(Beyond Pesticides, June 13, 2018) On June 6, 2018, the New York State Department of Environmental Conservation (NYSDEC) released its final policy for the disclosure of cleaning product ingredients under its Household Cleansing Product Information Disclosure Program. The program will require full disclosure of ingredients on product labels or manufacturer website for all products sold in the state, as well as the identification of chemicals of concern. NYSDEC states the program is intended to protect consumers from harmful chemicals in household products.

The Household Cleansing Product Information Disclosure Program requires manufacturers of cleaning products sold in New York to disclose chemical ingredients and identify any ingredients that appear on authoritative lists of chemicals of concern on their websites. Companies must also provide a list of links to product’s ingredients to NYSDEC. New York states that it “will be the first state in the nation to require such disclosure and the State’s program goes beyond initiatives in other states by requiring the robust disclosure of byproducts and contaminants, as well as chemicals with the potential to trigger asthma in adults and children.”

Products included in the program are cleaning products like soaps and detergents containing surfactants, emulsifying agents and used primarily for domestic or commercial cleaning purposes, including but not limited to the cleansing of fabrics, dishes, food utensils and household and commercial premises. Not covered are food, pesticides, drugs, cosmetics and other personal care items like shampoo and toothpaste. Now, known byproducts and contaminants in cleaning products, including 1,4-dioxane, perfluorooctanoic acid (PFOA) and perfluorooctanoic sulfate (PFOS) – all now found in drinking water supplies across New York State – will have to be disclosed.

All ingredients, including fragrances, surfactants, preservatives, etc, must be disclosed. Chemicals of concern must also be identified; these are defined as any chemical listed national and international lists including, California Prop 65, EU Carcinogen, Mutagen and/or reproductive toxicants (Cat 1A and 1B), EU Endocrine Disruptors (substances of high concern)
IRIS Carcinogens (Groups A B1, B2), Canada PBTs, IARC Carcinogens (Groups 1,2a, 2b), ATSDR Neurotoxicants, EPA Priority Chemicals List, and others (see full list here).  The Program Policy states that the fact that an ingredient appears on such a list “must be clearly and unequivocally indicated where the ingredient appears on the list of ingredients,” using phrases such as, “Present on XXX list,”, “Chemical of Concern” or “Present on List of Concern.” Additionally, nanoscale ingredients will also need to be disclosed. For example, according to the Program Policy, if the nanoscale material is carbon, the disclosure should use the term “nanoscale” carbon.

Manufacturers must post all required information for the following ingredients by July 1, 2019. However, small manufacturers (100 or less employees) will have until July 1, 2020 to comply. Manufacturers will have to update their disclosures each time they change the ingredients in a product, introduce a new product to the market, or a list of chemicals of concern is changed to include an ingredient present in any of their products.

The program was proposed and opened for public comment in 2017, under Environmental Conservation Law (ECL) Article 35 and New York Code of Rules and Regulations (NYCRR) Part 659. The statute and regulations authorize the Commissioner of the Department of Environmental Conservation to require manufacturers of domestic and commercial cleaning products distributed, sold, or offered for sale in New York State to furnish information regarding such products in a form prescribed by the Commissioner.

Beyond Pesticides advocates for the full disclosure of product ingredients on all consumer products. These products should avoid ingredients linked to human health or environmental hazards. Product disclosure programs are good first steps in improving consumer transparency and education. We encourage all consumers to read the label of all cleaning products and opt to choose products that contain safer options.

If you are looking for safer methods to manage pests, please visit our ManageSafe page and our Safer Choice page. Alternatively, EPA has a Safer Choice labeling program for cleaning products that evaluates the human and environmental risks of cleaning ingredients. Click here to see examples of Safer Choice Products.

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

Source: National Law Review

(Beyond Pesticides, June 12, 2018) Two recent studies are contributing to the growing understanding that challenges basic toxicological precepts as inadequate to comprehensive assessments of impacts, particularly in the realm of human exposures to chemicals. One investigation tackles the role of chemical pesticide exposures in the risk of developing Parkinson’s Disease. That study appeared in The FASEB (Federation of American Societies for Experimental Biology) Journal in April 2018. The other, published earlier this year in the journal Food and Chemical Toxicology, assesses potential negative health outcomes of long-term, low-dose exposure to admixtures of chemicals that more realistically represent real-life exposures than those typically created in a lab setting — one chemical at a time.

A basic concept of the classical scientific method is that relationships among phenomena, whether causal or associative, can be evaluated only through the isolation and consideration of elements one at a time. A core tenet of toxicology is the dose-response notion: that the lesser or greater the dose or exposure, the smaller or larger, respectively, the organismic response will be. Paracelsus is credited for the terse summary, “The dose makes the poison.” Most research into the health and environmental risks of toxic chemicals in the materials stream has been guided by these concepts. Most U.S. regulations governing what chemicals can be used have been informed by such research.

The first study looks at the role of chemical exposures in the risk of developing Parkinson’s Disease (PD), a relationship first identified in 1998; researchers have continued to study such relationships in the ensuing three decades. The variables implicated have long included a variety of pesticide compounds; research continues to examine which ones, at what levels of exposure, and by what mechanism(s) act to expedite development of the disorder. During the past 20 years, the related role of genetic predisposition to development of PD has come under increased scrutiny. Now, new research demonstrates that for people with a specific genetic mutation on chromosome #4, exposure to the agricultural pesticides paraquat and maneb — even at very low levels — can increase the risk of a PD diagnosis by approximately 250%.

PD is a progressive neurogenerative disorder that occurs when nerve cells in the substantia nigra region — a basal ganglia structure in the midbrain — are damaged or destroyed and can no longer produce dopamine, a neurotransmitter that helps mediate motor function. The disease exhibits a variety of symptoms, including loss of muscle control, trembling, and poor coordination.; it may additionally cause anxiety, constipation, dementia, depression, urinary difficulties, and sleep disturbances. Over time, symptoms intensify. Approximately one million people in the U.S. have PD, with 60,000 cases diagnosed each year; 7–10 million people suffer with it worldwide. It is the second-most-common, age-related neurogenerative disease; Alzheimer’s is the first.

Intriguingly, this in vitro study at the University of Guelph, Ontario reveals what transpires at the cellular level when both risk factors — the genetic mutation and exposure to these chemicals — are present. Exposure, even at very low levels, of dopamine-producing neurons (grown from stem cells) containing the mutation prevented the mitochondria, cells’ “power plants,” from functioning correctly, depriving the neurons of essential energy and causing them to fail. Cells that lack the mutation require higher doses before their function is compromised. The net is that exposure to these pesticides increases the risk of PD, and even small levels of exposure for people with the genetic mutation may increase risk greatly.

Critical exposure levels for the mutation-carrying cells are lower than the levels designated as “maximum safe” by regulations of the Canadian Environmental Protection Authority, and lower than the lowest observed effect level previously reported by U.S. regulators. The study’s lead author, Dr. Scott Ryan, says that on the basis of these outcomes, the current approach to regulation — “one level fits all” — should be abandoned, adding, “This study shows that everyone is not equal, and these safety standards need to be updated in order to protect those who are more susceptible and may not even know it.” His conclusion underscores one shortcoming of the “dose makes the poison” tenet in the realm of human exposure to potentially toxic chemicals.

The second study is an international effort whose publication is titled, “Six months’ exposure to a real life mixture of 13 chemicals below individual NOAELs induced non monotonic sex dependent biochemical and redox status changes in rats.” (The NOAELs in the title stands for no-observed-adverse-effect-levels.) In a 24-week toxicity study, the project administered to the rodents “mixtures containing carbaryl, dimethoate, glyphosate, methomyl, methyl parathion, triadimefon, aspartame, sodium benzoate, calcium disodium ethylene diamine tetra-acetate, ethylparaben, butylparaben, bisphenol A, and acacia gum at doses of 0, 0.25, 1, or 5 times the respective Toxicological Reference Values” — toxicological indices that, when compared with exposure, are used to qualify or quantify a risk to human health.

Most research on chemical exposures is done at much higher “dosage” levels and utilizing exposures to single compounds; this experiment created circumstances that more closely mimic much of actual human exposure: to multiple compounds and at modest levels. Its methodology addresses flaws inherent in most research on chemical toxicity: both the high-dosage protocols and the “one at a time” approach that fails to consider the nature and significance of synergistic or sequential exposure phenomena. Observed effects in the rats include significant weight gain (in males), liver toxicity, and adaptive responses to redox status. (“Redox status” can be understood as the body’s ability to maintain a balance of reductive and oxidative processes, or more simply, to respond to the presence of molecules that promote inflammation in a way that keeps it in check).

What is particularly notable is that the liver toxicity and redox status effects showed non-monotonic dose–response curves. To provide some context for that: a classic “dose makes the poison” response means that as dosage rises, the severity of organismic response increases correspondingly; such dose–response correspondence is termed “monotonic.” A non-monotonic dose–response curve will look quite different — if graphed, it will often appear as either a “U” or an inverted “U,” or sometimes take an entirely irregular path. The importance of the non-monotonic curve in this research is its representation that serious health impacts occurred at low doses, or exposure levels. Such responses contravene the “dose makes the poison” tenet that underlies not only toxicology broadly, but also, the regulation of toxic chemicals by government agencies such as the Environmental Protection Agency.

Some scientists long ago pointed to the inadequacy of the traditional toxicological approach, including endocrine disruption researchers Theo Colborn and John Peterson Myers, who wrote (with Dianne Dumanoski) the groundbreaking Our Stolen Future. A decade ago, Beyond Pesticides addressed this in an article in its journal, Pesticides and You. Beyond Pesticides has also repeatedly identified the need to consider synergistic and low-dose exposures in the development of genuinely protective public health and environmental regulations. It is critical that more research is done to address these two under-explored aspects, and that such research be used in regulation of potentially toxic chemicals.

Sources: https://cosmosmagazine.com/biology/mechanics-of-pesticide-parkinson-s-link-revealed and https://www.sciencedirect.com/science/article/pii/S0278691518302011?via%3Dihub

(Beyond Pesticides, June 11, 2018)  With news that the U.S. Environmental Protection Agency (EPA) allows Roundup and its active ingredient glyphosate to be used despite evidence that it causes developmental effects following low-dose exposure, it is crucial that citizens demand that local governments provide the protection that EPA refuses. A pilot study —the first stage of the Global Glyphosate Study by the Ramazzini Institute (Italy) released in May— found that doses of either glyphosate or Roundup considered “safe” by EPA produce genotoxicity, alterations in sexual development, and changes in the intestinal microbiome.

Tell your local leaders to take action to protect families from pesticides!

This study adds to the urgent need for action, given previous findings that Roundup is: (1) linked to cancer by the International Agency for Research on Cancer, and its subsequent listing on California’s Prop 65 (“chemicals known to cause cancer”) list; (2) promoted by its manufacturer, Monsanto, on the basis of questionable research practices; and (3) challenged in a consensus statement by scientists and medical doctors.

Glyphosate is not the only pesticide to which we all, including children, are exposed in schools and parks, but it is widely used and portrayed as “safe.” In order to protect children, our local governments and school districts should adopt these policies:

1. A precautionary approach to use of toxic chemicals –when in doubt, throw it out;
2. Organic land management practices, which create healthy environments and playing fields by building healthy soils;
3. Techniques not reliant on pesticides –such as using a steam machine or goats to manage weeds in difficult situations;
4. Limiting chemical use to an allowed list of organic-compatible fertilizers and pest control materials (see Products Compatible with Organic Landscape Management); and
5. An organic land management policy that protects children, families, and the local ecology.

If your community has not already acted to stop glyphosate use and adopt an organic land management policy, start the ball in motion in your town with the following letter to your local elected officials.

Tell your local leaders to take action to protect families from pesticides!

(Beyond Pesticides, June 8, 2018) In the wake of U.S. Department of Justice (DOJ) approval of the buyout of Monsanto by Bayer, the new mega-corporation — now the world’s largest agrochemical and seed company — has announced that it will drop the “Monsanto” name, possibly as soon as late summer, when the acquisition is expected to be completed. Bayer first needs to sell off $9 billion in assets to German chemical giant BASF in compliance with a DOJ antitrust agreement that will permit the merger. The union of these two corporations, which joins Bayer’s pesticide business with Monsanto’s genetically engineered (GE) seed operations, faced vigorous opposition from health and environment advocates both in the U.S. and abroad.

Fortune magazine has pointed out that dropping a well-known name is unusual, but given that Monsanto is one of the world’s most-hated companies, perhaps the move is understandable. Ditching the “Monsanto” moniker is reportedly one aspect of a coming Bayer campaign to regain public trust and make efforts to engage with critics, according to Bayer spokespeople. Liam Condon, president of Bayer’s Crop Science Division, has said, “Just changing the name doesn’t do so much — we’ve got to explain to farmers and ultimately to consumers why this new company is important for farming, for agriculture and for food, and how that impacts consumers and the environment. Confirming the name Bayer is just one step. . . . Of course, there needs to be a lot more engagement.”

It is not yet clear what such “engagement” might mean, but Bayer is working hard at reconstructing perception of the company now that it has acquired Monsanto. Bayer CEO Werner Baumann added, “We will apply the same rigor to achieving our sustainability targets as we do to our financial targets.” He said, “We aim to deepen our dialogue with society. We will listen to our critics and work together where we find common ground. . . . Agriculture is too important to allow ideological differences to bring progress to a standstill. We have to talk to each other. We need to listen to each other. It’s the only way to build bridges.” When asked if Bayer will continue Monsanto’s underhanded business practices (see next paragraph), Mr. Baumann said, “The new entity will be managed ‘according to our standards,’ adding that ‘Bayer stands for transparency, reliability and a different style of debate.’”

Building the bridges that Mr. Baumann references will be a tall order. There is obviously great concern at Bayer about the baggage that comes with the Monsanto name and history. Monsanto has long been criticized for its products, including genetically engineered (GE) seeds and toxic pesticides. Among the latter was the devastating Agent Orange, used by the U.S. military during the Vietnam War and causing terrible harm to the land and people of Vietnam, and to U.S. military members who were in country during its use. The company has also drawn the ire of health, agriculture, and environment advocates for its campaigns to discredit researchers and anti-GE and environmental activists, and its bullying tactics toward farmers to “protect” what it has seen as its proprietary interests. It has drawn significant pushback on the health and environmental safety of its popular herbicides Roundup (which contains toxic glyphosate) and dicamba. Adding to its unsavory reputation is Monsanto’s manufacture, during its 177-year history, of such dubious products as the pesticide DDT (dichlorodiphenyltrichloroethane), PCBs (polychlorinated biphenyls), saccharin and aspartame, polystyrene, and nuclear weapons (1943–1945 for the Manhattan Project).

Yet, Bayer has its own issues, as Beyond Pesticides covered a couple of years ago. “Bayer’s parent company, Bayer AG, was part of the German chemical conglomerate I.G. Farben [IGF], which ran slave-labor factories during the Holocaust. . . . IGF also had a decisive share in a company that made Zyklon B gas, used to kill hundreds of thousands of Jews at Auschwitz [and] was intimately involved with the human experimental atrocities committed by Mengele at Auschwitz.” Bayer also manufactures neonicotinoid pesticides, which are disastrous for pollinators, and bisphenol-A, a chemical known to have damaging impacts on the human endocrine system.

Last year saw two other unions of giants: a Dow Chemical and DuPont (now DowDuPont) merger, and China’s National Chemical Company’s (ChemChina’s) buyout of Syngenta. These moves serve to concentrate further the control of global seed and pesticide markets; such concentration is always a worry and is why anti-trust laws exist, yet these corporations were able to navigate regulations to achieve this degree of consolidation. Together, DowDuPont, ChemChina, and the “new” Bayer would control nearly 70% of the world’s pesticide market, 80% of the U.S. corn-seed market, and 90% of the soybean market. The new Bayer alone is projected to control 29% of the world’s seeds and 24% of its pesticides. These are alarming statistics for people concerned about the impacts of chemical-intensive agriculture.

Advocates continue to be vocal in opposition to the merger and what they expect from the newly minted mega-company. One concern has been that Bayer would use the moment as an opportunity to introduce GE crops to Europe; the European Union has been circumspect about them, and some countries have outright banned certain varieties of GE seeds. In 2016, Bayer CEO Werner Baumann indicated that the new company would not introduce GE crops in Europe. At the time, he said, “We aren’t taking over Monsanto to establish GM [GE] plants in Europe. Some people think it might be easier for us than for Monsanto, given the reputation we enjoy, but that’s not our plan. If politics and society in Europe don’t want genetically modified seeds, then we accept that, even if we disagree on the substance.”

The reliability of such reassurance will unfold in the coming years, but there are other fronts for concern. Farmers worry about undue influence on them to expand their use of the new company’s products, corporate control of data on farmers’ practices, and ratcheted-up pressure for chemical-dependent farming. Advocates’ distress about the use of toxic pesticides is unlikely to diminish.

As The Guardian reports, “Adrian Bebb, a food and farming campaigner at Friends of the Earth Europe, said Bayer’s decision to ditch the Monsanto name would not alter the company’s legacy. ‘Bayer will become Monsanto in all but name unless it takes drastic measures to distance itself from the US chemical giant’s controversial past. . . . If it continues to peddle dangerous pesticides and unwanted GMOs then it will quickly find itself dealing with the same global resistance that Monsanto did. . . . This merger will create the world’s biggest and most powerful agribusiness corporation, which will try to force its genetically modified seeds and toxic pesticides into our food and countryside. . . . The coming together of these two is a marriage made in hell — bad for farmers, bad for consumers and bad for our countryside.”

Beyond Pesticides, in its Daily News Blog of September 19, 2016, noted that the Bayer–Monsanto merger — because the new entity will create a near-monopoly that will allow it to increase prices — may offer only short-term financial stability to the company, while increasing the wealth of top executives and raising food costs. “Observers say that in the long-term, the market will reveal that relying on the promotion of chemical-intensive agricultural practices is not a sustainable business practice. Chemical-intensive agriculture depends on chemical fertilizers and toxic pesticides that have been shown to reduce soil organic matter and decrease the diversity of soil biota. These chemical inputs contaminate waterways, leading to ‘dead zones’ where nothing is able to live or grow. Eventually, as chemical-intensive agriculture depletes organic matter in the soil and there is nothing left with which to grow food or sustain life, toxic chemical inputs will become obsolete. Sustainability advocates say that the only way that the agricultural industry can create a sustainable business model is to produce products that are compatible with organic agriculture.”

Good organic practices work to build the soil and maintain an ecological balance that makes chemical fertilizers and toxic synthetic pesticides obsolete. Claims that organic agriculture cannot feed the world because of lower yields are contested by scientific studies showing that organic yields are comparable to conventional yields and require significantly lower inputs. Organic agriculture advocates say that it is necessary not only to eliminate the use of toxic chemicals, but also, to ensure the long-term sustainability of food production.

The Bayer buyout of Monsanto also has organic farmers worried. Kristina Hubbard, director of advocacy and communications for the Organic Seed Alliance, notes that “the National Organic Program’s regulations on organic seeds generally dictate that growers must use organic seeds to grow their crops. But there is an exception granted for non-organic seed when ‘an equivalent organically produced variety is not commercially available.’ That exemption is important because currently the supply [of organic seeds] isn’t sufficient to meet the diverse and regional needs of all organic farmers. With continued consolidation in the seed industry, farmers that rely on those non-organic seed options may find themselves faced with even fewer options as the merged companies cut down on research and development.”

In the advocacy community, the name change surely will not keep people from monitoring the new Bayer, and exposing the harm that comes with toxic pesticides and near-monopolies on seeds. See Beyond Pesticides’ Organic Agriculture webpage.

Primary source: https://www.washingtonpost.com/news/wonk/wp/2018/06/04/why-monsanto-is-no-more/?utm_term=.23158e15b440

(Beyond Pesticides, June 7, 2018) Health Canada is proposing to phase out a number of uses of neonicotinoids in order to mitigate risks to pollinators. The agency has completed its review of clothianidin and thiamethoxam — two neonicotinoids that have been linked to pollinator decline and finds risks of concern for bees. However, these measures do not go as far as those recently made in the European Union, but further than label restrictions issued by the U.S. Environmental Protection Agency (EPA).

Health Canada concluded its Pollinator Re-evaluation for clothianidin and thiamethoxam after examining hundreds of laboratory and outdoor field studies that examined the possible effects on bees from wide-ranging situations. The agency finds that uses of these neonicotinoids have “varying degrees of effects on bees,” and that some uses “may pose a risk of concern to bees.” However, instead of a complete ban of the neonicotinoids, the agency is proposing mitigation measures to minimize potential exposure to bees, which includes the phase-out of many uses and certain additional product label statements.

Clothianidin will see a phase-out of the following uses:

• Foliar application to orchard trees and strawberries, and
• Foliar application to municipal, industrial and residential turf sites.

There will also be a reduction in the maximum number of foliar applications to cucurbit vegetables — to one per season. Seeds coated with clothianidin will be required to have additional label statements that would address dust off during planting of cereal crops.

For thiamethoxam the following uses are to be phased out:

• Foliar and soil application to ornamental crops that will result in pollinator exposure,
• Soil application to berry crops, cucurbit crops, and fruiting vegetables, and
• Foliar application to orchard trees.

Foliar applications to legumes, outdoor fruiting vegetables, and berry crops will have prohibition restrictions before and/or during bloom. Additional label statements will also be required for cereal and legume seeds coated with thiamethoxam.

As part of the re-evaluation, the agency looked at situations where honey bees come into contact with the neonicotinoids while visiting flowers, consuming pollen and nectar, and exposure to water and dust, as well as how developing bees and the whole colony are affected. Other species of bees, like bumble bees and solitary bees, were also considered. The proposed decisions for each of the neonicotinoids are subject to a 90-day public comment period, and comments may submit to Health Canada.

Health Canada and the U.S. Environmental Protection Agency (EPA) collaborate on their pollinator assessments, which are based on the jointly developed harmonized Guidance for Assessing Pesticide Risks to Bees. EPA recently ended its public comment period for the ecological impacts of the neonicotinoids, with the separate pollinator assessments released last year. EPA’s risk assessments find deadly impacts to birds from neonicotinoid-treated seeds, poisoned insect prey, and contaminated grasses. Researchers have found that tiny amounts of neonicotinoids are enough to cause migrating songbirds to lose their sense of direction. A recent study by U.S. Geological Survey (USGS) researchers found neonicotinoids widespread in the Great Lakes at levels that harm aquatic insects, and potentially the aquatic food web—the foundation of healthy aquatic ecosystems.

The Beyond Pesticides report Poisoned Waterways documents the persistence of neonicotinoids in U.S. waterbodies and the danger they cause to aquatic organisms, resulting in complex cascading impacts on the aquatic food web. The report also highlights current regulatory failures of EPA aquatic standards, which continue to underestimate risks to sensitive species, due to a reliance on test protocols that do not reflect real-world exposures or susceptibilities.

In 2016, Health Canada released its aquatic assessment of imidacloprid which found that the pesticide was building up in the surface and groundwater water and causing widespread death among aquatic insects. Its interim recommendation then was to ban imidacloprid from most agricultural and outdoor uses entirely, however, a final decision has been delayed.

Lisa Gue, an environmental health policy analyst at the David Suzuki Foundation, says Health Canada’s results were not as complete as European work, but she remains pleased the agency is still moving to phase out the pesticide’s use. “Canada’s decisions are coming in much less protective than in the European Union,” Ms. Gue said.

The European Food Safety Authority in February confirmed its findings that most uses of neonicotinoids pose a risk to wild bees and honey bees. In April, the European Union member states voted in favor of a total ban on the use of neonicotinoids by the end of 2018, except when used inside closed greenhouses. This was an extension on an initial ban issued in 2013.

The loss of bees represents a significant issue for food sources, since about one-third of food crops require pollinators for production.  Numerous scientific studies implicate neonicotinoid pesticides as key contributors to the global decline of pollinator populations. EPA’s own scientists have found that neonicotinoids pose far-reaching risks not only to bees but to birds and aquatic invertebrates.

Given the historic move in Europe, and this proposal in Canada. U.S. regulators must also take action to protect sensitive species from toxic neonicotinoids. Help push EPA to take substantive action on neonicotinoids by urging your U.S. Representative to support the Saving America’s Pollinators Act. With managed honey bee losses remaining at unsustainable levels and many wild pollinators at risk of extinction, for the future of food and our environment it is urgent that the U.S. finally protect pollinators.

Source: Health Canada; Global News

(Beyond Pesticides, June 6, 2018) By the close of 2018, three top neonicotinoid (neonic) pesticides, linked to the worldwide decline in bee populations, will be banned for outdoor use in the European Union (EU), based on the General Court of the European Union’s (GCEU) ruling last month. The GCEU, the equivalent of the U.S. Supreme Court, ruled in favor of taking precautionary action to protect pollinators from clothianidin, imidacloprid, and thiamethoxam. This ruling allows for the limited use of neonic-treated seeds grown in permanent greenhouses where contact with bees is not expected.

In its lawsuit, multinational seed and chemical companies, Syngenta and Bayer –manufacturers of the neonics in question– argued unsuccessfully that the pesticides do not necessarily harm bees if farmers use them according to label instructions. Syngenta also sought compensation of approximately $435 million to offset market losses resulting from the ban, but that, too, was denied. In rejecting the arguments of Syngenta and Bayer, the high court aligned itself with the European Food Safety Authority (EFSA) and its assessment of the harm caused by the widely used pesticides. EFSA’s updated assessment, released in February of this year, provided convincing evidence that neonics represent a risk to wild bees and honey bees. They disorient the bees by disrupting their navigation skills and ability to pollinate, collect nectar, and return to their hives to process the nectar into honey. The GCEU verdict comes just weeks after the EU voted to extend the ban on the use of clothianidin, imidacloprid, and thiamethoxam in flowering crops that it already had in place on the three neonicotinoids since 2013.

In the U.S., the Environmental Protection Agency (EPA) has been reluctant to take action on neonics, despite the existence of multiple, independent scientific, peer-reviewed papers demonstrating their hazards to pollinators and non-target organisms. In fact, the agency’s own scientists have concluded that neonics pose far-reaching risks to birds and aquatic invertebrates. They also found that neonics poison insect prey and contaminate grasses as well as bee pollinators. Yet, a hesitancy to take preemptive action on particularly damaging pesticides has pervaded the agency for years under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). When setting allowable uses of the pesticides in agriculture, EPA utilizes risk assessment reviews with extreme limitations when evaluating the registration or registration review of a food use pesticide in combination with its non-food uses. The agency has been criticized by Beyond Pesticides for not fully accounting for the uncertainties associated with safety data gaps, preexisting conditions, label compliance/accidents, mixtures and synergism, ecological and biological complexities (from soil microbiota to gut microbiome), while ignoring the question of need or essentiality. When evaluating ecological effects, EPA weighs the “economic, social, and environmental costs and benefits” associated with a given pesticide to determine whether an “unreasonable risk to human health and the environment” will occur. The problem with this approach is that it fails to allow for the prioritization of ecological protection. (See Beyond Pesticides, Pesticides and You, Thinking Holistically When Making Land Use Decisions.) Therefore, even in the face of compelling scientific evidence of harm, such as is the case with the three neonics, the revocation of pesticide registrations has proven difficult.

FIFRA markedly contrasts with the registration, evaluation, authorization and restriction of chemical (REACH) standard in the EU, which explicitly “aims to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances” under the law’s precautionary principle. In striking contrast, FIFRA aims to manage and weigh acceptable risks instead of privileging human and environmental health protection. Moreover, it is well-known that EPA interprets FIFRA to exclude precautionary action, which is a core principle embedded in the EU’s environmental law, and the standard used by GCEU to support its decision to uphold the EU ban the neonics. Beyond Pesticides has argued, however, that under the FIFRA “no unreasonable adverse effects” standard, it is not reasonable to expose the public and environment to a toxic pesticide when there is a less or non-toxic method or substance to achieve that target pest management objective.

In the lawsuit, the GCEU relied heavily on arguments documenting the need for the precautionary principle to be applied when considering the ban on the three neonics. Implementation of the precautionary principle allows restrictions to be placed on a chemical when a suspicion of harm exists, even in the absence of conclusive evidence. According to Eur-Lex, the official website of EU law, it “enables a rapid response to be given in the face of a possible danger to human, animal or plant health, or to protect the environment. In particular, where scientific data do not permit a complete evaluation of the risk, recourse to this principle may, for example, be used to stop distribution or order withdrawal from the market of products likely to be hazardous.”

This guiding principle of taking precautionary action before extreme environmental impacts are demonstrated from exposure to a given toxic chemical is lacking in U.S. policy making processes. One notable exception is the National Organic Program’s legally-mandated review of synthetic chemicals petitioned for inclusion on the National List of Allowed and Prohibited Substances. The Organic Foods Production Act (OFPA) regulations, which govern how organic food is grown, handled, and processed, prohibit the use of synthetic substances except under certain limited circumstances. To determine whether a normally prohibited substance will be allowed in organic, an assessment is made about its human health and environmental impacts, its essentiality in the agricultural system, the availability of alternatives, and its compatibility and consistency with organic systems of food production. This review process ensures that precautionary action is taken to prevent organic production systems, farmers, and farmworkers from being subjected to the harm associated with the most toxic chemicals used in agriculture.

In the face of this historic court decision in Europe to uphold a ban on three of the most egregious neonics, it is incumbent upon U.S. regulators to follow suit and take action to protect pollinators from these hazardous pesticides. Help persuade EPA to take substantive action on neonics by urging your Congressional Representative to support Saving America’s Pollinators Act of 2017. Visit Beyond Pesticides’ website for a sample letter.

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

Source:  Politico; General Court of the European Union; European Food Safety Authority

(Beyond Pesticides, June 5, 2018) After more than 100,000 Swiss citizens signed a petition calling for a ban on pesticides, Switzerland will soon have to vote on a complete ban on the use of synthetic pesticides. The ban would apply to farmers, industries, and imported goods, and advocates hope this measure would cause other EU nations to follow.

Switzerland, home of the world’s largest pesticide manufacturer, Syngenta, has been engaged in the debate raging across the European Union (EU) about the future use of pesticides. Recently, the EU reapproved glyphosate (Roundup) after months of deadlock, while certain countries like France have indicated that it will ban the chemical within three years. Now, the Swiss initiative, according to the BBC, will make it the first country in Europe to ban all synthetic pesticides, and the second in the world after Bhutan imposed a ban in 2013.

Swiss group, Future3, advocated for a ban and began collecting signatures in a crowd-funded initiative. More than 100,000 signatures have been collected, and on May 25, the details of the signatures will be checked and transferred to the Federal Council – the Swiss federal cabinet – which has one year to give recommendations to parliament. The legislators then have two further years to accept the initiative and schedule a vote or to come up with a counter initiative that could also feature on the ballot. If passed, all synthetic pesticides would be phased out over a period of 10 years.

“To not use any pesticides will trigger a complete change in agricultural practices,” said Antoinette Gilson who is with the Swiss citizens’ group Future3 that are pushing for the ban. “It might be difficult to go through, but in Switzerland already around 13% of farmers are organic. I talk to a lot of them and I have not met one who has regretted giving up pesticides.”

The ban would also apply to imports which could have significant impacts on neighboring countries as Switzerland imports almost 500kg of food per head of population, according to figures from the Federal Customs Administration. Supporters of the initiative think that if the Switzerland vote is eventually carried, it will have reverberated effect on other countries. Unsurprisingly, farmers and industry representatives are dismissive of the idea of the referendum, saying that it is too extreme and will not gain popular support.

With tensions high over the review of Monsanto’s controversial glyphosate, other harmful pesticides, and industry’s influence in decision-making processes, the European Parliament decided to set up a special committee to look into the EU’s authorization procedure for pesticides. The special committee is to assess the authorization procedure for pesticides in the EU and potential failures in how substances are scientifically evaluated and approved.

In April, EU member states backed a proposal to further restrict uses of bee-toxic neonicotinoids finding the pesticides’ outdoor uses harm bees. These restrictions go beyond those already put in place in 2013, and now all outdoor uses of clothianidin, imidacloprid, and thiamethoxam will be banned. The European Commission, the protection of bees is an important issue since it concerns biodiversity, food production, and the environment. The new restrictions agreed to on April 27 go beyond the 2013 ban. All outdoor use of the three substances will be banned and the neonicotinoids in question will only be allowed in permanent greenhouses where no contact with bees is expected. French scientists say parts of their country’s forests, streams, and bucolic landscapes could be completely devoid of birdsong this year, as the results of two recent studies show staggering declines in bird populations throughout the nation linked to the intensification of agricultural practices and pesticide use.

While the U.S. continues to languish in regulatory inertia, the best way to avoid harmful pesticides is to support organic practices in landscapes and agriculture and purchase organic food. Beyond Pesticides has long advocated for organic management practices as a means to foster biodiversity, and research shows that organic land management does a better job of protecting biodiversity than its chemical-intensive counterparts. Instead of the prophylactic use of pesticides and crops bioengineered with insecticides, responsible organic practices focus on fostering habitat for pest predators and ecological balance and only resort to the judicious use of least-toxic pesticides when other cultural, structural, mechanical, and biological controls have been attempted and proven ineffective.

As evidence of the hazardous effects of glyphosate continues to mount, environmental groups, including Beyond Pesticides, are urging localities to ban or restrict the use of the chemical and other toxic synthetic pesticides.

Source: BBC News

Graphic will confuse consumers who do not realize the product contains genetically engineered ingredients.

(Beyond Pesticides, June 4, 2018) As the deadline approaches for regulations on labeling genetically engineered (GE or GMO —genetically modified organism) food, the U.S. Department of Agriculture (USDA) has proposed a rule that fails in every important respect:

• It allows information to be conveyed by QR codes, whose use requires a cell phone (with camera function) and a reliable broadband connection.
• It allows GE food to be identified as “bioengineered” OR by a smiley-faced symbol containing the letters “be.”
• It does not cover highly processed GE foods, like vegetable oils or sugar, and does not include newer genetic engineering techniques, such as CRISPR (a gene editing tool).
• Implementation is delayed.

USDA is accepting comments through Regulations.gov. For quick copy and paste, use the text below to comment at regulations.gov. Add a personal message at the beginning about why this is important to you, if possible.

Tell USDA We Need Honest, Transparent, Informative GE/GMO Labeling

Suggested Comments:

As a consumer, I have a right to know whether my food is produced using genetic engineering. As USDA finalizes labeling regulations, please ensure that labels are honest, transparent, and informative by adopting the following policies:

1. Reject package labeling with unreliable “QR codes” and other discriminatory communication methods; such options discriminate against more than 100 million Americans — especially many in rural communities, as well as low-income, people of color, and elderly populations that tend disproportionately to lack access to these technologies.
2. Require labeling to use only common, well-established labeling terms, such as GE or GMO. Do not allow these to be replaced with the term “bioengineered,” or the entirely unfamiliar acronym “be.”
3. Require neutral symbols: The disclosure law permits the use of symbols instead of text, but the proposed symbol — which conveys a blatant bias with its “smiley face” sun — should be prohibited, and only the acronym “GE” or “GMO” should be allowed as shorthand.
4. Require all foods produced with genetic engineering — including highly processed oils and sugars — to be labeled.
5. Include new and future methods of genetic engineering, such as gene editing (including CRISPR).
6. Require companies to use GMO content labels by January 1, 2020, and reject the proposed delay until 2022.
7. Ensure harmonization with the European Union by requiring disclosure if unintended GE contamination exceeds the current level of detection.

Thank you for your consideration of my comments.

(Beyond Pesticides, June 1, 2018) States and civil society organizations launched new lawsuits in late May against the Pruitt Environmental Protection Agency (EPA) for its continued attack against farmworker health and safety. Two separate lawsuits, one filed by attorneys general in the states of California, Maryland, and New York, and another by health and justice advocates represented by Earthjustice and Farmworker Justice take aim at EPA’s decision to delay the implementation of training requirements designed to protect farmworkers and their families. This is the latest in a series of lawsuits which began when EPA announced it would delay the Certification of Pesticide Applicators Rule in May of last year.

Under the Obama administration, EPA released new rules updating farmworker protections after over 20 years of inaction. These rules are important because unlike your average American worker, farmworkers do not have protections under the Occupational Safety and Health Administration (OSHA). At its introduction, the new standards raised the age to apply toxic pesticides to 18, and improved the frequency and quality of training materials farmworkers are provided, among a number of other positive changes.

After EPA announced it would be delaying the implementation of these changes, and reviewing the age requirement, the agency provided stakeholders only four days for public comments. This led to a lawsuit by Earthjustice and other farmworker groups, and a ruling earlier this year by a U.S. District Court judge for the Northern District of California that EPA’s delay was a violation of the law.

These new lawsuits focus on EPA’s continued delay of the mandatory training requirement for farmworkers, which detail how pesticide safety for workers can be improved, and steps can be taken to reduce exposure to their children and loved ones after working all day in a contaminated field. Despite the fact that EPA has acknowledged that these materials have been ready for more than a year, the agency has refused to issue a Federal Register notice. Once announced, the improved training materials would become mandatory and required to take place within six months.

“EPA is refusing to provide official notice that upgraded materials are available,” said Earthjustice attorney Hannah Chang. “This should be a no-brainer. But because of EPA’s refusal, thousands of farmworkers will not receive the pesticide training they need to know their rights in the workplace, and to protect themselves and their families from pesticide exposure.”

Public health and farmworker groups note that these protections are critical as farmworker life expectancy is 49 years compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s.

“Farmworker women suffer grave reproductive health consequences, along with the other health issues that workers and community members face, because of pesticides exposure. The risk of detrimental health consequences is exacerbated when they are not applied correctly,” said Mónica Ramirez, president of Alianza Nacional de Campesinas, a farmworker group represented in the current lawsuit. “Rigorous review by scientists and others has already determined that it was necessary to provide more training and increase regulation of these dangerous chemicals to protect the health of workers and community members. We are calling on the Trump Administration to put people’s lives and their health over cutting corners for corporate gain.”

Time and time again, the Pruitt EPA and the Trump Administration have taken the actions that benefit agrichemical corporations over the health of people. The administration has slashed EPA staff, kept highly toxic pesticides with known health risks on the market, and downgraded serious pesticide violations against farmworkers from $4.8 million to a $150,000 slap on the wrist.

Like the requirement that only those 18 and above handle highly toxic pesticides, implementation of these training requirements could slightly impact corporate profits. Unfortunately, despite being part of the negotiation process that produced the new farmworker standards under the Obama administration, the agrichemical industry does not appear to support simple protections for the workers they pay to grow their food and come in intimate contact with their hazardous products.

Before we ask you to take action, please listen to farmworkers tell their story in their own voice. At Beyond Pesticides 36^th National Pesticide Forum, four brave young agricultural and dairy workers participated in a panel discussion about what their lives were like working in agriculture and living in a farming community. For individuals unsure or unaware of the dangers of working in this industry, the discussion is required viewing and can be watched in full (~45 min) on Beyond Pesticides’ youtube page.

After you’ve taken time to hear their stories, act to protect farmworkers today. Tell your Congressional delegation to not allow EPA to eliminate minimum age requirements around highly toxic pesticides. More on the plight farmworkers face can be found on Beyond Pesticides’ Agricultural Justice webpage. Listen to speakers on farmworker health at the 36th National Pesticide Forum, Organic Neighborhoods: For healthy children, families, and ecology: Nayamin Martinez, MPH, executive director of Center California Environmental Justice Network, Fresno, CA; and, farmworker youth – Raul Garcia, Lety Loopez, Lupita Gonzalez, and Trinidad Moreno, introduced by Angel Garcia, founder and community organizer, Tulare County Coalition Advocating for Pesticide Safety, Lindsay, CA.

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

Source: EarthJustice

(Beyond Pesticides, May 31, 2018) Deforestation in tropical regions helps spread malaria, concludes a recent research study of the Amazon Rainforest. Published in Nature’s open-access journal, Scientific Reports, the study details researchers’ work, from 2009–2015, comparing patterns of deforestation to rates of malaria in nine states in the Brazilian rainforest. Investigators found that the highest malaria incidence concentrated in impacted patches of forest — areas deforested or otherwise degraded from an unmanaged or more-natural state.

These medium-sized patches (from .1 to 5 sq. km. in size) seem to be the “sweet spots” at which wood extraction activity (logging, charcoal production, et al.) correlate most strongly with malarial infection rates. The researchers suggest that the finding is perhaps related to the habitat preferences of the primary malaria vector in the region, Anopheles (Nyssorhynchus) darlingi, which breed most happily in shady, watery, edges of forest habitat. Sixty of the 380 mosquitoes in the genus Anopheles can transmit the malaria parasites.

Deforestation fragments the forest landscape, creating more forest “edges,” which means more places for mosquitoes to breed. This fragmentation may also help malaria-carrying mosquitoes spread to other areas as adults: “The new [fragmented] landscape delineated by the pattern of deforestation and soil occupation may favor dispersal of Ny. darlingi by creating forested areas interspaced by deforested areas, which are linked by forest corridors along [small streams] and shaded dirt roads,” note the researchers. They also discovered that the driest months in the region correlated with the heaviest logging activity, and therefore, increasing forest fragmentation and higher numbers of malaria cases. The deforestation activity itself can introduce malaria to areas previously untouched by the disease, via human loggers with previous exposure to the disease, who act as vectors as they move around the rainforest.

A leading cause of death in tropical regions, malaria continues to be a scourge in regions of Africa, Asia, and South America. As of 2016, 3.4 billion people across 91 countries face risk of infection and developing the disease, with more than 1 billion at high risk. In 2015, there were 212 million cases and 429,000 deaths globally; more than 90% of deaths were on the African continent (in the broad equatorial zone), and 2/3 of those were of children under 5 years of age. The disease varies widely in severity, and is generally curable if diagnosed and treated promptly and appropriately; among the symptoms of malaria can be fever, chills, sweating, nausea, vomiting, headache, body ache, enlarged spleen and/or liver, and mild jaundice, among others.

So how to combat malaria and the vectors that transmit it — particularly as rampant deforestation may cause spikes in malaria incidence? Reducing deforestation is an obvious, if daunting, goal. Medical approaches, once the disease is contracted, are limited; only a dozen or so antimalarial drugs are readily available for use, and there is significant malarial resistance to most of them. Without a reliable method for killing the parasite that causes the disease, approaches have tended to focus on killing the mosquitoes that transmit them. This has generally meant an abundant use of sprayed applications of insecticides, which are questionably effective and have myriad impacts related to their toxicity.

Beyond Pesticides has written, “Reliance on pesticides, especially DDT, as a silver bullet solution for malaria protection is extremely dangerous. When the underlying causes of pest problems are not adequately addressed, then a sustained dependence on toxic pesticides like DDT causes greater long-term problems than those that are being addressed in the short-term. Beyond Pesticides advocates the fighting of malaria without poisoning future generations of children in malaria hot spots. We should be advocating for a just world in which we no longer treat poverty and development challenges with poisonous band-aids, but instead, join together to address the root causes of insect-borne disease, because the chemical-dependent alternatives are ultimately deadly for everyone.”

From the 1940s until the 1960s, DDT — dichloro diphenyl trichloroethane — was the go-to control for mosquitoes that carry malaria. However, the compound was found to be extremely persistent in and harmful to the environment, and to accumulate in fatty tissue in humans. Exposure to DDT and its breakdown product DDE has been linked with impacts on fertility, immunity, hormones, and brain development, and with adverse health outcomes, such as breast cancer, diabetes, obesity, decreased semen quality, spontaneous abortion, impaired neurodevelopment in children, and even multigenerational effects.

In addition, its rampant overuse, both to control disease vectors and in agriculture, resulted in the development of significant resistance to the compound. Today, DDT resistance is widespread in Anopheles mosquitoes. As the Pesticide Action Network North America notes, “Of the 73 countries that provided monitoring data to WHO [the U.N.’s World Health Organization] from 2010 onward, 60 countries reported insect resistance to at least one insecticide and 50 reported resistance to 2 or more insecticides. This highlights the problem of relying on insecticide-based strategies for vector control. . . . Ultimately, disease vectors and parasites develop resistance to the insecticide and it becomes almost ineffective in the long run.”

Although DDT is no longer manufactured or used in much of the world (China is currently the largest manufacturer), its use continues in 19 countries. DDT was banned in the U.S. in 1972. In 2009, the United Nations Environment Programme (UNEP) and World Health Organization (WHO) announced an effort to fight malaria with incremental reduction of reliance on the synthetic pesticide DDT. As Beyond Pesticides has reported, WHO and the UNEP undertook an initiative, comprising a host of projects, aimed at reducing use of DDT worldwide by 30% by 2014 and a total phaseout by the early 2020s, while meeting malaria incidence targets. WHO sees these projects in the context of Integrated Vector Management (IVM), which it promotes as the approach of choice to control transmission of malaria and other vector-borne diseases. A key element of IVM is a solid evidence base for the effectiveness of combinations of locally adapted, cost-effective, and sustainable vector-control methods. This approach can facilitate a sustainable transition away from the use of DDT.

Pesticide Action Network of North America (PANNA) agrees, saying, “Vector control that uses community-based, least-toxic versions of IVM is more effective in the long-term than short-term toxic chemical controls. Pesticide Action Network has worked for a decade with communities in Senegal on use of IVM and observed significant reductions in malaria incidence.”

The problem of malaria in many affected regions is, in part, a development issue. Greater investment in living conditions, including those that suppress mosquito breeding — such as effective environmental and water body management (e.g., to limit breeding habitat) — as well as practices that keep mosquitoes out of people’s living spaces would go a long way to reducing disease occurrence. Improved healthcare and public education on personal protections would also support the effort. Low-tech and effective strategies include mosquito traps, bed nets, screening between outside and inside spaces, and personal repellents. Appropriate toolkits will differ somewhat, based on local conditions.

Check out all the mosquito prevention and management information on Beyond Pesticides’ mosquito management webpage and the Public Health Mosquito Management Strategy: For Decision Makers and Communities.

Source: https://news.mongabay.com/2018/05/study-links-deforestation-and-malaria-in-the-amazon/?utm_source=EHN&utm_campaign=da3be3d21f-Science_saturday&utm_medium=email&utm_term=0_8573f35474-da3be3d21f-99059849

(Beyond Pesticides, May 30, 2018) Six environmental groups have sued the Trump Administration for reversing a long standing interpretation of the Migratory Bird Treat Act (MBTA) that provides migratory bird protections from incidental killing or “taking” caused by industrial activities. The lawsuit, National Audubon Society v. Department of the Interior, was filed May 24, 2018 in the Southern District of New York, challenging as “unlawful and arbitrary and capricious the December 22, 2017 Solicitor’s Memorandum M-37050, which was issued by the office of the Solicitor of the Department of the Interior (“DOI”) and reverses Defendants DOI’s and the U.S. Fish and Wildlife Service’s (“FWS” or “Service”) longstanding interpretation and implementation of the Migratory Bird Treaty Act of 1918.” The Act’s prohibition on the killing or “taking” of migratory birds has long been understood to extend to incidental take from industrial activities — meaning unintentional but predictable and avoidable killing.

Last year, the Trump Administration issued a Memorandum gutting federal protections for migratory birds under the Migratory Bird Treaty Act (MBTA). The plaintiffs, including American Bird Conservancy, Center for Biological Diversity, Defenders of Wildlife, National Audubon Society, National Wildlife Federation, and the Natural Resources Defense Council, are seeking to protect waterfowl, raptors, and songbirds under the MBTA.

In the Memorandum issued December 2017, the Administration abruptly reversed decades of government policy and practice — by both Democratic and Republican administrations — on the implementation and enforcement of the MBTA. Under the Administration’s revised interpretation, the MBTA’s protections will apply only to activities that purposefully kill birds. Any “incidental” take — no matter how inevitable or devastating the impact on birds — is now immune from enforcement under the law.

According to the coalition that filed the lawsuit, the risk of liability under the MBTA has long provided the oil and gas industry, wind energy development companies, and power transmission line operators with an incentive to work with the U.S. Fish and Wildlife Service to minimize bird deaths. For example, in an effort to protect migratory birds and bats and avoid potential MBTA liability, the wind industry, conservation groups, and the U.S. Fish and Wildlife Service worked to develop comprehensive guidelines aimed to ensure best practices for siting and developing wind farms. The Administration’s new policy eliminates this incentive for industries and individuals to minimize and mitigate foreseeable impacts of their activities on migratory birds, putting already-declining populations of our nation’s songbirds and other migratory birds at risk.

The MBTA allows for criminal enforcement actions to target incidental take resulting from industrial activities that foreseeably and predictably kill migratory birds, such as operating oil pits without precautions to protect birds, misapplying pesticides in areas known to be frequented by birds, operating contaminated waste treatment ponds in the absence of any measures to safeguard birds, and erecting power lines in areas with high concentrations of migratory birds. If incidental take liability is eliminated, industry will no longer need to take measures to protect birds from these hazards.

“The Trump administration’s rollback of the Migratory Bird Treaty Act is an absolute disaster for America’s birds,” said Noah Greenwald, endangered species director at the Center for Biological Diversity. “Many bird species are already declining from habitat destruction and a host of other threats. This rule will allow the death of even more birds, whether they’re landing on polluted ponds left uncovered by the oil and gas industry or have their nest trees cut down from underneath them. It’s tragic.”

In addition, when the 2010 BP Deepwater Horizon disaster spilled more than 210 million gallons of oil in the Gulf of Mexico more than 1 million birds were killed in the four years following the blowout. BP paid $100 million in fines under the MBTA that supported wetland and migratory bird conservation. The new interpretation would bar the federal government from seeking such mitigation under the MBTA for devastating oil spills in the future.

“We cannot let Secretary Zinke add one of the oldest and most important laws for birds to his list of anti-environmental giveaways, especially when birds are in critical need of protection. Drastically slashing the reach of the MBTA and removing accountability for preventable bird deaths is unacceptable,” said Katie Umekubo, Natural Resources Defense Council, senior attorney, nature program.

Populations of birds, like other pollinators, have been declining. Researchers have found that small amounts of pesticides like the neonicotinoids are enough to cause migrating songbirds to lose their sense of direction. Recently, French scientists and ornithologists say parts of their country’s forests, streams, and bucolic landscapes could be completely devoid of birdsong this year, as the results of data that show staggering declines in bird populations linked to the intensification of agricultural practices and pesticide use.

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

Source: Center for Biological Diversity

(Beyond Pesticides, May 29, 2018) The Farm Bill is beginning to move in the U.S. Senate Committee on Agriculture, Nutrition, and Forestry, and your voice is critically needed to help stop provisions that are harmful to health and the environment.

Tell your U.S. Senators and Representative that they should vote against the Farm Bill unless harmful provisions to health and the environment are removed.

In addition to sending this urgent action on the Farm Bill, consider reaching out to your U.S. Senators and Representative when they return to your state for the Memorial Day holiday. If you’re part of a group, ask for a meeting. If you see them at an event or in town, let them know how important it is to keep the dangerous provisions listed below out of the Farm Bill.

The Farm Bill in the U.S. House of Representatives, H.R. 2, reported favorably out of the House Agriculture Committee, is stalled, after being defeated on the floor over unrelated immigration legislation. The House bill is a direct attack on organic standard setting, the authority of local governments to restrict toxic pesticides, and the protection of farmworkers, endangered species, and the environment. Without public outcry, it is likely that the bill produced by the Senate Agriculture Committee will be at least as bad as the House bill.

Protect Organic Standards. The Organic Foods Production Act (OFPA) gives the National Organic Standards Board (NOSB) broad authority and responsibility to ensure organic integrity. The House version of the Farm Bill contains provisions that will give USDA greater direct and indirect power to allow products and practices that were not intended to be a allowed in organic – hydroponics, poultry houses without real access to the outdoors, and dairy operations without meaningful pasture. The Farm Bill should not:

• Permit the U.S. Department of Agriculture (USDA) to sidestep the NOSB in allowing toxic post-harvest handling substances (sanitizers) to be used in organic production;
• Change the classification of types of people who may be appointed to the NOSB by adding employees of farmers, handlers, and retailers; and
• Force consideration of allowing the use of products in organic that are subject to weaker standards of the Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA).

The Farm Bill should also not contain provisions that:

• Amend the federal pesticide law to pre-empt local governments from restricting pesticide use on private property within their jurisdictions;
• Exempt the use of pesticides from the Endangered Species Act, effectively dooming hundreds of endangered species to extinction and making it legal to kill any endangered species with a pesticide at almost any time;
• Eliminate litigation as a remedy when pesticide decisions threaten endangered species;
• Eliminate all protections under the Clean Water Act when toxic pesticides are sprayed directly into rivers and streams;
• Enact the “Pesticide Registration Improvement Act,” providing long-term funding to EPA for expedited processing of pesticide approvals, without accompanying measures to ensure that farmworkers and other pesticide applicators are safe;
• Weaken restrictions on the use of the highly toxic ozone deplete, methyl bromide; and
• Provide state pesticide regulatory agencies a secret chance to slow or effectively veto EPA pesticide protections before they are proposed.

Tell your U.S. Representative and Senators that they should vote against the Farm Bill unless harmful provisions to health and the environment are removed.

Letter to Your Members of Congress:
Vote Against The Farm Bill (H.R. 2)  and Senate Version Unless Harmful Provisions to Health and the Environment Are Removed

The Farm Bill (H.R. 2), as reported out of the House Agriculture Committee, is unacceptable. It should not be passed by the House and similar provisions should not be passed by the U.S. Senate.

Regarding the importance of maintaining the integrity of food labeled organic, the Farm Bill should not:

• Permit the U.S. Department of Agriculture (USDA) to sidestep the National Organic Standards Board (NOSB) in allowing toxic post-harvest handling substances (sanitizers) to be used in organic production;
• Change the classification of types of people who may be appointed to the NOSB by adding employees of farmers, handlers, and retailers; and
• Force consideration of allowing the use of products in organic that are subject to weaker standards of the Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA).

The Farm Bill should also not contain provisions that:

• Amend the federal pesticide law to pre-empt local governments from restricting pesticide use on private property within their jurisdictions;
• Exempt the use of pesticides from the Endangered Species Act, effectively dooming hundreds of endangered species to extinction and making it legal to kill any endangered species with a pesticide at almost any time;
• Eliminate litigation as a remedy when pesticide decisions threaten endangered species;
• Eliminate all protections under the Clean Water Act when toxic pesticides are sprayed directly into rivers and streams;
• Enact the “Pesticide Registration Improvement Act,” providing long-term funding to EPA for expedited processing of pesticide approvals, without accompanying measures to ensure that farmworkers and other pesticide applicators are safe;
• Weaken restrictions on the use of the highly toxic ozone depleter, methyl bromide; and
• Provides state pesticide regulatory agencies a secret chance to slow or effectively veto EPA pesticide protections before they are proposed.

Please vote against the Farm Bill unless all these provisions are removed.

Sincerely,

(Beyond Pesticides, May 25, 2018) The results of a pilot study conducted by an international team of researchers finds that exposure to the herbicide glyphosate results in adverse health effects at levels below those regulators deem “safe” or acceptable. These results represent the first phase of a Global Glyphosate Study based at the Ramazzini Institute in Bologna, Italy, in coordination with the University of Bologna, the Italian National Institute of Health, George Washington University, and the Icahn School of Medicine at Mount Sinai, NY. Researchers are aiming to provide a truly independent, comprehensive evaluation of the risks posed by glyphosate-based herbicides.

The pilot study, available now on the research team’s website and later this month in the journal Environmental Health, focused on generating data on how glyphosate effects early-life stages of development. A three-month study on rats, used as a surrogate for human development until 18, exposed the animals to both technical grade glyphosate and the formulated herbicide Roundup. Rats ingested 1.75 miligrams of glyphosate or Roundup per kilogram of body weight each day from the womb until 13 weeks after weening. This is the chronic reference dose used by the U.S. Environmental Protection Agency, and an exposure rate at which the agency indicates humans will experience no adverse health effects.

Researchers found that Roundup exposure results in a range of adverse impacts to important biological processes. Biomarkers related to sexual development and genotoxicity, the ability to damage the genetic information within a cell, were found, as well as changes to the make-up of the rats’ gut microbiome. The rat microbiome underwent significant shifts before what would correspond as the onset for puberty in human life, indicating that glyphosate may impact young individuals during a “critical window of vulnerability” in the development of one’s intestinal flora. Formulated Roundup was also found to have a more significant impact on the gut microbiome than technical grade glyphosate, which researchers indicated may be indicative of synergistic impacts between glyphosate and inert ingredients in Roundup’s formulation.

“By its very nature and purpose, the pilot study does not resolve the uncertainties puzzling the various Agencies (IARC, EFSA, ECHA) as to whether glyphosate and Glyphosate Based Herbicides (GBHs) are carcinogenic or not, but it does highlight health effects that are equally as serious, that might manifest as long-term oncological pathology, and that might affect a huge number of people, given the planet-wide use of the GBHs,” said Phillip Landrigan, MD, of Ican School of Medicine at Mount Sinai said in a press release “These early warnings must be further investigated in a comprehensive long-term study.”

In order to achieve independence from outside interests on either side of the glyphosate debate, researchers aim to fund their project through crowdsourcing. The 300,000 euro pilot study was funded by 30,000 Italian residents, and the team is now accepting donations for the first stage of its long-term study. Researchers indicate the long-term study will look not only at carcinogenicity and chronic toxicity, but also review impacts relating to developmental and reproductive toxicity, fertility, gene expression, the microbiome, nervous system effects, critical windows of susceptibility, and prenatal, locational, and neonatal exposure. The long-term study will also investigate variations in impact between formulated Roundup and technical grade glyphosate. As researchers note, “This will be the most comprehensive study on GBHs to date and it will last 3-4 years.”

During the study period, researchers will create a scientific committee comprised of international experts to evaluate the study’s process and ultimately review its results. The team expects the study to provide “solid independent results” that can be integrated into risk assessments for glyphosate moving forward.

For more information, see Beyond Pesticides’ Monsanto’s Roundup (Glyphosate) Exposed and factsheet on Glyphosate (Roundup). Also see Beyond Pesticides’ Gateway on glyphosate.

In the meantime, those concerned about exposure to Roundup and other toxic synthetic herbicides in and around their homes and communities can take action to eliminate its use. Start by letting us know you’re ready to fight for a pesticide-free community. And to avoid exposure to glyphosate through food, choose organic, which never allows the use of glyphosate, genetically engineered foods, or other hazardous pesticides.

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

Source: Global Glyphosate Study

(Beyond Pesticides, May 24, 2018) California’s Department of Pesticide Regulation (DPR) is falling short of protecting vulnerable communities in the state, especially low-income and communities of color. This, according to a new report by California Environmental Justice Alliance (CEJA), which assesses state agencies on eight environmental justice principles. The poor showing by DPR comes at the forefront of reports that the state’s pesticide use has increased, nearing record highs.

The findings are from California Environmental Justice Alliance’s (CEJA) 2017 Environmental Justice Agency Assessment, which provides full assessments of nine key agencies in the state including, California Air Resources Board, Department of Pesticide Regulation, and the Department of Toxic Substances Control, and lists an additional six agencies to monitor. The assessment gave the California Department of Pesticide Regulation (DPR) poor grades for its persistent failure to prioritize community health over industry profits. The agencies were judged on eight environmental justice principles, with a score of good, fair or poor for each. DPR’s scores were evenly divided between “fair” and “poor.” Specifically, the report concludes, “Many state agencies are not successfully integrating [environmental justice] into their decision-making. Overall, many state agencies still make decisions that actively harm [environmental justice] communities and fail to meaningfully prioritize their long-standing health and quality of life needs.”

Under scrutiny is DPR’s relationship with DowDuPont and its hazardous, drift-prone fumigant, telone (1,3-dichloropropene), one of the most heavily used pesticides in California. Last year, despite public pressure to increase restrictions on telone, DPR relaxed its cancer risk level that allowed use to increase by 50%. DPR also drew criticism for its failure to take meaningful action on DowDuPont’s neurotoxic, organophosphate pesticide chlorpyrifos, which came under focus in California after U.S. EPA Administrator Scott Pruitt reversed a proposed federal ban. The report also called out DPR for its slow response to a series of pesticide drift incidents in 2017 that sickened dozens of farmworkers. Only two of the five incidents have been investigated to date.

CEJA’s assessment is the only one in the nation to evaluate state agencies based on the impact of their environmental policies on low-income communities and communities of color. This is critical as the California Department of Public Health finds that Latino schoolchildren are almost twice as likely as their white peers to attend schools in the top quartile for nearby pesticide use, but DPR’s regulations do not address the racial disparity in exposure

The assessment of DPR’s performance comes less than a month after their latest annual pesticide use report was released, which showed the overall use of pesticides close to an all-time high. Over 209 million pounds of pesticides were applied in the state in 2016, the third highest since reporting began in 1990. According to Pesticide Action Network (PAN), the greatest burden continues to be borne by the San Joaquin Valley, with half (106 million pounds) used in just five counties – Fresno, Kern, Tulare, San Joaquin and Madera. Among the top five most heavily used pesticides in 2016 were DowDuPont’s telone and Monsanto’s herbicide glyphosate (Roundup), both linked to the onset of cancer. Chlorpyrifos, the controversial neurotoxic organophosphate, which can lead to neurological impairments in children dipped to just under a million pounds for the first time in a decade. Last year, a proposed nationwide ban of chlorpyrifos was reversed at the last minute by U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt.  Thus far, California’s Attorney General Becerra joined with seven other Attorneys General in challenging the EPA’s decision, and the California Office of Environmental Health Hazard Assessment just added chlorpyrifos to the list of Proposition 65 chemicals. However, DPR has taken little meaningful action on the chemical despite calls for a ban in the state. Instead, the agency announced “Interim recommended permit conditions” that counties can implement to increase protections, including buffer as little as 150 feet – actions advocates called weak. Like EPA, DPR will continue to review the data surrounding chlorpyrifos despite the overwhelming evidence of harm.

Additionally, just last month a group of 56 scientists studying the effects of neonicotinoid pesticides sent a letter to DPR highlighting the threat neonicotinoids pose to the health of California’s waterways. The scientists urge DPR to take steps to reduce neonicotinoid contamination of the state’s streams and rivers. Earlier this year, a California court halted a state program allowing pesticide spraying at schools, organic farms, and backyards across the state because of inadequate public disclosure of the chemicals’ adverse effects. This was in response to a lawsuit brought by the City of Berkeley and eleven public-health, conservation and food safety organizations.

See Beyond Pesticides’ Agricultural Justice page.

Source: PAN News Release

(Beyond Pesticides, May 23, 2018) Earlier this month, the Connecticut state legislature voted to ban the use of residential pesticide misting systems. (These are devices that are typically placed outdoors and spray insecticides –mostly in an attempt to control mosquitoes.) This is the latest move from a state legislature that has also recently banned the use of bee-toxic neonicotinoids and stopped the use of hazardous lawn care pesticides on public playgrounds. The vote was unanimous in the state Senate, and won by a count of 132-17 in the state House. The bill is set to become law on May 24, unless Governor Malloy vetoes the legislation, which is not expected.

Pesticide misters are machines primarily used to spray mosquito adulticides. Many health advocates have expressed concern that these products, able to spray toxic pesticides on a timer at regular intervals, pose a significant risk to pets and children who can be directly in the path of a mister’s spray. The chemicals employed in these machines are often synthetic pyrethroids, which have been linked to a range of human health effects, from early puberty in boys, to behavioral disorders, learning problems, ADHD, and certain cancers. Neighbors who do not want to be exposed to these chemicals are also put at risk from pesticide drift.

Nancy Alderman, president of the Connecticut nonprofit Environment and Human Health, the organization that supported the legislation, said: “Mosquito misting devises are extremely dangerous and there were absolutely no regulations to control them. They spray toxic insecticides on a continual basis at heights that could spray children and pets. EPA does not regulate them, declaring they can only regulate pesticides – not the appliances that spray them. States therefore are left to do something about these dangerous appliances.  There is no way to regulate them – they are so dangerous they must be banned. These pesticide misting devices  go off every few minutes spraying toxic pesticides. Because they are often installed around the perimeter of a yard, they affect neighbors who have no way to protect themselves or their pets. The pesticides used in them are toxic to bees.”

These machines also endanger pollinators that may be foraging in an area where these devices are used. Studies find that sublethal concentrations of synthetic pyrethroids can significantly reduce bee fecundity and decrease the rate at which bees develop to adulthood and reproduce. Several field and laboratory studies using pyrethroids have consistently documented decreases in foraging activity and activity at the hive entrance after exposure.

While pesticides are regulated by the U.S. Environmental Protection Agency (EPA), pesticide misters and other application devices are not subject to EPA oversight. This leaves states with the authority to control their use. Connecticut appears to be the first state to restrict these machines through legislation. The state of New York took an administrative approach to regulating these devices, as the commissioner of the state’s Department of Environmental Conservation used his authority to deem pesticides used in misting systems as restricted use (only available to certified applicators).

In 2015, Public Employees for Environmental Responsbility (PEER) filed a complaint with the Federal Trade Commission, detailing false and deceptive claims by manufacturers of pesticide misters. Specifically, PEER noted that manufacturers claim that these misters i) are effective in controlling mosquitoes despite contention from experts and even the American Mosquito Control Association that they are not effective, ii) have the ability to kill ticks, of which there is no evidence, and iii) are “safe” and “natural,” despite their use of highly toxic pesticides. Absent federal action, the responsibility to regulate these dangerous devices falls to the states.

Staying mosquito-free in one’s backyard requires both individual and community efforts. For the individual, during mosquito season use least-toxic repellents like oil of lemon eucalyptus. If possible, wear loose, light colored long-sleeved clothing. If you want to spend protected periods outside sipping lemonade during a hot summer day, sit next to an oscillating fan, as mosquitoes are not great fliers. Or, for more effective management, sit inside a screened in deck, or more economical pop-up tent.

At the community level, you can achieve neighborhood-level reductions in mosquitoes by joining with your neighbors in regularly dumping out standing water or larvaciding sites that cannot be drained. Most common mosquitoes don’t fly too far from where they hatched, and often one location in a community, such as stagnant water in a neighbor’s old pool, can be a major vector for mosquito breeding throughout the neighborhood.

Use Beyond Pesticides’ mosquito doorknob hangers to get the word out. Contact the office for 25 free hangers, or purchase more at Beyond Pesticides’ Storefront. If you are concerned about broader aerial or truck-mounted spraying campaigns by governments or vector control districts, also reach out to Beyond Pesticides at [email protected] or 202-543-5450 for organizing strategies to stop toxic mosquito spray in your community.

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

Source: Connecticut General Assembly SB104

(Beyond Pesticides, May 22, 2018)  A staggering 209 million pounds of pesticides were used in California in 2016, according to the latest data released by the Department of Pesticide Regulation (DPR). This figure refers only to applied “active” pesticide ingredients and not “inerts,” which often account for 80 to 99 percent of pesticide products and can be equally hazardous to human health and the environment. Even though pesticide use in the state has dropped by 1.4 percent from the previous year, pesticide use in 2016 was still the third highest in recorded history, since the inception of DPR’s comprehensive data collection program in 1990. In fact, the total pesticide use was only six million pounds shy of the highest amount ever recorded – 215 million pounds in 1998. The land area treated with carcinogens is as large as the size of New Jersey and Connecticut combined.

Nearly 102 million cumulative acres of land were treated with pesticides in the state, ranging in toxicity from low to high risk. Each time an acre is pesticide-treated in a given year, DPR adds the acre to its cumulative list, even if the treatment is repeated on the same land. The 2016 figure represents an increase of 4.3 million treated acres (4.4 percent) over 2015. What is the most troubling about these data is the fact that pesticides on either California’s Prop 65 list or EPA’s list of chemical carcinogens were applied to more than nine million cumulative acres in the state. This is equivalent to spreading the most hazardous pesticides ever produced on a swath of land the size of New Jersey and Connecticut combined. Chief among the most widely used and carcinogenic pesticides listed in DPR’s report is the herbicide glyphosate, and the soil fumigants 1,3-dichloropropene and metam-potassium.

While California’s pesticide use has been increasing over the past ten years from 172 million pounds in 2007, DPR consistently downplays the community, worker, and environmental impacts of such enormous pesticide applications, year after year. In its report summary, DPR states that the continued use of such a high volume of pesticide reflects a move by farmers to apply lower-risk pesticides that require higher application rates to be effective. The report highlights the decrease in the developmental neurotoxin, chlorpyrifos, to below 1 million pounds, as a case in point. Yet, that number still represents a huge environmental release of an extremely toxic pesticide known for its harmful effects on the brain development of children in utero and the developmental functions of children into adulthood. Due to these and other serious health concerns, chlorpyrifos was on track to be banned nationwide until EPA Director, Scott Pruitt, intervened to stop it in February. This past month, the Hawaiian state legislature banned its use in response to widespread public pressure. Several other states are considering a ban and California, as the country’s biggest agriculture producer and pesticide user, should be one of them.

California’s Food and Agricultural Code requires DPR to use the data it collects to establish priorities for protecting public health, farmworkers, and rural communities, among other things. To that end, DPR’s analysis of pesticide use near schools indicates that children are experiencing unacceptably high exposure levels, due to the close proximity of farms to school yards. In response, DPR ruled in 2017 that farmers must refrain from applying pesticides within a quarter mile of K-12 schools and registered daycare centers when they are in session, from 6am to 6pm. While this represents an important change in pesticides practices, it does not eliminate pesticide spraying near schools altogether. Spraying can simply be done after hours and on weekends when community events could also be taking place. Much more aggressive actions are needed to prevent pesticide exposures, including banning the most hazardous chemicals.

In February of this year, USDA released its 2016 Pesticide Data Program (PDP) Annual Summary, which documents its pesticide residue testing of over 10,000 samples of a wide variety of domestic and imported food. While the report notes that “99.5 percent of the samples tested had pesticide residues well below benchmark levels established by EPA,” it concludes that 78 percent of the samples contain some amount of pesticide residue. Public health advocates say that this large percentage is cause for grave concern as pesticides accumulate in food, air and water. EPA establishes legal limits or tolerances for a pesticide chemical residue in or on a food that it deems “with a reasonable certainty that no harm will result from aggregate exposure to the pesticide chemical residue, including all anticipated dietary exposures and all other exposures for which there is reliable information.” The “no harm” standard is based on risk assessments establishing acceptable levels of risk. While calculating acceptable exposure by aggregating exposure pathways from food, drinking water, and residential settings, EPA does not, by law, include in its aggregate risk assessment occupational exposures such as agriculture, which is by far the greatest exposure pathway.

Beyond Pesticides has been critical of the manner in which EPA sets pesticide tolerance residues in food because of its wholly deficient review of the associated adverse effects. Many chemicals that account for a significant amount of dietary exposure and risk, such as organophosphate insecticides, carbamate insecticides and toxic soil fungicides in particular have yet to be assessed.

For decades, Beyond Pesticides has challenged the need for the extensive use of highly toxic, carcinogenic, ecosystem-depleting, and endocrine disrupting pesticides in agriculture. Instead, it has advocated that the government prioritize aiding farmers in the transition to organic agriculture.  You can learn about alternatives to toxic pesticide and herbicide use in your home and garden by consulting Beyond Pesticides’ The Safer Choice webpage. There you can obtain information about non-toxic product choices for your home and school, ideas for eating organically and affordably, and how you can organize to make your community a pesticide-free zone.

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

Source:  FairWarning;

(Beyond Pesticides, May 21, 2018)  490,000 Pounds of Toxic Pesticides Sprayed on National Wildlife Refuges in 2016

The nation’s 562 national wildlife refuges play a critical role in protecting fish, plants, and other wildlife. They include forests, wetlands, and waterways vital to thousands of species of plants and animals, including 280 that are protected under the Endangered Species Act. However, private chemical-intensive commercial farming of crops like corn, soybeans, and sorghum has become common on refuge lands, with the increasing use of highly toxic pesticides that threaten the long-term health of sensitive habitats and the creatures who depend on them. The Center for Biological Diversity (CBD) estimates that 490,000 pounds of pesticides were applied to commodity crops like corn, soybeans, and sorghum grown in national wildlife refuges in 2016, the most recent year for which data are available.

Tell FWS to take toxic pesticides out of wildlife refuges.

The nearly half million pounds of pesticides used on wildlife refuges in 2016 include 2,4-D, dicamba, and paraquat, all of which are toxic to fish, amphibians, crustaceans, and other animals. Also included are 116,200 pounds of glyphosate, the herbicide that has caused widespread decreases in milkweed plants, helping to trigger the 80 percent population decline of monarch butterflies over the past two decades.

In 2014, the U.S. Fish and Wildlife Service (FWS) announced a phase-out of the use of genetically engineered (GE) crops to feed wildlife and a ban on neonicotinoid insecticides from all wildlife refuges nationwide by January 2016. CBD found that although 498 pounds of neonicotinoid pesticides were applied in 2016 to potato crops on the Klamath Basin National Wildlife Refuge Complex, all neonicotinoid use has now been discontinued in the refuge system. The heavy use of glyphosate, generally used on crops that are engineered to tolerate it, suggests that the phase-out of GE crops may not have been so successful.

Refuges exist for the protection of wildlife, and activities there should not jeopardize their health. FWS should require that organic practices be used in any farming on refuges.

Tell FWS to take toxic pesticides out of wildlife refuges.

Letter: [Send to [email protected]]

Subject: Ban toxic pesticides in wildlife refuges

Refuges exist for the protection of wildlife, and activities there should not jeopardize their health. FWS should require that organic practices be used in any farming on refuges.

Private chemical-intensive commercial farming of crops like corn, soybeans, and sorghum on refuge lands threatens the long-term health of sensitive habitats and the creatures who depend on them. In examining records obtained through the Freedom of Information Act, the Center for Biological Diversity found that nearly half a million pounds of toxic pesticides were applied to U.S. Fish and Wildlife Service (FWS) refuges in 2016.

The pesticides used on wildlife refuges in 2016 include 2,4-D, dicamba, and paraquat, all of which are toxic to fish, amphibians, crustaceans, and other animals. Also included are 116,200 pounds of glyphosate, the herbicide that has caused widespread decreases in milkweed plants, helping to trigger the 80 percent population decline of monarch butterflies over the past two decades.

In 2014, the U.S. Fish and Wildlife Service (FWS) announced a phase-out of the use of genetically engineered (GE) crops to feed wildlife and a ban on neonicotinoid insecticides from all wildlife refuges nationwide by January 2016. CBD found that although 498 pounds of neonicotinoid pesticides were applied in 2016 to potato crops on the Klamath Basin National Wildlife Refuge Complex, all neonicotinoid use has now been discontinued in the refuge system. The heavy use of glyphosate, generally used on crops that are engineered to tolerate it, suggests that the phase-out of GE crops may not have been so successful.

Please eliminate the use of toxic pesticides in wildlife refuges and require that organic practices be used in any farming on refuges.

Sincerely,

(Beyond Pesticides, May 18, 2018) The U.S. Department of Agriculture (USDA) is putting an end to the process of creating an organic “check-off” promotion program, according to an announcement posted to the Federal Register earlier this week. The program, controversial from the start, split the organic community. While the industry group the Organic Trade Association (OTA) pushed for the program, small producers and family farmers cited exorbitant costs and ineffective government bureaucracy in their opposition.

Check-off programs are traditionally created for producers to pool their money together to further research, information sharing, and promotion of a particular food commodity. Famous programs of the past include “Beef: It’s What’s For Dinner,” “Got Milk?” and “I Love Eggs.” The proposed organic program was unique in that it aimed to promote an entire industry, rather than a specific food product. However, opponents view the program as another tax on farmers that is unnecessary and potentially damaging to small organic producers, citing a history of rigid guidelines, fund mismanagement, and lack of accountability. In the past, successful checkoff programs were associated with declines in family farmers, and opponents believe the program would promote low-priced organic imports at the expense of growing U.S. organic acreage. In eliminating the rule, USDA cited, “uncertain industry support” and “outstanding substantive issues” with the checkoff program.

OTA, however, is pushing back strongly against USDA’s decision, indicating the action as exemplary of the Department’s unfair treatment the organic industry. In a press release, OTA wrote that USDA’s decision “reflects a pattern of holding back forward progress on organic,” and that, “It makes no sense that the agency is continuing to take steps to cut it off at the knees.”

“If there was ever a need for an organic check-off, it is now,” said Laura Batcha, Executive Director of the Organic Trade Association. “We are seeing organic dairy and egg sales flattening because of USDA’s failure to move the animal welfare rule forward. Organic research funding is uncertain because it is tied to the unpredictable fate of the Farm Bill. The government also has interfered with the strong role of the National Organic Standards Board. These actions hurt U.S. organic farmers and businesses.”

OTA further cited the juxtaposition of eliminating the organic check-off program after releasing the “smiley face GMO disclosure logo” as evidence that the Department is not being even-handed.  Indeed, the agency appears to be targeting many policies recently passed by the National Organic Standards Board (NOSB) aimed at boosting the integrity of the organic label. This has led to a rise in third party organic labels such as the Real Organic Project and Regenerative Organic Certification.

According to the Northeast Organic Dairy Producers Alliance, “We believe that existing Check-off programs have not demonstrated that they contribute to keeping family farm producers in business. We continue to see declining farm numbers and increasing concentration in agriculture while these commodity research and promotion programs are in effect.”

While check-off program has some reeling and others sighing relief, its elimination could provide an opportunity for promote organic. “You can be more flexible with your messaging and even more efficient with the dollars if you’re not tied to the government,” said Harriet Behar, an NOSB member formerly with the Midwest Organic and Sustainable Education Service (MOSES) when the program was first proposed. For its part, OTA indicates it “will fully assess opportunities through the private sector to advance innovative solutions that will have important and long-lasting benefits for organic farmers.”

Beyond Pesticides strongly promotes the importance of organic farming in creating a truly sustainable food system for the future. The organization tracks the latest decisions from USDA and the NOSB affecting the integrity of the organic label through the Keeping Organic Strong webpage. Efforts to fight back and protect public trust in organic food can be found on the Save Our Organic program page. And for more information on why organic is the right choice for your food dollars see the Why Organic? page.

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

Source: Federal Register, OTA Press Release

(Beyond Pesticides, May 17, 2018)  Among the many reports of the salutary effects of nature on human health and well-being comes new research demonstrating that children who live in “green” neighborhoods have reduced risk of developing asthma. Researchers Jeroen Douwes, PhD and Geoffrey H. Donovan, PhD, of New Zealand’s Massey University (Centre for Public Health Research) and the U.S. Forest Service, respectively, conducted the longitudinal study with New Zealand subjects born in 1998, following them until 2016. The authors say the study results “suggest that exposure to greenness and vegetation diversity may be protective of asthma.”

Of concern are the pesticides used in green spaces. See Beyond Pesticides’ brochure, Asthma, Children, and Pesticides and El Asma, los Niños y los Pesticidas: Lo que usted debe saber para proteger a su familia. Also, see Children and Pesticides Don’t Mix.

In addition to the well-substantiated benefits of exposure to nature — reduction of the experience of stress; reduction in production of cortisol (the “stress” hormone that is linked to weight gain, hypertension, cardiac disease, weakened immune function, and loss of bone density); improved mental health; better cognitive function; and lower  BMI (body mass index) — this latest research evaluates the impact on children’s risk for asthma.

The research project used a large database of individual-level information maintained by the New Zealand government (done anonymously and in a secure lab to protect children’s privacy) to track children’s living environments from birth to age 18, quantify the “greenness” of those environments using satellite imagery and land-use data, and link to health records throughout each child’s life. The study measured “greenness” through a metric called the “normalized difference vegetation index,” and used standard deviations from that to categorize the plant systems to which children were exposed. It also controlled for numerous factors that might have been co-contributors to outcomes, including socioeconomic status, education, ethnicity, and income.

Project results show that not only is there benefit to growing up around green vegetation, but interestingly, that not all “green” has the same influence on asthma risk. Children living in greener areas were less likely to become asthmatic, but there was additional protective effect when the vegetation to which they were exposed was more diverse. The presence of more species apparently confers greater protection. And some land cover considered in the study — plants that are (in New Zealand) non-native, low-biodiversity species, such as exotic conifers and gorse — not only conferred no protection, but also, actually constituted a risk factor.

The incidence, as well as the health and cost consequences, of asthma are considerable: 334 million people are affected worldwide. In “developed,” English-speaking countries, such as the U.S., New Zealand, the UK, and Australia, approximately one in six people suffer from it. As the project investigators note, better prevention and treatment options are urgently needed. The decline in biodiversity around the world, due to impacts from climate change, pesticide use, and expansion of the human-made landscape and resultant habitat destruction, among other factors, is a growing environmental concern. This research suggests it may also be a growing public health threat.

What explains the mechanism for this protective effect of exposure to diverse plants in kids’ environment? One idea that has been advanced is the “hygiene hypothesis,” which posits that optimal development of the human immune system requires exposure to a wide variety of microbes, especially early in life. It also suggests that reduced exposure to a multitude of microbes — whether by virtue of living without much in the way of greenscape in one’s early surrounds, overexposure to antibiotics (medically or through diet), exposure to pesticides (environmentally or dietarily), anti-bacterials use (in personal care products, in particular), or perhaps simply living an über-clean home — may make children more vulnerable to immunological diseases, such as asthma and allergies, via a less-well-developed immune system.

This hygiene hypothesis could also explain why it is that children who grow up with siblings (especially multiple), or with animals (farm or pet), are less likely to become asthmatic. (The more “bugs,” it seems, the better.) Now, growing up with green biodiversity can be added to this list of protective factors. Studies have demonstrated that people who live in more-biodiverse areas actually have a greater variety of microbes on their skin. (Remember that humans contain, internally and externally, 10 times more microorganisms than human cells!) A greater range of “challenges” (i.e., exposure to a broad variety of microbes) to the human immune system in the early years of life appears to stimulate a healthy immune response, likely resulting in a more-robust immune system. The researchers do note that lower stress levels and increased physical activity, both of which are associated with living proximate to green space, may be an additional explanation for the protective effects.

Beyond Pesticides has reviewed research on the relationship of pesticide use to asthma, identified risks specific to children’s health, and makes suggestions to help protect children and others from pesticides that increase the risk of developing the disease. There is need for research that would consider whether, within the frame of this study — the more “green,” the less risk of asthma — there is any differential risk for children exposed to landscapes managed with pesticides, herbicides, and/or fungicides, and to those either entirely “unmanaged” or managed organically. For more information on children and pesticides, see Beyond Pesticides webpage on hazards of pesticides for children’s health.

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

Source: https://theconversation.com/children-living-in-green-neighbourhoods-are-less-likely-to-develop-asthma-96190

(Beyond Pesticides, May 16, 2018) Northern Harvest Sea Farms, an ocean-based fish farm in New Brunswick, Canada, was appeared in court yesterday to answer legal charges stemming from the off-label use of an unnamed pesticide added to its operations to combat severe sea lice outbreaks. The company holds nine licenses for farmed Atlantic salmon cages on the Bay of Fundy, as well as for fish farms off the Newfoundland coast. Sea lice outbreaks are a common at over-crowded, ocean-based fish farms because such facilities afford the optimum conditions for rapidly reproducing and spreading lice. In response, some companies have turned to using illegal and off-label pesticide applications to stave off the problem, which causes huge farmed salmon kills.

The company was issued a $12,000 fine that was challenged as inadequate by the Grand Manan Fishermen’s Association. Bonnie Morse, project manager for the association told Canadian Broadcasting Corporation (CBC) news, “I think any time there’s a fine that’s a deterrent to illegal activity, it should be an actual deterrent to the activity,” said Morse. “When you’re looking at $1.5 million worth of fish, their actions speak for themselves.” Maria Recchia, the executive director of the Fundy North Fishermen’s Association, questioned the allowance of fish farming in the ocean,telling the CBC that the province should not have permitted fish farming in Head Harbour.

Fish farming or aquaculture in the open ocean, refers to the breeding, rearing, and harvesting of aquatic organisms, such as fish, shellfish, and plants. In the open ocean, millions of salmon are reared in confined fish farms and fed processed feed, antibiotics, and parasiticides to keep them alive and disease-free. Ocean water flows in and out of these in permeable nets and pens, which often suffer breaches and fish escapes due to harsh climate conditions and predators.

Salmon net-pen aquaculture interacts with the environment

Fish lice are pervasive and lethal in fish farms. In 2017, over a quarter million salmon died from lice infestations at two Gray Group salmon farms in the Bay of Fundy in New Brunswick, Canada. The company preemptively killed another 284,000 salmon in an effort to contain the outbreak and further limit the damage. In Northwest Scotland, lice infestations are a huge problem in their fish farms as well and a leading threat to marine ecosystems where the country’s fish farms are located. In response, the wild fish and water conservation organization, Salmon & Trout Conservation Scotland (S&TC Scotland) and 27 environmental non-governmental organizations (NGOs) and others, are calling on Parliament to institute “an immediate moratorium on any new open cage marine salmon farms in Scotland.”

Lice attach to the skin of salmon, causing wounds by feeding on fish mucus, skin, muscle and blood. They weaken fish and expose them to infection and disease. Mortality occurs in young fish (smolts) due to damaged fins, skin lesions, stress, salt imbalances, altered swimming performance, and reduced resistance. Fish escapes are a common. As recently as February, over 21,000 fish escaped from a Norwegian-owned fish farm near the Island of Skye. Escaped farmed fish can infect wild salmon populations with lice and other diseases as they come into contact with smolts swimming out to sea and adults returning to their birth river to spawn.

At fish farms around the world, lice problems are worsening and the lice are developing resistance to the medicines and chemicals designed to curtail their spread. Routine treatments with pesticides, such as emamectin benzoate and cypermethrin, which is illegal in Canada, are used to minimize the impacts to farmed fish living in the unhealthy marine environment. Unfortunately, elevated pesticide use has had the opposite effect, contributing to accelerated pest resistance and prompting fish farms operators to employ increasingly higher doses at fish farms in Canada and elsewhere.

Environment Canada has found traces of cypermethrin in lobster traps and storage sites a mile from Pleasant Point, Maine. The New Brunswick-based Cooke Aquaculture, which operates 100 fish farms on Canada’s Atlantic coast, pled guilty and was fined for illegally using the cypermethrin implicated in hundreds of lobster deaths. Kelly Cove Salmon, a Cooke Aquaculture subsidiary, was also fined a half million dollars for illegally using cypermethrin in violation of Canada’s Fisheries Act. A 2018 Report to the Canadian Parliament by the Commissioner of the Environment and Sustainable Development examined the impacts of the country’s fish farms and concluded that little progress had been made in improving the situation. “Overall, we found that Fisheries and Oceans Canada had not made sufficient progress in completing risk assessments for key diseases, which were required to assess the effects of salmon farming on wild fish.” Matthew Abbott, New Brunswick’s Fundy Baykeeper and Marine Conservation Director, further warns that the use of pesticides in the bay is a big concern even when they are used legally.

The U.S. Department of Agriculture’s National Organic Program has been considering allowing salmon from ocean-based fish farms to be certified organic, against a strong tide of public opposition. Still, no regulations have been adopted to allow organic certification of farmed fish. In the EU and Canada, where governments certify organic fish, the environmental impacts remain remarkably similar to conventionally farmed salmon because the operations exist in the same marine environment, using similar management practices. The EU’s organic fish farms use some organic ingredients in their feed rations, like organic wheat and organic soy, which conventional farms do not use. But, neither ingredient is part of a salmon’s natural diet. The UK’s Organic Soil Association’s organic regulations require stocking densities of 30,000 fish per cage versus 70,000 for conventional fish farms. Either way, the salmon still grow in crowded cages where their natural migration behavior is completely eliminated.

It is important for consumers to know that all “Atlantic Salmon” sold in the U.S. is farmed. That is why it often has a slight gray tinge, it is oilier and less firm than normal, and it lacks the rich savory taste of wild salmon. Organic salmon certified in accordance EU regulations costs the same as wild salmon but affords little if any discernible environmental benefits, only costs. On the contrary, organic fish farming significantly contributes to marine pollution by adding synthetic pesticides and antibiotics to the marine environment, which contravenes consumer expectations of organic food production systems.

Given the enormous environmental burden fish farms pose to the marine environment – organic and conventional – and their deleterious effects on wild fish populations, certified organic salmon should never be considered an option in the US. To support the integrity of organic and to oppose allowing fish reared in ocean-based fish farms to be certified organic, go to Beyond Pesticides’ Keeping Organic Strong webpage.

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

Sources: CBC; Bangor Daily News; Organic Advocacy; CBC News

(Beyond Pesticides, May 15, 2018) According to a new report from the Center for Biological Diversity (CBD), hundreds of thousands of pounds of pesticides are sprayed on lands that are designated as refuges for wildlife and protected under U.S. law. Approximately 490,000 pounds of pesticides have been sprayed on crops grown in national wildlife refuges in 2016 alone. Pesticide use in these sensitive areas poses risks to pollinators, aquatic organisms, migratory birds, and other wildlife on refuges that were created to protect them.

The report, No Refuge, released last week, analyzes pesticide use on national wildlife refuges using records obtained through a Freedom of Information Act request. The report finds that in 2016 more than 270,000 acres of refuge lands were sprayed with pesticides for agricultural purposes. Five national wildlife refuge systems are identified as most reliant on pesticides for agriculture:

• Klamath Basin National Wildlife Refuge Complex in California and Oregon, with 236,966 pounds of pesticides;
• Central Arkansas Refuges Complex in Arkansas, with 48,725 pounds of pesticides;
• West Tennessee Refuge Complex in Tennessee, with 22,044 pounds of pesticides;
• Tennessee National Wildlife Refuge Complex in Tennessee, with 16,615 pounds of pesticides; and,
• Chesapeake Marshlands National Wildlife Refuge Complex on the Eastern Shore of Maryland and Virginia, with 16,442 pounds of pesticides.

Intensive commercial farming has become increasingly common on refuge lands, especially since the advent of genetically engineered (GE) crops like corn and soybean. Increased pesticide use, especially pesticides like glyphosate, 2,4-D, and dicamba threaten the long-term health of these sensitive habitats and the wildlife that depend on them. The report finds that more than 55,000 acres in the refuge system were treated with 116,200 pounds of glyphosate, the pesticide that has caused widespread decreases in milkweed plants, helping to trigger an 80 percent decline of the monarch butterfly over the past two decades. Over 15,000 pounds of 2,4-D was used on more than 12,000 refuges acres, and 6,800 pounds of paraquat dichloride was used on over 3,000 acres. These pesticides are toxic to mammals, aquatic organisms and can potentially jeopardize endangered and threatened species.

“These pesticides are profoundly dangerous for plants and animals and have no place being used on such a staggering scale in our wildlife refuges,” said Hannah Connor, a senior attorney at CBD who authored the analysis. “The Interior Department needs to put an end to this outrage and return to its mission of protecting imperiled wildlife, not row crops.”

Aerial spraying of pesticides routinely occurs on refuge lands. In 2016, 107,342 acres were aerially sprayed with 127,020 pounds of pesticides, including approximately 1,328 pounds dicamba, a pesticide that is known to drift for miles and adversely affect off-site areas and non-target species. The report calls for an end to the use of toxic pesticides on the refuges, saying, “The widespread use of pesticides for private agricultural purposes on national wildlife refuges conflicts with the mission of the refuge system and creates a legacy of chemical pollution that threatens the long-term health of these essential ecosystems.”

A federal lawsuit, filed by Center for Food Safety (CFS), Public Employees for Environmental Responsibility (PEER), Sierra Club, and Beyond Pesticides, challenged the U.S. Fish and Wildlife Service (FWS) over farming practices in five refuges in the Midwest (IL, IA, MN and MO) and sought to force the agency, which oversees refuges, to stop these practices until it completes rigorous analyses of their environmental impacts. In 2014, FWS announced it will phase out the use of GE crops to feed wildlife and ban neonicotinoid insecticides on all wildlife refuges nationwide beginning January 2016. In its statement the agency said, “We have demonstrated our ability to successfully accomplish refuge purposes over the past two years without using genetically modified crops, therefore, it is no longer possible to say that their use is essential to meet wildlife management objectives.” FWS continued, “We have determined that prophylactic use, such as a seed treatment, of the neonicotinoid pesticides that can distribute systemically in a plant and can potentially affect a broad spectrum of non-target species, is not consistent with Service policy. We make this decision based on a precautionary approach to our wildlife management practices and not on agricultural practices.” FWS is the first federal agency to restrict the use of GE crops in farming in the U.S. and the use of neonicotinoids based on a precautionary policy.

Scientists warn that the use of GE crops leads to increased pesticide use on refuges, negatively affecting birds, aquatic animals, and other wildlife. A vast spectrum of recent scientific findings has implicated neonicotinoids in pollinator declines and ecosystem harm. Reports from the U.S. Geological Survey routinely find widespread pesticide contamination of surface waters throughout the U.S.

For nearly a decade, Beyond Pesticides, CFS, and PEER campaigned against GE crops and pesticide use on refuges. In March 2009, CFS and PEER won a lawsuit, filed in 2006, halting GE plantings on Prime Hook National Wildlife Refuge in Delaware. In 2011, the groups forced a legal settlement ending GE planting on refuges throughout the 12-state Northeast Region. In 2012, a federal court formally halted the planting of GE crops on all National Wildlife Refuges in the Southeastern U.S., as well as ordered steps to mitigate environmental damage from their previous illegal cultivation.

For more information on pesticide impacts on wildlife, visit Beyond Pesticides’ wildlife page. For information on what you can do to protect bees and other pollinators, see Beyond Pesticides BEE Protective campaign information.

Source: Center for Biological Diversity Press Release

(Beyond Pesticides, May 14, 2018) Under EPA Administrator Pruitt’s proposed “transparency” plan, the public will still lack access to key data about the effects and efficacy of commercial poisons approved for sale and application in their communities and homes.

Tell EPA to adopt a real transparency plan for pesticides!

The proposed policy, posted on April 30 in the Federal Register, declares that it will “help ensure that EPA is pursuing its mission of public health and the environment in a manner that the public can trust and understand,” yet it applies only to a very limited set of studies used to support certain EPA regulations. The pesticide registration and review processes are particularly lacking in transparency, opportunity for public review, and access to data. Because pesticides are toxic chemicals broadcast into the environment, nowhere is transparency more important than in pesticide registration.

The proposed new policy does not cover pesticide registrations, warning labels, use restrictions, or proof of effectiveness. In the current process, the pesticide manufacturer produces the underlying data for these EPA approvals and controls access to them. Thus, despite Pruitt’s sweeping claims of “transparency in regulatory science”:

• The public does not have access to the underlying data provided by the manufacturer to justify registering a new pesticide for commercial distribution;
• Industry will not have to provide the data used to assess health and environmental effects and farmworker impacts to set allowable dietary and non-dietary exposure limits; and
• On the product’s efficacy, the public also does not have access to the underlying data, nor does EPA even review manufacturer data on product effectiveness, except for very limited purposes.

To ensure full review, it is critical that the public and independent scientific community have complete access to safety testing data before poisonous pesticide products enter the marketplace. If EPA applies the proposed policy to pesticides, the failure to allow consideration of independent study results without disclosing confidential patient information will cripple the validity of EPA safety reviews. Furthermore, the failure to label all ingredients in pesticide products used by the public runs contrary to the basic principle of informed decision making.

Mr. Pruitt’s plan does not enable the public to have any meaningful information about “environmental health risk or safety risk,” as he claims. Under a false flag of scientific transparency, Mr. Pruitt’s scheme hobbles scientific work used to protect the public, but shields industry data that may demonstrate a public health peril.

EPA pesticide regulation is based on secret science.

Although EPA has proposed a rulemaking that purports to make science used in EPA regulatory decision making transparent and available to the public, the proposal applies only to “significant” EPA rulemakings, but not to matters such as pesticide registrations, through which private companies seek authorization to market products that may be harmful to public health and the environment. The pesticide registration and review processes are particularly lacking in transparency and opportunity for public review and access to data.

Data used to approve pesticides are not available to the public.
Pesticides are registered (authorized for use) based on studies and data submitted by the manufacturer (registrant) —not based on science conducted or commissioned by EPA. Such registrant data are not available for public review until after the pesticide is registered. The nonpublic data submitted by the registrant are used by EPA to assess health and environmental effects of the pesticide and impacts on farmworkers, and to set allowable human exposures through dietary and non-dietary routes —all without any opportunity for public review of the underlying data.

After registration, the public can access the materials on the basis of which the registration was granted only through making requests under the Freedom of Information Act (FOIA), a lengthy process. Even then, much information is withheld as purportedly “confidential.” If problems are identified that uncover a hazard from the pesticide, a member of the public would need to petition for a proceeding to cancel the registration, a long and unwieldy process during which the pesticide remains on the market.

EPA’s registration, registration review, and cancellation of pesticides raise numerous issues regarding the application of legitimate scientific process, risk assessment, exposure assumptions, sensitive populations, and the “reasonableness” of what are found to be “acceptable” hazards. Transparency of agency processes and underlying data is key to allowing public participation concerning these issues.

Full disclosure of known and unknown adverse effects is needed. 

EPA does not currently require that registrants disclose data submitted to EPA or label pesticides (including household pesticides) with data concerning the full extent of knowledge and/or ignorance of possible adverse effects, including data gaps and chronic health effects. Registrants’ exposure and toxicology studies are not released to the public so that any interested stakeholder can review them prior to a product being permitted on the market.

Conditional registration is missing crucial data.
Pesticide registrations under special circumstances, known as “conditional registrations,” allow widespread use of toxic chemicals that are not fully tested. Conditional registration of pesticides allows market entry for a product in the absence of certain data normally required for registration. As one glaring example, EPA came under scrutiny when it conditionally registered the neonicotinoid pesticide clothianidin, tied to dramatic declines in pollinators, without required pertinent field data on honeybees, even though the pesticide is known to pose risks to these vulnerable pollinators.

Efficacy data on pesticide products are lacking.
The public does not have access to, and EPA does not review, manufacturer data on pesticide efficacy, even though the statutory registration standard requires weighing the risks of pesticides against their benefits. Without efficacy information, the real benefits of a pesticide are unknown, and the reasonableness of pesticide use cannot be assessed. The lack of efficacy data review results in escalating and predictable insect and weed resistance, unnecessary increases in pesticide use, and increased risk for farmers of crop loss and economic damage. The only instance in which EPA evaluates pesticide efficacy is as a part of public health (not agricultural) pesticide registrations, and even this is without public disclosure or opportunity for comment.

Secret ingredients in pesticide products are not disclosed.
Currently, pesticide labels do not identify “inert” ingredients that have been classified as hazardous under a variety of environmental laws, including the Clean Air Act, the Clean Water Act, and the Emergency Planning and Community Right to Know Act. Disclosure would provide information about almost 400 hazardous chemicals in pesticide products.

Only active ingredients, not formulations, are tested.
EPA does not require testing data on the full formulation of a pesticide product, including all of the “inert” ingredients. Thus, data on the human health and environmental effects of the actual product on the market are entirely lacking.

The federal government needs a vision for pesticide policy across relevant agencies that seeks to replace outdated approaches and technologies, reliant on toxic chemicals, with green approaches advanced through incentives, assistance, and restrictions. This cannot be achieved without full transparency and disclosure of toxic hazards of pesticide products in the marketplace. Without full information on pesticide hazards, access to underlying data on hazards, and a transparent assessment of the reasonableness of risk (given the availability of less or non-toxic alternatives), the public is left in the dark. Credible reviews, subject to public oversight, are essential in EPA’s regulation of pesticides to prevent contamination of air, land, water, and food.

Tell EPA to adopt a real transparency plan for pesticides!

Letter to EPA Docket (Docket No. EPA-HQ-OA-2018-0259)

[Send to [email protected]]

Under the proposed “transparency” plan, the public will still lack access to key data about the effects and efficacy of commercial poisons approved for sale and application in their communities and homes. The proposed policy declares that it will “help ensure that EPA is pursuing its mission of public health and the environment in a manner that the public can trust and understand,” yet it applies only to a very limited set of studies used to support certain EPA regulations. The pesticide registration and review processes are particularly lacking in transparency, opportunity for public review, and access to data. Because pesticides are toxic chemicals broadcast into the environment, nowhere is transparency more important than pesticide registration.

The proposed new policy does not cover pesticide registrations, warning labels, use restrictions, or proof of effectiveness. Because the pesticide manufacturer produces the underlying data for these EPA approvals and controls access to them, no transparency will be provided in pesticide registration, in which:

* The public does not have access to the underlying data provided by the manufacturer to justify registering a new pesticide for commercial distribution;

* Industry will not have to provide the data used to assess health and environmental effects and farmworker impacts to set allowable dietary and non-dietary exposure limits; and

* Neither the public nor EPA has access to the underlying efficacy data, except for very limited purposes.

To ensure full review, it is critical that the public and independent scientific community have complete access to safety testing data before pesticide products enter the marketplace. If EPA applies the proposed policy to pesticides, the failure to allow consideration of independent study results without disclosing confidential patient information will cripple the validity of EPA safety reviews. Furthermore, the failure to label all ingredients in pesticide products used by the public runs contrary to the basic principle of informed decision making.

The proposal does not prevent EPA from issuing conditional registrations in the absence of required data, nor does it require industry to make that data publicly available at a later date.

It does not grant the public access to meaningful information about “environmental health risk or safety risk,” as claimed. Instead, the policy hobbles scientific work used to protect the public while shielding industry data that may demonstrate the public health peril.

EPA pesticide regulation is based on secret science.

Although the proposed rulemaking purports to make science used in EPA regulatory decision making transparent and available to the public, by its own terms it applies only to “significant” EPA rulemakings, where EPA is seeking to protect public health and the environment, but not to matters such as pesticide registrations, through which private companies seek authorization to market products that may be harmful to public health and the environment. The pesticide registration and review processes are particularly lacking in transparency and opportunity for public review and access to data.

Data used to approve pesticides are not available to the public.
Pesticides are registered (authorized for use) based on studies and data submitted by the manufacturer (registrant). Such registrant data are not available for public review until after the pesticide is registered. The nonpublic data submitted by the registrant are used by EPA to assess health and environmental effects of the pesticide and impacts on farmworkers, and to set allowable human exposures through dietary and non-dietary routes –all without any opportunity for public review of the underlying data.

After registration, the public can access the materials on the basis of which the registration was granted (which still may not include all underlying data) only through the Freedom of Information Act (FOIA), a lengthy process. Even then, much information is withheld as purportedly “confidential.” If problems are identified that uncover a hazard from the pesticide, a member of the public would need to petition for a proceeding to cancel the registration, a long and unwieldy process during which the pesticide remains on the market.

EPA’s registration, registration review, and cancellation of pesticides raise numerous issues regarding the application of legitimate scientific process, risk assessment, exposure assumptions, sensitive populations, and the “reasonableness” of what are found to be “acceptable” hazards. True transparency of agency processes and underlying data is key to allowing public participation concerning these issues.  

Full disclosure of known and unknown adverse effects is needed. 

EPA does not currently require that registrants disclose data submitted to EPA or label pesticides (including household pesticides) with data concerning the full extent of knowledge and/or ignorance of possible adverse effects, including data gaps and chronic health effects. Registrants’ exposure and toxicology studies are not released to the public so that any interested stakeholder can review them prior to a product being permitted on the market.

Conditional registration is missing crucial data.
Conditional registrations allow widespread use of toxic chemicals that are not fully tested. Conditional registration of pesticides allows market entry for a product in the absence of certain data normally required for registration. As one glaring example, EPA came under scrutiny when it conditionally registered the neonicotinoid pesticide chlothianidin, tied to dramatic declines in pollinators, without required pertinent field data on honeybees, even though the pesticide is known to pose risks to these vulnerable pollinators.

Efficacy data on pesticide products are lacking.
The public does not have access to, and EPA does not review, manufacturer data on pesticide efficacy, even though the statutory registration standard requires weighing the risks of pesticides against their benefits. Without efficacy information, the real benefits of a pesticide are unknown, and the reasonableness of pesticide use cannot be assessed. The lack of efficacy data review results in escalating and predictable insect and weed resistance, unnecessary increases in pesticide use, and increased risk for farmers of crop loss and economic damage. The only instance in which EPA evaluates pesticide efficacy is as a part of public health (not agricultural) pesticide registrations, and even this is without public disclosure or opportunity for comment.

“Secret ingredients” in pesticide products are not disclosed.
Currently, pesticide labels do not identify “inert” ingredients that have been classified as hazardous under a variety of environmental laws, including the Clean Air Act, the Clean Water Act, and the Emergency Planning and Community Right to Know Act. Disclosure would provide information about almost 400 hazardous chemicals in pesticide products.

Only active ingredients, not formulations, are tested.
EPA does not require testing data on the full formulation of a pesticide product, including all of the “inert” ingredients. Thus, data on the human health and environmental effects of the actual product on the market are entirely lacking.

The federal government needs a vision for pesticide policy across relevant agencies that seeks to replace outdated approaches and technologies, reliant on toxic chemicals, with green approaches advanced through incentives, assistance and restrictions. This cannot be achieved without full transparency and disclosure of toxic hazards of pesticide products in the marketplace. Without full information on pesticide hazards, access to underlying data on hazards, and a transparent assessment of the reasonableness of risk (given the availability of less or non-toxic alternatives), the public is left in the dark. Credible reviews, subject to public oversight, are essential in EPA’s regulation of pesticides to prevent contamination of air, land, water, and food.

Sincerely,

(Beyond Pesticides, May 11, 2018) Earlier this month, the U.S. Department of Agriculture (USDA) released its long-awaited proposal for disclosing the presence of genetically engineering (GE) in foods. Much to the disappointment of health, environmental, and consumer advocates, the draft rule appears as an attempt mask or to promote GE products, rather than caution consumers. Concerned individuals can send comments to USDA on the proposed rule through regulations.gov until July 3^rd.

USDA’s Proposed Labels for GE foods

USDA’s proposal will move forward with wholly insufficient disclosure requirements that the Department’s own study had indicated are discriminatory, according to analysts. Rather than use the phrase “genetically modified,” or “genetically engineered,” or include the acronyms “GE” or “GMO,” USDA is using the term “bioengineered.” The symbols proposed by USDA are a happy, smiling sun that would read either “bioengineered” or “may be bioengineered food.” Of course, such a symbol suggests to consumers that these foods are a positive, rather than concerning addition to a food product. However, USDA is also giving the option of simply including the words “bioengineered food,” “contains a bioengineered food ingredient,” or even leaving that language out and directing consumers to a QR code.

A lawsuit by the Center for Food Safety forced USDA to release a congressionally mandated study on the viability of using QR codes, small barcodes that must be scanned with a smartphone app and require broadband internet access. The research reinforced the common sense around the issue: low-income and rural residents, individuals unfamiliar with QR codes, and those without access to a smart phone or internet services will lack access to this information. The study concluded that “offline alternatives are necessary for consumers who lack access to a scanning device or broadband.”

Perhaps the most concerning aspect of USDA’s proposed rule is that it has left the decision whether to label “highly refined” GE products like cooking oil, snacks, candy, and soda up in the air. If USDA were to determine these foods did not require labeling, consumers would be no better off than before the weak and controversial bill was signed into law by President Obama in 2016.

Consumer, health, and environmental advocates primary concern with GE foods is not the health issues of eating GE foods themselves, but the multitude of up and downstream impacts created by GE agriculture. Despite promises of disease-resistance, drought-tolerance, and vitamin enhancement, GE crops have primarily been developed by multinational agrichemical corporations as a way to increase profits by vertically integrating their seed and chemical divisions. Farmers that grow GE crops are locked into a contract that requires they use one specific company’s seeds and pesticides. This is bad for farmers and our agricultural economy, and it further erodes the preservation and development of heirloom and regionally adapted seed varieties.

Herbicide-tolerant GE crops have been associated with massive increases in herbicide use and the rampant takeover of US farms by weeds which, through incessant herbicide spray, have themselves developed genes to resist herbicide mortality. As glyphosate, the most common herbicide developed for crop tolerance, has decreased in effectiveness, chemical companies began rolling out new GE crops using older herbicides like 2,4-D and dicamba that rival glyphosate’s toxicity. Chemical companies have also incorporated insecticides into the crop itself, with evidence that resistance in target pests is trending synthetic insecticide use upwards.

Concern over farmers and our economy, farmworkers and their exposure, the impact of these pesticides on wildlife and the environment, and the likelihood for these overused pesticides to show up on GE foods make it clear that consumers should have a right to know whether their purchase contributes to the ongoing crisis GE crops create.

Beyond Pesticides strongly encourages individuals to provide substantive comments to USDA through regulations.gov before the July 3^rd deadline. For more information on this toxic form of agriculture, see Beyond Pesticides Genetic Engineering program page, and for a history of the GE labeling movement, see the Daily News archives.

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

Source: Regulations.gov, Modern Farmer