(Beyond Pesticides, May 8-9, 2024) In its proposal on mushrooms and pet food, the U.S. Department of Agriculture’s (USDA) National Organic Program is following up on recommendations of the National Organic Standards Board (NOSB) to ensure that two areas of organic production are clarified and in compliance with the Organic Foods Production Act (OFPA). The notice raises questions of standards that ultimately grow the organic market while ensuring that the USDA organic label is backed by standards that have integrity and garner the public’s trust. In this spirit, Beyond Pesticides participates in the NOSB review/recommendation process and USDA rulemaking through public comments. [Note: Beyond Pesticides has served on the NOSB for a five-year term (2010-2015) and urges other environmental organization representatives to consider self-nominating for service on the board.] The issues relating to clear standards for mushrooms and pet food have been before the NOSB and in discussion for some time as a part of ongoing efforts to ensure continuous improvement of standards governing the organic sector.

While virtually all in the organic community and industry agree that the USDA proposals are needed and long overdue, Beyond Pesticides points to problems in the proposed rule that need correcting: (i) Re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) Re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources.

>>Tell USDA to ensure that certified organic fungi and pet food are truly organic. 

In the context of upholding organic integrity and growing the market, Beyond Pesticides offers a perspective that it believes strengthens the value of protecting health and environment through a holistic systems approach to food production and processing—applying the principles and practices to all land management. This contrasts with chemical-intensive farming and land management with its reliance on petrochemical pesticides and fertilizers that contribute to the current existential health, biodiversity, and climate crises.

Mushrooms

Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised of carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards as well. Fungi deserve, and need, their own scope of standards that recognizes their unique biology and fosters consistency in their cultivation and certification.

Additionally, there are already some organic fungal products in the marketplace that are not mushrooms, such as drink powders made from lion’s mane mycelium as well as the fruiting body and mycelium extract dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling but would fit better under a separate fungi scope.

According to the 2021 National Agricultural Statistics Service Organic Survey, commercial organic mushroom production increased from 17 million pounds in the 2010/2011 marketing year to 114 million pounds in the 2022/2023 growing season. In other words, organic mushrooms made up just 2% of total retail market in 2009 and in 2021 rose to 11% of the total market share. This trend is consistent with the 5% increase in total certified organic farms across the United States within the same time period. Not to mention the 13% increase in certified organic commodities in 2021 relative to 2019 numbers, according to the 2021 Organic Survey. Consumers want access to organic food, and to cultivate a robust market tailored regulations must be developed for mushrooms as they defy certain characteristics of other commodities.

Beyond Pesticides makes the following comments: Framing new production standards to include only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for future innovative products to become certified. Conversely, framing new production standards to include all fungi would not only provide a better fit for current organic fungal products but provide ample room for additional markets to develop.

In 2001, the NOSB recommended that organic mushrooms must be grown on organic substrate. This position is based on the fact that fungi are composed of digested substrate and, as a result, the board said that only mushrooms grown on organic substrate—manure derived from organic sources or untreated wood that is grown without prohibited substances—can validly claim the organic seal.

Pet Food

The pet food rule is an effort to bring pet food production and materials standards in line with organic livestock standards, and adding an allowed synthetic amino acid, taurine, to the National List of Allowed and Prohibited Substances. Some pet food manufacturers maintain that the amino acid is necessary to fulfil a macronutrient requirement for cats generally and for dogs during specific periods of their lives.

While Beyond Pesticides supports bringing organic pet food production into conformance with livestock standards when incorporating meat into its products, it disagrees with the NOSB recommendation and USDA’s proposal to allow the use of synthetic taurine for all pet food. Beyond Pesticides maintains that the allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the OPFA, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by a manufacturer, it is difficult to argue that the substance is not available in its natural form. As Nature’s Logic® states on its website:

“Since our foods are made from high levels of animal protein, all Nature’s Logic diets naturally contain sufficient levels of the Omega-3 fatty acids, eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA). They also exceed AAFCO*’s protein amino acid requirements for arginine, histidine, isoleucine leucine, lysine, methionine-cystine, methionine, phenylalanine-tyrosine, phylalanine, taurine, threonine, tryptophan, and valine.”

Therefore, Beyond Pesticides is urging USDA to reject the recommendation to add taurine to the National List for pet food. Note that synthetic taurine has been petitioned and rejected for allowance in baby formula.

Take Action Today! >> Tell USDA to ensure that organic fungi and pet food are truly organic.

Proposed comment to USDA

USDA’s proposed regulations for organic certification of mushrooms and pet food are needed and long overdue, but there are problems that need correcting: (i) Re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) Re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources.

Mushrooms. Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised of carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards. They require their own scope of standards, recognizing their unique biology, which fosters consistency in their cultivation and certification.

There are already organic fungal products in the marketplace that are not mushrooms, but made from mycelium, such as drink powders and dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling, but would fit better under a separate fungi scope. New production standards including only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for innovative products to become certified. Framing new production standards to include all fungi would not only provide a better fit for current organic fungal products, but provide ample room for additional markets to develop.

In 2001, the NOSB recommended that organic mushrooms must be grown on organic substrate. Since fungi are composed of digested substrate, only mushrooms grown on organic substrate—manure derived from organic sources or untreated wood that is grown without prohibited substances—can validly claim the organic seal.

Please modify the proposed mushroom standard to: 1) give fungi—not mushrooms—a separate scope; 2) cover all fungi forms; and 3) require that certified organic fungi be grown on organic substrate.

Pet Food: The pet food rule attempts to bring pet food production and materials standards in line with organic standards. It also adds an allowed synthetic amino acid, taurine, to the National List of Allowed and Prohibited Substances. Some pet food manufacturers maintain that the amino acid is necessary to fulfill a macronutrient requirement for cats and dogs.

I support bringing organic pet food production into conformance with organic standards and incorporating meat into its products. However, I disagree with USDA’s proposal to allow the use of synthetic taurine for all pet food. The allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the Organic Foods Production Act, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by at least one manufacturer—Nature’s Logic®—it is difficult to argue that the substance is not available in its natural form. The original recommendation to add taurine for pet food was made in 2008, and it should be revisited by the NOSB before adding it into the regulations.

I urge USDA to reject the recommendation to add taurine to the National List for pet food.

Thank you.

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

Source: USDA, Agricultural Marketing Service, 7 CFR Part 205 [Doc. No. AMS–NOP–22–0063] RIN 0581–AE13 National Organic Program; Market Development for Mushrooms and Pet Food, Federal Register, March 11, 2024, pp17322-17338.

(Beyond Pesticides, May 8, 2024) In an unexpected turnaround, the U.S. Environmental Protection Agency (EPA) announced at the end of April a Proposed Interim Decision (PID) to discontinue all but one application of the insecticide acephate. Acephate is an organophosphate pesticide, a well-known neurotoxicant, widely banned globally, including in the European Union. Under the proposal, all uses would end except for the injection of trees that do not produce fruit or nuts. In its proposed action, EPA asks the manufacturer to offer the agency a voluntary settlement, a process that typically compromises the health of the public, workers, and the environment.

Acephate, an organophosphate (OP) pesticide, is approved for use in both agricultural settings, including crops like cotton and soybeans, and nonagricultural applications, such as injections for forestry trees. Acephate affects the nervous system by inhibiting the acetylcholinesterase (AChE) enzyme. Importantly, chronic, low levels of exposure can cause a range of adverse human health outcomes, from cancer to birth defects, reproductive and developmental problems, and learning disabilities.

While the proposed April interim decision, if it comes to pass, is welcomed by advocates, some are concerned that EPA’s proposal does not fully critique the scientific documents and conclusions on risk that it had previously published in August 2023. The earlier proposal was highly controversial because the assessment, and a proposed downgrading of risk and loosening of standards, relied on still controversial testing methods that did not consider laboratory animal testing.

On August 30, 2023, the agency published the following, relying on a revised acephate human health draft risk assessment (HH DRA) which would have allowed ten times more acephate on food than the currently allowed limits:

“Taking the WOE [weight of evidence] evaluation for DNT [developmental neurotoxicity] potential into account, although acephate and methamidophos are known neurotoxicants (i.e., chemicals that disrupt normal activity of the nervous system), there is little to no evidence that acephate or methamidophos are developmental neurotoxicants (i.e., chemicals that impact the normal development of the nervous system during pregnancy or childhood). Therefore, there is no additional risk when exposures of acephate or methamidophos occur to pregnant women or children. Changes in acetylcholinesterase (which causes a neurotoxic effect, not a developmental neurotoxic effect) continues to be the most sensitive and health-protective endpoint for the acephate human health risk assessment. As a result, EPA concluded there is reliable chemical-specific data to support reducing the acephate FQPA [Food Quality Protection Act] factor to 1x [no additional margin of safety for children provided for under FQPA].”

EPA explains the FQPA safety factor as follows: “[T]he Food Quality Protection Act safety factor (FQPA SF) . . . is intended to provide an additional 10X margin of safety to account for any additional risk to pregnant women and children, but which can be reduced or removed if a scientific determination is made that no such additional risk exists.

Then on April 30, 2024, EPA reversed itself with the following announcement:

“Today, the U.S. Environmental Protection Agency (EPA) released a revised human health draft risk assessment (HH DRA) and refined drinking water assessment (DWA) for acephate, an organophosphate pesticide (OP) that is registered for both agricultural and non-agricultural uses. The acephate HH DRA includes an assessment of methamidophos, which is also an OP compound that is formed when acephate is metabolized. The revised HH DRA showed significant dietary risks of concern from drinking water for registered uses of acephate, including non-agricultural uses. EPA also identified dietary risks of concern when only the two highest agricultural usage sites (measured by pounds sold), cotton and soybean, are considered.”

Where the agency will end up with these competing analyses remains to be seen; however, it is clear that the methodologies used to reach these decisions raise important scientific questions about the choices affecting the health of children and the general public who are eating acephate residues in their food and water.

Before making a decision, EPA will take comments under a 60-day comment period and presumably sort out the science and exposure patterns. According to the agency, “Acephate is proceeding through EPA’s standard registration review process. The revised HH DRA and DWA released in August 2023 and the PID released today are open for public comment for 60 days. Commenters may propose alternative mitigation for the Agency’s consideration for some or all uses of acephate, and the Agency will respond to these comments in the Interim Decision.”

Compromising the Public’s Health with Industry Negotiations?

Here is where the negotiations with the chemical manufacturer begin. Regulation by negotiation is EPA preferred approach to protecting the public. In its release, the agency explains its modus operandi: “If EPA determines that alternative mitigation options that are voluntarily agreed to by the registrant can address the identified risks to satisfy the standard for continued registration of the pesticide, this could allow EPA to put protections in place faster than the statutorily required process for involuntary cancellation that can take up to five years. Acephate is one of 18 OPs currently in registration review, with many scheduled to have interim decisions between 2024-2026.”

“While we believe that the accepted science supports acephate’s immediate removal from the market to protect developing fetuses and children, if past is prologue, EPA will allow itself to be whipsawed by the negotiation process, rather than enforce the intent and letter of the law,” said Jay Feldman, executive director of Beyond Pesticides. He continued, “We certainly urge that the agency follow the law—not negotiate away the public’s health and not capitulate to industry threats of litigation.”

Advocates and scientists have raised concerns about the underlying scientific approach used by the agency in its August announcement, which remains undisputed in its proposed interim decision last week. EPA’s history of negotiating away public health runs deep. With acephate, it appears that EPA will continue its pattern of negotiating with pesticide manufacturers and industry to elicit voluntary use restrictions, rather than cancel, suspend, or decline to reregister a pesticide without manufacturer concurrence.

While there are many examples of negotiated EPA decisions, the highly neurotoxic, carbamate insecticide aldicarb stands out as an example of this highly criticized EPA process. Behind closed doors in 2010, EPA and the chemical’s manufacturer, Bayer CropScience, announced an agreement on a set of measures to gradually reduce and ultimately ban fully the use of the insecticide in the U.S. This decision arrived on the heels of a revised risk assessment in which EPA found that babies and children under the age of five can ingest levels of the insecticide through food and drinking water at levels that exceed limits that the agency finds safe. As readers will recall, the intermediate ingredient in aldicarb, methyl isocyanate (MIC), caused an explosion in Bhopal, India, killing up to 20,000 people. Then, in December 2023, it was reported that EPA is again considering allowing the use of aldicarb in Florida citrus, nearly 14 years after the agency and the chemical’s manufacturer announced that it was being banned (technically voluntarily canceled). Please see more on this and Beyond Pesticides’ related Action here.

Acephate Use

Progressive Farmer reported on April 30, 2024, “In an assessment…by the EPA Biological & Economic Analysis Division… the insecticide [acephate] is used on soybeans almost exclusively in the Midsouth states of Arkansas, Louisiana, Mississippi and Texas. It is a minor component of insect pest management programs nationally, being applied to less than 2% of acres, but acephate is applied to 19% of soybeans within the Midsouth [states of Arkansas, Louisiana, Mississippi, and Texas].” 

A Brookings article by Nathan Donley, PhD and Environmental Health Science Director for the Center for Biological Diversity in September 2022 notes that over 4,370,000 pounds of acephate are used annually in the U.S., while banned or being phased out in the European Union, Brazil, and India. Dr. Donley notes that the U.S. is unable to implement rational regulation of pesticides, as other parts of the world continue to eliminate agricultural use of many of the most toxic pesticides. For example, in 2019 the U.S. used 322 million pounds of 70 agricultural pesticides that are banned in the European Union. Similarly, the U.S. uses 40 million pounds of pesticides banned or phased out in Brazil.

New Methodology Tests (NAMs)

EPA’s review of acephate (and the insecticide malathion) is notable as it marks two initial instances where the agency has proposed adjusting its legal safety limits primarily based on non-animal tests to assess the chemical’s effects on brain development through reevaluation of the Food Quality Protection Act safety factor. However, in announcing the PID last month, EPA identified risks to workers, homeowners, and ecosystems from currently approved uses of acephate in drinking water as justification for ending acephate use, except as a tree injection.

Regarding the August 30 risk calculations conducted by EPA, the agency developed new tests, known as “new approach methodologies” or NAMs, with the Organization for Economic Cooperation and Development, which presented its initial recommendations in 2023. Those findings stressed the need for additional information and follow-up studies as the nervous system is “arguably the most complicated organ in the body” and “involves integration of intracellular, intercellular, interregional, and system interactions.”  (page 45).

The 2016 amendments to the Toxic Substances Control Act (TSCA) mandate EPA to promote the adoption of scientifically valid testing methods and strategies that minimize or eliminate the need for testing on vertebrate animals. Developing “new approach methodologies” (NAMs) is intended to aid in establishing exposure limits, health advisories, and cleanup policies for harmful chemicals found in various environments and consumer products. However, the effectiveness of these cell-based methods hinges on their ability to provide scientific data of equivalent or superior quality and relevance compared to traditional animal testing methods. Despite their potential, the majority of NAMs have not undergone thorough validation for assessing critical health effects, apart from a few acute toxicity measurements. Consequently, advocates argue these ‘new approach methodologies’ have yet to fulfill the TSCA criteria for replacing or reducing reliance on animal studies in regulatory decision-making.

EPA’s own scientific advisory panels have found this methodology inadequate, specifically for properly assessing the cumulative impacts of pesticides on human health and development. The Children’s Health Protection Advisory Committee, a body of external researchers and community leaders who advise EPA, recommended that EPA limit the use of data from this methodology and use it only in conjunction with other data. In addition, California’s Department of Pesticide Regulation said the tests were inadequate to support “health-protective decisions” and urged EPA to continue developing this methodology before using it to replace traditional animal studies. Lastly, OECD warned against using the tests to conclude a chemical does not interfere with the brain’s development.

Acephate and malathion are two of the 18 organophosphates currently under review by EPA, with expected interim decisions in 2024-2026. Scientific agreement has long held that children are especially vulnerable to the dangers posed by pesticides, leading the EPA to implement stricter regulations. However, the agency is currently suggesting the elimination of these additional protections for acephate and malathion, based on results from ‘new approach methodologies’ (NAM) tests.

Acephate is in the same chemical class as the well-known neurotoxic chlorpyrifos. These insecticides inhibit proper nerve functioning, leading to paralysis and death in exposed insects; a large enough dose will cause similarly acute effects in humans. Importantly, chronic, low levels of exposure can cause a range of adverse human health outcomes, from cancer to birth defects, and reproductive and developmental problems. Researchers often look at exposures in the womb or at a young age because these are considered ‘critical windows of vulnerability’ during which even small amounts of a pesticide can create long-term damage.

Chemicals like acephate, with the capacity to disrupt the endocrine (hormonal) system by mimicking hormones in the body, are particularly pernicious. In the case of endocrine disruptors, science shows that lower amounts can result in worse health impacts than exposure to higher amounts, a phenomenon known as ‘non-monotonic dose response.’ The scientific literature on these chemicals has upended traditional toxicology, which goes by the oft-repeated phrase, ‘the dose makes the poison.’ Endocrine disruptors reveal this mode of thinking to be outdated, and dangerous to ignore.

EPA Flawed Approach to Cumulative Impact Risk Assessment

The use of such tests is in direct opposition to several executive orders by President Biden requiring EPA to develop policies and actions to assess the cumulative impacts of chemical exposures. Last year, the EPA’s Office of the Inspector General (OIG) released a report concluding that EPA “took a siloed approach” to the cumulative impacts of chemical exposures and the disproportionate nature of those exposures. This approach keeps different parts of the EPA from coordinating their efforts and hinders understanding of the breadth and depth of chemical exposures.

Pesticides are almost always mixtures of “active” and “inert” ingredients. As Beyond Pesticides reported previously, a 2021 study by Robert Sprinkle, MD, PhD, and Devon Payne-Sturges, DrPH, in Environmental Health, took a comprehensive look at EPA’s practices regarding mixtures. The authors write that in the original 1976 Toxic Substances Control Act, mixtures were excluded from the agency’s definition of a “chemical substance.” What this means in practice is that “[a]n environmental mixture could not be, in TSCA terms, a ‘mixture’ if its components include chemical substances altered in the environment. Nor could the still toxic breakdown products of two different industrial substances constitute a mixture.” There is an exception: if EPA finds that if a mixture’s effects could not be predicted by each constituent’s effects, laboratory testing would be required. This means that the agency could view each component of a mixture as “acting in isolation both from nature and from each other.”

What Will EPA Do to restrict acephate?

As Beyond Pesticides and Public Employees for Environmental Responsibility (PEER) wrote in a 2021 critique, EPA is an agency so captured by industry that it has lost sight of its health and environmental mission. EPA’s Office of Pesticide Programs (OPP) has registered more than 18,000 separate pesticide products—far more than any other country—and approximately 2 billion pounds (including wood preservatives) of pesticides are sold annually in the U.S. They are used annually over roughly 250 million acres of farmland, across millions of acres of urban and suburban lands, and inside millions of homes, schools, and other buildings. Yet, the letter recounts a litany of improper pesticide approval decisions. The cumulative effects of decades of this regulatory abuse are untold human deaths, disabilities, and illnesses. Mr. Feldman said, “We call on the Biden Administration to be a hero for health—the fastest thing it can do is immediately revoke the worst pesticides,” pointing to the 25 specific steps the coalition identifies that OPP can take to avoid or mitigate its mistakes in moving forward, all within its current authority. “Horror stories have piled up for too long and Americans no longer are safe from the very agency charged with protecting them.”

Beyond Pesticides urges a systemic move toward the adoption of proven agricultural methods and systems that do not use acephate, malathion, and other toxic synthetic pesticides: organic and certified organic regenerative agriculture.  Beyond Pesticides and other advocates call for a strategy that eliminates agricultural chemicals and supports organic agriculture. These measures also address other crises, including microbial support for ecosystem health and biodiversity. Industrial farming systems dependent on synthetic fertilizers and other chemical inputs can be replaced with organic systems that do not use toxic chemicals, in which animals and feed sources are fully integrated, and farmworkers’ health is protected.

To stay informed and raise your voice on this and other pesticide regulatory decisions, click here for updates from Beyond Pesticides.

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

Sources:

EPA Proposes to Cancel All but One Use of Pesticide Acephate to Protect Human Health, EPA announcement, April 30, 2024
EPA Proposes Ban on Controversial Pesticide Acephate, ProPublica, May 1, 2024
EPA Proposes Relaxed Limits on Acephate, a Toxic Pesticide, ProPublica, April 24, 2024
EPA Publishes Updated Risk Assessments for Chemical Acephate, EPA announcement, August 30, 2023
Acephate: Second Revised Draft Human Health Risk Assessment (DRA) in Support of Registration Review, EPA website, August 29, 2023
Approach for Evaluating Developmental Neurotoxicity Potential for the Organophosphate Pesticides, EPA website, August 29, 2023
Evaluation of the Developmental Neurotoxicity Potential of Acephate/Methamidophos to Inform the FQPA Safety Factor, EPA website, August 29, 2023

Initial Recommendations on Evaluation of Data from the Developmental Neurotoxicity (DNT) In-Vitro Testing Battery, OECD Environment, Health and Safety Publications Series on Testing & Assessment No. 377, Organisation for Economic Co-operation and Development, November 3, 2023

(Beyond Pesticides, May 7, 2024) The marginal user costs (MUC) of pesticide resistance for chemical-intensive farmers and the pest management industry are significantly affected by pesticide costs, density dependence (growth rate of a pest population impacted by its density), and dominant genetic mutations that cause resistance, according to a novel study published in Journal of the Agricultural and Applied Economics Association. Although the authors believe that integrated pest management (IPM) can be fine-tuned based on these findings, many advocates believe that these findings in fact underscore the importance of eliminating toxic pesticide use amidst compounding climate, biodiversity, and public health crises—which many IPM strategies do not adequately address.

As the costs of petrochemical-based pesticides increase, organisms identified as pests continue to increase in population density as global and regional temperatures dually increase. Organic agriculture, and organic land management principles more broadly, are an economically and ecologically advantageous leap ahead in transitioning to a food system that moves beyond the status quo that poisons people and the planet.

“This paper seeks to develop a better understanding of how the user costs of resistance are potentially determined by the interactions of heterogeneous bioeconomic factors that vary by context,” say the study authors. “We provide the first systematic numerical analysis of model-based user costs of pesticide susceptibility, that is, the price of resistance, and their variation across different bioeconomic contexts.” This study builds on an existing model focused on measuring Bacillus thuringiensis (Bt) species of bacteria in European corn borer. In this most recent study’s methodology, the authors expand the existing model through the implementation of stochastic dynamic programming and sensitivity analysis. Stochastic dynamic programming allows for the inclusion of unexpected variables such as weather fluctuations and the opportunity to “examine…user costs not just as calendar-based schedules…but in terms of how these quantities depend on the current state of pest population and resistance.” Meanwhile, authors indicate that sensitivity assessment is important because the findings can be “more broadly relevant for the economics of resistance management in general” rather than in just specific geographies or specific combinations of pesticides and crops.

“We adopt a two-state, discrete-time model of resistance to a single crop and single pesticide, in which resistance is generated from a single gene mutation R relative to the original wild-type gene S that left the pest susceptible to the pesticide,” according to further reporting by the authors on their methodology. “In our model, we define the net MUCs of resistance as the net adjustment factor to the marginal cost of the pesticide that would induce a self-interested farmer ignoring pest population dynamics and evolution to make a decision in the collective interest of farmers as a whole (see detailed rationale for this definition in Supporting Information).” Net MUCs of resistance is an important measurement to consider given the compounding factors (economic, socio-cultural, and philosophical) that impact the adoption of pesticide use by agricultural communities within and outside the United States. IPM claims a pesticide reduction strategy, meaning product substitution rather than the approach of organic land management principles that serves as a transformative alternative to rethink systems in alignment with the health of soil, water, ecosystems, wildlife, and humans.

Pest resistance to pesticides manifests for various pests and pesticides as documented over the years through numerous studies in the scientific literature. For example, a 2023 study published in Pest Management Science finds resistance to insecticides, like pyrethroids, is jeopardizing attempts to control the mosquito Aedes aegypti, the primary vector of dengue fever. Prevention of disease outbreaks is threatened by pesticide reliance to which pathogens and their vectors develop resistance.

A 2022 study published in Scientific Reports documents wholesale toxic pesticide use (deltamethrin, permethrin, lambda-cyhalothrin, propoxur, and malathion) for mosquito control, allowing genetic mutations to persist among mosquito populations and causing subsequent resistance to future exposure. In this study, two common species of female mosquitoes (Aedes aegypti and Culex quinquefasciastus) learned to evade pesticides following non-fatal exposure through smell. More concerning is the survival rate of these pre-exposed mosquitoes, as it is more than double that of unexposed mosquitoes. A 2021 study in Journal of Medical Entomology determined black-legged ticks (Ixodes scapulari) in the state of New York are developing potential resistance to the pyrethroid insecticide, permethrin. Regarding the resilience of cockroaches, a 2019 study in Scientific Reports found that many develop cross-resistance to insecticides to which they have never been directly exposed; additionally, pre-treatment application of synthetic pyrethroids revealed an 80% survival rate of these pesky insects. See more on pesticide resistance in the Daily News.

Antibiotic resistance is a compounding implication of relying on toxic chemical inputs in agriculture and broader land management strategies. Agricultural and veterinary uses of antibiotics significantly contribute to the resistance of certain bacteria or fungi to antibiotics that have historically knocked down such infections in humans, as mentioned in a 2017 Pesticides and You article written by Terry Shistar, Ph.D and Carla Curle, “Agricultural Uses of Antibiotics Escalate Bacterial Resistance.“ The authors note, “In addition to the promotion of weed resistance by widespread application of glyphosate and use of glyphosate-resistant genes in agriculture, there is evidence that glyphosate at environmentally relevant levels increases bacterial resistance to antibiotics important in fighting human pathogens and bacterial infections.” There are alternative models being developed in real time. For example, after successful challenges in federal court regarding synthetic antibiotic use for citrus orchards, the conventional citrus industry has been under pressure to find alternative strategies to lure pest insects such as the Asian citrus psyllid (citrus greening) away from trees through an agroecological method called “push-pull” pest management. See more on antibiotic resistance in the Daily News.

Beyond Pesticides collaborates with scientists, advocates, physicians, and local communities to pressure elected officials and regulators to reimagine pesticide regulation through a holistic, systematic approach. Through advocacy with frontline communities, farmers, farmworkers, immunocompromised individuals, and people of color, we enable advocates who believe that organic land management principles are a critical approach to eliminating toxic pesticide exposure to loved ones. See Keeping Organic Strong to see our proposed changes and opportunities to engage in strengthening federal organic standards and policy. See Eating With A Conscience to learn which pesticides are sprayed on conventionally grown fruits and vegetables to better inform your next grocery store run. See Mosquito Management and Insect-Borne Diseases to learn about the ineffectiveness of pesticide spraying and alternatives for ecologically based management strategies. See Action of the Week Archive to see how to stay engaged and get involved in advocacy each week.

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

Source: Journal of the Agricultural and Applied Economics Association

(Beyond Pesticides, May 6, 2024) The pattern of failure to protect the public from pesticides is again brought to public attention by an analysis by Consumer Reports (CR) that effectively updates its previous report released in 2020. The report and its earlier iteration identify deep structural weaknesses with the institutions charged with protecting the public’s health and safety. The health risks outlined by CR in 2020 and related to ongoing pesticide exposure, even at low levels, include cardiovascular diseases, cancers, reproductive dysfunction, respiratory problems (e.g., asthma, bronchitis), neurological impacts (e.g., developmental effects and dementia/Alzheimer’s), and endocrine dysfunction, among others. Previously, the magazine reported, “CR’s experts say the government hasn’t upheld its responsibility to protect consumers [and that] the research used to set [pesticide residue] tolerances is imperfect, and they’re often too high.” CR has cited the U.S. Environmental Protection Agency (EPA), which is primarily responsible for pesticide regulation, for multiple inadequacies.

According to the latest CR analysis, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. CR’s results are based on Consumer Reports-adjusted reference doses for all pesticides, including those linked to endocrine disruption, as mandated by the Food Quality Protect Act (FQPA) of 1996. As a result, CR is petitioning EPA to cancel the registrations of organophosphate (OP) and carbamate pesticides. 

⬇️ To sign on and support Consumer Report’s petition, please make sure to click the check box at the bottom of the form linked below!

>> Support Consumer Report’s petition and tell EPA / Congress to ban all toxic pesticides when the crop can be produced organically.

EPA’s failure to consider endocrine disruption is only one of many problems with relying on the agency’s tolerances as an indication of acceptable risk of pesticide use. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife. 

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

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

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

>> Support Consumer Report’s petition and tell EPA / Congress to ban all toxic pesticides when the crop can be produced organically.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress, with an option to support Consumer Report’s petition.

Letter to the EPA Administrator Michael Regan

According to a new analysis by Consumer Reports (CR), the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. CR’s results are based on including endocrine disruption, as mandated by the Food Quality Protect Act (FQPA) of 1996. As a result, CR is petitioning EPA to cancel the registrations of organophosphate (OP) and carbamate pesticides. I support CR’s petition and request that EPA further evaluate pesticides compared to the organic production of crops.

EPA’s failure to consider endocrine disruption is only one of many problems with relying on the agency’s tolerances as an indication of acceptable risk of pesticide use. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife.

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

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

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

Thank you.

Letter to the U.S. Congress

According to a new analysis by Consumer Reports (CR), the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. CR’s results are based on including endocrine disruption, as mandated by the Food Quality Protect Act (FQPA) of 1996. As a result, CR is petitioning EPA to cancel the registrations of organophosphate (OP) and carbamate pesticides. I support CR’s petition and request that EPA further evaluate pesticides compared to the organic production of crops.

EPA’s failure to consider endocrine disruption is only one of many problems with relying on the agency’s tolerances as an indication of acceptable risk of pesticide use. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife.

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

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

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

Thank you.

(Beyond Pesticides, May 3, 2024) Parkinson’s disease (PD) is the second most common neurodegenerative disease in the world after Alzheimer’s. Genetic factors account for only a fraction of PD cases, and for decades scientists have been aware of associations between pesticide exposures and PD. Yet, not everyone exposed to pesticides gets PD. Consequently, neither the genetic nor the environmental hypothesis is fully satisfactory; both may be involved. Thus, there has been great interest in identifying gene variants that affect the risks of PD associated with pesticide exposure.

Now a team of University of California at Los Angeles researchers led by neurologist Brent Fogel, MD, PhD has traced a connection between certain gene variants and the occurrence and severity of PD in a cohort of central California PD patients who have had long-term exposure to pesticides. The genes are related to autophagy, the process by which cells organize, degrade, recycle or eject molecules to maintain healthy chemical balance. Autophagy is an essential process throughout the body, including regulation of mitochondria, which are also vital for healthy cellular function. The study supports other research suggesting that autophagy is disturbed in neurodegenerative diseases.

As Beyond Pesticides discussed in its April 19 Daily News, PD features the accumulation of Lewy bodies in dopaminergic neurons, the nervous system cells most dysfunctional in PD. Lewy bodies are clumps of alpha-synuclein, a protein that, if not removed from neurons when no longer useful, may impede their signaling. This can lead to motor, sleep, behavioral, and other disorders. Lewy bodies are just the kind of problem autophagy should correct, so malfunctioning autophagy could contribute to PD progression.

In the current study, the researchers started with the Parkinson’s Environment and Genes (PEG) data from 757 PD patients who have been followed for decades. The participants in PEG are from California’s Central Valley. Sixty-two percent of the PEG cohort are male; the average age at diagnosis is 67.7 years. PEG includes the details of the patients’ disease onset, progression and severity, as well as their residential and work locations throughout their lives. The patients have also been screened for genetic mutations in genes known to be associated with PD.

The researchers combined the PEG data with land use data and the California Pesticide Use Report (PUR) system, which requires commercial agricultural pesticide users to report the details of pesticide applications, including date, method, location, poundage, type of crop and acreage.

This enabled the researchers to identify a subset of PD patients with known long-term pesticide exposures. They further refined their patient pool to select a group that had been exposed to the “cotton cluster” of pesticides. The cotton cluster includes organoarsenic pesticides, organophosphorus pesticides, and n-methyl carbamates, all of which have “strong epidemiologic association with Parkinson’s disease,” according to the researchers.

The authors single out cacodylic acid, a pesticide in the cotton cluster. This pesticide is an example of the EPA’s regulatory negligence. It is an arsenic compound. Arsenic, an element, is never good for living organisms, but is very common in the Earth’s crust. Cacodylic acid was first used as a pesticide in 1867 in a compound called Paris green, which was also used as a pigment in wallpaper and clothing, resulting in thousands of illnesses and deaths. Its carcinogenicity was suspected as early as 1887. Under the name “Agent Blue,” cacodylic acid was a principal means of killing rice during the Vietnam War—part of the “rainbow” of chemicals, along with Agent Orange, that defoliated much of Vietnam and led to generations of health problems in military veterans.

Despite a long historical record of arsenic compounds’ toxicity, most research has focused on its carcinogenicity rather than its neurological effects. Usage in agriculture has decreased, but EPA declined in its 2006 reregistration review to evaluate one of the still-used arsenic compounds for carcinogenicity. In 2009 EPA canceled registrations for organic arsenical herbicides but continued registration for monosodium methanearsonate (MSMA) on cotton, sod farms, golf courses and highway verges.

Progress has been made against other arsenic compounds. In 2015, after a lawsuit filed by the Center for Food Safety (CFS) and eight other organizations, FDA removed the last of three arsenic drugs from the market; the first two had been voluntarily removed by manufacturers in 2013. The three drugs had been used on chickens, turkeys and pigs to induce “faster weight gain” and create a “healthy color in meat from chickens and turkeys,” according to the CFS. Chromated arsenical manufacturers phased out those chemicals’ use as wood preservatives in 2003, but EPA still allows them to be used on certain wooden parts of buildings.

However, these improvements do not solve the problem with arsenic. Arsenic compounds do not sequester quickly in the environment (as an element, arsenic never breaks down). They are common in air; about two-thirds of atmospheric arsenic derives from human sources such as burning fossil fuels, ore smelting, and pesticides. Thus the legacy of arsenic pesticides is like that of lead, DDT and PCBs—it keeps giving generation after generation.

Arsenic promotes the aggregation of proteins such as alpha-synuclein into Lewy bodies in PD patients’ neurons. In a healthy cell, autophagy would remove Lewy bodies by engulfing them in lysosomes, where they would be taken apart and ejected from the cell. Because lysosomes are crucial to the process, genes known to be important for lysosomal function are of particular interest. If autophagy is inhibited and lysosomes are faulty, PD and other neurodegenerative diseases may progress.

For the current study, the researchers selected 85 genes associated with PD risk in the cotton cluster-exposed group. Of these, they focused on lysosomal genes because they knew such genes are overrepresented in the neurons of patients exposed to the cotton cluster pesticides and might be a locus of disease.

The researchers found that, in fact, nearly three quarters of the PD-associated gene variants in the cotton cluster-exposed PD patients were involved in lysosomal processes, including autophagy, and were not functioning properly. They interpreted this to mean that people carrying these gene variants have an “underlying susceptibility” to exposure to pesticides which, in turn, raises their risk of developing PD. Their neurons would not be able to properly clear Lewy bodies.

The authors also expressed concern about the other pesticides in the cotton cluster. Some are already linked to mitochondrial dysfunction and the proliferation of reactive oxygen species, which itself may trigger autophagy. For example, in laboratory studies the herbicide trifluralin interfered with mitochondria in neurons descended from those in PD patients, and its toxicity is enhanced when applied with other pesticides. Prometryn, a persistent herbicide harmful to fish, and phorate, an insecticide, damage mitochondria and have been associated with PD risk.

Organophosphorus compounds are associated with many health effects ranging from cancer to asthma and diabetes; both organophosphates and n-methyl carbamates are severe neurological toxins, interrupting the acetylcholinesterase signaling pathways in the nervous systems of everything from insects to humans. But they may have a more direct influence on PD induction: a 2024 Alzheimer’s study found that TDCIPP, an organophosphorus flame retardant, disrupts the proper formation of lysosomes.

Because some research shows that the organophosphorus pesticides chlorpyrifos and malathion, as well as the bipyridylium herbicide paraquat, affect lysosomes, the UCLA researchers also recommend further analysis of gene variants’ relationship with exposure to these pesticides.

One of the UCLA study’s coauthors, Kimberly Paul, PhD notes in a press release that Parkinson’s disease is the fastest-growing neurodegenerative disease in the world. Considering this growing prevalence, and the emerging evidence that pesticides are major contributors to it, regulation of the pesticides considered in the current study should be dramatically increased. In fact, elimination of pesticides would reduce the risk of not only neurodegenerative diseases but a wide range of modern human afflictions. The cost of managing chronic and degenerative diseases that are preventable, or at least mitigable, by transition to organic agriculture will certainly exceed the costs of growing food, livestock, and plant and animal materials without pesticides. Beyond Pesticides notes, “There is no conceivable economic rationale that outweighs the burdens suffered by exposed populations—a group that includes everyone.”

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

Sources:

Lysosomal genes contribute to Parkinson’s disease near agriculture with high intensity pesticide use
Ngo, K.J., Paul, K.C., Wong, D. et al. Lysosomal genes contribute to Parkinson’s disease near agriculture with high intensity pesticide use.
npj Parkinsons Dis. 10, 87 (2024).
https://doi.org/10.1038/s41531-024-00703-4
https://www.nature.com/articles/s41531-024-00703-4
[open access]

U.S. EPA. HEALTH AND ENVIRONMENTAL EFFECTS DOCUMENT FOR CACODYLIC ACID. U.S. Environmental Protection Agency, Washington, D.C., EPA/600/8-90/021 (NTIS PB91216473).
https://cfpub.epa.gov/si/si_public_record_report.cfm?Lab=NCEA&dirEntryId=37605

Arsenic Exposure and Toxicology: A Historical Perspective
Michael F. Hughes, Barbara D. Beck, Yu Chen, Ari S. Lewis, and David J. Thomas
Toxicol Sci. 2011 Oct; 123(2): 305–332.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3179678/#bib222|
[open access]

A review on arsenic in the environment: contamination, mobility, sources, and exposure
Khageshwar Singh Patel, Piyush Kant Pandey, Pablo Martín-Ramos, Warren T. Corns, Simge Varol, Prosun Bhattacharya, and Yanbei Zhu
RSC Adv. 2023 Mar 14; 13(13): 8803–8821.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10020839/
[open access]

Convergent pathways in Parkinson’s disease
Cherubini M, Wade-Martins R. Convergent pathways in Parkinson’s disease.
Cell Tissue Res. 2018 Jul;373(1):79-90.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6015598/
[open access]

(Beyond Pesticides, May 2, 2024) In the midst of a climate crisis and a lack of government recording of atmospheric measurements of sulfuryl fluoride (SO2F2), a study of the estimated emissions of sulfuryl fluoride throughout the U.S. shows elevated levels being released in California. The study, performed by researchers from Johns Hopkins University’s Department of Environmental Health and Engineering, University of California’s Scripps Institute of Oceanography, and National Oceanic and Atmospheric Administration’s (NOAA) Global Monitoring Laboratory, uses measurements from the NOAA Global Greenhouse Gas Reference Network and a geostatistical inverse model. Sulfuryl fluoride is a fluoride compound and pesticide used primarily for the extermination of drywood termites and beetles—linked to increased greenhouse gas emissions and having acute exposure consequences—with little data collected or reported on the amount of sulfuryl fluoride being used and released into the atmosphere. There is a long history of limited protections for the public centered around sulfuryl fluoride, with regulations from the U.S. Environmental Protection Agency (EPA) not addressing both dietary and nondietary exposure to fluoride compounds and the body burden this creates. With the dismissal of aggregate risk exposure, public health and safety and environmental sustainability are not prioritized. Organic alternatives have been left out of the conversation, but advocates are urging a shift in that direction. 

The measurements utilized in the study are from across North America between 2015-2019 and were also compared to global emission rates, as has been done in previous studies related to this compound. The findings of this study show “California has the largest SO2F2 emissions among all U.S. states, with the highest emissions from southern coastal California,” conclusions consistent with prior analysis of the data. The study goes on to say that there were “zero to low emissions across most of the rest of the U.S,” which signifies California as an outlier.  

In comparison to overall emissions, the authors found that “California emits 60-85% of U.S. SO2F2 emissions … equal to 5.5-12% of global SO2F2 emissions”. While analyzing this data, it was also found that when large spikes of emissions occurred, 98% of them were at sites in California. Total emission rates from California were found to be 0.26 Gg/year while the entire U.S. is 0.30 Gg/year, an alarming amount that calls for emissions in California to be regulated. Usage of sulfuryl fluoride in warmer states is expected since many of the targeted pests do not threaten areas with a colder climate. California, however, stands apart from other warm coastal regions that have low emissions. As a greenhouse gas (GHG), this is a concern since sulfuryl fluoride has a long atmospheric lifetime, high global warming potential, and strong infrared absorption properties. 

After the Montreal Protocol was finalized in 1987, a shift away from methyl bromide, which is known as an ozone depleting substance, occurred and the ozone layer started to show signs of recovery. This shift, however, led to an alternative being used in its place–which is when global use of sulfuryl fluoride significantly increased. Both compounds, however, are still used under critical use exemptions from the Clean Air Act despite pushback. The 2014 Farm Bill also contains language that allows for EPA to disregard safety thresholds for fluoride compounds. In addition to structural fumigation, EPA began allowing sulfuryl fluoride in the production of raw foods in 2004 and processed foods in 2005. Multiple points of exposure to these compounds occur through drinking water, food, and in the air, which begs the question of why total exposure, including the effects of climate change, is not considered when accessing potent pesticides such as sulfuryl fluoride. When calculating aggregate risk under the Food Quality Protection Act, EPA is required to consider exposure to fluoride used for water treatment when evaluating the hazards of sulfuryl fluoride. 

In 2008, a study determined that this pesticide was also a GHG after calculating its global warming potential. The Intergovernmental Panel on Climate Change officially recognized this and characterized sulfuryl fluoride as a GHG in 2013, and yet to date its atmospheric measurements are not recorded in the U.S., there is not a national inventory of its use, and EPA does not include it in any reporting programs. With global emissions of sulfuryl fluoride reaching a historic high, requirements for reporting and reducing these levels are needed, according to advocates. 

The initial research on sulfuryl fluoride that led to it being approved in 1959 did not show that it was long-lasting in the atmosphere, nor did it show a high global warming potential. Since then, additional studies have shed light on sulfuryl fluoride as a GHG with detrimental effects. A study in 2009 found that this pesticide is as much as 4,000 times more effective at trapping heat than carbon dioxide. Despite this, legislation such as from the 2015 Paris Climate Agreement, Nations Framework Convention on Climate Change, or EPA have failed to include this potent pesticide. 

Moreover, this study highlights other important consequences of sulfuryl fluoride use: “Apart from the climate-warming effect, there are public health and safety concerns surrounding the use of SO2F2 for fumigation. Most notably, there have been several documented cases of inadvertent human deaths caused by acute exposure.” Additional health effects include cancer, endocrine disruption, neurotoxicity, and impacts on reproduction and development. The authors also state that EPA considers sulfuryl fluoride as a “restricted-use pesticide (RUP) due to its inhalation toxicity” and yet does not require any reporting or regulate its usage. 

In researching California’s utilization of sulfuryl fluoride, records from the California Department of Pesticide Regulation were reviewed. These records “indicate that ~85% of SO2F2 use (by mass) in California is for structural fumigation, while ~15% is for agricultural and commodity fumigation.” As a GHG, portions of sulfuryl fluoride that escape into the atmosphere after fumigation remain in the atmosphere for decades, contributing to the climate crisis. The authors of this study also reviewed aerial imagery over the Los Angeles Basin that shows plumes of sulfuryl fluoride emissions from fumigation sites within residential neighborhoods, a concerning fact since “aeration of fumigated structures has been demonstrated to occur rapidly, with over 90% of indoor SO2F2 lost to the atmosphere within the first 2 hours of ventilation.” California heavily relies on sulfuryl fluoride to combat the western drywood termite, which is difficult to eradicate since they establish colonies without having contact with the soil, do not forage for their food, and tend to make aerial colonies that are inaccessible. In addition, the fumigation of structures with sulfuryl fluoride helps to target current infestations but does not prevent further ones. This causes the need for reoccurring treatments and increased emissions. 

California is the only state that currently keeps a public record of statewide application, even though this is not a requirement of EPA’s Greenhouse Gas Reporting Program or the National Greenhouse Gas Inventory. “The lack of inventory data on SO2F2 use complicates attempts to constrain U.S.-wide emissions,” this study states, which brings to light the inadequacies of EPA’s requirements around GHG. The authors go on to state that “under the Clean Air Act, the EPA is required to regulate emissions of hazardous air pollutants (HAPs), but SO2F2 has not been included in the list of HAPs to date”. Despite multiple studies and petitions, the inaction of EPA and other agencies is apparent. 

While many states have made goals around reducing GHG emissions, such as California has, this study raises a concern over the discrepancies affecting these goals: “California’s SO2F2 emissions provide a case study on how greenhouse gas emissions that are unaccounted for in emissions inventories can potentially offset progress made towards emissions reductions”. The authors of this study call for action in stating: “The pervasive threat of termite infestations in warm-climate regions highlights the need for the development and practice of sustainable, entomology-guided techniques for controlling urban pest populations without the release of harmful atmospheric pollutants or climate-warming gases,” which aligns with Beyond Pesticides’ mission. Alternatives are available, and advocates are urging for these non-toxic options to be used in the place of potent pesticides. Non-chemical and mechanical controls, biological controls, and least-toxic chemicals have all been effective against drywood termites and can be used in place of sulfuryl fluoride. 

For alternatives to other pests, Beyond Pesticides offers ManageSafe™ where you can search by pest type and see different options. There are also resources regarding products compatible with organic landscape management to help make a change and incorporate safer practices in homes and communities.  

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

Source: 

Gaeta, D.C. et al. (2024) California dominates U.S. emissions of the pesticide and potent greenhouse gas sulfuryl fluoride, Communications Earth & Environment. Available at: https://www.nature.com/articles/s43247-024-01294-x  

(Beyond Pesticides, May 1, 2024) According to a new analysis by Consumer Reports, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. A review of seven years of PDP data show that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day, according to Consumer Reports analysis. Consumer Reports contend that U.S. Environmental Protection (EPA) pesticide residue tolerances are too lenient. To better evaluate potential health risks associated with various foods, Consumer Reports applied stricter residue limits than the EPA tolerances (see here for CR’s analytical methodology). Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a function of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues.

The Consumer Reports results fly in the face of the rosy outlook reported by the USDA in its 2022 PDP Annual Summary, which found that 99% of the fruits and vegetables the agency tested “had residues below the established [EPA] tolerances.” Agencies typically point to acceptable or legal residues as protective of health and the environment, despite potential adverse effects associated with inadequate assessment of health outcomes, such as endocrine disruption, vulnerable population groups, exposure to mixtures and synergistic interactions, and more.

Beyond Pesticides reported in February that EPA’s methodology for calculating acceptable levels of pesticides in food has long been criticized as inadequate. Scientists at Consumer Reports note that EPA’s calculations of “tolerable” levels of pesticides in food are at least 10 times higher than they should be to adequately ensure the health and safety of the public and the country’s ecosystems. According to Consumer Reports, EPA has never applied the tenfold safety factor to certain pesticides required as by the Food Quality Protection Act of 1996 to protect vulnerable populations. [Readers and the public can reference Beyond Pesticides’ database Eating with a Conscience, which identifies the multiple pesticides that can be used on individual crops and the resulting exposures not only to consumers, but to farmworkers, farmers, neighboring communities, and the environment.]

Michael Hansen, PhD, senior scientist at Consumer Reports, states, “The way the EPA assesses pesticide risk doesn’t reflect cutting-edge science and can’t account for all the ways the chemicals might affect people’s health, especially given that people are often exposed to multiple pesticides at a time.”

To ensure the most up-to-date information, the list of pesticides to which the tenfold safety factor is applied by Consumer Reports is based on the latest scientific findings in the Endocrine Disruption Exchange, a database maintained by TEDX, a nonprofit research institute that uses publicly available scientific research to identify chemicals with at least one study demonstrating endocrine-disrupting properties. The tenfold safety factor is also applied by Consumer Reports to the list of endocrine disruptors identified by the European Commission. Consumer Report’s analysis not only applies the tenfold safety factor to appropriate chemicals, but it also calculates the relative risk of each food based on the average amount, frequency, and number of pesticide residues found on each food type, and the relative potential of the pesticide to negatively affect human health. Together, this information was used to develop a ranking system from “Very Low Risk” to “Very High Risk.”

Of the 59 fruits and vegetables included in the analysis, which includes data from 2016-2024, 22 foods are identified as “Moderate Risk” or higher, including seven that were “Very High Risk.” This is based on data analyzed from nearly 30,000 samples taken between 2016-2024. With this methodology, it is advisable that some people limit their food consumption to no more than one-half serving per day for many commonly eaten vegetables, such as bell peppers, blueberries, potatoes, and strawberries.

Watermelon and green beans were identified as some of the highest risk foods. Watermelon carries a small but serious risk of contamination with oxamyl, a highly toxic insecticide. [See Beyond Pesticides’ Gateway on Pesticides here]. Similarly, while only four percent of domestically grown green beans from chemical-intensive agriculture tested positive for the insecticide acephate or one of its breakdown products, the levels found were up to 100 times higher than considered acceptable by Consumer Reports scientists. Perhaps more alarming is the fact that acephate has been illegal for use in green bean cultivation since 2011. (See here for Beyond Pesticides coverage.)

Consumer Report’s analysis highlights the inadequacy of the PDP to adequately convey the potentially serious impacts of continuing to use toxic pesticides in the production of food. Beyond Pesticides has reported on the misleading nature of the PDP annual summary and how certain mainstream organizations, such as Blue Book Services/Produce, cover the annual update by reinforcing USDA’s depiction of pesticide exposure in produce as safe.

USDA’s PDP and EPA’s risk assessment measures fail to account for vulnerable subpopulations, such as farmworkers, people with compromised health or preexisting health conditions, and children (see here and here). Beyond the residues of pesticides in and on food, exposure to pesticides used in crop production results in disproportionate risk and harm to farmworkers, their families (including children who are working as farmworkers), and ‘fence line’ communities living near farms. [See here for coverage of a January 2024 report led by Nathan Donley, PhD, environmental health science director at the Center for Biological Diversity and Robert Bullard, PhD, executive director of the Robert D. Bullard Center for Environmental and Climate Justice at Texas Southern University in Houston].

Similarly, the PDP Annual Report also fails to adequately promote the benefits of organically grown produce. Consumer Reports found that nearly all organically grown food tested had low or very low pesticide risk and only spinach and potatoes posed a moderate risk among domestically grown varieties. Beyond Pesticides notes, organic food products have been found to have zero contact with pesticides unless due to pesticide drift from other farming operations.

Consumer Reports first began reviewing PDP data and presenting its own analysis in 2020. Since then, it has recommended that the public eat an organic diet whenever possible and has advocated for change in how pesticides are used and regulated. Not only is the production of organic food better for human health and the environment than chemical-intensive production, but emerging science reveals also what organic advocates have been saying for a long time—in addition to lacking the toxic residues of conventional foods, organic food is more nutritious.

A study published by The Organic Center reveals that organic food is higher in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally significant (read a summary in the Beyond Pesticides Daily News Blog). Another study published in the Journal of Agricultural Food Chemistry looked specifically at the total phenolic content of marionberries, strawberries, and corn, and found that organically grown products contained higher total phenolics. Phenolics are important for plant health (defense against insects and diseases), and human health for their “potent antioxidant activity and wide range of pharmacologic properties including anticancer, antioxidant, and platelet aggregation inhibition activity.”  For more on the health benefits of organic agriculture, see here.   

Organic agricultural practices, which reject the use of harmful pesticides, are capable of the benefits the Rodale Institute Farming Systems Trial is demonstrating. Not only does organic food remove the risk of ingesting toxic chemicals, it eliminates the risk posed to farmworkers and the environment. Such practices protect human and animal health, and support functional ecosystems and biodiversity. Widespread adoption of organic and certified organic regenerative agriculture can also lift human agro-activity out of its current chemical dead-end. The public has an important role to play in this transition: learn more about organic agriculture, advocate for it, and “vote” for organics by creating market demand for organic food.

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

Sources:

Produce Without Pesticides, Consumer Reports, April 18, 2024
6 Fruits and Vegetables Loaded With Pesticides, Consumer Reports, April 18, 2024
Consumer Reports recently conducted its most comprehensive review of pesticides in 59 US fruits and vegetables, The Guardian, April 18, 2024
Healthy or high risk? New analysis warns of pesticide residues on some fruits and veggies, New Lede, April 18, 2024
Agricultural Justice, Beyond Pesticides website
Gateway on Pesticide Hazards and Safe Pest Management, Beyond Pesticides website

(Beyond Pesticides, April 30, 2024) Researchers found epigenetic changes, including changes relating to “DNA methylation, histone modification, and differential microRNA expression [which ‘can alter the expression of many disease-related genes’],” in a systematic review and meta-analysis of existing literature published in Environmental Epigenetics. “Our review did provide evidence that pesticide exposure could lead to epigenetic modifications, possibly altering global and gene-specific methylation levels, epigenome-wide methylation, and micro-RNA differential expression,” researchers share in the conclusion of the study.

This study is an amalgamation of various studies on epigenetic changes based on a literature review process: “Article review involved [3,529 articles found through] extensive searches across major human health databases, including PubMed, Embase, and Cochrane, and BVS (Biblioteca Virtual em Saúde – the Latin American Health Database). Searches covered articles published through December 2020. Considering the diverse terminologies used to describe the same epigenetic mechanism in this field, the search strategy aimed to encompass all relevant articles by combining a variety of search terms in titles and abstracts. This approach was implemented across PubMed, Embase and Cochrane databases to ensure comprehensive coverage.” Studies were not included if the participants were not considered “healthy individuals” or if the participants had “known inherent/congenital or acquired genetic disorder[s].” Out of 3,529 articles initially found, 28 articles were finalized after going through eligibility criteria. 

“When a modification occurs in a gene’s promoter region, it impedes the binding of activating transcription factors and triggers the formation of a closed chromatin structure through specific histone modifications,” the researchers explain in describing the relationship between pesticide exposure and biomolecular alterations that impact an individual’s epigenetics. “Assessing sperm samples from military veterans of Operation Ranch Hand exposed to Agent Orange, Kelsey et al. (2019) associated loss of DNA methylation in four different CpG sites of the TEAD3 gene with dioxin exposure,” says researchers in the study. DNA methylation is essential to the development and transfer of genes. “In addition, by assessing regional DNA methylation changes, 36 gene regions, including the region of the imprinted gene H19 were found to have altered DNA methylation associated with high dioxin exposure compared to the low dioxin exposure group.”

One of the selected studies involves the tracking of micro-RNA (miRNA) profiles from urine of farmworkers exposed to organophosphate pesticides. “A cohort of mother-child farmworker pairs exposed to organophosphate pesticides and non-farmworker pairs was studied by measuring urinary microRNA profiles []. Significant differences in miRNA profiles were found between adult farmworkers and non-farmworkers and also between seasons. During the post-harvest season, six miRNAs were identified as being positively associated with farmworkers.”

Epigenetic changes through pesticide exposure have been documented by various scientific studies focusing on different adverse health effects. For example, a 2023 study published in Endocrine notes that endocrine-disrupting chemicals (including primary ingredients in herbicides such as glyphosate and organophosphate and carbamate insecticides) can bind to hormone receptors, dysregulating hormone receptor expression, disrupting the production and metabolism of the steroid hormone (steroidogenesis), and altering the epigenetic (heritable traits) mechanisms. The resulting reproductive outcomes from endocrine-disrupting chemical (EDC) exposure include poor semen quality, increased sperm DNA fragmentation, increased gonadotropin levels, a slightly increased risk of hereditary malformations (e.g., cryptorchidism and hypospadias), and testicular tumor development. Regarding prenatal exposure, maternal exposure to EDCs increases the predisposition for testicular tumor development, as well.

Additionally, a 2023 study published in Environmental Health Perspectives observed life-long exposure to glyphosate increases the risk of mosaic loss of chromosome Y (loss of chromosome Y occurs to many men in some cells due to aging [mLOY]) that impacts a noticeable contingent of cells. Although the loss of this sex chromosome does not cause cell death, like the loss of autosomal chromosomes, the risk of mLOY is a biomarker for genotoxicity (the damage of genetic information within a cell causing mutations from chemical exposure, which may lead to cancer) and expansion of cellular response to glyphosate, resulting in the precursor for hematological (blood) cancers. For a broader history of independent and peer-reviewed scientific literature in this field of study, see the Daily News Blog section on epigenetics.

Beyond Pesticides has discussed extensively the impact of pesticide exposure on human health, particularly in its relationship with epigenetics and environmental obesogens. Environmental obesogens are chemicals that are proven to have a health impact on metabolic systems relating to obesity. As a keynote speaker at Beyond Pesticides’ 36th National Pesticide Forum, “Organic Neighborhoods: For healthy children, families, and ecology,” Bruce Blumberg, PhD broke down the impacts of prenatal obesogens in the session Cutting Edge Science. “In the obesogen-exposed animals, this structure is disturbed, and that leads to heritable changes in which genes are expressed. This altered structure is inherited, and that leads us to get this leptin-resistant thrifty phenotype four generations later, as published in [a 2017 Nature Communications study which determined] ancestral perinatal obesogen exposure results in a transgenerational thrifty phenotype in mice.”

There are several aspects of obesogens that scientists are still determining, including the number of obesogens and the degree to which prenatal exposure alters adult phenotype from babies as they grow up from ancestors who have intergenerational interactions with obesogens. There is also a 2024 Chemosphere study that describes associations between type 2 diabetes, obesity, and pesticide exposure, specifically β-Hexachlorocyclohexane (β-BHC) and oxadiazon.

Long-term pesticide exposure, and exposure to a mixture of various chemicals, has impacts on a far range of health consequences not just to human health, but to ecosystem integrity in its entirety. Beyond Pesticides acknowledges the decades of advocacy toward organic principles not only for agricultural purposes, but for broader land management strategies to prevent the unnecessary spread of toxic petrochemical pesticides. See Eating With A Conscience to learn about the toxic pesticides commonly used in conventionally grown fruits and produce to make a more informed decision ahead of your next grocery store run. See Keeping Organic Strong to learn how to strengthen National Organic Program standards in service of public health, climate action, and consumer interests.

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

Source: Environmental Epigenetics

(Beyond Pesticides, April 29, 2024) The contamination and poisoning left behind from wood treatment sites, resulting in hundreds of designated Superfund clean-up sites across the country, is the subject of an action by Beyond Pesticides after the release of yet another report criticizing the federal government’s inadequate response to the public’s risk to “residual contamination in the groundwater and soil” by the U.S. Environmental Protection Agency (EPA) Office of Inspector General (OIG). The report criticizes EPA’s weak response at the American Creosote Works Superfund site in Pensacola, FL, a problem that reflects the unending dangers of sites contaminated with persistent toxic chemicals associated with wood preservatives. The site was put on the Superfund priority list in 1983 and in 2017 it was estimated that the clean-up would cost $35.3 million. Just last year, EPA Administrator Michael Regan toured another Superfund Site contaminated with creosote and pledged the clean-up of that site, which affects a community of predominantly people of color.

Tell EPA to cancel the registration of highly toxic wood preservatives, including creosote, chromated arsenicals, and copper compounds, and the U.S. Congress to ensure the prevention of future site contaminations.

As long as dependency on toxic wood preservatives (used on utility poles and railroad ties) continues—pentachlorophenol (penta), copper chromated arsenate, and creosote—the contamination at treatment and disposal sites will continue, advocates say. Beyond Pesticides found the following as far back as the late 1990’s: Wood preservative treatment facilities have contributed greatly to the ranks of Superfund cleanup sites. On the National Priority List (NPL) of sites identified by EPA: (i) Arsenic has been found in at least 781 NPL sites; (ii) Penta had been found at least 314 NPL sites; (iii) Chromium has been found in at least 386 hazardous waste sites on the NPL; (iv) Copper has been found at least 210 NPL sites; and (v) Creosote has been found at least 38 of NPL sites. Based on data from the EPA’s Superfund Enterprise Management System, there are 63 current and proposed Superfund sites based on former facilities in “Lumber and wood products/wood preserving/treatment” with creosote and pentachlorophenol that fall on the National Priorities list as of 2024.

Federal action falling short on toxic chemicals in wood products has been a longstanding problem. Beyond Pesticides released a report in 1997 on the lasting effects of toxic chemicals in traditional utility poles, “Poison Poles – A Report About Their Toxic Trail and Safer Alternatives.” The problem of public exposure to creosote and toxic chemicals in wood goes beyond Superfund sites. “Using a pole distribution formula…there are well over 116 million mini-waste sites in backyards, school yards, along rivers and lakes, and up and down roadsides across the country. Out of the over 3,000 electric utilities in the U.S., over one-half of these toxic poles are put in place by the 100 largest utilities. That translates to more than one toxic pole per household.” 

After nearly a century of use, the EPA announced in 2022 that it was officially cancelling the highly toxic wood preservative pentachlorophenol (penta). As one of the most dangerous pesticides ever produced, penta poses unacceptable risks to workers and surrounding communities, which often became superfund sites once manufacturing plants closed. According to the agency, “During the registration review process, EPA found that given the emergence of viable alternatives, the risks pentachlorophenol poses to workers’ health outweigh the benefits of its use.” Health and environmental advocates are pleased with the agency’s long overdue action on penta but remain incredulous that EPA has provided a generous phase-out for the utility and wood preservative industry, allowing use to continue for up to five years. Beyond Pesticides has been working to ban pentachlorophenol, creosote, and copper chromated arsenate since its founding in 1981. (See history of Beyond Pesticides’ work and litigation.) The agency said it was requiring registrants to voluntarily cancel their penta products by February 29, 2024. EPA will then provide another three years for registrants to utilize their left-over stocks of penta, placing a hard end date on February 29, 2027. In a response to Beyond Pesticides comments, the agency does indicate it will require mandatory cancellation should current registrants not follow through voluntarily. See more details. EPA did not act on penta until the market collapsed due to the closing of the last penta manufacturing facility in Mexico in compliance with the 2001 Stockholm Convention, under which parties to the treaty agreed to phased out Persistent Organic Pollutants. The U.S. never ratified the treaty to which 186 nations are signatories.

Advocates say that the ending of continued contamination requires the phasing out of these wood preservatives and replacing them with alternatives, including less toxic materials, cement, fiberglass, and, in the case of utility poles, burying lines.

Tell EPA to cancel the registration of highly toxic wood preservatives, including creosote, chromated arsenicals, and copper compounds, and the U.S. Congress to ensure the prevention of future site contaminations.

Engineering solutions, such as removing soil, sludge, and sediment and installing a temporary cap over the contaminated materials, have reduced risk from contamination by pentachlorophenol (penta), dioxins, creosote, and carcinogenic polycyclic aromatic hydrocarbons. However, protecting human health and the environment requires ongoing institutional controls—administrative and legal measures, such as zoning, public advisories about contamination at a site, and restrictions on permitted uses of private property. OIG finds, “The institutional controls that the EPA has established at the American Creosote Works, Inc. (Pensacola Plant) Superfund site in Pensacola, Florida, related to contaminated groundwater and soil are not sufficient to prevent potential exposure to contamination.”

Superfund, or the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted in response to growing public awareness of the dangers of hazardous waste sites, such as Love Canal. CERCLA created the Hazardous Substance Response Trust Fund (or “Superfund”) to collect taxes, cost recoveries, and fines and penalties to be used to finance emergency responses and cleanups. Ultimately, the costs should be reimbursed by responsible parties, if they can be located. Cleanup is expensive, but necessary. However, cleanup needs to be coupled with actions to prevent future contaminated sites.

It is no surprise that many Superfund sites are past or current sites of wood preservation. Since wood is a potential food source for organisms ranging from bacteria and fungi to insects and birds, and treated wood is expected to survive for years or decades when exposed to the elements, the ideal wood preservative chemical is broadly toxic and persistent. EPA must make connections between decisions that promote environmental contamination and programs that must clean up the toxic mess. Administrator Regan’s visit to Houston, Texas to tour a petroleum facility owned by Union Pacific Railroad Company followed a lawsuit filed by thousands of surrounding community members for adverse health effects allegedly caused by creosote contamination. Yet, Mr. Regan failed to see the connection between lived experiences of frontline communities impacted by creosote wood preservatives since the EPA moved forward with its decision to reauthorize creosote use for another 15 years.

Furthermore, alternatives exist—such as concrete or steel utility poles. If EPA is to prevent future sites contaminated with toxic wood preservatives, it must cease the use of these highly toxic persistent chemicals.

Tell EPA to cancel the registration of highly toxic wood preservatives, including creosote, chromated arsenicals, and copper compounds, and the U.S. Congress to ensure the prevention of future site contaminations.

Letter to EPA:

A recent report by the Office of Inspector General (OIG) of the Environmental Protection Agency found that due to inadequate institutional controls at the American Creosote Works Superfund site in Pensacola, FL, “the public remains at risk of exposure to residual contamination in the groundwater and soil,” pointing to the unending dangers of sites contaminated with persistent toxic chemicals. 

Engineering solutions, such as removing soil, sludge, and sediment and installing a temporary cap over the contaminated materials, have reduced the risk of contamination by dioxins, creosote, and carcinogenic polycyclic aromatic hydrocarbons. However, protecting human health and the environment requires ongoing institutional controls—administrative and legal measures, such as zoning, public advisories about contamination at a site, and restrictions on permitted uses of private property. OIG finds, “The institutional controls that the EPA has established at the American Creosote Works, Inc. (Pensacola Plant) Superfund site in Pensacola, Florida, related to contaminated groundwater and soil are not sufficient to prevent potential exposure to contamination.”

Superfund, or the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted in response to growing public awareness of the dangers of hazardous waste sites, such as Love Canal. CERCLA created the Hazardous Substance Response Trust Fund (or “Superfund”) to collect taxes, cost recoveries, and fines and penalties to be used to finance emergency responses and cleanups. Ultimately, the costs should be reimbursed by responsible parties, if they can be located. Cleanup is expensive but necessary. However, cleanup needs to be coupled with actions to prevent future contaminated sites.

It is no surprise that many Superfund sites are past or current sites of wood preservation. Since wood is a potential food source for organisms ranging from bacteria and fungi to insects and birds, and treated wood is expected to survive for years or decades when exposed to the elements, the ideal wood preservative chemical is broadly toxic and persistent. EPA must make connections between decisions that promote environmental contamination and programs that must clean up the toxic mess. For example, in 2021, EPA Administrator Michael Regan visited Houston, Texas to tour a petroleum facility owned by Union Pacific Railroad Company as thousands of surrounding community members sued the corporation for adverse health effects allegedly caused by creosote contamination. Yet, Administrator Regan failed to see the connection between the lived experiences of frontline communities impacted by creosote wood preservatives since the EPA moved forward with its decision to reauthorize creosote use for another 15 years.

Furthermore, alternatives exist, such as concrete or steel utility poles. I urge EPA to prevent future sites contaminated with toxic wood preservatives by ceasing the use of these highly toxic persistent chemicals, including creosote, chromated arsenicals, and copper compounds.

Thank you.

Letter to U.S. Representative and Senators

A recent report by the Office of Inspector General (OIG) of the Environmental Protection Agency found that due to inadequate institutional controls at the American Creosote Works Superfund site in Pensacola, FL, “the public remains at risk of exposure to residual contamination in the groundwater and soil” points to the unending dangers of sites contaminated with persistent toxic chemicals. 

Engineering solutions, such as removing soil, sludge, and sediment and installing a temporary cap over the contaminated materials, have reduced the risk of contamination by dioxins, creosote, and carcinogenic polycyclic aromatic hydrocarbons. However, protecting human health and the environment requires ongoing institutional controls—administrative and legal measures, such as zoning, public advisories about contamination at a site, and restrictions on permitted uses of private property. OIG finds, “The institutional controls that the EPA has established at the American Creosote Works Inc. (Pensacola Plant) Superfund site in Pensacola, Florida, related to contaminated groundwater and soil are not sufficient to prevent potential exposure to contamination.”

Superfund, or the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted in response to growing public awareness of the dangers of hazardous waste sites, such as Love Canal. CERCLA created the Hazardous Substance Response Trust Fund (or “Superfund”) to collect taxes, cost recoveries, and fines and penalties to be used to finance emergency responses and cleanups. Ultimately, the costs should be reimbursed by responsible parties, if they can be located. Cleanup is expensive, but necessary. However, cleanup needs to be coupled with actions to prevent future contaminated sites.

It is no surprise that many Superfund sites are past or current sites of wood preservation. Since wood is a potential food source for organisms ranging from bacteria and fungi to insects and birds, and treated wood is expected to survive for years or decades when exposed to the elements, the ideal wood preservative chemical is broadly toxic and persistent. EPA must make connections between decisions that promote environmental contamination and programs that must clean up the toxic mess. For example, in 2021, EPA Administrator Michael Regan visited Houston, Texas to tour a petroleum facility owned by Union Pacific Railroad Company as thousands of surrounding community members sued the corporation for adverse health effects allegedly caused by creosote contamination. Yet, Administrator Regan failed to see the connection between the lived experiences of frontline communities impacted by creosote wood preservatives since EPA moved forward with its decision to reauthorize creosote use for another 15 years.

Furthermore, alternatives exist—such as concrete or steel utility poles. I urge you to ensure that EPA prevents future sites contaminated with toxic wood preservatives by ceasing the use of these highly toxic persistent chemicals, including creosote, chromated arsenicals, and copper compounds.

Thank you.

(Beyond Pesticides, April 26, 2024) Researchers build on existing research when assessing the relationship between long-term exposure to organophosphorus pesticides—widely used in food production and homes and gardens—and the human gut microbiome. In a new study published in Environmental Health, an interdisciplinary research team from University of California, Los Angeles determined, “that exposure to [organophosphorus pesticides] is associated with changes in the abundance of several bacterial groups and differential functional capacity in metabolic pathways supported by the human gut microbiome.”

The study draws upon data from a “Parkinson’s, Environment and Gene study (PEG)” in which 190 participants were asked to submit fecal samples and answer interview questions. “[The study] was initially designed to investigate the etiology of Parkinson’s disease (PD) and participants were recruited in two study waves [‘over the full 10-year exposure window’]: 2001–2007 and 2012–2017. At baseline, [Parkinson’s disease] patients were diagnosed within the past 5 years and randomly selected community controls were also recruited,” the research team shares in their Methodology section. “Since 2017, we invited previous study participants who could be contacted to enroll in a pilot study of the gut microbiome. In addition, we invited a household or community member of [Parkinson’s] patients to participate.” To be eligible for the study, it was determined that the participants did not have the following:

1. “acute/chronic gastrointestinal conditions; or 
2. an immunocompromised state and/or were taking immunosuppressants;
3. antibiotic intake continuously or within the past three months”

The collection kit for the research was based on protocol developed under the Microbiome Core of the Goodman-Luskin Microbiome Center. The microbiome was assessed through bacterial DNA found in the fecal samples. A software, PICRUST₂ was used to identify 16S RNA markers—“metagenomic profile of the gut microbiome”—to make predictions on relationships between pesticides and its genetic impacts. For the pesticide exposure assessment component, researchers use a geographic information system (GIS) method with data from California Pesticide Use Reports, land-use survey data from California’s Public Land Survey system, and residential use data from the participants. Researchers found “most abundance changes at the genus level associated with high ambient [organophosphorus pesticide] exposure belong to Lachnospiraceae (seven genera were increased and two were decreased) and Ruminococcaceae (3 genera were increased and 2 were decreased) families in the Clostridia class.” This is significant given these two families are related to anaerobic bacteria present in individuals with healthy gut microbiomes as they produce short-chain fatty acids (SCFAs) “critical in maintaining the homeostasis of the gut microbiome including gut barrier integrity, immunomodulation and regulation of the metabolism of lipids, cholesterol, and glucose []. The production of SCFAs is determined by the type of dietary fibers, the fermenting bacteria, the gut environment, and the substrate []. Therefore, it is possible that the observed changes in SCFA-producing bacteria are an indicator of disturbed homeostasis of the gut environment due to chronic [organophosphorus pesticide] exposure, and the body’s response to such changes.”

This study builds on existing scientific evidence analyzing the impact of toxic pesticides on human health pertaining specifically to the gut microbiome. For example, in a 2023 study released in ISME Journal, researchers determined that the gut and the brain are deeply integrated through the vagus nerve and the neuroendocrine system. The vagus nerve is a treelike bundle of fibers extending from the lower part of the brain to nearly every body organ, but particularly the heart, lungs and digestive tract. The neuroendocrine system comprises specialized cells inhabiting nearly all the organs of the body that respond to signals from the brain and gut to produce hormones that regulate digestive enzymes, the pace of digestion, air and blood flow in the lungs, blood pressure, heart rate, blood glucose levels, and other functions.

Moreover, Demetrio Sierra-Mercado, MD shared findings from research originally published in 2022 in the Federation of American Societies for Experimental Biology, aimed at documenting the relationship between glyphosate exposure and gut health. Dr. Sierra-Mercado noted how even exposure levels that fall within the realm of “safe” can lead to anxiety-like behaviors and alter the delicate balance of gut microbiota. Pesticide exposure has been linked to other adverse health impacts on the gut, including irritable bowel syndrome (IBS). A 2023 study published in Environmental Toxicology and Pharmacology determined that populations living near intensive agricultural operations face higher levels of toxic pesticide exposure (i.e. chlorpyrifos, N-methyl carbamates, macrocyclic lactones, neonicotinoids, pyrethroids, [di] thiocarbamates, conazoles, dicarboximide, anilino-pyrimidines, copper salts, bipyridyl (paraquat, diquat), organophosphates (glyphosate), chlorotriazine, and phenylurea) simultaneously faced higher rates of IBS compared to populations living in areas of low pesticide use and exposure.

Microbiome health for pollinators is also impacted, as documented in a 2022 study published in Science of the Total Environment. Bees subjected to sulfoxaflor and azoxystrobin in combination experienced significantly reduced survival when compared to a sole sulfoxaflor exposure, underscoring the importance of studying chemical mixtures in holistically assessing health-based consequences of pesticide exposure. Bees were exposed to field relevant levels of each pesticide per U.S. Environmental Protection Agency (EPA) data, as well as combinations of pesticides for a period of 10 days through sugar water. A separate experiment on the honeybee gut microbiome was constructed using newly emerged bees, which were housed and reared separately, and then exposed to a similar pesticide treatment as the initial experiment. See Beyond Pesticides’ Daily News blog sections on microbiota and microbiome for further documentation of scientific literature and health impacts.

The continuous growth and adoption of organic agricultural and land management practices is a hopeful sign of systems change away from the chemical treadmill and dependence on petrochemical-based toxic pesticides. Yet advocates are weary of piecemeal bans when the foundation of inaction stems from a failed regulatory system that permits the use of toxic pesticides. See Tools for Change to discover resources and strategies to organize your community against toxic pesticide use. See Eating With A Conscience to learn more about potential pesticide exposure on commonly consumed fruits and vegetables. For the latest scientific literature on adverse health impacts of herbicides, pesticides, and fungicides, see Gateway on Pesticide Hazards and Safe Pest Management and Pesticide-Induced Disease Database.

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

Source: Environmental Health

(Beyond Pesticides, April 25, 2024) In a study from earlier this year, “Pesticides: An alarming detrimental to health and environment,” scientists compiled research from 154 articles regarding pesticide use and the adverse effects they have on the environment and human health. Among the effects of the harmful pesticides described is genotoxicity—the alteration of genetic material that results in the mutations in DNA that cause cancer. 

The authors state that “genotoxins are mutagenic chemicals, and exposure to them increases the risk of developing tumors, hormonal changes, DNA damage, and changes in the ovaries and eggs, all of which leading to cancers… The risk of DNA damage surges with increased genotoxicity in people exposed to pesticides.” In addition, the National Institute of Health states that all “pesticides are highly biologically active chemicals. They may interact with DNA and damage its structure.” Despite these documented risks, pesticide use continues to surge. 

While phased out to a considerable extent after being widely used in agriculture and residential areas, organochlorine pesticides (OCPs) like dichlorodiphenyltrichloroethane (DDT) or its breakdown compound dichlorodiphenyldichloroethylene (DDE) continue to show up as residues in the environment and food supply. Symptoms in humans that have been exposed to these chemicals include: seizures, vomiting, anemia, rapid heart rate, and muscular pain. OCPs have also been linked to changes in the following: hematological/hepatic (blood and bone marrow), endocrine (hormones), and reproductive body systems. Most OCPs are categorized as carcinogens and are linked to genotoxicological properties. 

Organophosphates (OPs), another class of pesticides that were “touted as an eco-friendly alternative” to OCPs, have a wide body of research on their negative health effects. Glyphosate, a phosphonate within the OP family which acts by inhibiting the plant enzyme 5-enolpyruvylshikimate-3-phosphate synthase (EPSP), is most widely used. According to this study, OPs have “been linked to health issues related to endocrine and nervous systems, cellular oxidative stress, effects on the functioning of important enzymes such as cholinesterase, reduced secretion of insulin, dysregulation of cellular metabolism of proteins, carbohydrates, and fats, and increased genotoxic effects. Population-based research has suggested links between exposure to organophosphates and major health issues, such as dementia, cardiovascular illnesses, adverse effects on the reproductive system in males including the nervous system, and an elevated risk for non-lymphoma Hodgkin. Additionally, prenatal exposure to organophosphorus pesticides is related to shorter gestational times and children developing neurological issues.” Many studies have been performed to show these correlations. 

The greatest risk for pesticides lies in those who apply them. The authors of this study state: “Workers and farmers, are frequently exposed to relatively higher levels of pesticides, occupational exposure to pesticides is giving rise to more hazards. For an instance, it has been noted that farmers exhibit greater immunotoxicity of pesticides during the pesticide spraying season.” Other elevated risks for farmers’ body and mind have also been studied. 

Pesticide use dates back thousands of years, even as far as 4500 years ago when sulfur was used to control insects and mites. Starting in the 1500s, mercury and arsenic were utilized against insects, bacteria, and fungi until it was discovered in the 1940s that these metallic elements were toxic, affecting human health and staying in the soil for decades. The 19th and 20th centuries brought the invention and application of many new pesticides that were thought to be safer and more effective, only to be proven to have lethal effects and be banned. Notably, in 1962 Rachel Carson wrote “Silent Spring” to shed light on DDT and the damage it caused for over 20 years on not only bird species, but humans and the environment as well. 

Since then, pesticides on the market continue to be studied and are found to have adverse effects that include resistance. “Due to the increased quantity and frequency of pesticide applications, the targeted pests evolved and adapted to the newer environments and harsh conditions which led to an increase in the prevalence of the resurgence of pests and the appearance of pesticide-resistant species,” the authors of the study affirm. This resistance creates a vicious cycle for the introduction of additional chemicals to combat unwanted species. 

Research is ongoing into current pesticides in use, their impacts on DNA, and the link to those, especially farmers, who develop cancer after exposure. As more pesticides are being proven to have severely detrimental effects on not only our environment’s water, soil, and air but also on human health and the health of critical species (such as pollinators), higher standards needs to be set for the approval of such chemicals. Extensive testing on all pesticides and potential synergistic effects they have need to be performed, and transparency from the Environmental Protection Agency needs to be in place to close loopholes that allow for lethal chemicals to be utilized.   

Safer alternatives are currently available for the pesticides that are widely used today. Natural pesticides, also known as biopesticides, are considered “more efficient, less expensive, and ecologically sound,” based on this study. Since biopesticides are derived from natural materials, they are overall less toxic and have fewer unintended effects. As Beyond Pesticides states on their National Organic Standards page, “Under the organic regulations, only naturally derived pesticides and a small number of synthetic ingredients of low toxicity, such as boric acid, may be used. Inert ingredients in these products must be approved for organic production.” The National Organic Standards Board (NOSB) has recommended to the U.S. Department of Agriculture (USDA) a process for a thorough review of all inert ingredients used in products allowed for organic production to ensure compliance with the Organic Foods Production Act. The standards in place for organic farming call for the full elimination of pesticides with harmful or even unknown effects with the adoption of a soil-based systems approach to land management that enhances biodiversity and prevents disease and infestation in plants. 

While pesticides target weeds, insects, or diseases that affect crop production and nonagricultural land management (e.g., parks and playing fields), these same chemicals damage the environment and many species, as the study indicates. Advocates say that these effects call for not only a reduction in the use of harmful chemicals, but the disuse of them with safer, organic alternatives in their place. 

Act today by writing a letter to legislators about your local community and the impact of pesticides on pollinators that are needed for our food production, as well as the need to switch to organic methods of pest management and help protect children from pesticides by telling the EPA to ban carcinogenic pesticides here. Beyond Pesticides’ mission is for the phase out of toxic petrochemical pesticides by 2032, which can be achieved through local and national change.  

An organic agricultural approach supports biodiversity, soil health, improved water quality, sustainable practices, energy efficiency, and higher food quality, in addition to preventing exposure to toxic or lethal chemicals. A world-wide shift towards organic standards for food production is a necessity to ensure the survival of all species and the environment. Stay up to date on the Daily News for studies on current pesticides and the safer alternatives to them that exist. The Gateway on Pesticide Hazards and Safe Pest Management allows for additional research on pesticides, and The Safer Choice provides resources for the public to make healthier, more informed choices.  

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

Source:  

Kaur, Rajwinder et al. “Pesticides: An alarming detrimental to health and environment.” The Science of the total environment vol. 915 (2024): 170113. doi:10.1016/j.scitotenv.2024.170113 https://pubmed.ncbi.nlm.nih.gov/38232846/ 

(Beyond Pesticides, April 24, 2024) On April 16, 2024, the U.S. Environmental Protection Agency (EPA) posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency’s efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers’ “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, advocates are again questioning EPA’s commitment to fulfilling legal requirements under the Endangered Species Act (ESA) or protecting endangered species and their habitats in the midst of an unprecedented rate of global extinction.

ESA is celebrated as one of the most far-reaching conservation laws globally, credited with preventing the extinction of 99 percent of those species the government targets for protection, according to the U.S. Fish and Wildlife Service (USFWS). ESA establishes a framework to categorize species as “endangered” or “threatened,” granting them specific protections. Under ESA, EPA is required to consult with relevant agencies when registering chemicals to assess their impact on endangered species. EPA has been found by the courts and numerous investigations to consistently fallen short in fulfilling its statutory obligation when registering and restricting pesticides, as documented by Beyond Pesticides.

This EPA update to the Draft Herbicide Strategy was written to address public comments received by EPA last fall, many of which were submitted by the petrochemical pesticide industry, and reflects the anticipated changes that will be included in the final Strategy to be released on August 30, 2024. It appears that revisions to the Strategy will not address any concerns submitted by Beyond Pesticides and other advocates during the comment period. EPA responded with three categories of revisions to the draft policy and noted that it will not impose immediate requirements or restrictions on existing pesticide use but will adopt mitigation requirements for new herbicide registrations and reviews moving forward. Mitigation measures will only become effective upon EPA approval of herbicide labels. 

• First, EPA aims to simplify the decision framework for determining mitigation requirements, moving from a nine-point system to four tiers. Additionally, it plans to develop educational materials to help users understand how to determine mitigation needs based on product labeling.
• Second, EPA intends to enhance flexibility for growers by expanding the menu of mitigation measures, especially for so-called minor and specialty crops (which includes most vegetable production and ornamentals). Note: According to EPA, “Several hundred crops, including most fruits and vegetables, meet the acreage criterion in this definition.” EPA is collaborating with USDA and other agencies to identify additional measures, hosting workshops for agricultural stakeholders to gather input.
• Third, EPA is exploring ways to reduce mitigation requirements in certain circumstances, such as areas with “minimal” runoff or where growers have adopted practices to reduce pesticide runoff. It also considers whether participation in agricultural conservation programs could fulfill mitigation requirements.

Apart from these changes, EPA says it is working on refining species range maps with USFWS to ensure a narrower delineation of areas requiring pesticide-related mitigation measures, certainly resulting in a reduction of restrictions under the final strategy for many species. 

This update to the EPA Draft Herbicide Strategy follows closely on the heels of a commentary by the Wall Street Journal that EPA is “walking back” a proposal for the ambitious Vulnerable Species Project (VSP), a project that is related to EPA’s efforts to protect endangered species from herbicides in compliance with ESA, in favor of a much smaller project with looser restrictions and narrower requirements. EPA published a November 2023 update to the VSP that indicates a retreat from its July 2023 proposal, similar to the capitulation seen in this April EPA update to draft Herbicide Strategy. 

Together, these moves suggest that EPA is proceeding with “business as usual” and that its decisions continue to embrace a narrow approach to risk mitigation. EPA does not evaluate “reasonableness” of risk considering the availability of less toxic alternative substances and practices. Beyond Pesticides maintains that practices to eliminate the need for pesticides must be emphasized because so many pest problems are a function of faulty management practices. Instead, EPA assumes the need for pesticide dependency, even though the scientific literature and empirical evidence may say otherwise.

Over the years, the slow pace of litigation has been a critical strategy in compelling pesticide restrictions to protect endangered and threatened species. The Strategy itself arose from litigation along with a suite of related projects and programs to revamp EPA’s regulation of pesticides and herbicides. A 2011 lawsuit brought by the Center for Biological Diversity and Pesticide Action Network North America forced EPA to finally reach a 2023 agreement to take measures to protect threatened and endangered species when it approves pesticides.

Moreover, EPA’s risk assessment process, in which EPA uses data on how a pesticide moves through the environment and its relative toxicity to assess its impacts to the ecosystem, is criticized as being seriously flawed (see here). EPA’s registration (and periodic 15-year pesticide registration review) process relies on industry-provided data and safety research, which has been wrought with deficiencies and a lack of a strenuous audit process. Agrochemical companies sometimes purchase research that yields biased or distorted findings, cherry-pick results in their submissions to EPA, or try to suppress research findings. For example, as Beyond Pesticides reported in 2021, researchers at the Medical University of Vienna, Austria, found that most of the studies submitted by Monsanto/Bayer to register glyphosate (Roundup) in the European Union were not “scientifically reliable” or only “partly reliable.”

Recognizing that its Office of Pesticide Programs has failed to meet its obligation to protect endangered species from registered pesticides, EPA has devised a strategy to redefine its responsibilities to protect endangered species in its pesticide registration and registration review program. According to EPA, “The proposed Strategy is structured to provide flexibility to growers to choose mitigations that work best for their situation. Additionally, the draft Strategy may require more or less mitigation for growers/pesticide applicators depending on their location.”

EPA has taken this approach after finding it virtually impossible to meet the statutory obligations of ESA—a fact that the agency itself admits, “EPA’s Pesticide Program has been unable to keep pace with its ESA workload, resulting not only in inadequate protections for listed species but also successful litigation against the Agency.” And “(e)ven if EPA completed this work for all of the pesticides that are currently subject to court decisions and/or ongoing litigation, that work would take until the 2040s, and even then, would represent only 5% of EPA’s ESA obligations.”

As Beyond Pesticides previously reported, EPA starts with the position that farmers must use toxic chemicals, an assumption that clouds and undermines the regulatory process and supports farmers being on a pesticide treadmill. EPA says, “Without certain pesticide products, farmers could have trouble growing crops that feed Americans and public health agencies could lack the tools needed to combat insect-borne diseases.” Not true, according to advocates. Productive and profitable organic farmers are not reliant on these pesticides (see here for Rodale Institutes’ 40-Year Farming Trial Report). Fundamental change requires EPA in every pesticide registration and registration review to ask whether there are practices that can eliminate the harm, not reduce risk with high degrees of uncertainty.

The planet faces an existential biodiversity crisis, with a rising number of species on the brink of extinction. The goal of ESA is to address the broader issue of biodiversity loss by protecting habitats of species most at risk, or, as stated in ESA, to “Provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions set forth. . .” in the law.

On the contrary, EPA’s language about its proposed changes includes phrases like “draft Strategy may require more or less mitigation for growers/pesticide applicators depending on their location.” Advocates note that this is not a plan to avoid biodiversity collapse.

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

Yet EPA admits the limitations of its own proposal, saying, “The scope of this document is limited to spray drift, aqueous runoff, and runoff of sediment-bound residues (erosion).” Moreover, EPA fails to recognize that the agency does not have toxicological data for key endpoints or health outcomes like endocrine disruption, an effect that can wipe out a species by undermining its ability to reproduce.

Pesticides are a major contributor to the loss of insect biomass and diversity, known as the “insect apocalypse,” posing a threat to life on Earth. EPA’s registration of insecticides has always endangered insects, but herbicides destroy the food and habitat of insects. Similarly, pesticides threaten food webs in aquatic and marine environments.

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

Industrial agriculture eliminates habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. As opposed to industrial agriculture, organic producers are required to conserve—protect and increase—biodiversity.

Organic agriculture is a viable, productive option that is embraced by consumers and thrives as a $60 billion industry.  This market success comes despite structural bias in USDA funding or programs, including the continued subsidization of conventional and monocrop agriculture Congressional Farm Bill. Consumers continue to make a difference by choosing to buy organic- reducing their own exposure to pesticide residues from conventional produce- and supporting organic farming, which protects not just consumers but farmworkers, surrounding ‘fence-line communities’, and the environment, including threatened and endangered species.

As Beyond Pesticides has advocated since its founding, supporting organic agriculture must include consideration of and protection for farmworkers. Read more about agricultural justice here and here.

In the face of growing recognition that the planet faces an existential biodiversity crisis, with a rising number of species on the brink of extinction, a coalition of environmental organizations, including Beyond Pesticides, sent an urgent letter to President Joe Biden. This letter, titled “Meeting the Challenges of the Biodiversity and Extinction Crisis Over the Next 50 Years,” calls for bold and comprehensive action to preserve our planet’s natural heritage for future generations. To join with Beyond Pesticides in future actions, click here.

Beyond Pesticides works to expand support for public organic land care through our Parks for a Sustainable Future program, converting local parks and playing fields to organic land management practices to make them safer for kids, people, pets to play, while protecting all species and our environment. Beyond Pesticides is also honored to partner with Natural Grocers. During the month of April 2024, Natural Grocers is donating $2 for every Ladybug Love pouch sold and $1 for every “Organic Month Headquarters” bag sold at all in-store locations to Beyond Pesticides! With your support, we can say YES to the livable future we aim to achieve for endangered species, people, and the environment we all share.

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

Sources

EPA Draft Herbicide Strategy Full plan. EPA Public Docket, EPA-HQ-OPP-2023-0365 at www.regulations.gov

Implementing EPA’s Draft Herbicide Strategy. Announcement. Full update, EPA website, April 16, 2024

Protecting Endangered Species from Pesticides, EPA website

EPA Endangered Species Act (ESA) Workplan, EPA website, updated November 2022

Implementing EPA’s Workplan to Protect Endangered and Threatened Species from Pesticides: Pilot Projects, EPA website, updated November 2023

EPA Update on Update on Vulnerable Species Pilot and Press Release, November 2023

EPA Marks National Pollinator Week by Proposing Protections for 27 of the Most Vulnerable Endangered Species, Including Some Pollinators, from Pesticides, EPA Press Release, June 2023

Endangered Species Litigation and Associated Pesticide Limitations, EPA website

Take Action Today: Tell EPA To End Pesticide Dependency, Endangered Species Plan Is Inadequate, Beyond Pesticides, October 20, 2023

Landmark Legal Settlement Locks in EPA Actions to Protect Endangered Species From Pesticides, Center for Biological Diversity Press Release, September 2023 

Corporate studies asserting herbicide safety show many flaws, new analysis finds, The Guardian, July 2, 2021

Links to the 53 studies cited in reprint by US Right to Know.

Monsanto’s Roundup (Glyphosate) Exposed, Beyond Pesticides, Pesticides and You, 2017

Farming Systems Trial 40 Year Report, Rodale Institute, November 2022

(Beyond Pesticides, April 23, 2024) The Office of Inspector General for the U.S. Environmental Protection Agency (EPA) released a report last week finding that the agency has failed to establish “institutional controls” at the American Creosote Works Superfund Site in Pensacola, Florida, leading to continuous groundwater and soil contamination that “leav[es] the public at risk of exposure.” The 1980 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) established the Superfund program, codified under 42 U.S.C. Chapter 103, to clean up contaminated sites with tax money from polluting industries.

The OIG made eight recommendations for the regional EPA administrator and one for the assistant administrator “for Land and Emergency Management to improve the institutional controls at American Creosote Works Superfund Site.” There are three main determinations found in the results section of the OIG report: first, the institutional controls to prevent potential exposure were either “insufficient or unimplemented;” second, the EPA missed its mark in communicating associated risks to the public in areas surrounding this Superfund site; and third, the full administrative record for this site was not available at the time of inspection. This report builds on what advocates argue is the sustained legacy of EPA inaction and failure to protect public health and enforce environmental protections, particularly on the issue of wood preservatives laced with toxic chemicals.

Each determination breaks down as follows: First, the OIG defines institutional controls as “administrative and legal tools that help minimize the potential for human exposure to contamination and protect the integrity of the engineered remedy by limiting land or resource use and guiding human behavior.” EPA failed to achieve the basic definition of institutional controls when it permitted the use of groundwater through the installation of new wells on some nearby private land parcels and “did not conduct well surveys between 2002 and 2013.” When EPA did conduct surveys, “only 61 percent of the properties listed inside the groundwater delineation area” were included despite the remaining residents living in areas of potential contamination. Regarding information sharing on potential exposure via soil contamination, “EPA relied on the community to distribute information and the remedial project manager’s verbal direction to private property owners to guide the owners’ land-use choices,” which is problematic given the turnover of private land over the years can lead to construction that dredges up contaminated soil and leads to potential increased levels of exposure. Compounding the lack of information sharing and administrative hiccups, there was also missing required documents (per CERCLA regulations) between EPA and local/state stakeholders including a memorandum of understanding between EPA and Northwest Florida Water Management District regarding protocols around denying well drilling permits within the zone of potential contamination. Nor was there proof of the creation of an Institutional Control Implementation Assurance Plan for the Superfund site that is designed to establish the parameters and monitoring mechanisms for the institutional controls in question.

Second, EPA failed to adequately and consistently keep the public informed of the associated hazards the Superfund site posed for nearby community members. For example, “EPA’s GIS databse file for the ACW Superfund site does not accurately represent the extent of the site contamination” in terms of contamination spillover beyond the geographical boundaries of the site, which OIG predicts could “mislead interested parties, such as parcel owners, real estate agents, and contractors…to believe that there is no soil contamination” outside of the old site.

Third, the report cites EPA’s failure to maintain a complete copy of the site’s administrative record near or at the site for public access per CERCLA regulations. Both in the office and on the website page, there was a lack of complete, relevant documentation. On the website, as of 2023, “The webpage did contain an electronic repository of documents under the ‘Reports and Documents’ section. However, collectively these documents also do not compose a complete administrative record because they do not include all the Records of Decision or the assessments, investigations, or feasibility studies on which the EPA based its remedial decisions. The EPA’s ACW webpage also did not include an index, and the electronic repository does not include documents demonstrating public involvement in the remedial decisions.”

The report outlines that, out of the nine total recommendations, there are still three left unresolved due to disagreement with the EPA Region 4 lead as signaled in the previous paragraph. Recommendations 3, 4, and 6 unpack how to solve the listed problems above.

• Recommendation 3 recommends that “the EPA work with property owners and appropriate local governments to establish restrictive covenants before remediation began to prevent the disturbance of soil on impacted properties.”
• Recommendation 4 recommends that “[EPA Region 4] establish formal agreements with state and local government stakeholders regarding institutional controls.”
• Recommendation 6 recommends that “the region ensure the existence of a complete physical administrative record.”

The report goes on to assess the regulatory inconsistencies of EPA’s insistence on exclusively maintaining an electronic administrative record, “Given that this site-specific language is used in the final rule [a CERCLA regulation from 2013 called ‘National Contingency Plan’] to address a comment on how the EPA will determine community preferences, the region’s approach to provide an electronic-only administrative record is inconsistent with the assurances provided during the rulemaking process.” (See page 22 of the OIG report for a status update on all 9 recommendations.)

“This report is not an aberration, but it is an indication that the U.S. EPA continues to fall short of its commitment to inform the public in accordance with federal regulations,” says Max Sano, organic program associate at Beyond Pesticides.

Case in point back in 2021, EPA Administrator Michael Regan visited Houston, Texas to tour a petroleum facility owned by Union Pacific Railroad Company as thousands of surrounding community members sued the corporation for adverse health effects allegedly caused by creosote contamination. The city of Houston was sued in the aftermath of a 13-year-old boy living near the facility who died of leukemia after a five-year battle with the disease. Yet, Administrator Regan failed to see the connection between lived experiences of frontline communities impacted by creosote wood preservatives since the EPA moved forward with its decision to reauthorize creosote use for another 15 years. Beyond Pesticides engaged with grassroots advocates for the EPA to acknowledge this fundamental disconnect through a previous Action of the Week (You can still engage on this issue as well!)

Creosote-induced health problems have emerged in communities across the country, such as Springfield, Missouri where a retired Kerr-McGee Treatment Facility continues to threaten community members. Creosote-laced wood in railroad tracks has also been of considerable alarm for community members living alongside railroad tracks dotted across the nation, including concerns from residents in Great Barrington, Massachusetts.

Federal inaction on toxic chemicals in wood products has been a longstanding problem. Beyond Pesticides released a report on the lasting effects of toxic chemicals in traditional utility poles, “Poison Poles – A Report About Their Toxic Trail and Safer Alternatives.” The problem of public exposure to creosote and toxic chemicals in wood goes beyond Superfund sites. “Using a pole distribution formula…there are well over 116 million mini-waste sites in backyards, school yards, along rivers and lakes, and up and down roadsides across the country. Out of the over 3,000 electric utilities in the U.S., over one-half of these toxic poles are put in place by the 100 largest utilities. That translates to more than one toxic pole per household.” In May, King 5 News in Seattle, WA, sampled soil near pentachlorophenol-treated utility poles and found that in every case pentachlorophenol had leached out of the wood.” Beyond Pesticides found the following as far back as the late 1990’s: Wood preservative treatment facilities have contributed greatly to the ranks of Superfund cleanup sites. On the National Priority List (NPL) of sites identified by EPA: (i) Arsenic has been found in at least 781 NPL sites; (ii) Penta had been found at least 314 NPL sites; (iii) Chromium has been found in at least 386 hazardous waste sites on the NPL; (iv) Copper has been found at least 210 NPL sites; and (v) Creosote has been found at least 38 of NPL sites. Based on data from the EPA’s Superfund Enterprise Management System, there are 63 current and proposed Superfund sites based on former facilities in “Lumber and wood products/wood preserving/treatment” with creosote and pentachlorophenol that fall on the National Priorities list as of 2024. If you zoom out beyond those two contaminants, there are 76 current and proposed Superfund sites on former wood product facilities that fall on the National Priorities List. If you zoom out further, former wood product facilities make up over 139 across all different site types (NPL, Superfund Alternative Approach, or not NPL) .

In 2022, EPA announced the cancellation of pentachlorophenol, which is still used on utility poles and railroad ties, as well as other industrial uses. The agency announced that registrants (chemical manufacturers) were to voluntarily cancel their penta products by February 29, 2024. EPA is then providing another 3 years for registrants to utilize their left-over stocks of penta, placing a hard end date on February 29, 2027. Despite highly elevated risk factors, EPA did not act until the last manufacturer shut down their operations in Mexico under the Stockholm Convention on Persistent Organic Pollutants, (See also Environmental Racism Strikes South Carolina Community—with the siting of a pentachlorophenol wood preservative plant.) Regarding creosote, the European Union begun a review of its environmental health impacts in 2011. Fast forward to 2022, the majority of EU states voted in favor of restricting its further authorization. Then, beginning at the end of April 2023, creosote was banned for treatment on fenceposts. However, the pesticide continues to be authorized for railroad tracks and utility poles.

Consumers and children, who are particularly susceptible to deadly and chronic health problems compared to the general population, have the right to avoid exposure to toxic chemicals in and surrounding their homes. See Tools for Change to learn how to organize in your community toward policies that align with Beyond Pesticides’ mission to eliminate toxic petrochemical substances and pesticides within the decade. See Gateway on Pesticide Hazards and Safe Pest Management to identify particular toxic pesticides and substances of concern linked with relevant reports, fact sheets, and studies.

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

Source: Office of Inspector General U.S. Environmental Protection Agency

(Beyond Pesticides, April 22, 2024) Today, on Earth Day, the future of the planet and the health of all its inhabitants come into focus from numerous human and ecosystem health perspectives, with particular concern for the health of the next generation—as childhood cancer continues to be a leading cause of death from disease among children. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring.

Taking Action in Your Community: On Earth Day, Beyond Pesticides invites communities to join together in its nationwide campaign to convert parks to organic land management practices through the Parks for a Sustainable Future program. Through this program, Beyond Pesticides works with park managers, bringing hands-on horticultural support to eliminate petrochemical pesticides and fertilizers and instead nurture soil organisms to cycle nutrients naturally while creating resilient landscapes that resist weeds, insects, and disease. This program outlines the steps to become a parks advocate and how Beyond Pesticides works with communities committed to safe parks and playing fields for communities, children, and pets.

One major impetus for the Parks program are the many studies that find prenatal and early-life exposure to environmental toxicants increases disease susceptibility. For decades, studies have long demonstrated that childhood and in-utero exposure to the U.S.-banned insecticide DDT increases the risk of developing breast cancer later in life. Risks from exposure to pesticides and other toxic chemicals during pregnancy include: pesticides and children’s sleep disorders; prenatal exposures to a multitude of chemicals; insecticides and childhood leukemia; insecticides and Attention Deficit/Hyperactivity Disorder.

Taking Action on Policy:
Tell EPA to ban carcinogenic pesticides. Tell your Congressional Representative and Senators to support S. 269 and H.R. 5085, the Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA).

A study published in Environmental Research suggests occupational (work-related) exposure to pesticides among nonpregnant women and men may increase childhood cancer risk for offspring. Low levels of pesticide exposure during pregnancy or childhood cause adverse health effects from metabolic disorders to mental and physical disabilities. Moreover, several studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer, specifically focusing on leukemia. Acute leukemia is the most common type of childhood cancer, accounting for one of three cancer cases in children ages 0 to 14. Although the disease is rare, incidents have been steadily increasing among adolescents over the last 30 years.

Researchers at the National Institute of Pediatrics and National Polytechnic Institute found positive associations between pesticide exposure and heightened risk of certain childhood cancers. The finding is derived from a meta-analysis of 174 studies published between 2013 and 2023 and reported in the International Journal of Molecular Science. The authors note, “Although [pesticide exposure] association with childhood cancer has not been fully demonstrated, we found that more than 80% of the epidemiological studies show positive associations [with forms of childhood cancer].”

Even household cleaners, many of which are pesticides, can increase nephroblastoma (kidney cancer) and brain tumor risk in children. Furthermore, long-term exposure to organophosphate (OP) pesticides increases adverse health and cancer risks, specifically among women. Since DDT and its metabolite DDE residues, current-use pesticides, and other chemical pollutants contaminate the environment, exposure to these chemical mixtures can synergize to increase toxicity and disease effects.

A literature review published in Ciência & Saúde Coletiva finds environmental exposure to all classes of pesticides (fungicides, herbicides, insecticides) has an association with childhood astrocytoma (brain/central nervous system [CNS] tumor). CNS tumors represent half of all malignant neoplasms (tumors) in children.

A 2024 Environmental Research study found an association between adverse neurodevelopment (brain function and development) among infants and exposure to the herbicide glyphosate during pregnancy, which becomes more pronounced at 24 months. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure, leading to reduced melatonin levels that ultimately disrupt circadian rhythm and lead to sleep disorders later in life, according to a 2023 study in Antioxidants.

In addition to maternal/prenatal exposure to herbicides, children experience exposure to pyrethroid insecticides early in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life, according to a study published in Frontiers in Public Health in 2023. Moreover, pediatricians strongly agree that pregnant mothers and young children should avoid pesticide exposure during critical development periods.

The state of pesticide regulation and of research into pesticide impacts is inadequate and like nothing so much as a game of “whack-a-mole.” A single pesticide or class of pesticides is studied, a paper is written, and policy makers and regulators may or may not pay attention. Then another one happens, and another, and another, ad infinitum. The pattern of “progress” is similar on the regulation side: individual pesticides registered (aka, approved) by the U.S. Environmental Protection Agency (EPA) are reviewed “on the regular” — but only every 15 years, barring an emergent and urgent concern. Given the cascade of discovery of harmful impacts over the past couple of decades, 15 years has become a very long window in which to allow continued use without review.

When EPA undertakes more timely review due to an urgent concern, it still considers one chemical at a time. Even more fundamentally, its approach to regulation, in the face of evidence of harm, is often characterized by tweaking the use of toxic pesticides “at the margins” — requiring a change to the text on a pesticide label, reducing the time frame in which a compound can be used, restricting application to trained applicators, or other piecemeal actions that are generally wholly inadequate to reducing the health and environmental harms of these compounds being unleashed into the environment.

EPA also continues to fall short on multiple research and regulatory fronts, failing to consider synergistic impacts, multiple exposure vectors, and endocrine disruption effects, among others. In addition, the agency is far too dependent on industry-generated research, influenced by agrochemical industry lobbying, and sometimes, in downright collusion with industry.

It is unconscionable to continue tweaking restrictions on pesticides with known hazards and broad uncertainties about the effect of mixtures, synergistic effects, and cumulative risk, given the availability of organic systems that eliminate those hazards economically and solve the looming environmental threats. Buying, growing, and supporting organic land management can reduce human and environmental contamination from pesticides. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices. Numerous studies find that pesticide metabolite levels in urine significantly decrease when switching to an all-organic diet.

Globally, cancer is one of the leading causes of death, with over eight million people succumbing to the disease every year. Notably, the International Agency for Cancer Research (IARC) predicts a 67.4 percent rise in new cancer cases by 2030. Thus, it is critical that both government officials and the public understand the health implications of pesticide use and exposure on humans, especially when pesticides increase chronic disease risk.

Some elected officials are attempting to take action. The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S. 269 and H.R. 5085, addresses many of the controversial issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S.

Tell EPA to ban carcinogenic pesticides. Tell your Congressional Representative and Senators to support S. 269 and H.R. 5085, the Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA).

Letter to EPA:

I am writing out of concern that EPA is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects.

Occupational exposure to pesticides among nonpregnant women and men may increase childhood cancer risk for offspring. Studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer, specifically leukemia. Acute leukemia is the most common type of childhood cancer, accounting for one of three cancer cases in children ages 0 to 14, and incidence has been steadily increasing among adolescents over the last 30 years.

Even household cleaners, many of which are pesticides, can increase kidney and brain cancer risk in children. Long-term exposure to organophosphate pesticides increases adverse health and cancer risks. A literature review published found environmental exposure to all classes of pesticides is associated with childhood brain/central nervous system tumors, representing half of all malignant tumors in children.

Adverse neurodevelopment among infants is associated with exposure to glyphosate during pregnancy. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure. In addition to maternal/prenatal exposure to herbicides, children experience exposure to pyrethroid insecticides early in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life.

Moreover, pediatricians strongly agree that pregnant mothers and young children should avoid pesticide exposure during critical development periods.

The state of pesticide regulation and of research into pesticide impacts is inadequate and resembles a game of “whack-a-mole”—in which single pesticides or a class of pesticides are studied for specific effects. And EPA only considers one chemical at a time, ignoring research showing that the synergy of exposure to multiple chemicals in the environment that increases toxicity and disease effects. All of these effects have environmental justice implications since farmworkers are most exposed.

More fundamentally, the approach to regulation in the face of evidence of harm, characterized by tweaking the use of toxic pesticides—requiring a change to the text on a pesticide label, reducing the time frame in which a compound can be used, restricting application to trained applicators, or other piecemeal actions—is wholly inadequate to reduce the health and environmental harms of these compounds being unleashed into the environment.

It is unconscionable to continue tweaking restrictions on pesticides with known hazards and broad uncertainties about the effect of mixtures, synergistic effects, and cumulative risk, given the availability of organic systems that eliminate those hazards economically and solve the looming environmental threats. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices.

Our children’s health requires elimination of cancer-causing pesticides.

Thank you.

Letter to U.S. Representative and Senators who are co-sponsors of PACTPA:

I am writing out of concern that our pesticide law is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects.

The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269 and H.R 5085, addresses many of the issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S. I am happy to see that you have joined this effort to protect our nation’s children. In addition to thanking you for your co-sponsorship of the legislation, I’m writing to ask you to also seek broader protections, especially necessary to protect children.

Despite an impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, please consider amending the legislation to:

* Prohibit the registration and use of pesticides that do not meet these criteria:

– Necessary to prevent harm to humans and the environment based on an analysis of all alternatives;

– Cause no harm to humans and the environment; and

– Protect against the existential crises of biodiversity collapse, runaway climate change, and chronic and acute health threats.

* Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration).

* Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects.

* Deny and cancel registrations of all pesticides posing a threat to life in the soil—and hence threatening the climate.

* Deny and cancel registrations of all pesticides posing a threat to any endangered species.

Thank you.

Letter to U.S. Representative and Senators who are NOT co-sponsors of PACTPA:

I am writing out of concern that our pesticide law is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects.

The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269 and H.R 5085, addresses many of the problems with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S.

PACTPA would provide some desperately-needed improvements to FIFRA to better protect people and the environment, including:

* Bans some of the most damaging pesticides scientifically known to cause significant harm to people and the environment:

– Organophosphate insecticides, which have been linked to neurodevelopmental damage in children;

– Neonicotinoid insecticides, which been shown to cause developmental defects, heart deformations, and muscle tremors in unborn children;

– Paraquat, which is one of the most acutely toxic herbicides in the world—already banned in 32 countries, including the European Union.

* Removes dangerous pesticides from the market by:

– Creating a petition process to enable individual citizens to petition the EPA to identify dangerous pesticides so that dangerous pesticides would not remain on the market indefinitely;

– Closing loopholes that have allowed the EPA to issue emergency exemptions and conditional registrations to use pesticides before they have gone through full health and safety review;

– Enabling local communities to enact protective legislation and other policies without being vetoed or preempted by state law;

– Suspending the use of pesticides deemed unsafe by the E.U. or Canada until they are thoroughly reviewed by the EPA.

* Provides protections for frontline communities that bear the burden of pesticide exposure by:

– Requiring employers of farmworkers to report all pesticide-caused injuries to the EPA, with strong penalties for failure to report injuries or retaliating against workers;

– Directing the EPA to review pesticide injury reports and work with pesticide manufacturers to prevent future injury;

– Requiring that all pesticide label instructions be written in Spanish and in any language spoken by more than 500 pesticide applicators.

Despite this impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, please support legislation to:

* Prohibit the registration and use of pesticides that do not meet these criteria:

– Necessary to prevent harm to humans and the environment based on an analysis of all alternatives;

– Cause no harm to humans and the environment; and

– Protect against the existential crises of biodiversity collapse, runaway climate change, and chronic and acute health threats.

* Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration).

* Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects.

* Deny and cancel registrations of all pesticides posing a threat to life in the soil—hence threatening the climate.

* Deny and cancel registrations of all pesticides posing a threat to any endangered species.

Thank you.

(Beyond Pesticides, April 19, 2024) Parkinson’s disease (PD) and certain forms of dementia have been associated with exposure to pesticides, industrial chemicals, and air pollution for decades. But the mechanisms of disease progression have been unclear, and U.S. regulators have been reluctant to recognize the risks. Now neurologist E. Ray Dorsey, MD of the University of Rochester and researchers from the University of Alabama at Birmingham and Aarhus University in Denmark propose a new research paradigm based on tracking how toxicants cause neurodegeneration through inhalation and ingestion pathways.

The paradigm, the authors believe, can be used to gain insight into how PD and a form of dementia known as Lewy body disease (LBD) are initiated as many as 50 years before the onset of symptoms. Dorsey and colleagues build on a recent theory that PD and LBD may be two versions of the same basic disease, both involving Lewy bodies in the nervous system.

The group’s proposal was published in the Journal of Parkinson’s Disease in April. If its recommended research agenda produces the anticipated empirical support, the new paradigm will demand integration of many interdisciplinary lines of evidence showing that environmental exposures to synthetic chemicals may be the primary cause of the worldwide epidemic of neurodegenerative disease. Regulatory capture by industry and spineless policy responses to it will no longer suffice to prevent reimagining chemicals policy at a most basic level.

A symposium to discuss the proposed paradigm will occur on Monday, May 20 from 9:00 a.m. to 5:30 p.m. at the Phillips Collection, 1600 21st Street NW, Washington, D.C. Sessions will be moderated by journalists Katie Couric, Jake Tapper, and others. The Michael J. Fox Foundation is a major conference funder.

Dorsey and colleagues review the mounting evidence that PD and LBD have two principal routes to their ultimate neurological harms. One, known as “brain-first,” is quite direct: inhaled through the nose, a toxicant can travel to the olfactory bulb in the brain, from which it spreads to many other brain structures. The second route, through ingestion, called “body-first,” takes the toxicant to the gut, where it initiates the Lewy body disorder in the enteric nervous system (ENS or digestive system’s nervous system). Lewy bodies then propagate into the parasympathetic nervous system, the central nervous system and the brain. Thus, according to this paradigm, the dysfunctions associated with PD and LBD affect the entire neurological network of the body, not just the brain.

The researchers estimate that the majority of LBD cases and about a third of PD cases result from the body-first route. The timing of onset of various symptoms such as loss of motor control, sleep disorders and dementia varies according to the route.

One of the pesticides associated with PD is paraquat, a powerful herbicide currently registered by EPA for application only by licensed operators. Our April 16 Daily News Brief delineates the reasons paraquat should be taken off the market entirely.

Paraquat presents myriad health hazards—EPA itself says, “One small sip can be fatal and there is no antidote.” Beyond this direct lethality to humans and many other organisms, paraquat is linked to thyroid cancer, lung fibrosis, endocrine disruption and liver tumors. It was banned in the European Union in 2007; currently more than 60 countries prohibit its use. But EPA refused to accept the mounting evidence that paraquat is implicated in PD, stating in a 2019 human health risk assessment that for both occupational and non-occupational exposures, there is “insufficient epidemiologic evidence of a clear associative or causal relationship.” This echoes paraquat manufacturer Syngenta’s position in class action litigation brought by PD victims. One bright spot is that the California Assembly is currently considering phasing out paraquat from all uses by the end of 2025.

Only 15 percent of PD victims have a family history of the disease, which implies that environmental factors—and likely multiple simultaneous insults—are involved. Toxicants linked to PD and LBD include not just paraquat but also organochlorine pesticides, trichloroethylene and perchloroethylene (largely responsible, along with benzene and vinyl chloride, for the severe water contamination at Camp Lejeune in California), and particulates from fossil fuel air pollution and wildfires. Dorsey and colleagues’ literature review includes many studies demonstrating PD’s and LBD’s association with environmental toxicants. “In rural areas,” they write, “the prevalence of PD is almost perfectly correlated with pesticide use.” Just drinking well water and working in agriculture are strongly associated with PD prevalence.

The exact processes by which degenerative brain diseases progress remain complex and confusing. PD and LBD resemble Alzheimer’s disease and have some commonality with transmissible spongiform encephalopathies such as Creutzfeldt-Jakob disease, “mad cow,” and the sheep disease scrapie. In PD and LBD, a protein called alpha-synuclein (α-Syn) is important to neuronal signaling. It is something of an oddity, being able to fold itself into multiple configurations even in healthy brains, but is also prone to misfold in ways that interfere with neurotransmitters. During development of PD and LBD, clumps of α-Syn called Lewy bodies form. Once this happens, neurons die and various neurological processes affecting motor coordination, sleep, memory and many other functions begin to fail. Dorsey’s team suggest that α-Syn behaves something like the prions that misfold to induce the transmissible encephalopathies. One misfolded protein can trigger another to copy it, propagating the problem throughout a nervous system.

The authors emphasize that not everyone exposed to environmental toxicants develops PD or LBD. Age at exposure, length of exposure, the involvement of multiple toxicants, and other factors influence the outcome. While a family history of PD and LBD accounts for a small percentage of cases, it does raise the risk of contracting the diseases, and several genes are known to be involved. Little of their influence is understood. At the same time, however, Dorsey and colleagues write that despite having known for a generation about environmental factors, “[We] have fundamentally underinvested in and under-investigated the role environmental toxicants are playing.”

Much research remains to determine the validity of the double-route toxicant paradigm. Clearly there must be research into enteric Lewy bodies and their propagation throughout the whole body nervous system. Dorsey and colleagues suggest approaches for further investigation of exposure scenarios, including comparative analysis of environmental samples such as air, water, and food, as well as biomonitoring samples such as breast milk, urine and blood; and geospatial mapping of PD/LBD prevalence in areas where pesticides and industrial chemicals are present. They also find reason to hope that the severity of these incurable, devastating and fatal diseases can be reduced if exposures are reduced even after disease onset.

Proving the principle will require interdisciplinary studies and synthesis of results from numerous research specialties. If it pans out, it will throw open the gates of inquiry and destabilize chemicals policy, because if PD, LBD and other neurodegenerative diseases are initiated by environmental exposures through the gut and olfactory pathways to the nervous system, the causes of these diseases can no longer be considered in piecemeal fashion. They cannot be entirely explained as mysterious ailments that randomly strike unfortunate people, or are determined by genes. They must be considered as manifestations of the fossil fuel system that is destroying the health of humans and ecosystems and dealt with at the scale of the problem.

For more information on the adverse health impacts of paraquat, see its entries in Beyond Pesticides’ Gateway on Pesticide Hazards and Safe Pest Management and Pesticide-Induced Disease Database.

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

Sources:

The Body, the Brain, the Environment, and Parkinson’s Disease
Dorsey, E. Ray et al.
Journal of Parkinson’s Disease
1 Jan. 2024: 1 – 19.
https://content.iospress.com/articles/journal-of-parkinsons-disease/jpd240019

Risk of Parkinson Disease Among Service Members at Marine Corps Base Camp Lejeune
Samuel M. Goldman et al.
JAMA Neurol. 2023;80(7):673-681. doi:10.1001/jamaneurol.2023.1168
https://jamanetwork.com/journals/jamaneurology/article-abstract/2805037

Brain and Environment Symposium: A day-long symposium to uncover the influence of environmental toxicants on brain disorders
https://brainandenvironment.org/

Comment submitted by Beyond Pesticides
Paraquat Interim Registration Review
March 29, 2024
EPA-HQ-OPP-2011-0855
https://downloads.regulations.gov/EPA-HQ-OPP-2011-0855-0339/attachment_1.pdf

Secret files suggest chemical giant feared weedkiller’s link to Parkinson’s disease
Documents seen by Guardian detail effort to refute scientific research into paraquat and derail nomination of key EPA adviser
by Carey Gillam and Aliya Uteuova
https://www.theguardian.com/us-news/2022/oct/20/syngenta-weedkiller-pesticide-parkinsons-disease-paraquat-documents

(Beyond Pesticides, April 18, 2024) University of Michigan researchers have found a statistically significant relationship between heightened risk of amyotrophic lateral sclerosis (ALS) and household exposure to lawn care products and pesticides. The study results were published earlier this month in Amyotrophic Lateral Sclerosis and Frontotemporal Degeneration. The interdisciplinary research team concludes that modifying residential exposure to toxic substances, including pesticides, can play an important role in ALS susceptibility and prognosis. The results build on a substantial body of scientific literature identifying pesticide exposure in various ALS cohort studies. Advocates say that these adverse effects, along with other numerous health and environmental effects, inform their call for the phaseout of toxic pesticide use and the adoption of alternative practices and eco-compatible products.

All participants in this study are patients at the University of Michigan Pranger ALS Clinic with Gold Coast ALS diagnosis, which according to a Muscle & Nerve study refers to the identification of two factors: “progressive motor impairment documented by history or repeated clinical assessment” and “the presence of upper and lower motor neuron dysfunction in a least one body region.” All 367 ALS and 255 control patients were tasked with completing a survey in which they self-reported their exposure to a list of toxic substances at four households over their lives: current home, birth home, and two other homes where they had lived the longest. The researchers split up the patients into three “latent profile” groups. The first group consisted of participants with “high storage of chemicals in a detached garage;” the second group consisted of participants “who had high storage of chemicals in an attached garage;” and the third group consisted of participants “who had low storage of chemicals in a garage.” Generally, group three participants had a higher proportion of participants without ALS than the other two groups with detached and attached garages with higher proportions of chemicals.

The researchers in this study find that pesticide storage, lawn care product storage, and woodworking supplies storage indoors have a statistically significant relationship with poorer ALS survival.

Researchers used a descriptive statistical analysis for their study cohort, using logistic regression models “to estimate one-at-a-time association[s] between residential exposures and case/control status.” The researchers describe their analytical approach as follows: “[M]ultinomial [more than two categories] regression models estimated associations between residential exposures and three onset segments (bulbar, cervical, lumbar); and Cox proportional hazards models estimated associations between residential exposures and post-diagnosis survival.” Onset segments refer to the parts of the body in which patients noticed early indications of motor disfunction consistent with ALS. “Logistic and multinomial regression models were adjusted for military service, sex, education, life-years covered by self-reported residences, and life-years not covered by self-reported residences. The hazards models were adjusted for military service, sex, age at diagnosis, education, log-transformed time between symptom onset and diagnosis, El Escorial criteria [for ALS classification], onset segment, family history of ALS, life-years covered by the self-reported residences, and life-years not covered by the self-reported residences.” The use of logistic and multinomial regression is helpful in determining patient demographics not otherwise covered in the self-reported survey component of the study.        

A team of researchers at Michigan Medicine reached similar conclusions in a 2022 study published in International Archives of Occupational and Environmental Health, which indicated that ALS patients working in manufacturing, welding, and chemical jobs “reported higher occupational exposure to metals, particulate matter, volatile organic compounds and combustion pollutants prior to diagnosis.”

While there is no confirmed treatment or cure for ALS, scientists have engaged in studies to better understand the triggers for this neurodegenerative condition since it was discovered in 1869 by French neurologist Jean-Martin Charcot. Approximately 5,000 new cases of ALS are documented annually in the United States, according to the Centers for Disease Control and Prevention. There is sporadic ALS and familial ALS, with the former making up more than 9 in 10 of all ALS cases. Sporadic ALS means that the condition is not necessarily onset by a particular risk factor or familial history. Cohort studies on sporadic ALS are important to follow because studies such as the one conducted by Michigan Medicine indicate the associated risks that pesticide applicators face with heightened risk of debilitating chronic illnesses such as ALS. Otherwise regarding familial history cases, according to National Institute of Neurological Disorders and Stroke, 25-40 percent of all cases are a result of a defect in the C9orf72 gene and another 12-20 percent of all cases are from a genetic mutation in the SOD1 gene.

Beyond Pesticides tracks the latest scientific literature on adverse health effects of toxic pesticide exposure, including ALS. A 2021 study published in Toxicology, for example, found individuals working or living in areas with frequent neurotoxic herbicide, insecticide, and fungicide (i.e. 2,4-D, glyphosate, carbaryl, and chlorpyrifos) use experience more ALS incidences than the general population. An earlier study published in International Journal of Environmental Research and Public Health in 2020 determined that exposure to agricultural and industrial pesticides, solvents (thinners), electromagnetic fields, and heavy metals predispose humans to ALS. For more studies and analysis, see the Daily News Blog section on ALS.

Advocates, scientists, community leaders, and physicians have engaged with Beyond Pesticides resources to mobilize their communities and institutions to address the longstanding adverse health effects of pesticide exposure. After tracking the latest scientific literature, synthetizing breaking developments and studies through the Daily News Blog, and submitting public comments and testimony at local, state and national levels for over four decades, advocates look to Beyond Pesticides to meet the mission of eliminating toxic petrochemical pesticide use by 2032. See Gateway on Pesticide Hazards and Safe Pest Management to learn about specific pesticide ingredients and the various adverse health impacts they impose on wildlife, ecosystems, and humans. See Pesticide-Induced Disease Database to learn about the impacts of toxic pesticides in contributing to chronic diseases, including ALS. See Non-Toxic Lawns and Landscapes to learn about strategies and access resources to move beyond the use of toxic petrochemicals in lawncare throughout your community.

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

Source: Amyotrophic Lateral Sclerosis and Frontotemporal Degeneration

(Beyond Pesticides, April 17, 2024) With headlines drawing public attention to the contamination of drinking water after years of federal government neglect, the U.S. Environmental Protection Agency (EPA) announced on April 10 new standards to reduce public exposure to PFAS, or per- and polyfluoroalkyl substances, commonly referred to as “forever chemicals” because of their persistence. EPA has finalized a National Primary Drinking Water Regulation (NPDWR) for six PFAS, including PFOA and PFOS, which EPA has recognized have no safe level of exposure, regulating new chemicals for the first time since the 1996 amendments to the Safe Drinking Water Act (SDWA). PFAS persistence and bioaccumulation in humans, wildlife, and the environment is due to the strength of a resulting fluorine–carbon atom bond. PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply—among other resources—is ubiquitous worldwide. PFAS is used in everyday products, including cookware, clothes, carpets, as an anti-sticking and anti-stain agent, in plastics, machinery, and as a pesticide. The action was welcomed by environmentalists and public health advocates as an important step but left many concerned that any level of exposure to these chemicals is unacceptable and critical of EPA’s ongoing failure to act despite years of overwhelming scientific evidence of harm and the availability of safer alternative materials and practices.

PFAS or related compounds are included in 70% of pesticides introduced to the global market from 2015 to 2020, according to a review paper published in January 2022 in Environmental Pollution. And the surge in their use has come without a full understanding of their potential impact on the environment and human health. PFAS health risks include developmental, metabolic, cardiovascular, and reproductive harm, cancer, damage to the liver, kidneys, and respiratory system, as well as the potential to increase the chance of disease infection and severity. Gestational (during pregnancy) and childhood exposure to PFAS increases cardiometabolic risk, or the risk of heart diseases and metabolic disorders, later in life, according to a Brown University study published in Environment International in 2021.  In light of the adverse effects, Beyond Pesticides has urged EPA and other federal agencies to advance alternatives to PFAS, rather than establish levels of harm with acceptable residues, issuing a nationwide action in March calling for the federal government to facilitate a transition away from plastics in farming, food, and water.

PFAS Solution Must Be Comprehensive: Stop Use of PFAS, Prevent “New” PFAS Replacements

The PFAS contamination problem, according to advocates, calls for a comprehensive policy rather than the “whack-a-mole” approach to chasing individual contamination crises after they have occurred and inflicted serious harm to people’s health. With a holistic strategy, like that contained in organic land management under the Organic Foods Production Act (OFPA), the government must consider “cradle-to-grave,” from production through use to disposal, and require that systems are put in place to prevent the need for use of synthetic materials. In this context, the goal is to eliminate the use of petrochemical substances that are contributing to daily health threats, biodiversity collapse, and the climate emergency.

EPA PFAS Drinking Water Regulation

The NPDWR establishes maximum contamination limits (MCLs) for PFOA and PFOS at 4 parts per trillion (ppt) (the limit of detection), two among the roughly 14,000 known PFAS. Additionally, the rule imposes a 10 parts10 parts per trillion (ppt) limit for three other PFAS—PFHxS, PFNA, and HFPO-DA (commonly referred to as GenX), while introducing a combined limit for four PFAS, calculated using a Hazard Index method. The Hazard Index calculates a compliance value from the detected PFAS levels—if the total ratio of these levels reaches or exceeds 1.0, water systems are required to lower these PFAS levels. Actions might be necessary even if only one of these four chemicals is detected at significant levels. EPA plans to provide an online calculator to help water systems determine their Hazard Index compliance. In addition, regulated public water systems have three years to complete their initial monitoring. Systems must include their results in their Annual Water Quality reports to customers, and PFAS detected above the new standards triggers a requirement to reduce if levels exceed the new limits within five years. EPA estimates that six to ten percent of water systems will be affected. These rules will be implemented by and will require state, tribal, and other public water systems to implement testing and treatment to remove these chemicals.

Additionally, EPA has set Maximum Contaminant Level Goals (MCLGs), which are non-enforceable health goals indicating safe levels without any health risks. These goals are not legally enforceable, focusing purely on health impacts without considering economic or technical feasibility—unlike MCLs, which are legally enforceable under SDWA and require a cost-benefit analysis. EPA has set MCLGs at zero for PFOA and PFOS, recognizing no level of exposure is safe, and 10 parts per trillion ppt for the remaining PFAS. Given that EPA itself has set health advisory levels for certain PFAS at zero, or in the parts per quadrillion, advocates continue to raise alarm at the inability of the regulatory framework to impact the enormity of the crises PFAS represents.

Through the Bipartisan Infrastructure Law, EPA has $21 billion allocated to strengthen U.S. drinking water systems, with $9 billion targeted toward addressing PFAS and emerging contaminants. The financing programs are part of President Biden’s Justice40 Initiative, seeking to have 40% of the overall benefits of certain federal investments flow to disadvantaged communities historically marginalized by underinvestment and overburdened by pollution. With this funding, EPA commits to assisting water systems with the adoption of technologies like granular activated carbon and reverse osmosis to meet the new standards.

After years of advocate pressure, EPA began to take action under its PFAS Strategic Roadmap—including “designat[ing] two of the most widely used PFAS [PFOA and PFOS] as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),” issuing interim updated drinking water health advisories for PFOA and PFOS, and issuing final health advisories on two others that had been considered “replacement” chemicals for manufacturing uses—perfluorobutane sulfonic acid and its potassium salt (PFBS), and hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (the so-called “GenX chemicals”). And yet, amid the public outcry, the number of PFAS compounds continues to grow. Since the phase-out of PFOA and PFOS, companies have shifted to “short-chain” PFAS such as GenX, which is now a significant concern, for example, in the Cape Fear Watershed downstream of a Chemours manufacturing plant in North Carolina,

Despite these new drinking water standards and progress, EPA’s steps are seen as incremental in confronting the pervasive threat of PFAS. This suggests a need for more aggressive and comprehensive regulations that preemptively curb the production and widespread use of PFAS rather than just managing their consequences. While setting a floor, advocates note that only six PFAS chemicals in use and production are covered by the new regulations.

In the absence of viable solutions at the federal level, a 2022 Safer States’ analysis of state-level legislation on PFAS demonstrates the extent of the problem that 22 states have taken steps to protect their residents. Eleven states (ME, MA, MI, NH, NJ, NY, PA, RI, VT, WA, WI) have implemented standards like Maximum Contaminant Levels (MCLs) for specific PFAS in drinking water. As of January, Maine currently enforces an interim standard during its rule-making process to set final PFAS MCLs, with a phase out by 2030, except for “currently unavoidable use.” Delaware and Virginia are also in the process of setting their own PFAS standards. Additionally, twelve states (AK, CA, CT, CO, HI, IL, MD, MN, NC, NM, OH, OR) have established guidance, health advisories, or notification levels for various PFAS chemicals to protect their residents. A handful of state legislatures are considering banning pesticides containing PFAS entirely—as the Maryland General Assembly considers HB 1190, prohibiting the sale and use of pesticides with PFAS as an active ingredient by 2025. (See Beyond Pesticides’ statement in support here and call to action here). Furthermore, recognizing the impacts on the agricultural sector from PFAS, the state of Maine has taken the lead in both state and federal efforts to support farmers who have been affected by PFAS contamination, including the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act. 

PFAS Contamination Vectors

As Beyond Pesticides reported in July 2023, a study by the United States Geological Survey (USGS) finds that almost half of U.S. tap water is contaminated with PFAS chemicals, with measured concentrations in both private wells and public water sources. Authors of the study “estimate that at least one PFAS could be detected in about 45% of U.S. drinking-water samples,” likely a low estimate as only 32 are detectable by USGS lab tests. Advocates note that while PFOA and PFOS are the most studied, it should not be implied that other legacy contaminants are safe or safer—the absence of knowledge does not translate to an absence of harm.

A known source of soil and drinking water contamination is PFAS added as ‘inert’ ingredients to pesticides and fertilizers. As Beyond Pesticides has noted, “Why would PFAS be found in a pesticide formulation? The chemicals are included as dispersants, surfactants, anti-foaming agents, or other pesticide adjuvants intended to increase the effect of the active ingredient. EPA includes PFAS chemicals in its “Inert Finder” database, and according to a PEER [Public Employees for Environmental Responsibility] press release, many companies have patents on file for pesticide formulations containing PFAS, shrouded behind claims of trade secret formulation and do not disclose PFAS ingredients. PFAS soil contamination is also likely from PFAS as an undisclosed ingredient in pesticide and/or fertilizer formulations.  pesticides with PFAS active ingredients will not cause disruptions to the pest management industry. Pest problems in agriculture and landscaped areas can be prevented through practices that improve soil health and promote biodiversity and habitat for pest predators. If pest problems do become an issue, a wide range of insecticidal soaps and essential oils, classified either as certified organic, or minimum risk, are available and represent a least-toxic option. See Beyond Pesticides resources on Organic and Organic Compatible Products, what individuals can do organically in yards and gardens, and the benefits of organic agriculture and choosing organic food.

Secondly, PFAS contamination results from leaching out of plastic containers and contaminating food products. As reported by Beyond Pesticides in 2023, research published in Environment Technology and Letters confirm the propensity of PFAS to contaminate various pesticide products through storage containers. Testing done by PEER in 2020 initiated testing done separately by the Massachusetts Department of Environmental Protection and the EPA, all of which found high levels of PFAS in several mosquito insecticide products sprayed throughout states like Massachusetts, Florida, and New York. Ultimately, EPA traced significant PFAS contamination to the manufacturing process used since 1983 by one manufacturer, Inhance Technologies, which produces 200 million HDPE containers a year. Multiple lawsuits and EPA stop use orders have been ineffective at ending this manufacturing process, used only by Inhance, although some other plastic containers have been shown to leach PFAS at lower levels.

Finally, PFAS compounds have been found to contaminate water and irrigation sources, and soils themselves — often using fertilizers made from so-called “biosludge” (biosolids) from local waste treatment plants. In addition, these plants may discharge millions of gallons of wastewater into waterways, contaminating them; current waste and water treatment generally does not eliminate PFAS compounds from the treated effluent water. Biosolids and wastewater have long been sources of exposure concerns related to pesticides, industrial chemicals, pharmaceuticals, personal care products, and household chemicals; PFAS contamination is now rising as a specific and concerning addition to that nasty list. These forever (and perhaps “everywhere”) compounds may be contaminating nearly 20 million acres of productive agricultural land in the U.S. A significant portion of farmers, perhaps 5%, is using biosludge from local treatment plants as fertilizer on their acreage. The use of biosludge was thought by many, a decade ago, to be a sensible use of the waste products from treatment; it was even encouraged by many state agricultural department programs, but now it is recognized that these products present threats when spread on fields that produce food—or anywhere that presents the possibility of living or environmental exposures to PFAS compounds. Notably, there are currently no federal requirements to test such sludge “fertilizers” for the presence of PFAS.  (See Beyond Pesticides reporting from 2022 on Maine laws against biosludge).

Biosludge products are not only sold to farmers; they also show up on the shelves of retailers as fertilizers for consumer home and garden use. The organization wrote in 2021 that these products not only often contain PFAS but also harbor “hazardous pesticides, heavy metals, antibiotics, and other pharmaceuticals, personal care products, and a range of other toxicants… None of these risks [are] relayed to consumers on fertilizer packages. With fertilizer regulations failing the American consumer, it becomes more important than ever to seek out certified organic fertilizer products.” (See here, here, and here for Beyond Pesticides list of organic and organic-compatible products).

Organic agriculture and land care

These new drinking water regulations from EPA would not happen without pressure from advocates, non-profit groups, and independent science, however, the solution does not go far enough. Transition, of course, requires time and effort, and should be supported by the state (and federal) governments, but getting off the toxic chemical treadmill in agriculture resolves multiple environmental and health problems simultaneously — including that of PFAS in pesticides and fertilizers and related contamination of soils, groundwater, and drinking water. EPA’s latest attempt underscores federal failures in regulation and the gravity of realigning federal and state agencies so that precaution becomes the guiding watchword. Legacy or “forever” chemical contamination is a dramatic demonstration of how a historically non-precautionary ethic in the U.S. can cause egregious harm — even years and decades hence. 

And the viable solution available to all producers? Organic regenerative agriculture.

Certified organic production and food labeled “USDA Organic” may not be produced with biosolids or fertilizers containing biosolids, and the National Organic Program proscribes the use of toxic pesticides.  For more on Beyond Pesticides’ work with grassroots support across the U.S. to “Keeping Organic Strong” through the robust organic certification process, overseen by the National Organic Standards Board (NOSB).  The strength of the Organic Certification label rests on the independent system established by the 1990 Organic Food Production Act and, despite industry pressure to weaken organic certification standards (see most recent Beyond Pesticides March 18, 2024, comments to the NOSB on Compost), consumers and organic producers alike can have confidence in the integrity of organic certification.

Beyond Pesticides offers a variety of articles in the archives detailing the dangers and prevalence of PFAS in pesticides. Check out “Threatened Waters: Turning the Tide on Pesticide Contamination” to learn more about the health and safety of water sources. Click here to sign up for action alerts from Beyond Pesticides to take action on PFAS contamination and other environmental issues, and please take a moment to explore Beyond Pesticides’ Tools for Change webpage to begin your journey in advocacy. 

Another important place to eliminate exposure to the harmful impacts of synthetic pesticide/fertilizer use is in our local public parks, playgrounds, and open spaces managed by municipalities, school districts, and colleges. Beyond Pesticides established the Parks for a Sustainable Future program to assist with the transition to organic land management in communities across the U.S. This holistic approach provides a 2-year pilot program with free technical training and transition to organic management guidance for two sites. See here for more information. 

The organization also strives to maintain the integrity of organic standards through the Keeping Organic Strong campaign and historical work to transition agriculture to organic practices. In 2022, Beyond Pesticides sponsored a Climate Change Calls for Phase Out of Fossil Fuels Linked to Petrochemical Pesticides and Fertilizer series of national virtual seminars (with archived videos) covering health, biodiversity, and climate. For more on climate-friendly organic agriculture, see Daily News and the groundbreaking work of the Rodale Institute, as captured in its Farming Systems Trial — 40-Year Report, which shows the efficacy and benefits of organic agriculture. California Certified Organic Farmers Association’s Roadmap to an Organic California provides a policy framework for advancing agricultural programs that eliminate the use of petrochemical PFAS containing pesticides and fertilizers while combating climate change.  

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

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

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

Sources

Biden-Harris Administration Finalizes First-Ever National Drinking Water Standard to Protect 100M People from PFAS Pollution, EPA announcement, April 10, 2024.

Why is the EPA regulating PFAS and what are these ‘forever chemicals’? The Washington Post, April 10, 2024.

Meaningful and Achievable Steps You Can Take to Reduce Your Risk, EPA website

Reducing PFAS in Drinking Water with Treatment Technologies, EPA website

Pesticides Are Spreading Toxic ‘Forever Chemicals,’ Scientists Warn, Scientific American, June 2022.

Revisiting pesticide pollution: The case of fluorinated pesticides, Environmental Pollution, January 2022.

PFAS Interactive Map: PFAS Contamination Crisis, Environmental Working Group (EWG) website 

Fertilizers Compatible with Organic Landscape Management, Beyond Pesticides Fact Sheet

Pesticides in My Drinking Water? Beyond Pesticides Fact Sheet

Per- and Polyfluorinated Substances (PFAS) Factsheet, National Biomonitoring Program, U.S. Centers for Disease Control and Prevention

EPA Announces New Drinking Water Health Advisories for PFAS Chemicals, $1 Billion in Bipartisan Infrastructure Law Funding to Strengthen Health Protections, EPA Announcement, June 15, 2022.

PFAS-FREE PROCUREMENT ACT OF 2023 Report by The Committee on Homeland Security and Governmental Affairs, United States Senate, November 30, 2023.

(Beyond Pesticides, April 16, 2024) Citing serious health issues associated with its use, including Parkinson’s disease, and inaction by the U.S. Environmental Protection Agency (EPA), the weed killer paraquat would be banned through legislation introduced in the California Assembly (AB 1963). Assemblymember Laura Friedman (D-Burbank), in the Assembly’s leadership, chair of the bicameral Environmental Caucus, and a self-described “steadfast advocate for the environment [and] sustainable communities,” introduced the legislation to phase out and ban the use of paraquat across all uses, including agriculture, by the end of 2025. The introduction of this bill follows a long history of scientific documentation of the pesticide’s hazards, fits and starts in the regulatory process, and previous efforts to ban the herbicide through legislative action. In 2018, U.S. Representative Nydia Velasquez (D-NY) introduced legislation (Protect Against Paraquat Act) to ban paraquat.

In a 1986 factsheet, Beyond Pesticides wrote, “In mammals, paraquat attacks the epithelial tissues (the skin, nails, the cornea of the eye, and the linings of the respiratory and gastrointestinal tract). There have also been reports of damage to the heart muscle and to nerves. It is easily absorbed through the skin as well as orally [and through inhalation]. Paraquat causes specific damage to the lungs, where residues concentrate in a particular lung cell, the pneumonocyte. This leads to the formation of large amounts of non-functional scar tissue so that poisoning victims suffocate to death. Paraquat is a lung carcinogen in rats.” A 2005 study in Toxicological Sciences was able to “reproduce features of Parkinson’s disease (PD) in experimental animals.” And studies continued to replicate findings associating paraquat with Parkinson’s disease, as the U.S. Environmental Protection Agency (EPA) continued to reject the need for action. Paraquat was banned in the European Union in 2007, following its prohibition years earlier in 13 countries, including Sweden, Denmark, and Austria.

In the U.S., paraquat is currently a restricted-use pesticide (meaning it can only be applied by certified applicators or those working under their on- or off-site supervision) and banned on golf courses. There is established and mounting evidence of links between minimal exposure and various adverse health impacts for humans and wildlife. This has mobilized advocates within and outside of California for more robust action by the federal government to serve the public interest.

In 2018, EPA downplayed the connection between exposure to paraquat and the development of Parkinson’s disease, per registration review documents released by the agency. But, Assemblymember Friedman, in a press release on the day the legislation was introduced, said, “We cannot afford to ignore decades of mounting evidence linking paraquat exposure to Parkinson’s disease, non-Hodgkin, and childhood leukemia.” She continued: “In 2021, the latest year for which data are publicly available, just over 430,000 pounds were applied in California, primarily in Kern, Kings, Fresno, Merced, and Tulare counties. The herbicide is extremely toxic to humans, with low doses causing death, and it has been linked to increased risk of Parkinson’s disease.”

Beyond Pesticides continues to track the latest scientific literature on adverse health impacts of paraquat. Within all the single-pollutant models employed in a 2022 study published in Journal of Clinical Endocrinology and Metabolism, researchers found a linkage between paraquat dichloride and thyroid cancer. A different study published that same year in Independent determined the toxic impacts of paraquat on bird embryos, including the Japanese quail, mallards, bobwhite quail, and ring-necked pheasant. Over 60 countries have already banned the use, production, and sale of paraquat, including China, where the pesticide was first developed. EPA’s actions, or inaction as some advocates would argue, on recognizing the scientific literature on paraquat exposure and Parkinson’s disease represent a failure of EPA to take a proactive approach in ending the continued exposure and health impacts of the toxic herbicide to chemically sensitive populations. According to the EPA’s Office of Pesticide Programs’ guidelines on paraquat and diquat, these ammonium herbicides are life-threatening in toxic doses and hold the potential to “impact GI tract, kidney, lungs liver, heart, and other organs.” Specifically regarding paraquat, “pulmonary fibrosis is the usual cause of death in paraquat poisoning.”

In 2019, EPA released, “Systematic Review of the Literature to Evaluate the Relationship between Paraquat Dichloride Exposure and Parkinson’s Disease.” Advocates, following this ruling, lambasted the EPA for its dismissal of the linkage between Paraquat exposure and Parkinson’s Disease, despite a growing body of literature between 2009 and 2019 and, given that “[a]n EPA environmental review conducted as part of the reregistration process found evidence of significant reproductive harm to small mammals, and determined that songbirds may be exposed to levels well beyond lethal concentrations known to cause death. Threats to mammals and songbirds are particularly concerning considering significant declines in these animal groups.”

At that time, Beyond Pesticides submitted comments and concluded: “Since the agency risk assessments are intended to support Agency risk management review, risk management recommendations are not provided in its draft risk assessments. The many risk concerns and uncertainties (lack of data) identified in both the human health and ecological risk assessments makes it unconscionable to allow continued use of such a dangerous pesticide as paraquat. A restricted use label will do little to allay the ecological risk concerns enumerated or adequately protect persons in vicinity of treatments or in harvest and post-harvest activities. Taken together with the clear inability of the agency to preclude potential for Parkinson’s disease, it is recommended that the use of paraquat should be immediately suspended if not outright cancelled as it is in the EU and several other countries.”

On alternatives to paraquat, Beyond Pesticides stated, “The agency asserts that there are no direct alternatives to paraquat, however, several alternatives, chemical and non-chemical, are widely available. Given the availability of alternative pest management practices that incorporate alternative cultural practices and/or less toxic products, including other registered pesticides, the agency has a statutory duty to revoke all registrations of the paraquat under its unreasonable adverse effects standard in FIFRA. The risks and uncertainties identified by the agency in its assessments and the independent scientific literature are not reasonable in light of the availability of less toxic alternatives and cultural practices. To refute a rebuttable presumption against paraquat registration, the many data gaps listed previously would need to be fulfilled and reveal opposing evidence to the existing adverse effect data.”

In late January 2024, EPA released a report, “Preliminary Supplemental Consideration of Certain Issues in Support of its Interim Registration Review Decision for Paraquat.” According to the interim report, “The Agency prepared several documents to support its 2021 interim registration review decision for paraquat and attempted ‘to connect the dots’ of the risk-benefit information contained in its support documents in the Paraquat ID.” The results of this interim report, specifically regarding linkage to Parkinson’s Disease and other health risks associated with chronic exposure to paraquat, highlight the flaws in EPA’s approach to risk assessment and opportunities to incorporate additional sources of sound science in the final report in January 2025. For example, “EPA intends to consider [additional studies] as part of the next steps in this process. First, EPA recognizes that the Michael J. Fox Foundation and Earthjustice submitted letters to EPA on August 4, 2023, along with information that they believe is relevant to EPA’s consideration of paraquat’s health risks. This information consisted of approximately 90 submissions including scientific studies, as well as testimony filed in an ongoing state lawsuit concerning paraquat. EPA has included these documents in the docket for paraquat at EPA-HQ-OPP-2011-0855-0317 and EPA-HQ-OPP2011-0855-0313. While the Agency has started reviewing that material, it was unable to complete that review prior to the issuance of this document. [As a result, this document does not reflect the Agency’s review of any of those materials.] Second, new information on paraquat vapor pressure was submitted on January 18, 2024, which may impact the Agency’s volatilization analysis. Due to the late submission of that data, EPA has not incorporated that information into this document. Therefore, EPA intends to address that material along with any other significant information it receives during the public comment period and incorporate its consideration of those materials into any final document(s) issued by January 17, 2025.” Advocates found it surprising that the EPA was not able to review studies submitted by the Michael J. Fox Foundation and Earthjustice even though the agency had more than several months for review. Beyond Pesticides will continue to track updates to this upcoming public comment period to insert new studies and data points for the EPA to include in their final report.  

In April 2024, Beyond Pesticides’ comments on the Paraquat Interim Registration Review stated, “EPA failed to assess a common mechanism of toxicity for PQ and any other substance in its review for the ID, erroneously concluding that PQ does not have a common mechanism of toxicity or combined toxic action with other substances that may interact and potentiate its action.” The comments address the mandates under the Federal Insecticide, Fungicide, and Rodenticide Act and Food Quality Protection Act (FQPA), stating that the agency failed to meet its mandate to obtain proof that paraquat “unequivocally does not cause or contribute to Parkinson’s Disease” and to assess paraquat endocrinological risk through FQPA’s Endocrine Disruptor Screening Program, respectively. Additionally, the comments cite EPA’s failure to adequately review and incorporate the breadth of studies pointing to a relationship between Parkinson’s Disease and paraquat exposure; failure within its ecological risk assessment to consider risks to endangered wildlife and subsequent ecosystem balance concerns; and failure in its risk-benefit analysis to fully consider the risks of paraquat exposure

Beyond Pesticides and advocates around the nation take the position that the failed regulation, and subsequent harm, caused by paraquat is but one representation of a failed regulatory system that can and should do more to eliminate the use of toxic petrochemical-based pesticides. The convergence of crosscutting crises of health threats, biodiversity collapse, and the climate emergency stems from continued reliance on fossil fuels and petrochemical pesticides and fertilizers, which perpetuate the harms of greenhouse gas emissions. These crises are causing ecosystem fragmentation and failure, and public health crises that undermine the nutritional integrity of the food supply and the scientific integrity the public relies on for safety and well-being. After decades of working with farmworkers and farmers who face the brunt of toxic pesticide exposure, Beyond Pesticides echoes the call for advocates across the nation to expand and strengthen organic land management principles to move beyond the existing product substitution framework that leads to the continuous use of toxic pesticides. We have engaged our members with actions to call for EPA to improve its scientific integrity after criticism by the Inspector General and whistleblowers. For more information on the adverse health impacts of paraquat, see its entries in the Gateway on Pesticide Hazards and Safe Pest Management and Pesticide-Induced Disease Database.

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

Source: Mother Jones

(Beyond Pesticides, April 15, 2024) At first, some thought this was an April Fools’ announcement by pranksters like the YES men. Put out an announcement pretending to be the U.S. Environmental Protection (EPA) with a warning to farmworkers that they are being exposed to a highly hazardous weed killer, dacthal (dimethyl tetrachloroterephthalate or DCPA), offering no protection. The announcement says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA” and notes that the agency will be “pursuing” further action at some unspecified time in the future. But, this was no joke, especially for farmworkers. The agency somehow believed it was fulfilling its statutory duty to protect farmworkers and their families with a warning that a chemical they may be exposed in their workplace and possibly their homes and schools is harming them and, for those pregnant, destroying the health of their fetus. “In light of the workplace reality for farmworkers, the lack of labor protections, and the documented deficiencies in the existing worker protection standards, it is difficult to conceive of how EPA officials think this warning is protective in any way. And in light of what agency officials know, or should know, about the reality for farmworkers in their agricultural workplace, why are they not exercising the imminent hazard authority to suspend the chemical that Congress gave them,” said Jay Feldman, executive director of Beyond Pesticides. Mr. Feldman continued, “It’s not even clear in EPA’s press release how this warning will reach farmworkers.”

Beyond label warnings, EPA does not typically issue public warnings, as it has done in this case, with the determination that the agency’s mitigation measures (requirements for personal protective equipment) under a product’s existing registration is not protective of farmworkers, and specifically pregnant farmworkers and their fetuses. In its release and announcement on its website, the agency says “EPA is taking this rare step of warning farmworkers about these concerns while it works on actions to protect workers because of the significant risks the agency has identified.”

Quoting from the agency, “In May 2023, EPA released its assessment on the risks of occupational and residential exposure to products containing DCPA, after the agency reviewed data that it compelled AMVAC [the product’s manufacturer] to submit, which had been overdue for almost 10 years. The assessment found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.” 

The delays associated with this one pesticide exemplifies concerns that advocates have raised as endemic to EPA’s pesticide registration process, resulting in serious harm that is not adequately prevented or managed by the agency. Beyond Pesticides has pointed to this historical and ongoing failure as one of the many reasons to shift to organic management practices that, under the Organic Foods Production Act, do not allow the use of hazardous substances like dacthal.

Tell EPA to immediately suspend the registration of dacthal, while Congress must urge the agency to take immediate action.

Although it suggests several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, acknowledging that DCPA use on turf was voluntarily canceled in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include “non-golf turf uses; sod farms, commercial turf, and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism. 

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. EPA does have imminent hazard authority, which it can use to remove pesticides from use while it works through the legal process. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.  

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, “US pesticide regulation is failing the hardest-hit communities. It’s time to fix it,” finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others (see earlier coverage) on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. In a piece posted earlier this year by Beyond Pesticides, the serious weaknesses in the worker protection standard for farmworkers are documented.   

In view of the serious health risks acknowledged by EPA, the agency must immediately suspend the registration of dacthal, pending any other actions. 

Tell EPA to immediately suspend the registration of dacthal, while Congress must urge the agency to take immediate action.

Letter to EPA:

In a move that defies the most basic principles of worker and public health protection, EPA has warned farmworkers of the risks of dacthal (dimethyl tetrachloroterephthalate or DCPA), instead of taking steps to eliminate the risks. EPA’s press release says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA and will be pursuing action to address the serious, permanent, and irreversible health risks associated with the pesticide as quickly as possible.”

EPA states that it “found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.”

Despite suggesting several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, admitting that DCPA use on turf was voluntarily canceled by in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include “non-golf turf uses; sod farms, commercial turf and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism.

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, US pesticide regulation is failing the hardest-hit communities: It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. The serious weaknesses in the worker protection standard for farmworkers have also been documented.  

In view of the serious health risks acknowledged by EPA, the agency must immediately suspend the registration of dacthal pending any other actions.

Thank you for considering these comments.

Letter to Congress:

In a move that defies the most basic principles of worker and public health protection, EPA has warned farmworkers of the risks of the weed killer dacthal (dimethyl tetrachloroterephthalate or DCPA), instead of taking steps to eliminate the risks. EPA’s press release says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA and will be pursuing action to address the serious, permanent, and irreversible health risks associated with the pesticide as quickly as possible.” In view of the serious health risks acknowledged by EPA, please urge EPA to immediately suspend the registration of dacthal, pending any other actions.

EPA states that it “found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.”

Despite suggesting several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, admitting that DCPA use on turf was voluntarily canceled by in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include “non-golf turf uses; sod farms, commercial turf and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism.

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, US pesticide regulation is failing the hardest-hit communities: It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. The serious weaknesses in the worker protection standard for farmworkers have also been documented.  

Thank you for consideration of my request.

(Beyond Pesticides, April 12, 2024) In honor of Earth Month, Natural Grocers® is partnering with Beyond Pesticides for its seventh annual Ladybug Love^SM campaign. Natural Grocers, a longtime leader of the organic movement through national advocacy efforts and rigorous product standards, encourages its communities to pledge to protect beneficial insects and further Beyond Pesticides’ critical mission of converting local parks and playing fields to organic landscape management practices.  

Natural Grocers’ annual Earth Month fundraising efforts benefit the nonprofit organization, Beyond Pesticides and its Parks for a Sustainable Future program. Cleaner air, water, and land make for a healthier food supply – a principle Natural Grocers has championed since 1955. Click here to see the campaign from last year.

April shoppers at Natural Grocers’ 168 stores are also invited to donate to Beyond Pesticides at checkout. Ladybug Love also features in-store promotions!

LADYBUG LOVE & BEYOND PESTICIDES
Natural Grocers’ Ladybug Love campaign aims to bring awareness to the precious insects that play a crucial role in the stability of our food supply and regenerative farming. The annual Earth Month fundraising efforts benefit Beyond Pesticides and its Parks for a Sustainable Future program, designed to assist communities in transitioning away from pesticide use at local parks and public areas by providing the education, training, and practical assistance needed to move toward organic land care.

Beyond Pesticides envisions a future where local parks, playing fields, and greenways are managed without unnecessary toxic pesticides. Where children and pets are safe to run around on the grass, and bees and other pollinators are safeguarded from toxic chemicals.  

Raquel Isely, vice president of marketing for Natural Grocers, states, “Natural Grocers, in partnership with Beyond Pesticides, is pleased to support Parks for a Sustainable Future with our seventh annual Ladybug Love campaign. Through this program and the generosity of our customers, we are underwriting the cost of horticultural services to transition parks and playing fields to organic land management. Cleaner air, water, and land make for a healthier food supply – a principle Natural Grocers has championed for almost 70 years. We are thankful for our generous customers who share our passion to protect our beneficial insects, the land, and our planet.”  

Jay Feldman, executive director of Beyond Pesticides, states, “Natural Grocers is a leader in corporate social and environmental responsibility, and the company’s support of efforts to convert land management to organic shows a strong commitment to public health and environmental protection. The funds raised for Beyond Pesticides’ Parks for a Sustainable Future program enable the organization to work with municipal governments and community people to create safe spaces for children, families, pets, wildlife, and waterways. The parks and playing fields under organic management serve as a model for parks nationwide and prove that toxic chemicals are not needed to have beautiful landscapes.”  

The Company’s underwriting effort has enabled Beyond Pesticides to convert almost a dozen parks and playing fields to organic management practices from Arizona to Utah, with more in the works in Colorado and Texas.

For those wanting to bring this program to their community, contact Beyond Pesticides at [email protected].

Beyond Pesticides’ website explains the process of joining the organic land management program as follows:

• The first step is for the community to apply for the program. Beyond Pesticides asks that the application be submitted by an individual within a local government that has oversight over land care management or with their full knowledge and consent.
• Once a community applies, Beyond Pesticides will review your application and discuss the program with local officials in charge of land care maintenance.
• Beyond Pesticides will work with the community to determine two pilot sites for transitioning to organic land care. The community is encouraged to select high-use/heavy-traffic sites to showcase the program to residents.
• Officials receive a questionnaire on past management practices to help them understand current and past management practices at the pilot sites.
• Soil samples will be taken from the pilot sites in order to analyze soil structure, chemistry, and, most importantly, soil biology.
• Once the soil test results and a completed questionnaire for the pilot sites are ready, a date for the organic land care training will be set.
• As of October 2021, training is being conducted virtually. As conditions allow, Beyond Pesticides will conduct training consisting of classroom lectures and in-field discussions. Staff will walk the pilot sites with land care officials and answer land management questions.
• After the training, the park officials will receive a detailed Organic Transition Management Plan to assist with the organic transition over the pilot sites’ next several seasons. This management plan outlines cultural practices and timing and provides product recommendations.
• Beyond Pesticides remains available to consult with officials regarding the implementation of the management plan throughout the pilot sites’ transition and the program on lands beyond the pilot site.
• Beyond Pesticides offers to conduct a community meeting with the town and community organizations to explain the program and the value that it offers for the protection of health and the environment.

Financial Arrangements: With Natural Grocers support, along with other supporters, Beyond Pesticides will pay up to 100% of the training program to our partner, Osborne Organics, or an equivalent service provider. The community may contribute to this cost; it is not required, but is appreciated to allow for expansion of the program.

Parks for a Sustainable Future supports Beyond Pesticides’ mission to protect public health and the environment, starting at the local level. Given increasing public understanding of the dangers associated with lawn care pesticides, our organization strongly encourages localities to take advantage of the growing availability of alternative practices and products that do not subject people or the local environment to these hazards. Beyond Pesticides’ efforts to eliminate the use of petrochemical pesticides and fertilizers, which contribute to existential public health threats, biodiversity collapse, and the climate crisis. Through the Parks program, communities become the leaders in their state and region to take the practical steps necessary for a sustainable future.

TAKE THE PLEDGE
To help raise funds for this effort, Natural Grocers is urging people to take or renew their pledge online and commit to not using chemicals that harm ladybugs and other beneficial insects at home, in yards, gardens and to support 100% organic produce. Natural Grocers’ goal is to raise $25,000 in April for the Organic Parks Project with Beyond Pesticides through the following in-store fundraising opportunities:  

• Whether it’s a first-time pledge or renewed, Natural Grocers will donate $1.00 (up to $25,000) to Beyond Pesticides for every Ladybug Love pledge signed from April 1 – April 30.
• For every Ladybug Zip Pouch sold from April 20 – 22, Natural Grocers will donate $2 to Beyond Pesticides.
• {N}power® members who make or renew their pledge from April 1 – 15, will receive $5 off their purchase, April 20 – 22.
• {N}power members will also receive a free limited-edition Ladybug Love reusable bag and free sticker with purchase April 20 – 22.

{N}power is Natural Grocers’ FREE member rewards program. The program is easy to join and offers exclusive discounts, digital coupons, rewards benefits, and other members-only features. Customers can sign up for {N}power at www.naturalgrocers.com/join.

Even if you’ve signed the pledge in previous years, please take a moment to sign! You do not need to shop at Natural Grocers to sign, but it’s a great store if there’s one in your area!

>> Don’t forget to advertise your commitment with a Beyond Pesticides “Pesticide Free Zone” sign, featured right. 

COUNT THE LADYBUGS SWEEPSTAKES
Throughout the month, customers are invited to count the ladybugs placed throughout the pages of the April 2024 Natural Grocers good4u® Health Hotline® magazine, for the chance to win a $500 Natural Grocers gift card. To enter the contest, customers fill out the form in the magazine and drop it off at any Natural Grocers store by April 27, 2024. A drawing among all entries with the correct number of ladybugs will determine the winner.

 SPECIAL EARTH DAY EDUCATION & DEALS
Natural Grocers will be promoting regenerative living insights and resources related to food, homes, gardens and yards all month long. Natural Grocers’ 2024 Earth Day Celebration culminates April 20 – 22, with three days of special Earth Day discounts, freebies and sweepstakes. Customers can learn more by picking up the April edition (Vol. 81) of the good4u℠ Health Hotline at their local Natural Grocers store or click here to view it online. For media requests, please contact Katie Macarelli: [email protected].

ABOUT NATURAL GROCERS BY VITAMIN COTTAGE
Founded in 1955, Natural Grocers by Vitamin Cottage, Inc. (NYSE: NGVC) is an expanding specialty retailer of natural and organic groceries, body care products, and dietary supplements. The products sold by Natural Grocers must meet strict quality guidelines and may not contain artificial colors, flavors, preservatives or sweeteners, or partially hydrogenated or hydrogenated oils. The Company sells only USDA-certified organic produce and exclusively pasture-raised, non-confinement dairy products, and free-range eggs. Natural Grocers’ flexible smaller-store format allows it to offer affordable prices in a shopper-friendly, clean, and convenient retail environment. The Company also provides extensive free science-based Nutrition Education programs to help customers make informed health and nutrition choices. Headquartered in the Union Square neighborhood of Lakewood, CO, Natural Grocers has 168 stores in 21 states. Visit www.naturalgrocers.com for more information and store locations.

ABOUT BEYOND PESTICIDES
A 501(c)3 nonprofit organization headquartered in Washington, Dc, Beyond Pesticides works with allies in protecting public health and the environment to lead the transition to a world free of toxic pesticides. Regenerative organic land management practices that use ladybugs and other beneficial insects instead of harmful synthetic pesticides to control pests, embrace the connectedness of planet Earth’s vibrant ecosystem and chart a path towards a livable world.

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

Source:

Natural Grocers® Promotes Seventh Annual Ladybug Love Campaign for Earth Month, Press Release, PRN, Natural Grocers® Promotes Seventh Annual Ladybug Love Campaign for Earth Month

(Beyond Pesticides, April 11, 2024) Scientists are moving forward in testing an agroecological method of “push-pull” pest management (reducing the attractiveness of the target organism and luring pest insects towards a trap) to fight the Asian citrus psyllid (ACP) in Florida orange groves, as it spreads a plant disease known as the pathogenic bacteria huanglongbing (HLB), also known as citrus greening, which is deadly to citrus trees. The disease is spread by the pathogenic bacteria Candidatus Liberibacter asiaticus (CLas).  The chemical-intensive, or conventional, citrus industry is under intense pressure to find alternatives, as synthetic antibiotic use for this purpose has been successfully challenged in court.

ACP is the carrier, or vector, for HLB, spreading it through the citrus groves and killing the trees. The chemical-intensive industry has focused on using antibiotics, which the environmental and public health community has rejected because of serious medical concerns associated with life-threatening bacterial resistance to antibiotics used to protect humans. A federal district court decision in December 2023 found illegal the U.S. Environmental Protection Agency’s (EPA) decision to register the antibiotic streptomycin in Florida citrus without adequate review of its impact on endangered species. The streptomycin lawsuit, filed in 2021 by a coalition of farmworker and public interest groups, including Beyond Pesticides, raises critical issues of antibiotic resistance, public health protection, and impacts on bees.

Organic citrus production has been on the cutting edge when it comes to managing citrus greening. Citrus farmers, growing under the USDA certified organic label, are prohibited from employing antibiotics along with other toxic pesticides. Organic growers like Uncle Matt’s in Florida discuss the importance of soil health that supports plant resilience, breeding programs for tolerant rootstock, the use of botanical insecticides such as neem and clove oil, and the release of the biological control agent Tamarixia wasps, which feed on Asian Citrus Psyllids. Watch Uncle Matt’s Benny McClean, production manager, speak about organic citrus production in Florida at Beyond Pesticide’s 33rd National Pesticide Forum.

Similarly, Mongabay (an international environmental science nonprofit news platform) reports that those practicing agroecology, while not certified organic, are utilizing “push-pull” methods, using an organic plant-pheromone, methyl salicylate (oil of wintergreen), to lure pests away from citrus crops and toward “trap crops” instead. The method was first developed in East Africa, and represents a more holistic and environmentally friendly approach to pest management, transitioning away from dependence on pesticides.

The “push-pull” pest management strategy focuses on manipulating the behavior of the psyllids to protect citrus crops by making the citrus trees less attractive while simultaneously luring ACP toward alternative, non-citrus “trap crops.” While the final results are pending, the anticipated outcome is a significant reduction in ACP populations on the treated citrus trees, thereby lowering the incidence of HLB transmission.

Methodology

An Argentinian research team, led by María Victoria Coll-Aráoz, PhD, formerly on the science faculty of the Universidad Nacional de Tucumán, studied a series of experimental plots designed to test the efficacy of the “push-pull” method in a real-world setting. Her research was funded under the Fulbright Scholars Program with the project title “Utilizing Plant Signaling Compounds to Manage Asian Citrus Psyllid (Diaphorina Citri), Vector of Huanglongbing Disease of Citrus.”

The three distinct test groups include:

• Control: Trees receive no treatment to serve as a baseline for comparison.
• Treated citrus only: Trees are sprayed with an organic plant hormone solution that inhibits the production of methyl salicylate, a chemical that naturally attracts psyllids.
• Treated citrus with trap crops: In addition to the treated citrus trees, this setup includes curry leaf plants (Murraya koenigii) surrounding the citrus trees. These trap crops are sprayed with methyl salicylate (a plant hormone compatible with organic systems) to make them more attractive to the psyllids than the citrus trees.

The methodological approach features two key actions simultaneously: pushing ACP away from the citrus (the “push”) and pulling them toward another target (the “pull”).

• Push: The citrus trees are sprayed with an organic plant hormone that suppresses their natural emission of methyl salicylate, a compound that attracts psyllids and other pests. Normally, when a tree becomes infected with citrus greening, the bacteria causes the tree to produce even more methyl salicylate — a positive feedback loop “designed by the bacteria for its own propagation,” as Dr. Coll-Aráoz explains. Reducing this methyl salicylate attractant makes the citrus trees less appealing to the psyllids and breaks this feedback loop.
• Pull: Simultaneously, the surrounding trap crops (curry leaf plants) are made more attractive by enhancing their emission of methyl salicylate, either through direct spraying of the substance or using dispensers that release the chemical, acting like perfume bottles to lure the insects.

Approaching HLB—No cure, but manageable under organic

HLB is one of the most researched plant diseases in the current times. Hundreds of millions of dollars have been spent on research and, as The Organic Growers Guide noted in 2019, “It is universally agreed by growers and scientists that no ‘silver bullet’ has yet been discovered” for HLB, therefore the presence of ACP poses a severe risk to citrus crops with the potential to cause catastrophic losses. [Infected trees must be completely removed to combat this disease, as symptoms may not appear for one to two years, and a tree may succumb to HLB within five years.] Measuring between 1/6 and 1/8 inches in length, this small insect serves as the carrier for the deadly bacterium. When ACP feeds on a plant, it transmits the bacterium, which is harmless to the psyllid but causes HLB, also known as citrus greening or yellow dragon disease, in citrus and certain ornamental plants. With a one to two-month lifespan, ACP can infect an enormous number of trees by spreading the bacterium.

Most management of the HLB vector centers primarily on the intensive use of synthetic insecticides, which are prohibited from use under organic management. ACP management in conventional citrus is based largely on the intensive use of synthetic insecticides such as imidacloprid, chlorpyrifos, and dimethoate, as well as new insecticides such as cyantraniliprole. Studies have investigated the development and use of synthetic pesticides, agricultural antibiotics, and genetically engineered citrus varieties. Advocates have noted with alarm the danger of continuing to rely on highly toxic synthetic pesticides like chlorpyrifos (banned in 39 countries) and aldicarb ( banned in 100+ countries). Even Florida’s Department of Agriculture and Consumer Services rejected state-level approval of aldicarb: “While there are promising new horizons for fighting citrus greening, like recent breakthroughs at UF/IFAS on genetic resistance, aldicarb poses an unacceptable risk to human, animal, and environmental health in Florida, is one of the world’s most toxic pesticides, and is banned in more than 100 countries,” said Florida Agriculture Commissioner Nikki Fried in 2021. “The registrant’s application does not meet the requirements of state law, and we must therefore deny the registration of aldicarb for use in the State of Florida.” In addition, concerns over using medical treatments as pesticides are not conjecture but borne out of experiences already concerning on the ground. In January 2021, EPA authorized the antibiotic streptomycin to combat citrus greening disease despite the potential for significant environmental and health risks. Critics point out that while citrus greening and cancer are serious threats, the solution should not involve repurposing critical medical treatments for widespread agricultural application, a practice that benefits corporate interests more than farmers and poses long-term public health risks.

The devastating impact of citrus greening disease has left the citrus industry in disarray, with declining production and economic losses. However, examination of available literature, unpublished research data, and grower observations have produced evidence that citrus greening may be managed and marketable fruit produced by adopting organic agricultural (and agroecological) methods, including push-pull pest control, strict disease prevention, diligent scouting, ACP control, nutritional support of healthy and infected trees, implementation of biological controls and the planting of cultivars considered “tolerant” or “resistant” to HLB. “Pesticides haven’t worked to control this vector, and we’re entering a time when these alternatives are unsustainable,” said Lukasz Stelinski, PhD, a leading entomologist at the University of Florida’s Citrus Research And Education Center. “They’re too expensive. They’re having negative impacts in terms of insecticide resistance development, and they’re not working.” Despite this plethora of research, there is still a dramatic underfunding of research on methods compliant with and supporting organic cultivation.

Conventional approaches relying on synthetic pesticides have proven ineffective, harmful to human health, and detrimental to the environment. Advocates say that the time has come for a transformative change in citrus farming practices, as organic citrus represents 1.5 percent of citrus acreage in the United States and three percent of the dollar value—in other words, providing a significantly greater economic return per acre planted. Organic citrus production, supported by agroecology principles like push-pull pest management, offers a superior approach to combat citrus greening disease and revive the struggling industry. By reducing reliance on synthetic pesticides, promoting ecosystem health, and meeting the demand for organic products, organic citrus production can pave the way for a brighter future for the citrus industry.

In 2022, after yet another closure of international juice company Tropicana’s Fort Pierce processing facility from a lack of fruit supply, plant breeder Fred Gmitter, PhD, at the University of Florida’s land grant Citrus Research and Education Center, commented, “It’s difficult to imagine being much worse off in our industry right now. I ask this question all the time: Is this the bottom? Is this as bad as it’s going to get?”  In light of Dr. Gmitter’s comments and devastating crop losses (from 200 million boxes of oranges produced in Florida in the 2000s to just 20 million boxes in Florida’s 2023-2024 forecast), advocates urge that the current situation be viewed as a tipping point for the end of chemical-intensive, pesticide first industrial production of oranges. Florida-based national leader in organic orange juice production, Uncle Matt’s Organic, now a Certified B company, has seen growth and success and leads the way with supporting research, and practical application of organic compatible methods. For more information, please see Uncle Matt’s Benny McClean, production manager, speak about organic citrus production in Florida at Beyond Pesticide’s 33rd National Pesticide Forum.

Beyond Pesticides argues that the urgency of the existential crises that conventional Florida citrus management exemplifies can only be met with an immediate end to the use of highly toxic synthetic pesticides (including insecticides) like aldicarb, human antibiotics like streptomycin, and more. The time is now to follow what consumers already know, and a growing organic market shows that organic agriculture can overcome challenges of pest and plague to deliver nutritious food, without pesticide residue, or pesticide exposure and harm to farmers and fields, neighbors, children, wildlife, and the environment.

Our food choices directly affect the health of our environment and those who grow and harvest what we eat. That’s why food labeled “organic” is the right choice. In addition to serious health questions linked to actual residues of toxic pesticides on the food we eat, our food-buying decisions support or reject hazardous agricultural practices, protect farmworkers and farm families, and provide stewardship for the earth. See Beyond Pesticides for more on Eating with a Conscience. Beyond Pesticides’ article, “The Real Story on the Affordability of Organic Food,” lays out the hidden costs and risks of conventional, chemical-intensive agriculture, and offers helpful ideas on eating organic on a budget. To learn more about opportunities to strengthen the National Organic Program, please see the “Keeping Organic Strong” webpage.

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

Sources

Florida growers eye agroecology solution to devastating citrus disease, Marlowe Starling, Mongabay News, April 3, 2024

Combatting Huanglongbing in Organic Systems, International Journal of Horticulture, Agriculture and Food Science (IJHAF), Cochrane, Ellen, Shade, Jessica,  Jan-Feb 2019

Combatting Citrus Greening in Organic Systems A GROWER’S GUIDE, The Organic Center, January 2019

Citrus Greening: A positive outlook despite Mother Nature’s setbacks, Uncle Matt’s Organic, November 2022

Genetic Improvements Offer Best Long-term Solutions to Citrus Greening Disease, Uncle Matt’s Organic January 19, 2021

Progress Toward an Attract-and-Kill Device for Asian Citrus Psyllid Using Volatile Signatures of Citrus Infected With Huanglongbing as the Attractant, Journal of Insect Science, November 2020

(Beyond Pesticides, April 10, 2024) Researchers in a 2024 Chemosphere study find synergistic relationships in certain chemical mixtures, particularly heptachlor and triallate and trifluralin and lindane at lower concentrations, respectively. “Investigators should consider additional binary data for acute toxicity and potential chronic health impacts on these mixture…which showed synergism at low levels,” the researchers conclude. “According to a Centers for Disease Control (CDC) assessment, more than 50 pesticides are detected in blood or urine samples from the US population,” Researchers point to a cause for concern. The findings come as no surprise to advocates who have urged an assessment of the potential synergistic impacts of pesticide mixtures in the regulation of pesticides.

Researchers “used the exposure data from a complex operating site with legacy pesticide pollution to evaluate if

1. Inhalation of pesticide mixtures released from such contaminated sites could pose a risk to human health,
2. The component-based risk assessment approaches that rely on additivity can predict the actual risk of pesticides in a mixture, and
3. The legacy organochlorine pesticides banned many years ago interact with registered and supposedly safe herbicides in a mixture.”

The study site is “a pesticide packaging and handling facility” contaminated with the following pesticides (“historical and in current use”): 2,4-D (2,4-dichlorophenoxyacetic acid), 2,4-DB (4-(2,4-dichlorophenoxy)butyric acid), 2,4-DP (Dichlorprop), Aldrin, Bromacil, Bromoxynil, Chlordane, Clopyralid, DDD p,p, DDE p,p, DDT, o, p’, DDT, p,p’, Dicamba, Dieldrin, Dimethoate, Endrin, Heptachlor, Lindane, Malathion, MCPA, MCPP (mecoprop), Metribuzin, Treflan (Trifluralin), and Trilate/Triallate. “Only volatile COPCs (Henry’s Law Constant (H) greater than 10⁻⁵ atm m³/mol) in soil and groundwater were included in this study (triallate, trifluralin, lindane, heptachlor, dieldrin, and aldrin,” the researchers indicate in the Methods section. Quantitative risk assessment for pesticide exposure was rooted on oral exposure, which comes with potential uncertainties. For example, oral exposure tends to demand a higher dose to induce an identifiable adverse effect relative to inhalation exposure. In other words, using an oral reference dose may underestimate the potential risk.

Risk assessment of pesticide mixtures follows different logic systems depending on the research approach. As this study describes, “The default assumption is that at low concentrations, pesticides interact additively with one another; thus, the risk posed by each component of a complex mixture could be simply added up.” The binary weight of evidence, or BINWOE, builds on EPA’s approach at risk assessment through the interaction-based hazard index (HI _Interaction). There was not enough published data on animal binary pesticide interaction which meant finding an alternative approach. Researchers used a cell line, SH-SY5Y, after a previous meta study found it to be an effective method to obtain relevant binary data that fits EPA’s HI _Interaction approach while acting as a “predictive indicator” of adverse human health impacts to pesticide exposure.

Researchers did find values suggesting “significant health concerns” to toddlers, infants, teenagers, and adults in “commercial and industrial land use.” Additionally, there are several important takeaways from the study, including pivotal details on the synergistic impacts of chemical mixtures at different concentrations. “Nine of the 15 tested binary mixtures of pesticides synergistically reduced cell viability []. Seven mixtures (Trifluralin/Heptachlor, Trifluralin/Aldrin, Lindane/Heptachlor, Lindane/Aldrin, Heptachlor/Dieldrin, Heptachlor/Aldrin and Dieldrin/Aldrin) were synergistic at higher concentrations. However, two mixtures of herbicides and OCPs (Trifluralin/Lindane and Triallate/Heptachlor) interacted synergistically at lower concentrations. All binary mixtures of OCPs [organochlorine pesticides], except for Lindane/Dieldrin (additive at all concentrations), elicited synergistic effects at higher concentrations and additivity at lower concentrations.” Lindane, considered a legacy organochlorine, does in fact interact with “supposedly safe herbicides in a mixture.” The findings of this study, and similar findings in the scientific literature going back decades, demonstrate the importance of measuring the potential impacts of chemical mixtures in promulgating pesticide safety regulations.

The health consequences of chemical mixtures gained national attention in a recent dispute between the Office of the Inspector General (OIG) and the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs regarding the agency’s review of pet flea and tick collars. The OIG report indicated, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.”

Pollinators are also impacted by the mixture of toxic chemicals in the environment that are not evaluated by EPA for synergistic effects. A 2023 Nature study found a combination of insecticides and fungicides (including indoxacarb, spinosad, chlorpyrifos-ethyl, deltamethrin, dimethoate, imidacloprid, cyfluthrin, dithianon, etofenprox, and chlorpyrifos-methyl in 106 agricultural landscapes across Europe through identifiable adverse health impacts of bumble bees, signaling EPA and European environmental regulators’ failure to “safeguard bees and other pollinators that support agricultural production and wild plant pollination.” A 2014 study reached a similar conclusion regarding the synergistic effects in most pesticide combinations exacerbated pollinator mortality rates around the four-day mark of exposure. More concerning, however, were the results focusing on the allegedly “inert” ingredient, N-methyl-2-pyrrolidone. In this study, published in PLoS One, researchers indicate, “Even for the lowest concentration of [this inert ingredient], the estimated time to cause 50% larval mortality was 4 days.”

Given both the known and still unevaluated effects of pesticides, including the impact of mixtures and synergistic effects, and given the commercial viability and effectiveness of alternatives in both agricultural and nonagricultural use, Beyond Pesticides is calling for the phase out of toxic petrochemical pesticides by 2032. See the Gateway on Pesticide Hazards and Safe Pest Management to learn specific adverse health impacts of particular pesticide ingredients. See Pesticide-Induced Disease Database to peruse the latest scientific literature on pesticide exposure and health consequences. Safety Source on Pest Management Providers offers a list of pesticide application companies that avoid the use of toxic pesticides. To identify if you suspect that you or a loved one was or is being exposed to a harmful pesticide or chemical, see Pesticide Emergencies.

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

Source: Chemosphere

(Beyond Pesticides, April 9, 2024) The United States Court of Appeals for the Fifth Circuit, in an opinion authored by Circuit Judge Cory T. Wilson, has vacated an action by the U.S. Environmental Protection  Agency (EPA) that had ordered the Texas-based manufacturer Inhance Technologies, L.L.C. to stop producing plastic containers that leach toxic per- and polyfluoroalkyl substances (PFAS) into pesticides, household cleaners, condiments, and additional products. EPA has taken action after the agency determined that the PFAS created during the fluorination process “are highly toxic and present unreasonable risks that cannot be prevented other than through prohibition of manufacture.”

While the court is not challenging EPA’s authority to determine the hazards associated with PFAS exposure to be unacceptable, on a technicality, it is finding that the agency used the wrong section of the Toxic Substances Control Act (TSCA), Section 5, which the court says is focused on new uses. According to the Court, “The EPA is just not allowed to skirt the framework set by Congress by arbitrarily deeming Inhance’s decades-old fluorination process a “significant new use,” even though EPA’s awareness of the PFAS contamination was “new” to the agency and not disclosed by the manufacturer. Even if EPA were to pursue another approach (Section 6) under TSCA, the court notes that the agency must “weigh the costs to businesses and the overall economy before shutting down an ongoing manufacturing process.” And so goes the limitations of federal law in protecting public health as a primary and superseding goal.

This case serves as one example, among the many under federal law, in which efforts to limit the use of petrochemical pesticides are impeded by weak policy without clear mandates. The court decision elevates the challenges posed by federal laws that do not clearly meet the enormity of the current and escalating public health, environmental, and climate crises—in this case, exemplified by long-chain PFAS contamination from one manufacturer. Organic land management practices and certified organic agriculture are critical to the systemic shift to prevent further PFAS contamination, as Beyond Pesticides continues to call on the National Organic Standards Board (NOSB) to develop a strategy for eliminating plastics and PFAS from organic as a priority issue including at the upcoming meeting this spring.

Background
The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products, such as the mosquito insecticide Anvil 10+10, raises alarm about the extent of PFAS contamination and its potential impact on public health, including contamination of drinking water and waterways. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—as the plastic containers leached PFAS. 

In response, PEER and the Center for Environmental Health (CEH) notified EPA and Inhance Technologies in October 2022 of their intent to file a lawsuit to stop the manufacture and use the PFAS-contaminated product. EPA eventually filed a lawsuit against Inhance in December 2022, as did PEER and CEH, seeking to enjoin the company from continuing to produce multiple per- and polyfluoroalkyl substances in violation of TSCA. The two cases were later combined in the District Court for the Eastern District of Pennsylvania. In April 2023, a federal district court judge dismissed the PEER and CEH suit without prejudice at the request of both Inhance and EPA on the grounds the government was “diligently prosecuting” its case.  In response to the 5th Circuit Court’s appellate decision to vacate EPA’s stop manufacturing order, PEER and CEH are moving to intervene in the DOJ suit against Inhance. In February 2024, PEER and CEH announced a newly filed lawsuit against EPA for wrongfully withholding vital information, including test data on the presence of PFAS.

The EPA’s Determination and the Fifth Circuit Decision
The two orders by EPA prohibiting Inhance from manufacturing or processing PFAS during its fluorination process were issued under Section 5 of the TSCA, which empowers EPA to oversee and examine chemicals produced or brought into the United States. (See here for EPA’s PFAS framework and TSCA section 5). However, the company argued, and the court agreed, that the agency had incorrectly applied a TSCA section related to the new uses of chemicals, asserting that its process did not represent a new use. [Inhance has been fluorinating plastic containers using the same process since 1983, a process that manufactures PFAS and produces 200+ million containers annually.] While acknowledging the unreasonable risk to human health and the environment, the court concurred with Inhance’s interpretation and vacated the orders.

The Fifth Circuit decision alarms advocates with its significant implications for public health and the environment, as the public is left exposed to toxic PFAS without adequate protection. In addition, the court’s finding raises questions about the EPA’s authority to issue significant new use rules (SNURs) under TSCA. SNURs are crucial tools for managing chemical risks, and limiting EPA’s authority in this regard weakens the agency’s ability to protect public health and the environment (see PEER and CEH response here and here). Although EPA does not regulate PFAS in pesticide formulas, the agency lists these substances in the inert ingredient database, and thus product labels do not require disclosure of contaminants fundamental to pesticide products as a result of the manufacturing or packaging process. This is yet another reason to end the use of synthetic pesticides and recognize the benefits of organic agriculture.

The Impact on Public Health  and the Only Viable Solution—Organic

As PEER noted, PFOA and twelve other PFAS chemicals are formed during the fluorination of high-density polyethylene (HDPE) plastic containers by Inhance Technologies, LLC of Houston, Texas. Inhance is the sole U.S. company conducting this type of fluorination. Studies by EPA, independent researchers, and Inhance itself show that PFAS leaches from the walls of containers into their contents, thus exposing millions of people to PFAS without their knowledge. In February 2024, EPA announced new methodology for detecting dangerous low levels of PFAS in plastic containers. The leaching of PFAS from plastic containers into various products, including pesticides, food, cosmetics, and cleaning supplies, poses a significant risk to millions of Americans though exposure via ingestion, inhalation, and dermal contact.  

PFAS have been linked to various health issues, including cancer, reproductive problems, and immune system dysfunction. Concerns of safety in the use of fluorinated plastic containers used for packaging are because exposure to PFAS comes not just from leaching into the contents of the plastic containers, but also from handling the exterior of the containers. Factory workers and farmworkers have higher cumulative exposures, while critical windows of vulnerability, from pregnancy through childhood and the elderly, experience disproportionate risks of exposure. (See here, and here). The chemicals have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. As new drinking water health advisories issued by EPA show, PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.

Certified organic agriculture can play a crucial role in addressing the widespread contamination of PFAS as the only viable solution in the long run. Organic agriculture prohibits the use of petrochemical pesticides and fertilizers under a robust regulatory system created by the Organic Food Production Act (OFPA) and overseen by the NOSB, which reports directly to the U.S. Secretary of Agriculture. As the only agricultural system with public input and standards as defined by federal law, organic promotes sustainable farming practices that prioritize soil health and biodiversity. As the governing body responsible for setting organic standards, the NOSB must take a leadership role in developing a comprehensive strategy for eliminating plastics and PFAS from organic production and packaging, ensuring that organic agriculture remains a safe and sustainable alternative to conventional farming.

Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. For more information on why organic is the healthy choice, see Beyond Pesticides’ webpage, Health Benefits of Organic Agriculture. Additionally, learn more about how the lack of adequate pesticide regulations can adversely affect human and environmental health by visiting Beyond Pesticides’ website, Keeping Organic Agriculture Strong, and a special edition of Pesticides and You, “Keeping Organic Strong.” 

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

Sources 

Inhance Technologies vs US EPA, US 5th Circuit Court Decision, March 21, 2024

US court blocks EPA order to eliminate PFAS in plastic containers, The New Lede, March 25, 2024

EPA Orders Issued to Inhance Technologies Related to Long-Chain PFAS Significant New Use Notices, EPA website, December 14, 2023