products will not defined by a term Americans are familiar with, such as GE or GMO. Instead, the term USDA will require on product labels is “bioengineered.”

USDA is allowing companies to choose one of the following methods to alert consumers to the presence of GE ingredients in their foods:

• Inclusion of a “bioengineered” or “derived from bioengineering” symbol alongside a sunny plant and farm field. USDA decided not use the bioengineered symbols from its proposed rule, which mimicked a happy, smiling sun, but its new symbol is not a major improvement.
• Notification through a QR barcode. Despite widespread criticism that using a QR code will discriminate against the elderly and poor who may not have smartphones, the Department has provided that as an option.
• A phone number to text that will reply back with information. Many are concerned about the privacy aspect of this requirements, as this provision would require concerned consumers to disclose their private contact information to food companies.
• A simple statement that includes “Bioengineered Food,” or “Contains a Bioengineered Food Ingredient.”

Many advocates urged USDA to require only the last option, but under the final rule food companies are only required to choose one, making it easy to continue to hide GE ingredients from consumers.

Perhaps most concerning is how narrowly USDA decided to define foods subject to GE disclosure. For instance, if a food product has multiple ingredients, but the first product on the ingredient list is either meat, poultry, eggs, broth, stock or water, even if other ingredients in the product are GE, USDA will not require GE disclosure. Further, food products containing “refined” GE ingredients (such as oil from GE soybeans, or candy bars with high fructose corn syrup from GE corn) will not require disclosure as long as the refining process is “validated” by USDA.

Taken as a whole, many advocates are uncertain that consumers are now better off than before the weak and controversial bill was signed into law by President Obama in 2016.

Fearing consumer backlash, even large food companies are speaking out against the final rule. Sustainable Food Policy Alliance, which includes Danone, Mars, Nestle, and Unilever, wrote in a statement “The standards fall short of consumer expectations, and the practices of leading food companies, particularly when it comes to how we are already disclosing highly-refined ingredients and the threshold for disclosure.” While big food retailers are upset, organizations such as the American Farm Bureau Federation, which represents the companies that develop and produce GE crops, were pleased with the final version of the rules.

The passage of mandatory GE labeling came prior to the implementation of Vermont’s landmark legislation, after it survived a court challenge from many of the industrial food companies now opposed to USDA’s requirements. Senators Stabenow (D-MI) and Pat Roberts (R-KS) struck a deal that ultimately resulted in these predictably weak, anti-consumer provisions.

Beyond Pesticides and many other advocates for GE labeling are primarily concerned about the health impacts of consuming products awash in pesticide residue, and believe consumers have a right to avoid products produced as part of a highly toxic GE agriculture system. Herbicide-tolerant GE crops have been associated with massive increases in herbicide use and the rampant takeover of U.S. farms by weeds which, through incessant herbicide spray, have themselves developed genes to resist herbicide effects. Glyphosate, the most common herbicide developed to be sprayed on GE plants, has decreased in effectiveness. Now, chemical companies are using older herbicides like 2,4-D and dicamba that rival glyphosate’s toxicity. Chemical companies have also incorporated insecticides into the crop itself, with evidence that resistance in target pests is trending synthetic insecticide use upwards.

The fact remains that the sort of techno-utopia of plant drought and disease resistance, increased vitamin content, and the like promised by agrichemical companies that develop GE crops has never been widely commercialized. Critics maintain that the main goal of GE crops is not to solve real agricultural problems, but instead to increase sales of seeds and pesticides, and companies’ profits and stock prices. Why else would they want to keep consumers in the dark?

For more information on the health and environmental impacts of herbicide tolerant and insecticide incorporated GE agriculture, see Beyond Pesticides GE program pages.

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

Source: USDA Press Release, Federal Register, Portland Press Herald, QZ

(Beyond Pesticides, January 7, 2019) As the dust settles on the final Farm Bill, which passed the U.S. Senate and House of Representatives last month, it is clear that neither the substance nor the process on a range of issues meet the urgent need to address key sustainability issues that put the future in peril.

We must not allow this Farm Bill to be the final word on a number of critical environmental issues facing the nation and world. That is why it is absolutely critical that we get to work immediately, with the new Congress, to set a new course that transforms the institutions of government that are holding back the urgently needed transition to a green economy.

Tell your Senators and Representative to support a Green New Deal that restructures food and agriculture programs.

On the Farm Bill, our victories were mostly measured in terms of what we were able to remove from the Farm Bill—not the standard of achievement that we need to face critical environmental threats.

 The good. Our major victory in the Farm Bill does not move us forward, but simply protects the status quo of our democracy—protecting the power of states and local government to adopt pesticide restrictions that are more stringent than the federal government. With your help and the help of a broad network of local officials nationwide, we were able to stop a preemption provision from being inserted in the federal pesticide law. Although the victory was in defeating this provision, the chemical industry has awakened a new front in the pesticide reform movement. As a result of this provision, there is new momentum to reassert the rights of local governments and repeal state-level preemption of municipalities. Other environmental setbacks to the Endangered Species Act, Clean Water Act, and farmworker protection were taken out of the final bill. So, thank you to all who participated in this important process.

The bad. We were unable to remove an amendment to organic law that introduces confusion on the mandate to sunset all synthetics used in organic agricultural production and processing, forcing the National Organic Standards Board (NOSB) and USDA to reassess the science and necessity of these inputs with the most rigorous scrutiny by requiring a super-majority vote of the board every five years to allow continued use of these synthetics—the same standard used when synthetics are initially petitioned. The growth of organic is essential to solving our key environmental challenges, from the dramatic decline in biodiversity to global climate change. Nothing should be done to undercut the integrity of the organic standard setting process. Additionally, new language in the organic law allows farmer, handler, and retailer positions on the NOSB to be filled by employees of farmers, handlers, and retailers, making the decision making process less robust.

The ugly. The Farm Bill sets policy on food and farm issues for the next five years and should not be the result of backroom negotiations in Congress, as it was this round. Important and controversial issues deserve public hearings in which all members of Congress and the public can participate, and all perspectives can be heard.

More on organic. There were some “wins” for organic in continued funding for programs important to organic production and research, and necessary improvements to oversight and enforcement of organic imports.

New leadership. Increasing support is being shown for a proposal by U.S. Representative-Elect Alexandria Ocasio-Cortez of New York to form a House Select Committee for a Green New Deal that addresses economic and environmental reforms while ensuring a functioning democracy. A Green New Deal  provides a framework for supporting agriculture that helps farmers, consumers, and the environment by advancing organic agriculture. In the words of commentator and former Texas Agriculture Commissioner Jim Hightower, “Everybody does better when everybody does better.” We need new food and farm policy that benefits all farmers and consumers.

Tell your Senators and Representative to support a Green New Deal that restructures food and agriculture programs.

Letter to U.S. Representatives, including newly-elected members:

I am writing to urge you to support the proposal by U.S. Representative Alexandria Ocasio-Cortez of New York to form a House Select Committee for a Green New Deal that addresses economic and environmental reforms while ensuring a functioning democracy. A Green New Deal provides a framework for supporting agriculture that helps farmers, consumers, and the environment. In the words of commentator and former Texas Agriculture Commissioner Jim Hightower, “Everybody does better when everybody does better.” We need new food and farm policy that benefits all farmers and consumers.

In the wake of a disappointing Farm Bill vote, following an even more disappointing undemocratic process, it is evident that the process of creating food and farm policy every five years in the backrooms of Congressional agriculture committees fails to move the country forward in a way that is needed for farmers, farm communities, the national economy, and the environment. Food and agriculture policy needs to be guided by a vision for the future where everybody does better–where policies are not viewed in terms of trade-offs, but synergy benefiting all.

Please support the formation of a House Select Committee for a Green New Deal.

Thank you.

Sincerely,

Letter to U.S. Senators:

I am writing to urge you to support hearings in the Senate on a Green New Deal that addresses economic and environmental reforms while ensuring a functioning democracy. A Green New Deal provides a framework for supporting agriculture that helps farmers, consumers, and the environment. In the words of commentator and former Texas Agriculture Commissioner Jim Hightower, “Everybody does better when everybody does better.” We need new food and farm policy that benefits all farmers and consumers.

In the wake of a disappointing Farm Bill vote, following an even more disappointing undemocratic process, it is evident that the process of creating food and farm policy every five years in the backrooms of Congressional agriculture committees fails to move the country forward in a way that is needed for farmers, farm communities, the national economy, and the environment. Food and agriculture policy needs to be guided by a vision for the future where everybody does better–where policies are not viewed in terms of trade-offs, but synergy benefiting all.

Please support hearings on a Green New Deal.

Thank you.

Sincerely,