(Beyond Pesticides, April 10, 2019) Last month, the Washington State Senate unanimously passed HB 1906, designating April 10 as Dolores Huerta Day. In July of 2018, a similar California law proclaimed April 10 Dolores Huerta Day in that state. In an interview with Vida del Valle, Ms. Huerta stated, “I’m happy to hear that our young learners will have the opportunity to learn more about social justice and civil rights, because there is still a lot of work to do by the Dolores Huerta Foundation.”

Following decades of leadership in the fight for farmworker justice, Ms. Huerta founded the Dolores Huerta Foundation in 2002, with a focus on grassroots organizing in Central Valley. According to its website, the Dolores Huerta Foundation trains low-income Central Valley residents “to advocate for parks, adequate public transportation, infrastructure improvements, the reduction of pesticide use, increased recreational opportunities, and culturally relevant services.”

“We build leadership in low-income communities and organize people so that they can have a sense of their own voices and their own power,” Ms. Huerta said of her foundation in an interview with Civil Eats. “Once they understand this process and they have the power to change policy – and politicians – they really feel empowered and they want to go on and keep organizing,” she explained, adding, “It’s wonderful. I call it ‘magic dust.’”

Dolores Huerta has been spreading this “magic dust” for over six decades.

Ms. Huerta co-founded the National Farmworkers Association – now called the United Farm Workers (UFW) – in 1962. Ms.Huerta became well known as a thought leader, organizer, lobbyist, and negotiator. As lead organizer for the historic Delano grape boycott of 1965, she convinced more than 17 million consumers to stop buying grapes in support of workers’ demands for collective bargaining rights. The boycott was as much a battle against growers as it was against the U.S. government, which interfered by purchasing grapes to send to U.S. soldiers in Vietnam. Nonetheless, the campaign succeeded, and Ms. Huerta led the negotiations that followed to secure collective bargaining agreements between the California grape industry and UFW.

Author and organizer Randy Shaw credits Ms. Huerta and her collaborators in the fight for farmworker justice for helping to lay the groundwork for “the whole idea of Environmental Justice.” “The Environmental Justice movement said that certain environmental hazards are disproportionately impacting on people of color,” Mr. Shaw explained in the 2017 documentary, Dolores. He continued, “It wasn’t simply stopping DDT, but it was also making the larger point, you’re only allowing this because of who the workers are, and their race and class background.”

That larger point came with a larger cost. “Once we started making those kind of demands, we had the same response that the Black movements had,” said Ms. Huerta of the fight for farmworker rights. “Our people were killed.” Ms. Huerta herself was brutally attacked by a crowd control police officer during a demonstration in San Francisco in 1988. She broke three ribs and had to have her spleen removed. Ms. Huerta said, “The system doesn’t really want brown people or black people to have an organization and to have real power. I found out that no matter what I did, I could never be an American. Never.”

The fight for pesticide regulation is inextricably linked to the fight for immigrant rights. “Growers don’t want [their workers] to be legalized,” said Ms. Huerta in Dolores. “Because once they’re legalized, they can protest against pesticide poisoning, they can protest against the low wages they’re being given,” she said.

To this day, Ms. Huerta is fighting for stricter regulation and a transition away from pesticide use. As stated on its website, the Dolores Huerta Foundation “organizes communities that face critical exposure to pesticides through their work in the fields and the proximity of their residence to them. . . DHF advocates against the use of harmful pesticides whenever possible.”

As Ms. Huerta points out in an interview with NPR, women and children working in the fields are especially vulnerable to pesticide poisoning: “The pesticides in the fields really affect women even more than they do men. They affect children and they affect women more than they do men.” Research indicates that exposure to common agricultural pesticides, both during development and in adulthood, is associated with increased susceptibility to breast cancer. Across the board, studies show that children’s developing organs create “early windows of great vulnerability” during which exposure to pesticides can cause lifelong damage.

Ms. Huerta represents one of many women who have been standing up for the right to healthy and safe working conditions. “There were more women involved in the UFW than probably every other labor union in the United States combined,” said author and organizer Randy Shaw in Dolores. However, many believe that Ms. Huerta was not given the credit she deserved for her accomplishments. Ms. Huerta was the only woman on the executive board during her tenure in the UFW, and several of those closest to her lament that fellow board members resisted her leadership expressly because of her gender. When co-founder Cesar Chavez died in 1993, the board chose not to elect Huerta as the new president due, many believe, to their reluctance to appoint a female leader. In August, the UFW executive board appointed union Secretary-Treasurer Teresa Romero to replace UFW’s retiring president Arturo S. Rodriguez. She is the first Latina and immigrant president of a U.S. national union.

“We’re knee deep in sexism when it comes to why she isn’t studied, and why people don’t know her,” said educator and activist Curtis Acosta, featured in the 2017 documentary. According to Mr. Acosta, Ms. Huerta publicly criticized the UFW itself for being “rife with sexism.” According to Mr. Acosta, Ms. Huerta said, “I even said to Cesar at one point in time, I said, look, we have a lot of machismo here in the farmworkers movement, and I am not going to take it anymore.” Her message to the young women and Chicana girls with whom she now works – be bold and take credit for your work.

As some of Ms. Huerta’s colleagues note, her erasure from history is not only the product of sexism, but also a testament to her continued threat to those in power. In 2010, the Texas State Board of Education removed Dolores Huerta from the state’s history curriculum. In that same year, fueled in part by Ms. Huerta’s controversial messaging to students at a Tucson school, the Arizona House Education Committee passed a bill to ban Ethnic Studies in the state. Addressing the committee at the bill’s hearing, then Superintendent Tom Horne characterized Ms. Huerta as “a former girlfriend of Cesar Chavez.” With the passage of the ban, Mr. Horne and the Education Committee struck deeper than insult – the law effectively targeted and removed a longstanding Mexican-American studies program that had empowered Tucson’s Chicano students to hold pride in their ancestry and stand up for their rights.

Though the newly designated Dolores Huerta Day will not be recognized as a legal holiday in either Washington or California, its passage provides an opportunity for education and critical reflection. The day offers an opportunity to recognize and support the work of Dolores Huerta and join with advocates standing up for justice in their communities.

As part of the 37^th annual National Pesticide Forum this past weekend, Beyond Pesticides featured a panel of youth advocates for environmental justice. Stay abreast of updates on our Youtube page to learn directly from advocates how you can be a part of the movement to grow out of our oppressive present and into an ecologically and socially just future of food production.

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

Sources: The Cascadia Advocate, Civil Eats, NPR, Dolores Huerta Foundation, People For the American Way, Dolores (2017 film)

(Beyond Pesticides, April 9, 2019) It is time for all local and state governments and school districts to stop the use of glyphosate/Roundup. The last month has seen a level of activity that supports immediate action. A second jury came in with the verdict that the herbicide caused plaintiffs’ non-Hodgkin’s lymphoma (NHL) —this time handing the manufacturer, Monsanto/Bayer, a bill for $80 million ($5 million in compensatory damages and $75 million in punitive damages).

Tell your Governor to act now to stop the use of glyphosate/Roundup.

 Insurance companies are now backing away from Roundup. Harrell’s is a company that sells chemical pesticides, synthetic fertilizers, and “adjuvants and colorants,” among other products, primarily to golf courses, and to the horticulture-nursery, turf, and landscape sectors. The company announced on March 11 that it stopped selling products containing glyphosate as of March 1, 2019 because neither its current insurance company nor others the company consulted would underwrite coverage for the company for any glyphosate-related claims.

Harrell’s CEO stated: “During our annual insurance renewal last month, we were surprised to learn that our insurance company was no longer willing to provide coverage for claims related to glyphosate due to the recent high-profile lawsuit and the many thousands of lawsuits since. We sought coverage from other companies but could not buy adequate coverage for the risk we would be incurring. So we had no choice other than to notify our Harrell’s Team and customers that we would no longer offer products containing glyphosate.”

The announcement stands in contrast to a Fox Business story shortly after the verdict in the Johnson v. Monsanto case. That article reported, “Top U.S. retailers such as Home Depot, Target, Walmart and Amazon are sticking by Monsanto’s controversial weedkiller Roundup one week after a California jury awarded a school groundskeeper $289 million for proving the spray caused him to develop non-Hodgkin’s lymphoma.” Indeed, insurer (and perhaps re-insurer) concern may well increase in light of the deluge of lawsuits glyphosate use has triggered.

Meanwhile scientific studies linking glyphosate to serious adverse effects still keep coming in. A recent study by Fabiana Manservisi, Corina Lesseur, et al., published in Environmental Health on March 12, shows glyphosate-based herbicides are associated with endocrine and reproductive effects. This is on top of the scientific findings by the World Health Organization that the chemical probably causes cancer. A meta-study in February 2018 concluded that there is a “compelling link between exposures to GBH [glyphosate-based herbicides] and increased risk of NHL.” Still the U.S. Environmental Protection Agency fails to act.

On March 1, the City of Miami established a ban, which went into immediate effect, on the use of any glyphosate-based herbicides (including Roundup compounds) by the city and any of its contractors.

It is time to stop glyphosate use or risk continued exposure to the state’s populations and adverse health effects, along with the financial exposure that the threat of litigation brings.

Beyond Pesticides and other organizations that have worked for many years to educate stakeholders and policy makers about the dangers of pesticides, stand ready to assist the state and communities in transforming pest management by eliminating a reliance on toxic pesticides and adopting organic management practices.

Tell your Governor to act now to stop the use of glyphosate/Roundup.

Letter to Your Governor:

It is time for all local and state governments and school districts to stop the use of glyphosate/Roundup. The last month has seen a level of activity that supports immediate action. A second jury came in with the verdict that the herbicide caused plaintiffs’ non-Hodgkin’s lymphoma (NHL) —this time handing the manufacturer, Monsanto/Bayer, a bill for $80 million ($5 million in compensatory damages and $75 million in punitive damages).

Insurance companies are now backing away from Roundup. Harrell’s is a company that sells chemical pesticides, synthetic fertilizers, and “adjuvants and colorants,” among other products, primarily to golf courses, and to the horticulture-nursery, turf, and lt is time for all local and state governments and school districts to stop the use of glyphosate/Roundup. The last month has seen a level of activity that supports immediate action. A second jury came in with the verdict that the herbicide caused plaintiffs’ non-Hodgkins lymphoma (NHL) —this time handing the manufacturer, Monsanto/Bayer, a bill for  $80 million ($5 million in compensatory damages and $75 million in punitive damages).

Insurance companies are now backing away from Roundup. Harrell’s is a company that sells chemical pesticides, synthetic fertilizers, and other products, primarily to golf courses and the horticulture-nursery, turf, and landscape sectors. The company announced on March 11 that it stopped selling products containing glyphosate as of March 1, 2019 because neither its current insurance company nor others Harrell’s consulted would underwrite coverage for any glyphosate-related claims.

Harrell’s CEO stated: “During our annual insurance renewal last month, we were surprised to learn that our insurance company was no longer willing to provide coverage for claims related to glyphosate due to the recent high-profile lawsuit and the many thousands of lawsuits since. We sought coverage from other companies but could not buy adequate coverage for the risk we would be incurring. So we had no choice other than to notify our Harrell’s Team and customers that we would no longer offer products containing glyphosate.”

Concern has increased since a Fox Business story shortly after the verdict in the Johnson v. Monsanto case, which reported, “Top U.S. retailers such as Home Depot, Target, Walmart and Amazon are sticking by Monsanto’s controversial weedkiller Roundup one week after a California jury awarded a school groundskeeper $289 million for proving the spray caused him to develop non-Hodgkin’s lymphoma.” Indeed, insurer (and perhaps re-insurer) concern may well increase in light of the deluge of lawsuits glyphosate use has triggered.

Meanwhile scientific studies linking glyphosate to serious adverse effects still keep coming in. A recent study published in Environmental Health on March 12, shows glyphosate-based herbicides are associated with endocrine and reproductive effects. This is on top of the scientific findings by the World Health Organization that the chemical probably causes cancer. A meta-study in February 2018 concluded that there is a “compelling link between exposures to GBH [glyphosate-based herbicides] and increased risk of NHL.” Still the U.S. Environmental Protection Agency fails to act.

On March 1, the City of Miami established an immediate ban on the use of any glyphosate-based herbicides by the city and any of its contractors.

It is time to stop glyphosate use or risk continued exposure to the state’s populations and adverse health effects, along with the financial exposure that the threat of litigation brings.

Beyond Pesticides and other organizations that have worked for many years to educate stakeholders and policy makers about the dangers of pesticides, stand ready to assist the state and communities in transforming pest management by eliminating a reliance on toxic pesticides and adopting organic management practices.

Thank you for your attention to this important matter.

(Beyond Pesticides, April 8, 2019) Officials in Europe and the U.S. focus on banning problem pesticides, raising concerns about their replacements in the face of pesticide-intensive management strategies, while organic advocates call for a systems change in land management. In reference to widespread community bans of Roundup/glyphosate, Cary Gillam, author of Whitewash, told last year’s Beyond Pesticides’ Forum, “Glyphosate is the poster child for the bigger pesticide problem.” She continues, “If it goes away tomorrow, we are not okay.” Because of this, Beyond Pesticides has strategically sought to transform our country’s approach to pest management, both agricultural and residential/structural, by eliminating a reliance on pesticides and advancing organic management practices that do not rely on toxic inputs. This Daily News Blog post offers updates on progress in the European Union (EU), in the U.S. Congress, and in communities and sates nationwide.

The EU is poised to ban clorothalanil, a commonly used — and highly toxic — organochlorine fungicide, The Guardian reported, in mid-to-late May 2019. After a review by the European Food Safety Authority (EFSA), EU states voted to approve a ban. EFSA identified as a chief safety concern the possibility that breakdown products (metabolites) of the compound may cause damage to DNA. The group also reported that for all identified uses, there is “a high risk to amphibians.” It further noted that recent research points to chlorothalonil (and other fungicides) as primary contributors to the alarming decline in bumblebee populations. The ban comes shortly after the European Parliament’s Special Committee (the PEST Committee) approval of a draft report recommending significant strengthening of pesticide restrictions.

Chlorothalonil, sold commercially under the names Bravo, Echo, and Daconil, is a broad- spectrum, non-systemic fungicide used to control fungal foliar diseases of vegetable, field, and ornamental crops; it is also deployed as a wood protectant, anti-mold and antimildew agent, bactericide, microbiocide, algaecide, insecticide, and acaricide. Its impacts on bumblebee and other bee populations have been chronicled by Beyond Pesticides and others; the mechanism of action is strongly suspected to involve disruption of the organisms’ gut biomes. The chemical is also regarded as a likely human carcinogen.

The United Kingdom’s National Farmers Union reacted to this EU move by calling it “overly precautionary,” and warning that such a ban fails “to consider the particular importance of this [pesticide] in the control of critical fungal diseases and in managing disease resistance. As a result, we believe sectors of UK agricultural and horticultural production will be put at significant risk.”

However, Mark Shardlow, director of the nonprofit Buglife, supported the ban, saying that the fact that established links to bumblebee harm had not led to safety tests for wild bees showed the inadequacy of the EU’s regulatory system. He added, “[T]he EU process failed to apply the EFSA guidance on assessing risk to bees, so there were no bumblebee safety tests. When will regulators learn the lessons, [and] stop kowtowing to the demands of the pesticide manufacturers?”

A spokeswoman for the European Commission (EC), the executive branch of the EU, defended the action, saying, “The [chlorothalonil ban] is based on EFSA’s scientific assessment, which concluded that the approval criteria do not seem to be satisfied for a wide range of reasons. Great concerns are raised in relation to contamination of groundwater by metabolites of the substance.”

Back across the pond, in the ongoing “chlorpyrifos saga,” Senator Tom Udall of New Mexico introduced a bill in the U.S. Senate on March 28, just one day after the current Environmental Protection Agency (EPA) once again argued to delay the agency’s own 2016 ban on the compound, to ban the use of the toxic pesticide, chlorpyrifos. If passed and enacted, the Protect Children, Families and Farmworkers from Nerve Agent Pesticides Act of 2019 (S.921) would ban the compound, widely recognized as a dangerous neurotoxin that imperils human health, and puts children and farmworkers at particular risk. Chlorpyrifos has impacts beyond its neurotoxicity; it is also associated with harmful effects on human endocrine, reproductive, hepatic, and renal function, is a skin and eye irritant, and distorts development. Cosponsors of the Senate bill include Senators Blumenthal, Booker, Cardin, Feinstein, Gillibrand, Harris, Leahy, Markey, Merkley, Sanders, Van Hollen, and Whitehouse.

The chlorpyrifos saga began as far back as 2000, with an agreement between EPA and Dow AgroSciences, maker of the pesticide, to stop the sale of the chemical for most home, lawn, and garden uses because of its health risks to children, which proscription did happen. Fast forward to 2015, when EPA proposed to eliminate all food tolerances for the compound — functionally, a ban — although other non-food uses, for landscape and turf management (especially golf courses), and for greenhouse and mosquito control were not affected by the decision. This proposal was made public on the very day that a U.S. Court of Appeals judge in the Ninth Circuit ordered the agency to respond, finally, to a suit filed nine years earlier petitioning for a ban on all uses of chlorpyrifos, given the established health risks of exposure. EPA dithered, ultimately promising to release a final rule in December 2016.

In 2016, the agency did develop a regulation banning the compound. Then, in March 2017, Trump EPA Administrator Scott Pruitt, just three weeks after meeting “privately” with the CEO of Dow chemical, rejected the conclusions of EPA’s own scientists and announced that EPA would reverse course and not ban the use of chlorpyrifos on food crops. Last August, the Ninth Circuit Court once again weighed in, ordering EPA to implement its previous proposed ban of the chemical in the U.S.

Andrew Wheeler, the EPA Administrator who followed Mr. Pruitt, soon after asked the court to rehear the chlorpyrifos case in an en banc proceeding — one in which a case is heard before all the judges of a court rather than by a selected panel of them. (The request is based primarily on challenges to that court’s authority in the matter.) In February 2019, the court granted the request, meaning that public health, labor, and science advocates will have to re-argue, again, that chlorpyrifos should be banned from all food uses. In the wake of this protracted delay, legislators such as Senator Udall have begun to pick up the mantle, given EPA’s failure to protect the public from this toxic and dangerous compound.

Over on the U.S. House side, Representative Nydia Velázquez of New York filed a bill in January, the Ban Toxic Pesticides Act (HR.230), which would ban chlorpyrifos from any commerce in the state. These Senate and House bills follow on previous iterations filed by Sen. Udall and Rep. Velázquez, as well as other legislative initiatives, chronicled here. Rep. Velázquez said of the bill, “It’s unconscionable for EPA to turn a blind eye as children and workers are exposed to this poison. If the EPA won’t do its job when it comes to chlorpyrifos, then Congress needs to act — and do so quickly. As long as there are efforts underway in the courts or administratively to undo the ban on this toxic pesticide, I’ll be working to see chlorpyrifos removed from commerce through the legislative process.”

Momentum is growing for better protection from pesticide use, as these examples and others demonstrate. But ultimately, the widespread adoption of organic management practices is what will provide genuine and long-term protection of human and environmental health from compounds like chlorpyrifos and chlorothalonil. Beyond Pesticides has long sought a broad-scale marketplace transition to organic practices, which prohibit the use of toxic synthetic pesticides. Organic production is a viable, scalable, cost-effective method without any of the long-associated harm of conventional agriculture, but it requires public advocacy to move government to act effectively on behalf of public health and environmental integrity.

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

Sources: https://www.theguardian.com/environment/2019/mar/29/eu-bans-widely-used-pesticide-over-safety-concerns and https://earthjustice.org/news/press/2019/sen-udall-senate-leaders-introduce-bill-to-ban-chlorpyrifos-nationwide and https://www.fredericknewspost.com/news/economy_and_business/agriculture/md-senate-to-consider-statewide-ban-of-the-pesticide-chlorpyrifos/article_6d72c120-565d-50fa-b63a-295e720c840b.html

(Beyond Pesticides, April 5, 2019) Beyond Pesticides’ 37^th National Pesticide Forum, Organic Strategies for Community Environmental Health, begins today at the New York Academy of Medicine, and continues until tomorrow night, where the New York City premiere of the new documentary Ground War will take place with special guest Lee Johnson—who successfully sued Monsanto after linking his cancer to exposure to the weed killer glyphosate. (Tickets are $10 and available through Ticketmaster until sold out, please sign up/log in to a Ticketmaster account to purchase). The two-day conference is convened by Beyond Pesticides in collaboration with the Children’s Environmental Health Center of the Icahn School of Medicine at Mount Sinai, and 24 local cosponsoring organizations. The conference begins at 4:30 pm on Friday April 5, followed by a reception and evening session. Saturday includes breakfast and runs from 8:30 am until 5:30 pm. The Ground War screening, to be held at Florence Gould Hall (55 E. 59th Street), starts at 7:30 pm and concludes with a panel discussion featuring advocates and California Groundskeeper Dewayne Lee Johnson.

The Forum provides a unique place to network with advocates, scientists, practitioners, policy makers, and other experts on the cutting edge of the pesticide reform movement. Featured speakers include:

• Joan Dye Gussow, EdD, a nutritionist, educator, writer, and gardener. She was one of the first experts to advocate, as early as the 1970’s, that we “eat locally, think globally.” Gussow is a leading thinker not just about food, but also about how consumerism damages the planet. By 1971, the year after she published her first book on the relationship between nutrition and children’s performance in school, Gussow was invited to testify before Congress about Saturday morning cereal commercials and the confusing, harmful messages they send to children and families about food. In 2010, her garden, where she grows seasonal produce for her own consumption, was flooded by Superstorm Sandy and destroyed. However, Gussow insists that’s no reason to give up. In her book, The Feeding Web, Gussow explains why gardening matters: “Food comes from the land. We have forgotten that. If we do not learn it again, we will die. …Are we not, in fact, more helpless than any people before us, less able to fend for ourselves, more cut off from sources of nourishment? What would we do if we could not get to the supermarket?”
• Peter Del Tredici, PhD, recently retired from the Arnold Arboretum of Harvard University after working there for 35 years. He taught in Harvard’s Landscape Architecture from 1992 through 2016 and is currently teaching in the Urban Planning Department at MIT. He is the winner of the 2013 Veitch Gold Medal from The Royal Horticultural Society and has studied the ecology and cultivation of the Ginkgo tree since 1988. Dr. Del Tredici is the author of more than 140 scientific and popular articles including the widely acclaimed “Wild Urban Plants of the Northeast: A Field Guide” (2010). His recent work is focused on urban ecology and climate change.
• Jeff Pettis, PhD, former research leader of the USDA-ARS Bee Research Laboratory in Beltsville, MD and now an independent consultant, Dr. Pettis has focused on improving colony health by limiting the impact of pests, diseases and pesticides on honey bees. His research areas include; IPM techniques to reduce the impacts of parasitic mites and disease, effects of pesticides and pathogens on queen health and longevity, host-parasite relationships and bee behavior. Dr. Pettis serves on several international committees including the World Organization for Animal Health (OIE) and is current President of the Bee Health Commission of Apimondia.  With more than 35 years of research experience conducted in more than 15 countries; he is frequently interviewed by the media for his opinions on worldwide pollinator declines and honey bee health. Dr. Pettis received undergraduate and MS degrees from the University of Georgia and his doctoral degree in Entomology from Texas A&M University in 1992.
• Virginia Rauh, ScD, a member of Columbia’s faculty since 1984 and is Deputy Director of the Columbia Center for Children’s Environmental Health. Her work focuses on the adverse impact of exposure to air pollutants, including second hand smoke and pesticides on pregnancy and child health, and the susceptibility of individuals and systemically underserved populations to environmental hazards. She has been principal investigator on numerous major research projects, including studies of the impact of organophosphorus insecticides. Dr. Rauh serves on numerous national committees, including advisory groups at NIEHS, NICHD, and the Scientific Advisory Board for the Environmental Protection Agency.

The conference also includes workshops on a number of salient topics in pesticide reform, including on biodiversity, human health and pesticides, local organizing, organic land management, and methods to leverage the law for health and the environment. See here for a schedule of events.

The Forum co-sponsors include: Environmental Law Advocates at Fordham University School of Law, No Spray Coalition, Grassroots Environmental Education, New York Environmental Law and Justice Project, Friends of Animals, New Yorkers for Pesticide-Free Parks (NYPFP), The Sierra Club NYC Group, Sixth Street Community Center, Food and Water Watch in New York, NYC Grassroots Alliance, Garden of Eve Organic Farm & Market, iEatGreen, Perfect Earth Project, Battery Park City Authority, WE ACT for Environmental Justice, Center for Earth Ethics, Brooklyn Grange Rooftop Farms, Northeast Organic Farming Association of New York (NOFA-NY), Clean Water Action NJ, Green City Force, Newtown Creek Alliance, 350 NYC, Green Inside and Out, and more.

Tickets are still available for the Forum and Ground War screening (sign in to Ticketmaster to purchase)!

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

(Beyond Pesticides, April 4, 2019) Contamination of drinking water with toxic breakdown products and risks to fish and and amphibians has led to a ban on the fungicide chlorothalonil in the European Union (EU). While the pesticide will be out of use in the EU next decade, tens of millions of pounds will continue to be sprayed throughout the U.S. unless regulators take action quickly.

“The [chlorothalonil ban] is based on [the European Food Safety Authority’s] EFSA’s scientific assessment which concluded that the approval criteria do not seem to be satisfied for a wide range of reasons,” a spokeswoman for the European Commission told The Guardian. “Great concerns are raised in relation to contamination of groundwater by metabolites of the substance.”

EFSA’s review of chlorothalonil categorized it as a 1B carcinogen, meaning it “may cause cancer,” with the most significant risk found for kidney cancer based on laboratory animal studies. Further research was needed into many of the metabolites (break-down substances) created when chlorothalonil degrades. However, regulators determined enough data was present to conclude that these breakdown substances may be genotoxic, with the potential to damage DNA and lead to cancer.

European regulators also identified a high acute risk to amphibians, and chronic risks to fish from chlorothalonil-contaminated water.  However, many European advocates are concerned that the assessment did not adequately characterize the risks the fungicide poses to wild pollinators. EFSA found low risks to honey and bumblebees at both acute and chronic doses, but advocates indicate these data should have precipitated follow up tests on wild pollinators. Matt Shardlow of the European environmental non-profit Buglife told The Guardian, “Instead the EU process failed to apply the EFSA guidance on assessing risk to bees, so there were no bumblebee safety tests. When will regulators learn the lessons, stop kowtowing to the demands of the pesticide manufacturers and start applying the Efsa guidance that was finalised in 2013?”

Prior research backs up Buglife’s concerns. A 2018 study found that pollinators display a concerning attraction to chlorothalonil. Research from Cornell University in 2017 even singled out chlorothalonil as a contributing factor to the ongoing decline of pollinators. A 2016 study found that chlorothalonil altered the microbiome of honey bees, and a 2015 study showed reduced bumblebee colony size and health after exposure to the fungicide.

Although regulators did not go further with data relating to potential wild pollinator impacts, the justification surrounding impacts to aquatic species matches up with recent independent scientific literature. In 2011, a study found that chlorothalonil, even at low doses, poses significant risks to a range of frog species. And building on that research, a year later scientists determined that the chemical altered the proper functioning of aquatic ecosystems.

While EU regulators have been hard at work reviewing the impacts of this chemical and its effects on human health and aquatic species, the U.S. Environmental Protection Agency is two years late on a workplan it set for itself on chlorothalonil. EPA estimated it would open a review document for the chemical in 2016, but the most recent action taken, according to the agency’s docket folder on regulations.gov, was a meeting with the chemical’s registrant Syngenta (now owned by ChemChina).

Chlorothalonil has been in use since the 1960s, yet only now are regulators beginning to understand its impacts to human health, water quality, pollinators and aquatic species; after half a century and tens of millions of pounds of use. Cases like these are not rare, or an exception, but frustratingly common in the world of pesticide regulation.

But, in conjunction with an increasing understanding of the toxicity of chemicals once used with minimal scientific review, is a growing realization that they’re simply unnecessary to grow food or maintain healthy landscapes. A 2017 study found that farmers can sustain yields and profit margins while eliminating their pesticide use. And a United Nations report published around the same time sharply criticized the “myth” perpetuated by the agrichemical industry that toxic pesticides are necessary to feed the world.

Join Beyond Pesticides in urging civilization off the pesticide treadmill by going organic whenever and wherever possible – in your food choices, your backyard, and community. The more that we create and promote organic systems that do not necessitate toxic pesticides, the greater chance we have to leapfrog the decades-long timelines regulators take to restrict hazardous chemicals in the environment.

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

Source: The Guardian, EFSA (review document for chlorothalonil)

(Beyond Pesticides, April 4, 2019)  Following on its verdict that the herbicide Roundup caused plaintiff Edwin Hardeman’s  non-Hodgkin lymphoma (NHL), the jury on March 27 issued an award of $80 million—$5 million in compensatory damages and $75 million in punitive damages—for improper labeling and negligence on the part of the manufacturer and defendant, Monsanto. The trial, the first federal Roundup cancer trial, marks the first of a multidistrict litigation against Monsanto, with more than 1,600 similar lawsuits pending in San Francisco’s federal court. The jury’s second verdict affirmed Mr. Hardeman’s allegations that Roundup’s design is defective and lacks sufficient warnings, and that Monsanto was negligent by not using reasonable care to warn about Roundup’s NHL risk.

The Edwin Hardeman v. Monsanto Co. jury verdict marks the second multi-million dollar award to be granted in a landmark case against Bayer/Monsanto within the past year. Last August in San Francisco Superior Court, California groundskeeper Dewayne “Lee” Johnson was awarded $39 million in compensatory damages, and $250 million in punitive damages in the first case that linked his NHL to Monsanto’s glyphosate/Roundup. In October, the judge in the case upheld the verdict, but reduced the award to $78 million. Mr. Hardeman is represented by lawyers Aimee Wagstaff of Andrus Wagstaff and Jennifer Moore of Moore Law Group, and the case is presided by Judge Chhabria.

Edwin Hardeman and his wife began using Roundup in the 1980s to treat their 56-acre Sonoma County property, an area that had such prolific poison oak that the township used to hold an annual poison oak festival, said Mr. Hardeman. As Mr. Hardeman testified, he and his wife are “do-it-yourselfers.” After hiring an applicator once, the couple decided to buy Roundup and a pump-up sprayer off the shelf and spray the product themselves. Mr. Hardeman mixed the formulation himself, using Roundup concentrate available at their local hardware store. For 25 years, from May to November, Mr. Hardeman would mix and spray Roundup as a regular part of property maintenance.

On Christmas morning of 2014, as he was making preparations for his sister’s funeral, Mr. Hardeman noticed a lump on his neck. By February of 2015, he was diagnosed with B-cell NHL. Last month, in the first phase of the trial, the jury delivered a unanimous verdict that Monsanto’s Roundup herbicide significantly contributed to Mr. Hardeman’s NHL.

Despite the prevalent myth that this widely-used herbicide is harmless, glyphosate (N-phosphono-methyl glycine) is associated with a wide range of illnesses, including NHL, liver and kidney damage, endocrine disruption, as well as environmental damage, including water contamination and harm to amphibians. Glyphosate based herbicides are by now ubiquitous, due in large part to the increased cultivation of genetically engineered glyphosate-tolerant crops beginning in the mid-1990s. As expert witness  Beate Ritz, PhD testified in the first phase of the case, “What happened to glyphosate is pretty unique because of these glyphosate-resistant crops… the purpose of use changed between 1993, ’94, ’95, and starting in 1996, because the farming practice changed. It was a radical change in farming practice.”

Since EPA’s contentious classification of glyphosate as a Group E carcinogen—or “evidence of non-carcinogenicity for humans,” after reversing its original  Group C, possible carcinogen, rating in 1985, the International Agency for Research on Cancer (IARC) in 2015 classified glyphosate as a Group 2A “probable” carcinogen, which means that the chemical is probably carcinogenic to humans based on sufficient evidence of carcinogenicity in experimental animals. The most recent studies and a 2019 meta-analysis have added to a wealth of literature confirming a compelling link between glyphosate and NHL. As of July 7, 2017, glyphosate is listed as a cancer-causing chemical under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). This requires cancer warning labels be placed on end-use glyphosate products in California.

But glyphosate is far from the whole story of Roundup toxicity. As Johnson v. Monsanto lead attorney Brett Wisner attested in an interview with Democracy Now!,

“Glyphosate is part of Roundup, but Roundup is a combined product of glyphosate plus a bunch of other chemicals that make glyphosate significantly more potent… And the simple fact is, Monsanto has never tested the carcinogenicity of the combined product. And this omission is glaring, and it’s intentional. In fact, we have internal documents that say, ‘We do not want to look at this issue because we’re afraid of what we’re going to see.’”

Researchers have determined that the “inert” added ingredients in glyphosate products, especially polyethoxylated tallow amine or POEA — a surfactant commonly used in glyphosate and other herbicidal products — are even more toxic than glyphosate itself. Critically, full formulation Roundup products, as with all other whole formulation pesticide products registered by EPA, have not been assessed for carcinogenicity or other chronic effects. This is especially concerning given the fact that several peer-reviewed studies have found Roundup formulations to be an average of 124 times and up to 357 times more toxic than glyphosate alone (Mesnage et al. 2014; Mesnage et al. 2012; Benachour and Seralini 2009; Richard et al. 2005).

The lack of testing and regulation of whole formulations is in fact a much broader issue, representing systemic failure by chemical companies and regulators to ensure the safety of actual pesticide products, as they are commonly used. Pesticide users are exposed to whole formulations, whole tank mixtures, and whole pesticide combinations, not just active ingredients (those that the manufacturer claims are the only ingredients that attack the target pest). It is the whole formulation that makes the poison, and that whole formulation must be considered when filing for damages or pushing for adequate regulation.

As public health and environmental advocates attest, the fight is broader than any single pesticide. Beyond Pesticides holds the position that both chemical producers and regulators must be held accountable for the damage that widespread, corruptly regulated, toxic pesticides wreak on public health and the environment. Take action and tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on company-sponsored, scientifically questionable studies of isolated active ingredients. Stay abreast of legal, regulatory, and scientific pesticide news by following the Beyond Pesticides Daily News Blog.

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

Sources: Baum Hedlund Aristei Goldman PC, Democracy Now!

(Beyond Pesticides, April 2, 2019) Throughout the month of April, and in celebration of Earth Day on April 22, Natural Grocers is inviting the community to pledge to protect one of nature’s most beloved beneficial insects—the ladybug. From April 1^st through the 22^nd, Natural Grocers will donate 10 cents to Beyond Pesticides for every pledge taken on their website, up to $25,000. Pledge takers will commit to never use chemicals that are harmful to ladybugs and other beneficial insects, and to support 100% organic produce. The stability of our food web depends on insects, but recent studies suggest they have declined by more than 75 percent in the last three decades.[i] Agricultural pesticide use has steadily increased since 1960.[ii] According to the most recent EPA report (2012), estimates of annual pesticide use in the United States topped 1 billion pounds[iii] in 2011 and 2012, and 88 million U.S. households use pesticides at home.[iv] Natural Grocers is excited to partner with Beyond Pesticides to keep the public informed about the threat toxic pesticides pose to human health, insect health, and the health of the planet. Take the pledge today at https://www.naturalgrocers.com/ladybuglove/!

[i] Hallmann, Caspar A., et al. “More than 75 Percent Decline over 27 Years in Total Flying Insect Biomass in Protected Areas.” PLOS ONE, Public Library of Science, journals.plos.org/plosone/article?id=10.1371%2Fjournal.pone.0185809.

[ii] Fernandez-Cornejo, Jorge, et al. “Pesticide Use in U.S. Agriculture: 21 Selected Crops, 1960-2008.” Https://Www.ers.usda.gov, May 2014, www.ers.usda.gov/webdocs/publications/43854/46736_eib124_summary.pdf?v=41830.

[iii] Alavanja, Michael C R. “Introduction: Pesticides Use and Exposure Extensive Worldwide.” Reviews on Environmental Health, U.S. National Library of Medicine, 2009, www.ncbi.nlm.nih.gov/pmc/articles/PMC2946087/#R1j.

[iv] “Pesticides Industry Sales and Usage 2008-2012 Market Estimates.” Https://Www.epa.gov, 2016, www.epa.gov/sites/production/files/2017-01/documents/pesticides-industry-sales-usage-2016_0.pdf. pages 9 and 21.

(Beyond Pesticides, April 2, 2019) The new documentary film “Ground War” will have its New York City premiere screening on Saturday, April 6, 2019, 7:30pm at Florence Gould Hall, 55 East 59^th Street, New York, NY. The film is a moving depiction of a son’s quest for answers about the cause of his father’s cancer—which takes him into the world of doctors, scientists, pesticide regulators, victims of pesticide poisoning, activists, and land managers. The issue is exposure to pesticides used to manage lawns and playing fields and the father’s exposure as an avid golfer. The son, who is the filmmaker, finds others on the same search for answers because of harm or death of a loved one, then finds a solution in the work of activists and organic land managers.

The film is particularly timely with public controversy about the use of the weed killer glyphosate (Roundup) and two lawsuits with multimillion dollar jury verdicts for compensation and punitive damages against its manufacturer, Monsanto (Bayer)—while thousands of lawsuits are pending. All of this widespread pesticide exposure is taking place in the face of inaction by the U.S. Environmental Protection Agency and headlines pointing to officials sidestepping the law. The film screening will be followed by a panel discussion with the filmmaker, Andrew Nisker, and the former applicator of Roundup, groundskeeper Dewayne “Lee” Johnson—terminally ill from non Hodgkin lymphoma, but committed to speaking out.

Pesticide use is being hotly debated in New York City and across the country as the New York City Council considers legislation to stop all toxic pesticide use in city parks and public spaces. For those registered for the conference (see below), the film is free of charge. Tickets for only the film can be purchased for $10.00 from Ticketmaster.

The National Forum at New York Academy of Medicine, 1216 5th Ave, New York, NY 

The film and panel discussion conclude a two-day conference at the New York Academy of Medicine beginning on Friday, April 5. The conference, Organic Strategies for Community Environmental Health, the 37^th National Pesticide Forum, is convened by the Washington, DC-based Beyond Pesticides in collaboration with the Children’s Environmental Health Center of the Icahn School of Medicine at Mount Sinai, and cosponsored by 24 local organizations. The conference begins at 4:30pm April 5, followed by a reception and evening session.

Among the many illustrious speakers at the conference are Joan Dye Gussow, EdD, author and educator, former head of Columbia University’s Nutrition Education Program; nationally renowned scientists from Mount Sinai and Columbia University, including cancer and health researchers tracking disease outcomes linked to pesticides; bee scientist and former head of USDA’s bee lab, Jeff Pettis, PhD, whose studies have found pesticides’ adverse impacts on pollinators; land managers who eschew pesticides in favor of organic practices, including Peter Del Tredici, PhD, senior scientist emeritus at Arnold Arboretum at Harvard University; other researchers, legal experts, land management practitioners, and urban farmers who are growing food organically. The conference will provide participants with the cutting edge science on pesticide issues related to health and the environment as well as the solutions for managing land without toxic materials. New York City Council Member Ben Kallos will discuss his legislation to stop pesticide use on public spaces. For the complete program, go to www.beyondpesticides.org.

Inquire about a press pass with Garret White at 202-543-5450, after Tuesday, April 4 at 202-255-4296.

Conference website: www.beyondpesticides.org

(Beyond Pesticides, April 1, 2019) National Organic Standards Board (NOSB) meets next month in Seattle, Washington to debate issues concerning what goes into your organic food. Written comments are due April 4. The format for messaging the NOSB requires copying and pasting comments into regulations.gov, so we apologize that this is not a “single click” action. Please add a personal message about why this is important to you at the top of your comments, if possible.

Lend your voice to continuous improvement by learning about issues and submitting comments to regulations.gov (directions below, or click here).

From the very beginning, with the passage of the Organic Foods Production Act (OFPA) in 1990, “organic” has meant “continuous improvement ” in organic food production. The primary mechanism for this is the high level of public involvement that comes from twice-annual meetings of the stakeholder board and decisions related to the allowance of substances/materials used in organic production.

The second mechanism is the sunset process, which helps move synthetic substances out of organic production as we learn more about hazards and alternatives. Those substances allowed in organic production must be placed on the National List of Allowed and Prohibited Substances and may be re-listed every five years after a mandatory rigorous assessment of their adverse effects from cradle-to-grave, and a determination of their necessity, given alternative practices and products.  Imagine what could happen if pesticide registrations went through a rigorous reevaluation and relisting process like this every five years!

Items on the NOSB agenda include voting on materials allowed in organic production and policies, as well as discussion of policies and sunset materials on which the NOSB will vote in the Fall. We have identified some priority issues of both kinds. Starred issues are voting issues.

To comment on these priority issues, highlight the entirety of the comments below (including headers) and hit “copy”

Then click here to go to Regulations.gov and paste into the comment field.

Add a personal message about why this is important to you at the top!

PRIORITY COMMENTS: 

Reject Petition to Allow Silver Dihydrogen Citrate* [HS]
Silver dihydrogen citrate poses health and environmental risks, particularly the risk of increasing resistance to antibiotics and silver-based medications. Both ionic silver and nanosilver are toxic not only to microbes, but to other species as well. The petition for SDC must be denied to protect human health and the environment and ensure the effectiveness of remaining antimicrobial medications.

Reject Petition to Allow Allyl Isothiocyanate (AITC)* [CS]
Allyl isothiocyanate (AITC) must not be included on the National List because it does not meet any of the criteria in OFPA for allowing an exemption. It poses environmental and health hazards, is not essential for organic production, and is not compatible with organic practices. It would be difficult to find a practice less compatible with organic production than soil fumigation with a “broad-spectrum antimicrobial compound that effectively kills both plant pathogens and beneficial soil microorganisms.” Organic production uses practices that feed soil organisms who feed crop plants. It creates healthy soil food webs. Using a toxic chemical to wipe out soil biology is the antithesis of organic practices.

Reject Petition to Allow Collagen Gel Casings* [HS]
Collagen gel casings should not be added to the list of allowed nonorganic agricultural materials because collagen gel casings are synthetic, the listing discourages the development of organic collagen gel casings, and the contamination from nonorganic feedlots and other practices poses environmental and health hazards.

Non-organic collagen gel casings derived from animals raised in concentrated animal feeding operations (CAFOs) contaminate organic products with toxic pesticides and other chemicals widely recognized as hazardous to farmworkers, the environment, and consumers. 

Any agricultural commodity can be produced organically, so listing on §606 only stifles organic production of new organic crops and promotes chemical-intensive production. Instead of petitioning for the use of casings made from meat contaminated with pesticides and antibiotics, processors should devote their efforts to eliminating practical obstacles to sourcing organic collagen.

Protect Marine Environment by Limiting Marine Materials [MS]
We must set enforceable, protective rules for the use of marine algae in organic production. Enforceability implies rules that are verified by on-site inspection and that will stand up to legal challenge. Rules must protect the marine ecosystem and biological communities.

An annotation is the most effective way to introduce enforceable, protective rules for marine algae. Annotations are not subject to discretionary alteration without a decisive vote of the NOSB. On the other hand, because the listings are reviewed on a five-year cycle, they can be updated when needed. 

Evaluating Sanitizers [MS]
The Materials Subcommittee has outlined many of the issues that should be covered regarding sanitizers, but they need to be addressed within a framework that first identifies the needs for cleaning and sanitizing materials in organic production and handling.

Such a review should start with the questions:

1. For what purposes are cleaning and sanitizing materials needed?
2. Are specific cleaning and sanitizing materials required by law?

Both in terms of a strict reading of OFPA and common sense, all cleansers and antimicrobials used in organic production and handling should be on the National List.

Stop Methionine [LS]
The NOSB should delist synthetic methionine (an alternative to natural amino acids) or add an expiration date to force serious reconsideration. The current listing of methionine is based on inadequate support for a regulatory decision that reverses a previous NOSB decision to phase out methionine and incentivize alternative approaches to managing poultry. 

The listing of synthetic methionine must be considered in the context of an organic management system. The “need” for synthetic methionine is a result of choices regarding poultry flock breeds, stocking rates (both density and group size), and outdoor access. Increasingly, consumers are turning to eggs and meat produced in pastured poultry systems, which require fewer synthetic inputs. In the time since the last consideration of synthetic methionine by the NOSB, there have been advances in the use of insects — specifically black soldier fly larvae — as a source of natural methionine. However, organic poultry producers and the NOSB should not limit their consideration to one source.

Synthetic methionine is not necessary for animal welfare. Studies show that reduced stocking rates (both density and group size), outdoor access, and slower-growing birds (who use the outdoors more effectively), but not synthetic methionine and cysteine, have a positive impact on the welfare of poultry.

Lend your voice to continuous improvement by learning about issues and submitting comments to regulations.gov (directions below, or click here).

(Beyond Pesticides, March 29, 2019) The U.S. Environmental Protection Agency (EPA) made a low-key announcement on March 19 suggesting that it may change its handling of requests from states to exert stricter controls on use of pesticides than the federal agency sets out in its registration of the compounds — by disapproving them. This is potentially a big deal because it signals that the agency will be less-kindly disposed to states’ desires to establish either somewhat different parameters of use based on local conditions and needs, or more-stringent regulations on pesticide use than those set out by federal regulators. This issue of preemption of localities’ desires to protect their populations and environment has become an increasingly dynamic frontier at the nexus of pesticide use, health, and environment. Beyond Pesticides has written more frequently about this issue in recent years as the tension between centralized, federal regulation and more-local regulation has risen; see more below.

EPA appears distressed by some of the approximately 300 annual requests it gets to make some adjustment to the federal regulation. This can happen under Section 24(c) of FIFRA, which allows for a Special Local Need Label, which can be requested under a variety of conditions, including when a “federally registered pesticide a) is not available in the state for the desired site(s) to adequately control the target pest(s), or b) cannot be applied without causing unacceptable risks to human health or the environment, or c) is necessary to maintain resistance management, or d) could be replaced by a formulation that poses less risk to man [sic] or the environment.”

Some states assign some rulemaking authority over pesticide use to specific state entities, and use that authority to institute additional restrictions on pesticide use. But states do sometimes go to EPA for a 24(c) Special Local Need Label.

EPA seems to be signaling its disinclination toward those requests that seek to “narrow the federal label,” i.e., set a standard or regulation more stringent than the federal registration process and labeling does (e.g., greater applicator training requirements, a foreshortened window during which use is allowed, or reducing the number of applications allowed by the federal label). EPA said it will not institute any changes for the 2019 growing season and will set a public comment period before changes are made, but noted it is “re-evaluating its approach to reviewing . . . [such] requests and the circumstances under which it will exercise its authority to disapprove those requests.”

This is the text of the EPA announcement: “This is the time of year that EPA receives many special local needs registration requests from states under section 24(c) of FIFRA. Section 24(c) states that “A State may provide registration for additional uses of federally registered pesticides formulated for distribution and use within the State to meet special local needs . . .” EPA currently receives approximately 300 24(c) requests annually. Many of these requests are for additional uses not considered by the federal label – e.g., applying the pesticide to a different crop to address an outbreak of disease, adding an alternative application method that suits the practices of that state, or adding a new pest species that is not on the federal label. However, some requests are to narrow the federal label, such as to add a more restrictive cut-off date, to add training and certification requirements, or to restrict the use directions by limiting the number of treatments permitted by the federal label.

“Due to the fact that section 24(a) allows states to regulate the use of any federally registered pesticide, and the fact that some states have instead used 24(c) to implement cut-off dates (and/or impose other restrictions), EPA is now re-evaluating its approach to reviewing 24(c) requests and the circumstances under which it will exercise its authority to disapprove those requests. Before making any changes in this regard, EPA intends to take public comment on any potential new approaches before adopting them.

“EPA is not making any immediate changes in this area and does not expect any potential changes will impact 24(c) requests that states submit ahead of the 2019 growing season.”

The regulation of pesticide use is a multi-variate enterprise; what follows here is a brief primer: EPA is primarily responsible for regulation of pesticides (insecticides, herbicides, and fungicides) under FIFRA (the Federal Insecticide, Fungicide, and Rodenticide Act) and the Food Quality Protection Act (FQPA). The EPA looks at what potential human health and environmental impacts might be associated with use of a pesticide. It is supposed to do so by evaluating — on the basis of scientific studies that investigate the matter — whether compounds proposed for use may cause adverse effects on humans or the environment. It is charged with approving only those that cause “no unreasonable adverse effects, taking into account the risks and benefits of pesticide use.” (This, of course, begs the question: what are “reasonable” adverse effects?) In its evaluations, the agency also uses the National Research Council’s four-step process for human health risk assessment, which includes: (1) hazard identification, (2) dose-response assessment, (3) exposure assessment, and (4) risk characterization.

If a pesticide meets the “no unreasonable adverse effects” requirements, it can be “registered,” which means approved, for use within prescribed limits and parameters. When registered, a pesticide acquires its “federal label,” which sets out the requirements for, and limitations on, its use. In addition, pesticides are assigned a Toxicity Class, based on their acute toxicity; these include: Categories I (highly toxic and severely irritating), II (moderately toxic and moderately irritating), III (slightly toxic and slightly irritating), and IV (practically nontoxic and not an irritant). “Signal words” must be used on the labels of categories I–III and are, respectively, “Danger,” “Warning,” and “Caution.” Once registered, pesticides must be reviewed every 15 years to ensure that they continue to meet these requirements.

FIFRA was amended by the 1996 FQPA, which mandated a health-based standard for pesticides used on and in food; created protections for infants; expedited the approval process for pesticides deemed “safe”; incentivized development of safer pesticides; and required that pesticide registrations remain current. In addition to the EPA, the U.S. Department of Agriculture (USDA) and the U.S. Food and Drug Administration (FDA) share some responsibility for regulation, though it all ultimately falls to EPA to investigate and approve or disapprove use. They help establish standards, or tolerances, for the allowable levels of pesticide residues on food crops and in animal feed. The FQPA requires that, when setting tolerances, EPA establish a safety finding, meaning that a pesticide can be used only when there is “a reasonable certainty of no harm.”

Federal regulation of pesticide use has increasingly been challenged by localities, whether states, counties, cities, or towns — often with the advocacy of community and nonprofit groups — seeking greater levels of protection for residents and/or the local environment. Localities will establish stricter regulations, and nearly inevitably, pre-emption — the ability of a “higher” level of government to override laws of a lower level — becomes an issue. Pre-emption happens not only from the federal to state level; states often act to pre-empt county and municipal attempts to enact more-protective local regulation. Typically, a state, often spurred by complaints from trade associations or individual companies in the agrochemical industry, will litigate with the goal of state pre-emption of a local statute that seeks to rein in pesticide use in some way.

As Beyond Pesticides wrote in 2017 about an attempt by an Oregon county to ban aerial pesticide spraying: “The case points to the legal conundrum that localities face in trying to protect their residents, lands, and resources from the assaults of pesticides, GMOs (genetically modified organisms), factory farms, fracking sites, or a host of other ills that communities may find objectionable because of health, safety, and/or environmental concerns. As communities . . . initiate efforts to establish regulations that may be more protective than prevailing state laws are, states and, very often, corporations persistently challenge those initiatives, arguing that state statutes supersede local authority to regulate. Such deference to state authority and statute is referred to as preemption — the use of state law to nullify the authority of a “lower” level of government, or a specific statute or ordinance, on that preemptive basis.”

Other states and localities have also moved to establish more protective regulations, including Montgomery County, Maryland; Maine; and Connecticut. Localities also sometimes push back on state pre-emption action, as in the case of three communities in Illinois looking to have the state repeal its pre-emption statute. A recent study by the U.S. Department of Agriculture’s National Institute of Food and Agriculture, covered by Beyond Pesticides, found that “state pesticide preemption laws ‘compromise public health and economic well-being’ by preventing localities from enacting pesticide use restrictions on private property that are more restrictive than their state’s regulations.”

POLITICO’s reporting notes that the greatest near-term impact of this signaled change in EPA’s responses to 24(c) requests might be the significant state regulation of dicamba, the Monsanto/BASF herbicide product that was formulated and marketed to deal with weeds that have developed resistance to the glyphosate-based Roundup. Dicamba, which is commonly used on soybean crops through the Midwest and South, has been the subject of great concern for the damage it causes to crops from drift, as well as for its health and environmental impacts.

A number of states, including Indiana, Minnesota, Missouri, South Dakota, North Dakota, Illinois, and Arkansas, have instituted restrictions on its use that surpass those accompanying the federal registration of the compound. Texas, Iowa, Georgia, Kentucky, Alabama, and North Carolina are all eyeing 24(c) requests for tighter application windows, additional training requirements, better record keeping, new fine structures for violations, and other modifications of the federal label. Arkansas banned dicamba use entirely in early 2018; that ban was upheld in the face of Monsanto’s lawsuit challenging it. Then, in November 2018, EPA stepped in to rule that the herbicide could be used in the state for two years, superseding the state ban. Such experiences with EPA around use of dicamba may be a harbinger of what is to come.

As reported by POLITICO, Rose Kachadoorian, president of the Association of American Pesticide Control Officials, said EPA is touting a remedy for a problem that doesn’t exist, adding that the system in place works fine, and that such a change would limit states’ rights. She notes, “A lot of these states want to ensure the continued availability of a technology. By having the ability to have increased training, cut-off dates and other restrictions, it’s actually enabling states to use that technology.”

Beyond Pesticides emphatically advocates for the ability of communities to protect themselves by adopting protective regulations, as well as nontoxic approaches to pest management of all kinds. For context and history on pre-emption in the U.S., see this 2013 Beyond Pesticides factsheet, which says, “State preemption laws effectively deny local residents and decision makers their democratic right to better protection when a community decides that minimum standards set by state and federal law are insufficient. Given this restriction, local jurisdictions nationwide have passed ordinances that restrict pesticide use on the towns public property, or school districts have limited pesticides on its land.”

From Beyond Pesticides’ March 14, 2019 Daily News Blog: “Beyond Pesticides looks toward a future when federal, state, and local governments are all accountable to the people they serve; when pesticide use across the board is recognized as unacceptably hazardous; when agrochemicals are rendered unnecessary due to the regeneration of healthy soils and resurgence of beneficial insect and microbial communities brought about by the widespread adoption of organic practices; when health is a right, and not a choice for some. As a step toward that endpoint, localities must be able to build the models we need to follow nationally and globally to ensure our future on this planet.”

Stay current on these issues through the Beyond Pesticides Daily News Blog, check out advocacy activity in any state, and join Beyond Pesticides in pushing for the local authority to create more-robust protections from pesticide use.

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

Source: https://www.politico.com/story/2019/03/26/epa-pesticide-rules-1292061

(Beyond Pesticides, March 28, 2019) A set of documents obtained by the Center for Biological Diversity reveals that the Trump administration has known for over a year – and actively concealed – that the organophosphate insecticide chlorpyrifos jeopardizes the existence of 1,399 endangered species. Top officials at the U.S. Department of the Interior, including Acting Secretary David Bernhardt, were privy to and prevented the release of a “biological opinion,” completed by the Fish and Wildlife Service (FWS) in 2017, which contains a full analysis of the extensive environmental impacts wrought by three organophosphate insecticides.

While chlorpyrifos is the worst of the three, the censored biological opinion includes similarly concerning findings for two other organophosphate pesticides, malathion and diazinon, which are currently jeopardizing 1,284 and 175 species, respectively. The U.S. Environmental Protection Agency (EPA) has determined that that all organophosphates have a common mechanisms of effect and therefore the multiple exposures to these pesticides lead to a cumulative risk.

“It’s outrageous that Trump, Bernhardt and the industry hacks inhabiting this administration are speeding the extinction of nearly 1,400 endangered species by refusing to take any action on chlorpyrifos,” said Lori Ann Burd, environmental health director at the Center for Biological Diversity (CBD). “If political appointees weren’t stopping the government’s own scientists from doing their jobs, this brain-damaging, wildlife-killing horror of a pesticide would already be banned.”

Mr. Bernhardt, whose nomination for Secretary of the Interior may be confirmed today, led the Department of the Interior’s effort to block the release of these critical findings. According to documents obtained by CBD through a Freedom of Information Act request, Mr. Bernhardt had six meetings with Fish and Wildlife in October of 2017, and was shown a recovered PowerPoint containing the findings of the three organophosphates’ widespread harms to endangered plants and animals. Following these meetings, Mr. Bernhardt helped to draft a letter stating that the assessment was not ready for release.

The FWS opinion, a compilation of nearly four years of rigorous scientific review, was not just a routine assessment; rather, it was the outcome of a legal settlement with CBD, which required EPA and FWS to make such assessments public by the end of 2017. In April of 2017, Dow AgroSciences directly requested that the agencies abandon the assessment. Seven months later, under the direction of the Department of the Interior, FWS indefinitely delayed efforts to release the already completed assessment, thus failing to fulfill the terms of the settlement and their mandate under the Endangered Species Act.

This latest revelation adds to a trend of Trump administration officials interfering with a legally mandated environmental assessment and regulation. In fact, Mr. Bernhardt would have had less opportunity for the present interference, had it not been for former EPA Administrator Scott Pruitt’s push, in collaboration with Dow Chemical, to keep chlorpyrifos on the market in 2017.

Under the Obama administration, EPA announced its intent to cancel agricultural uses of chlorpyrifos due to strong evidence of harm to the brain and proper development of children. This move itself was the result of a petition and hard fought legal case by the Natural Resources Defense Council and Pesticide Action Network.

With the election of Trump, however, EPA appointee Scott Pruitt made quick work of reversing the proposed ban and delaying any further action until 2021. In response to the about-face by the Pruitt EPA, Earthjustice and a coalition of other groups sued EPA for its delay. That lawsuit was successful, resulting in an order from the appeals court requiring EPA to ban chlorpyrifos within 60 days. However, under the leadership of  the current EPA Administrator, Andrew Wheeler, the agency appealed the decision. Though the evidence for damage is by now overwhelming, the case is still not closed. On Tuesday this week, the appeal was heard in the U.S. Court of Appeals for the Ninth Circuit in San Francisco.

“Even as more and more studies point to pesticides as the leading cause of disturbing drops in insect populations, the Trump administration is only concerned about protecting pesticide company profits,” said Ms. Burd, who sits on EPA’s pesticide program dialogue committee, a federal advisory committee. “This administration’s shameful political meddling in scientific assessments demands an independent investigation by the Department of the Interior’s inspector general and makes it clearer than ever that David Bernhardt’s not fit to lead the agency.”

In light of CBD’s findings, Beyond Pesticides signed on to a letter opposing David Bernhardt’s nomination for Secretary of the Interior. Beyond Pesticides holds the position that Mr. Bernhardt’s role in this unlawful censorship disqualifies him from holding power over critical regulatory agencies. The Department of Interior is tasked with conserving the nation’s natural resources and providing scientific information about natural hazards to address societal challenges.

According to Beyond Pesticides, it is insupportable that a man who has demonstrated his readiness to censor findings so critical to the health of our nation’s endangered wildlife should be charged with a role so vital to their protection. Join Beyond Pesticides in telling your Senators and representatives in the Senate Energy and Natural Resources Committee to oppose David Bernhardt’s nomination. Stay abreast of new legal and regulatory developments by following the Daily News Blog.

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

Source: CBD press release, March 26th, 2019

(Beyond Pesticides, March 27, 2019) Exposure to commonly used pesticides in the womb and during the first year of life is linked to a higher risk of developing autism, according to the study, “Prenatal and infant exposure to ambient pesticides and autism spectrum disorder in children: population based case-control study,” published in the journal BMJ last week. Although the study does not reveal a causal link, it adds to previous literature highlighting autism risks from pesticide exposure, and reinforces calls to limit pesticide exposure during early life critical windows of vulnerability. The authors note their findings “support the need to avoid prenatal and infant exposure to pesticides to protect the developing child’s brain.”

Researchers used data from California’s records of autism disorder diagnosis and birth rates from 1998 to 2010. Roughly thirty-five thousand healthy patients acted as a control, while scientists identified nearly three thousand patients with an autism diagnosis, of which 445 also displayed a co-occurring intellectual disability.

Data was then drawn from California’s pesticide use recording database, and eleven pesticides (glyphosate, chlorpyrifos, diazinon, acephate, malathion, permethrin, bifenthrin, methyl bromide, imidacloprid, avermectin, and myclobutanil) were analyzed for their use within 2000 meters (1.25 miles) of the homes of those involved in the study. Confounders (variables that can influence the statistical determination) such as the mothers age, socioeconomic status, and exposure to air pollution were adjusted for in the researchers’ model.

Results showed, when compared to a control group unexposed to the same pesticides during birth and infancy, modest increases in autism risk for exposure to glyphosate, chlorpyrifos, diazinon, malathion, avermectin and permethrin. For cases of autism with co-occuring intellectual disabilities, a more robust link was found for glyphosate, chlorpyrifos, diazinon, permethrin, methyl bromide, and myclobutanil. A similar link was found between exposures within the first year of life, with glyphosate revealing the strongest association – increasing risk of autism by 50% for exposures occurring during infancy.

This is not the first study to link prenatal and early life pesticide exposure to autism and learning disabilities. In fact, previous studies have found stronger links than the present research. A 2014 study found that pregnant women living less than a mile from crops sprayed with organophosphate insecticides increased risk of their child receiving an autism diagnosis by 60%. For women in the second trimester, chlorpyrifos exposure increased autism risks by 3.3 times. Exposure to synthetic pyrethroids, like permethrin and bifentrhin, during the last trimester of pregnancy corresponded with an 87% increased risk of an autism diagnosis. A 2017 study found that those living in zip codes where pesticides are aerially sprayed for mosquitoes with synthetic pyrethroids were 37% more likely to have higher rates of children diagnosed with autism and other developmental delays.

In an editorial co-released with the study, psychiatrists from the University of Utah note that the study focuses on outdoor air in an agricultural region and that the results may not be generalized to other settings. They also indicate that in many communities, “reducing maternal exposure to zero for a pesticide such as glyphosate might be close to impossible.” Beyond Pesticides rejects these assertions.

If there is a problem with outdoor areas, similar issues are likely to arise when pregnant mothers and young children are exposed to pesticides in their homes. For example, the same synthetic pyrethoids applied over farm fields are also found in RAID and other bug sprays, and evidence suggests that once applied they can persist in one’s home for over a year. Previous studies have linked the presence of these chemicals in a child’s body to increased rates of behavioral and emotional problems, externalizing and internalizing disorders, and accelerated puberty in boys.

Reducing maternal exposure to glyphosate can be solved simply by eliminating its use and cancelling its registration by the U.S. Environmental Protection Agency. More and more studies are finding that not only can organic feed the world, is should be considered an essential part of building a sustainable future.

As lead author of the current study, Ondine von Ehrenstein, PhD, said to TIME, “I would hope that these findings would make some policy makers think about effective public health policy measures to protect populations who may be vulnerable and living in areas that could put them at higher risk. Raising awareness in the public may be the way to eventually change practices and agricultural policies.”

For more information on the link between pesticides and autism and other learning disabilities, see Beyond Pesticides Pesticide Induced Diseases Database.

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

Source: BMJ (peer reviewed journal), TIME

(Beyond Pesticides, March 26, 2019) In a study investigating the carcinogenic effects of pesticide exposure by analyzing data on 316,270 farmers and farmworkers in the U.S., Norway, and France, researchers have identified elevated risk for non Hodgkin lymphoma (NHL) and some subtypes, linking glyphosate and large B-cell lymphoma. Other pesticides linked to the disease include the pyrethroid deltamethrin and chronic lymphocytic leukemia/small lymphocytic lymphoma; and terbufos and NHL overall.

Researchers also found “inverse associations of NHL overall with the broader groups of organochlorine insecticides and phenoxy herbicides, after adjusting for exposure to other pesticides”; such inverse associations were not found with active ingredients within these groups. The research underscores how complex the science of pesticide impacts on human health, and on cancer incidence, can be. To wit: in evaluating 14 different pesticide categories and 33 individual, active chemical ingredients, Maria E. Leon, et al., conclude that associations of pesticides with the development of NHL appear to be (NHL) subtype- and chemical-specific.

Published in the International Journal of Epidemiology in mid-March, the study, “Pesticide use and risk of non-Hodgkin lymphoid malignancies in agricultural cohorts from France, Norway and the USA: a pooled analysis from the AGRICOH consortium,” uses data from three large cohort groups in AGRICOH, “an international consortium of agricultural cohort studies formed in October of 2010 to encourage and support data pooling to study disease-exposure associations that individual cohorts do not have sufficient statistical power to study.” AGRICOH is a program of the World Health Organization’s International Agency for Research on Cancer (IARC).

The three cohort groups included those from AGRICAN, a program of the Mutualité Sociale Agricole, the French national health insurance system of agricultural workers; CNAP, an aggregate group of farm holders and families compiled by Statistics Norway; and the Agricultural Health Study (AHS), which enrolled farmers and farm workers from Iowa and North Carolina.

Farmers and farmworkers are commonly exposed to a multitude of chemical compounds — especially pesticides (which term here includes herbicides and fungicides, as well) — through their work. Such activities can include: mixing and storing pesticide chemicals; applying them to seeds and/or fields; cleaning of related equipment; applications to livestock; and pest management in barns, soils, and animal compounds.

Notably, 75% of subjects in this study were male.

Each database exhibited linkages to cancer and mortality registries in their respective countries. Data were tracked for exposures to the subject pesticide (and other) compounds and the 33 active ingredients, and first incidence of cancer diagnoses. Subjects had no previous cancer diagnoses, except for an occasional non-melanoma skin cancer, before or during follow-up. The span of time frames for each study plus follow-up were as follows: AGRICAN, 2005–2009; CNAP, every five years from 1969 through 1989, with follow-up through 2011; and AHS, 1993–1997, with follow-up through 2010 in North Carolina, and 2011 in Iowa. Results of the study show that there were more than 2,400 cases of NHL across more than 3.5 million person-years of follow-up.

For this research, chemical groups and active ingredients were selected based on common use in at least two of the three countries. In addition, researchers gave priority to chemical groups and active ingredients for which some associative evidence with lympho-hematological malignancies has already been established, and to active ingredients not previously investigated in epidemiological studies. Glyphosate and dicamba were included in the study, as well as these categorical compounds: four insecticides (organophosphates, organochlorines, carbamates, and pyrethroids); seven herbicides (phenyl ureas, chloroacetanilides, dinitroanilines, phenoxys, thiocarbamates, triazines, and triazinones); two fungicides (dithiocarbamates and phthalimides); and arsenical compounds.

The ingredients (active, adjuvant, and “inert”) in those pesticides represent a variety of chemical compounds, and exposures to one — or more — of them may have any number of mechanisms of action in the human body, per se or in combination. The investigators in this study note that “pesticide exposure can induce genotoxicity, immunosuppression, oxidative stress and/or inflammatory effects, hormone receptor modulation and/or other biological responses that are important characteristics of carcinogens.” They make the case that because of this plethora of factors, individual active ingredients should be researched, as well as categories of pesticides.

The territory for research on pesticides’ potential carcinogenicity, and other impacts on human health, is almost ridiculously complicated. Yet there is some convergence across research that exposure to certain pesticides increases the risk of developing some cancers. The association that has been in a blinding spotlight for the past few years is that between exposures to glyphosate and/or glyphosate-based herbicides and risks of developing non-Hodgkin’s Lymphoma, in particular. Beyond Pesticides has covered the mounting evidence of the dangers of glyphosate; most recently, it reviewed a meta-study that suggests a compelling link between exposures to glyphosate-based herbicides and increased risk of NHL.

In addition, it has written extensively on developments in the science and regulatory arena, including:

• the IARC’s 2015 landmark designation of glyphosate as potentially carcinogenic
• evidence that the Environmental Protection Agency colluded with Monsanto (maker of Roundup, the most widely used glyphosate-based herbicide) to advantage industry, and that Monsanto had actually ghostwritten research that countered scientific conclusions on the cancer associations of the compound
• California’s 2017 listing of glyphosate under Proposition 65 as a probable carcinogen and a 2018 Appellate Court affirmation of its ability to do so

Beyond Pesticides has also tracked the falling dominoes in the glyphosate drama that is currently unfolding in the courts. In the summer of 2018, California groundskeeper Dewayne Johnson won a $289 million jury verdict against Monsanto for his development of NHL after consistent exposure to Roundup. The jury awarded him $39 million in compensatory damages, and $250 million in punitive damages, finding that Monsanto acted with “malice or oppression.” That amount was later amended by the judge to a total $78 million. Most recently, in another court case, again in California, the jury found unanimously that Edwin Hardeman’s development of NHL was substantially caused by Roundup; the case moves next to award of damages to the plaintiff. On the commercial front, insurers are beginning to balk at the liability inherent in use of these herbicides; beyond these two cases, another 8,000+ glyphosate-based suits against manufacturers, sellers, and users are in queue. In addition, localities are taking steps to protect the health of residents by reining in the use of glyphosate, as has happened recently in Montgomery County, Maryland, and Miami, Florida.

Industry will not back down easily, making it critical that voices across all sectors speak out for increased regulation of these compounds, at the very least. With all the increased attention on glyphosate and its risks, there is more reason than ever to advocate for its elimination and the advent of less toxic alternatives. Beyond Pesticides is ready to help with organizing communities; contact us. We also urge those concerned about glyphosate exposure to support organic systems that do not rely on hazardous, carcinogenic pesticides. To learn about all the reasons to “go organic” and advocate for organic integrity, see Eating with a Conscience and Keeping Organic Strong.

It is possible that the use of glyphosate is approaching a tipping point, beyond which recognition of its dangers may result in greater public demand for regulation that’s protective, and withdrawal of the products from the marketplace. Beyond Pesticides remains determined to advance the cause of human and environmental health, and looks forward eagerly to that tipping point.

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

Source: https://academic.oup.com/ije/advance-article/doi/10.1093/ije/dyz017/5382278

(Beyond Pesticides, March 25, 2019) EPA is using a regulatory loophole – the “treated articles exemption” – to allow systemic insecticides to be used in mass quantities, without regulating or labeling them as required under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). EPA does not currently assess adverse effects on the environment and public health caused by widespread use of neonicotinoid insecticides delivered through seeds coated with the insecticides, resulting in widespread exposure to one of the most environmentally damaging classes of chemicals on the market.

Tell your Congressional delegation that EPA must fully regulate treated seeds to protect the environment and public health.

Pesticide-coated seeds are now ubiquitous, yet their far-reaching impacts on wildlife and human health continue to go unregulated. The introduction and spread of seed-delivered pesticides to major field crops, beginning around 2003, caused a massive increase in total neonicotinoid use nationwide. As of 2011, 34 to 44% of soybeans and 79 to 100% of maize acres were planted with coated seeds, accounting for an astounding 35-fold increase in nationwide neonicotinoid use from baseline rates prior to 2003 (Douglas and Tooker, 2015). Alarmingly, because the national pesticide survey conducted by the National Agricultural Statistics Service fails to include seed-applied neonicotinoids, i reports give the misleading impression that neonicotinoid use has declined over the past few decades.

Seed coating technologies have dramatically altered the landscape of pesticide contamination nationwide. U.S. croplands are currently planted with roughly 3.5 million kilograms of neonicotinoid-coated seeds each year (Tooker and Douglas, 2017). On top of causing massive increases in the total extent and per-acre rate of neonicotinoid application, seed treatments increase the proportion of neonicotinoids applied that enter soil and groundwater. From 90 to 99% of active ingredient delivered through seed treatments is lost to air, soil, and water –including environmental losses caused by the release of contaminated seed dust during mechanical planting (Wood and Goulson, 2017). Neonicotinoids in seed dust can reach concentrations up to five orders of magnitude higher than their acute contact LD50 values, leading to documented mass honey bee poisonings (Wood and Goulson, 2017). Inaction by EPA has led state regulators to avoid investigating these bee deaths from exposure to dust from planting seeds treated with neonicotinoid insecticides.

Neonicotinoid-coated seeds pose far-reaching risks to wildlife, above and beyond those posed by neonicotinoids delivered in other forms. In EPA’s 2017 ecological assessment of neonicotinoids, coated seeds in particular were identified as posing the highest dietary risks to birds –exceeding the agency’s level of concern as much as 200-fold.

There is substantial evidence that neonicotinoid-coated seeds cause unreasonable harm to aquatic invertebrates – the foundation of healthy aquatic ecosystems. An EPA Aquatic Risk Assessment for imidacloprid, released in 2017, found that imidacloprid threatens the health of U.S. waterways with significant risks to aquatic insects and cascading effects on aquatic fo od webs.

In addition to threatening wildlife, the widespread use of neonicotinoid-treated seeds also puts human health at risk. The mass leaching of seed-delivered pesticides may lead to unreasonable adverse effects on public health via contamination of drinking water. Recent studies have found neonicotinoids pervasive in finished drinking water (Klarich et al. 2017; Sultana et al. 2018). Alarmingly, University of Iowa researchers found that finished drinking water frequently contains metabolites of the neonicotinoid imidacloprid that have never been evaluated for their potential risks to human and environmental health. Experts warn that these metabolites may morph further into new forms of chlorinated disinfection byproducts during routine water treatment processes, with potential for high toxicity to humans due to loss of insect specificity.

The continued under-regulation of treated seeds is in violation of EPA’s federal mandate to regulate and fully assess the risks posed by pesticides as they are commonly applied.

Tell your Congressional delegation that EPA must fully regulate treated seeds to protect the environment and public health.

Letter to your members of Congress

I urge you to tell EPA to regulate systemic insecticides as they are most commonly applied through treated seeds, in order to comply with FIFRA and adequately protect the environment and public health. The agency is currently considering public comments on this issue and your voice is critical to public health and environmental protection.

The Environmental Protection Agency (EPA) is under public scrutiny for failing to regulate pesticide-treated seeds, which by now comprise roughly 95% of total neonicotinoid use in the U.S. EPA is misusing a regulatory loophole – the “treated articles exemption” – to allow systemic insecticides to be used in mass quantities, without regulating or labeling them as required under FIFRA.

Seed coating technologies have dramatically altered the landscape of pesticide contamination nationwide. U.S. croplands are currently planted with roughly 3.5 million kilograms of neonicotinoid-coated seeds each year (Tooker and Douglas, 2017). On top of causing massive increases in the total extent and per-acre rate of neonicotinoid application, seed treatments increase the proportion of neonicotinoids applied that enter soil and groundwater. A review of the literature indicates that 90 to 99% of active ingredient delivered through seed treatments is lost to air, soil, and water –including environmental losses caused by the release of contaminated seed dust during mechanical planting (Wood and Goulson, 2017). Neonicotinoids in seed dust can reach concentrations up to five orders of magnitude higher than their acute contact LD50 values, leading to documented mass honey bee poisonings (Wood and Goulson, 2017). Inaction by EPA has led state regulators to avoid investigating these bee deaths from exposure to dust from planting seeds treated with neonicotinoid insecticides.

Treated seeds lead to unique exposures, such as through seed dust, and unique contamination of surrounding vegetation, soil, surface water and groundwater, with far-reaching consequences for wildlife and human health. The continued under-regulation of treated seeds is in violation of EPA’s federal mandate to regulate and fully assess the risks posed by pesticides as they are commonly applied.

Please tell EPA to fulfill its federal mandate and regulate pesticide-coated seeds, as they are commonly applied. Anything less falls short of adequate protection under the law.

(Beyond Pesticides, March 22, 2019) A two-year study, published March 14,  finds that field-relevant contamination with the neonicotinoid insecticide imidacloprid causes reduced body weight and metabolism in white-tailed deer, and – in fawns – mortality. Remarkably, researchers uncovered imidacloprid levels in free-ranging deer a full 3.5 times higher, on average, than the levels in the animals treated in their experiment. These new findings add to the mounting evidence of the hazards posed by current patterns of neonicotinoid use, while evidence of benefits remains sparse.

The study, published in Nature Scientific Reports, includes two years of data on the physiological and behavioral outcomes of imidacloprid contamination in 80 white-tailed deer housed in a South Dakota State University captive research facility. Notably, researchers were unable to entirely control imidacloprid levels in untreated deer, most likely due to background contamination from corn- and soy-based feed, and surrounding vegetation infiltrated by runoff from nearby agricultural fields. This background contamination altered, but did not compromise, the analysis. Researchers found that imidacloprid levels detected in the spleens of treated and control animals were significantly predictive of reduced thyroid hormone levels, shorter jawbones, lower activity levels, and higher fawn mortality.

Lead authors Elise Berheim, Jonathan Jenks, PhD, and Jonathan Lundgren, PhD, were motivated to pursue their study by the appearance of new morphological and developmental abnormalities in Northern Great Plains white-tailed deer populations over the last decade. The researchers suspected that pesticides might be to blame for some of these defects, documented at high frequencies in west-central Montana and South Dakota. Indeed, their newest findings confirm that neonicotinoids likely play a role in the documented declining health of white-tailed deer. But, adds, Dr. Lundgren, “Neonicotinoids are just one of the chemistries that these deer are being exposed to regularly in the environment, and so understanding where they fit within that range of contacts, whether there are synergisms with other pesticides, those are the important next questions.”

While open questions remain, this latest study adds yet another file in the case against the expanding and under-regulated use of systemic insecticide treated seeds, now the dominant form of neonicotinoid delivery affecting tens of millions of hectares of treated U.S. land per year. There is substantial evidence that neonicotinoids, as they are currently used, cause harm to wildlife, including mammals, as well as birds, insect pollinators and other beneficial insects, and aquatic invertebrates.

Neonicotinoids are most infamous for their well-documented role in driving mass pollinator declines. However, pollinators are far from the only victims of ubiquitous neonicotinoid contamination. In a recent avian risk assessment, EPA scientists found that neonicotinoids present in treated seeds exceeds the agency’s level of concern for certain birds by as much as 200-fold. A 2017 study by researchers at the University of Saskatchewan confirmed that tiny amounts of neonicotinoids – the equivalent of just four treated canola seeds, for example – are enough to cause migrating songbirds to lose their sense of direction and become emaciated.

Because neonicotinoids persist in soil and easily become airborne, the chemicals spread far beyond target crops and can contaminate nearby plants, soil, and water, thus posing far-reaching threats to wildlife. An EPA aquatic risk assessment for imidacloprid, released in 2017, found that imidacloprid threatens the health of U.S. waterways with significant risks to aquatic insects and cascading effects on aquatic food webs. Neonicotinoids contaminate over half of urban and agricultural streams across the U.S. and Puerto Rico, according to a report by the U.S. Geological Survey (USGS) that expands on a previous study finding the chemicals in Midwest waterways.

In keeping with these broad contamination trends, authors of the present study uncovered a disturbing degree of imidacloprid in the organs of free-ranging deer. Of the 367 deer sampled from North Dakota, 77.5% had spleen levels of imidacloprid greater than 0.33 ng/g – the mean level detected in the spleens of fawns that died in the experiment. Referring to this high degree of environmental contamination, Dr. Lundgren states, “I was surprised, absolutely, by those results… I felt like our doses were actually pretty high in the experiment – they were ecologically relevant, but they were pretty high – so to find 3.5 times the quantity of imidacloprid in wild-caught deer, that was really surprising.”

Not only were these levels shockingly high, they also increased with time, notes Dr. Jenks. The average concentration of imidacloprid in free-ranging deer increased by an average of 0.11 ng/g per year from 2009 to 2017. During that same period, nationwide use of neonicotinoids in corn, soy, and other major crops increased by more than 2.6-fold. Referencing the increasing trend of contamination, Dr. Jenks notes, “I think that’s a really interesting finding that relates to the amount of this chemical that’s been utilized in agriculture over time here.”

Treated seeds have dramatically altered the landscape of pesticide use and pesticide contamination in the U.S., yet their use goes largely undocumented and unregulated due to an EPA regulatory loophole. The introduction and spread of seed-delivered pesticides to major field crops beginning around 2003 caused a massive increase in total neonicotinoid delivery nationwide; a 2015 review of USGS survey data found that 79 to 100% of maize acres and 34 to 44% of soybeans preemptively seed-treated with neonicotinoids by 2011. As of 2014, total neonicotinoid use in the US was estimated at 3.47 million kg, representing a 46-fold increase over pre-2003 annual application rates.

Alarmingly, over that same period of rapid expansion, multiple studies have demonstrated that neonicotinoid seed treatment does little to mitigate target pests. A significant body of research, including EPA studies, have found that neonicotinoid seed treatments provide little to no benefit to farmers. An assessment published in 2018 by an international team of scientists found that an alternative insurance model could easily replace the need for farmers to purchase expensive neonicotinoid-coated seeds.

“There’s a balancing act. Risk is balanced against benefits,” Dr. Lundgren explains, referring to public perception of EPA’s pesticide registration process. Yet, he observes, “In the case of neonicotinoids, there really aren’t a lot of agricultural benefits that are realized from the use of neonics. The cost seems high but the data don’t support a lot of benefits from them. It really does beg the question of what’s acceptable and what’s not.”

Beyond Pesticides holds the position that the widespread and unchecked expansion of neonicotinoid use is unacceptable. The well-documented risks of neonicotinoid seed treatment far outweigh the unsubstantiated, and in large part disproven, claimed benefits. The time is now to demand firmer regulation of all forms of neonicotinoids, including the vast majority delivered through currently unregulated treated seeds. Act now, and tell your Congressional delegation that EPA must fully regulated treated seeds to protect the environment and public health.

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

Sources: Effects of Neonicotinoid Insecticides on Physiology and Reproductive Characteristics of Captive Female and Fawn White-tailed Deer (Nature Scientific Reports), Beyond Pesticides Interview

(Beyond Pesticides, March 21, 2019) Corporate food giant General Mills has thrown some weight behind regenerative agriculture, committing to converting one million acres of farmland to regenerative practices by 2030. Some – but not all – of the initiative involves organic land management.

Regenerative agriculture is a term with a range of interpretations, but the key element is improving soil health through carbon sequestration. Robert Rodale, one of the early proponents of organic agriculture and a major publisher, coined the name to characterize a process that moves beyond sustainable maintenance and into improvement of resources. This methodology is gaining traction in the farming world because it is economically beneficial to farmers and promotes environmental remediation. A 2018 study shows that ecologically-based farming systems have fewer pests and generate higher profits than their conventional counterparts.

“Practitioners who have done this the longest point to the fact that in extreme years, their farms will do better than those who do not,” says Jerry Lynch, General Mills’ chief sustainability officer, “After some transition time, depending on their location and cropping system, farmers are saving a lot of money because they’re using fewer inputs.”

In their press release, General Mills lays out three foci within their definition of regenerative agriculture:

1. Healthy Soil: Carbon rich, biologically active soil plays an essential role in cleaning and storing water, supporting biodiversity and regulating the climate.
2. Above-Ground Biodiversity: Diversity in crop varieties, grazing animals, wildlife and pollinators supports resilient ecosystems that can better withstand disease, pests and climate fluctuations.
3. Farmer Economic Resilience: Regenerative agriculture practices can strengthen whole farm profitability and resilience over time.

General Mills is making significant investments, including grand-scale land conversions and working with training partners. They have donated $650,000 to nonprofit organization Kiss the Ground for training and coaching. Part of their million-acre effort includes converting 34,000 acres in South Dakota from conventional farm land to organic.

Agriculture contributes, by some estimates, up to 30% of global greenhouse gas emissions. On the other hand, soil is an enormous potential area for carbon storage (a “sink”) and in fact benefits from the additional carbon structure. Healthy, carbon-rich soil stores water and erodes less, making fields more tolerant to disruptive weather such as heavy rain or drought.

There is crossover with regenerative and other agricultural movements, such as organic or no-till. In the face of “erosion” of the organic label by hydroponics and big agriculture, the Real Organic Project – a coalition of farmers and advocates – has been trying to bolster the organic label by reiterating the importance of soil in organic. “Organic Farming was defined back in its infancy as a farming method that is centered on maintaining fertile and biologically healthy soil,” states the organization’s website.

Last year, the Rodale Institute introduced a label for regenerative agriculture food using the USDA certified organic as a baseline requirement. As an add-on to the organic label, Regenerative Organic Certification (ROC) involves three pillars of soil health, animal welfare, and social fairness. Their definition of soil health includes no synthetic inputs (i.e. pesticides or fertilizers).

In another realm of regenerative agriculture, some no-till advocates, while focused on improving soil health and reducing inputs, find it difficult to move away from synthetics entirely. A Civil Eats article quotes no-till advocate and Arkansas farmer Adam Chappel, “You can’t quit [synthetic fertilizer and herbicides] cold-turkey,” but he notes that after a few years in the practice, “I don’t need seed treatments for my cotton anymore. I’ve taken the insecticide off my soybeans. I’m working toward getting rid of fungicide … I’m hoping that eventually my soil will be healthy enough that I can get rid of all of it all together.” Many programs that are dependent even on reduced pesticide and synthetic fertilizer use maintain a dependency on those toxic inputs because the soil biology is not fully supported by practices and amendments that grow the biomass and ultimately nutrient cycling.

The heavy involvement of General Mills might raise some eyebrows in a field generally dominated by small, even anti-establishment farmers and advocates. Addressing cynicism of investment by their corporate entity in organic, Carla Vernon, president of General Mills’ natural and organic business stated, “We feared the skepticism of General Mills would overshadow the good work of our natural and organic brands, but Big Food must be at the table if we are going to make a difference at scale.” [Of note, Beyond Pesticides recently won a legal settlement against General Mills regarding their misleading “100% Natural Oats” label on Nature Valley Granola Bars.]

General Mills has a bottom line that will be impacted indiscriminately by climate change and pollinator decline. Lynch states, “The trend is increased demand and coupled with a dwindling natural resource supply, and the pressure facing farming communities, we are concerned with that.”

Whatever the motive, industry involvement is significant in a growing movement. Robert Rodale remarked in a 1989 interview, “I don’t think the average person aspires to live in a sustained environment, they want to live in something that’s expanding and getting better, so I think the idea of regeneration is more appealing.” Beyond Pesticides looks forward to an expanding future of organic and regenerative agriculture.

Check out Beyond Pesticides’ Eating with a Conscience to share with those who don’t think beyond the dinner plate, but may be interested to know the effect of the chemicals used where food is grown on the environmental, people, and wildife.

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

Sources: Successful Farming, General Mills

(Beyond Pesticides, March 20, 2019) In a second verdict against Bayer/Monsanto yesterday, a jury found unanimously that a California man’s non Hodgkin lymphoma (NHL) was substantially caused by the herbicide glyphosate (Roundup). The case being heard in federal court in San Francisco now moves to the damages phase. Last August in San Francisco Superior Court, a California groundskeeper was awarded $39 million in compensatory damages, and $250 million in punitive damages in a case that linked his NHL to Monsanto’s glyphosate/Roundup. In October, the judge in the case upheld the verdict, but reduced the award to $78 million.

According to the Associated Press, the trial judge, U.S. Judge Vince Chhabira “is overseeing hundreds of Roundup lawsuits and has deemed [this case] and two others ‘bellwether trials.“ The case was brought by Edwin Hardeman of Santa Rosa, CA. He said he had been using Roundup since the 1980’s. During the trial, according to The Guardian, Judge Chhabria, “approved Monsanto’s request to prohibit Hardeman’s attorneys from raising allegations about the corporation’s conduct, saying issues about its influence on science and government were a ‘significant … distraction.’” This set up a limitation that required the plaintiff’s attorneys to focus solely on studies linking the chemical to cancer risks.

The plaintiff’s attorney, Aimee Wagstaff, told the Guardian: “The jury will hear about the science, but they won’t get to hear about how Monsanto influenced it,”  “The jury won’t have a complete understanding of the science. If we win without the jury knowing the complete science, that’s a real problem for Monsanto.”

The jury verdict in August was reported by Beyond Pesticides as a “stunning victory.” Beyond Pesticides reported at the time a statement of Beyond Pesticides’ executive director: “While we know that the jury verdict cannot restore Mr. Johnson’s health, we believe that the verdict is a clarion call to manufacturers that ignore the devastating impact that their products can have on unsuspecting workers, consumers, and families. We look forward to the day in the not-too-distant future when we recognize as a society that products like glyphosate (Roundup) are not necessary, and effective and affordable land and building management can be achieved without toxic chemicals. The case should also signal to all levels of government – local, state, and federal – that we have a social, public health, and environmental responsibility to remove toxic pesticides from use with a high degree of urgency.”

Ms. Wagstaff, working with co-counsel, Andrus Wagstaff, PC and Jennifer Moore of Moore Law Group, PLLC, said,

“Mr. Hardeman is pleased that the jury unanimously held that Roundup caused his non-Hodgkin’s lymphoma. Now we can focus on the evidence that Monsanto has not taken a responsible, objective approach to the safety of Roundup. Instead, it is clear from Monsanto’s actions that it does not particularly care whether its product is in fact giving people cancer, focusing instead on manipulating public opinion and undermining anyone who raises genuine and legitimate concerns about the issue. We look forward to presenting this evidence to the jury and holding Monsanto accountable for its bad conduct.”

Despite the prevalent myth that this widely-used herbicide is harmless, glyphosate (N-phosphono-methyl glycine) is associated with a wide range of illnesses, including NHL, genetic damage, liver and kidney damage, endocrine disruption, as well as environmental damage, including water contamination and harm to amphibians. Researchers have also determined that the “inert” ingredients in glyphosate products, especially polyethoxylated tallow amine or POEA —a surfactant commonly used in glyphosate and other herbicidal products—are even more toxic than glyphosate itself. Monsanto, manufacturer of glyphosate, formulates many products such as Roundup™ and Rodeo™ and markets formulations exclusively used on genetically engineered (GE) crops. Glyphosate, one of the most widely used herbicides in the world, due in large part to the increased cultivation of GE crops that are tolerant of the herbicide.

Since EPA’s classification of glyphosate as a Group E carcinogen—or “evidence of non-carcinogenicity for humans,” the International Agency for Research on Cancer (IARC) in 2015 classified glyphosate as a Group 2A “probable” carcinogen, which means that the chemical is probably carcinogenic to humans based on sufficient evidence of carcinogenicity in experimental animals. As of July 7, 2017, glyphosate is listed as a cancer-causing chemical under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). This requires cancer warning labels be placed on end-use glyphosate products in California.

Newer scientific studies have also looked in greater depth at glyphosate’s mode of action and the implications for human and ecological health. Glyphosate works by disrupting a crucial pathway for manufacturing aromatic amino acids in plants—but not animals—and, therefore, many have assumed that it does not harm humans. However, many bacteria do use the shikimate pathway, and 90 percent of the cells in a human body are bacteria. The destruction of beneficial microbiota in the human gut (and elsewhere in and on the human body) is, therefore, a cause for concern—and a major contributor to disease. In addition, the destruction of soil microbiota leads to unhealthy agricultural systems with an increasing dependence on agricultural chemicals. Assessing the mode of action of glyphosate, scientists have found that it starves and sickens the very crop plants that it is supposed to protect. It is dangerous to base the review of chemicals on the assumption that microbiota is irrelevant to assessing dangers.

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

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

Source: The Guardian, Associated Press, U.S. Right to Know

(Beyond Pesticides, March 19, 2019) Research is beginning to explain how systemic neonicotinoid insecticides affect often overlooked species of ground nesting bees. While much of the current scientific literature has focused on the impacts of pesticides to bumblebees and honey bees, a study, Chronic contact with realistic soil concentrations of imidacloprid affects the mass, immature development speed, and adult longevity of solitary bees, recently published in Scientific Reports, confirms that wild, soil-dwelling bees are at similar risk. As policy makers consider ways to protect pollinators, this research finds that uncontaminated soil is an important aspect of ensuring the health of wild, native bees.

“This is an important piece of work because it’s one of the first studies to look at realistic concentrations of pesticides that you would find in the soil as a route of exposure for bees,” said Nick Anderson, co-author of the study. “It’s a very under-explored route, especially for some of the more solitary species that nest in the ground.”

In order to study the impact of neonicotinoids on ground nesting bees, researchers used orchard mason bees and leafcutter bees as proxies, as they are easier to gather and rear in the lab, and have a similar ecology to ground nesting species. Roughly 300 bees of each species were taken into the lab as larva, and exposed every 48 hours to either 7.5, 15, or 100 ppb of the neonicotinoid imidacloprid. A control with no exposure was also established as a baseline. The authors explain that these amounts represent realistic exposure patterns that wild bees are likely to encounter in soil.

Researchers monitored the bees every day until they reached adulthood, recording longevity, development speed, and mass. Results show that male and female bees have different reactions to exposure. Female mason bees subject to the highest concentrations of imidacloprid live much shorter lives than those unexposed, while the authors had difficulty determining effects on male bees due to an equipment malfunction. Male leafcutter bees actually lived longer than control bees, but developed much faster and to a smaller size than bees not exposed to a pesticide. Female leafcutter development appeared to depend on the concentration of exposure, with the 15ppb group developing slower than other treatment levels and the 100ppb group developing two days faster than control bees.

The changes are likely a result of a hormetic response by the pollinators. This is a phenomena that results from exposure to pesticides; changes in development occur in order to compensate for energy the bee diverts into physical and biological protections from pesticide exposure. This has important implications for the long term health of ground-nesting bees. Any change in development that distracts or alters normal functioning can affect fitness in the field.

Previous research on the environmental fate of neonicotinoids shows that they have the potential to remain in soil from 200 days to as long as 19 years. This means that the type of chronic exposure tested in the current study could occur years or even a decade after an initial pesticide application. Although scientific literature on wild pollinators is limited, past research on mason bees revealed 50% reduced total offspring and a significantly male-biased offspring sex ratio.

The pollinator crisis is broader than honey and bumble bees, and extends not only to native, ground nesting bees but also butterflies and birds. The New York Times has identified the precipitous decline in insect populations over the past several decades as an insect apocalypse.

While bombastic “apocalyptic” language may be criticized for stoking panic and fear, even these warnings have been generally ignored by many policy makers, begging the question of what it will actually take in order to get action on this critical issue. We need to protect not only honey bees, but the wide diversity of native pollinators in order to maintain agricultural production, floral resources, and other ecosystem services that enable our environment, and ultimately human civilization to thrive.

U.S. Representatives Earl Blumenauer, Jim McGovern, and the 33 current cosponsors of the Saving America’s Pollinators Act are listening to these warnings, and have introduced legislation that would substantive address the threats pesticides pose to pollinators. But in order for change to happen, we need a significant outpouring of public support in favor of this proposal. Take action today by urging your member of Congress to cosponsor SAPA. And if you’re also interested in working on this issue in your state or local community, contact Beyond Pesticides at [email protected] or 202-543-5450.

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

Source: University of Illinois Press Release, Scientific Reports (peer reviewed journal)

(Beyond Pesticides, March 17, 2019) Forget about single-pesticide issues: this affects every single one of them. EPA is allowing massive data gaps to persist for each and every pesticide product it registers by conducting the bulk of its health and environmental risk assessments using active ingredients alone. With its current practices, EPA is failing its federal mandate to protect public health and the environment and misleading the public about what is “safe.”

Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients.

When pesticides are sprayed on our crops, lawns, and roadsides, and enter into our waterways, groundwater and drinking water, we are exposed to whole formulations, whole tank mixtures, and whole pesticide combinations, not just active ingredients (those that the manufacturer claims are the only ingredients that attack the target pest). It is the whole formulation that makes the poison, and that whole formulation must be regulated.

Active ingredients are far from the whole story of pesticide poisoning. Despite their name, “inert” ingredients are very often not chemically, biologically, nor toxicologically inert or innocuous. According to a peer-reviewed study, as of 2006, more than 500 ingredients that were listed as “inert” in some products serve as the active ingredient in other products. Many “inert” ingredients are known to state, federal, and international agencies to be hazardous to human health. One of the most hazardous ingredients in common formulations of the popular herbicide Roundup is a surfactant, which is classified as an “inert,” and therefore not listed on the label. A 2013 study found that some Roundup adjuvants are 9,661 times more toxic to human cells than the active ingredient glyphosate. The real threats of herbicides, fungicides, and insecticides are masked when EPA only tests active ingredients.

Synergy between ingredients adds yet another layer to the stack of untested threats. Ingredients added to formulations are specifically selected for their ability to make the active ingredient more potent, yet these effects are ignored in the vast majority of EPA-required testing. A 2016 Center for Biological Diversity (CBD) Investigative report found that 69% of recently approved pesticide patent applications claimed or demonstrated synergy between ingredients in the product.

Based on EPA’s current policies, the agency does not require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor does it require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.

To put it another way: EPA has no idea whether the pesticide products it registers and claims pose an “acceptable risk” could cause cancer, chronic disease, developmental delays, or infertility. EPA has no idea whether the pesticide products it registers could harm or kill birds, fish, aquatic invertebrates, or honey bees. These data gaps are alarming and unacceptable, and a misinterpretation of the law.

Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients.

If you have a moment, please take a few minutes to navigate to EPA’s public comment page and tell EPA directly that it must require whole mixture testing. By clicking on ‘Comment Now!’ you can become part of the official decision-making process in this critical, far-reaching issue. See below for suggested comments (which you can cut-and-paste into the EPA docket), or personalize your own.

(Suggested Comment):

I am writing in support of the policy amendments detailed in the petition, “Seeking Revised Testing Requirements of Pesticides Prior to Registration,” Docket # EPA-HQ-OPP-2018-0262-0001.

Whole pesticides must be tested across all areas of toxicity in the same form in which they are commonly applied, in order to comply with FIFRA and adequately protect the environment and public health.

Based on published policies (40 C.F.R § 158.500-660), EPA does not currently require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor does it require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.

By requiring only the active ingredient for the majority of pesticide risk assessment tests, EPA is failing to adequately protect against known widespread hazards of “inert” ingredients and their synergistic effects on whole pesticide toxicity.

EPA must fulfill its federal mandate and test whole pesticide formulations and mixtures, as they are commonly applied. Anything less falls short of adequate protection under the law.

Sincerely,

(Beyond Pesticides, March 15, 2019) Beyond Pesticides and others have worked for many years to educate stakeholders and policy makers about the dangers of pesticides, and to transform pest management by eliminating a reliance on toxic pesticides and advancing organic management practices. Considerable focus has been on glyphosate, which is used in several herbicides, most notably in Bayer’s (then Monsanto’s, until its 2018 purchase by Bayer) Roundup. The compound has had a relatively high profile in the pesticide landscape, due in part to the ubiquity of its use, and in part to the tireless work of health and environmental advocates and scientists to expose its risks. With that profile, glyphosate has been a bit of a stand-in for the dangers of pesticides broadly. As journalist Carey Gillam said at Beyond Pesticides’ 36th National Pesticide Forum in 2018, “Glyphosate is the poster child for the bigger pesticide problem. . . . If it goes away tomorrow, we are [still] not okay.”

The variety of risks this compound poses is broad, and pushback and risk evidence on its use come from multiple sides. This Daily News Blog focuses on recent developments on several of those fronts, all of which advanced knowledge and momentum, and could spell more trouble for the future of this toxic herbicide.

First up: Harrell’s is a company that sells chemical pesticides, synthetic fertilizers, and “adjuvants and colorants,” among other products, primarily to golf courses, and to the horticulture-nursery, turf, and landscape sectors. The company announced on March 11 that it stopped selling products containing glyphosate as of March 1, 2019 because neither its current insurance company nor others the company consulted would underwrite coverage for the company for any glyphosate-related claims. This follows the successful and landmark glyphosate case in 2018 of DeWayne Johnson v. Monsanto Company. The insurers’ decision also recognizes the additional 8,000+ glyphosate-based suits against manufacturers, sellers, and users that are in queue — many of them aimed at glyphosate’s carcinogenicity. A meta-study in February 2018 concluded that there is a “compelling link between exposures to GBH [glyphosate-based herbicides] and increased risk of NHL [non-Hodgkin’s Lymphoma].”

Harrell’s CEO’s statement included this: “During our annual insurance renewal last month, we were surprised to learn that our insurance company was no longer willing to provide coverage for claims related to glyphosate due to the recent high-profile lawsuit and the many thousands of lawsuits since. We sought coverage from other companies but could not buy adequate coverage for the risk we would be incurring. So we had no choice other than to notify our Harrell’s Team and customers that we would no longer offer products containing glyphosate.”

The announcement stands in contrast to what Fox Business identified shortly after the verdict in the Johnson v. Monsanto case. That article reported that, “Top U.S. retailers such as Home Depot, Target, Walmart and Amazon are sticking by Monsanto’s controversial weedkiller Roundup one week after a California jury awarded a school groundskeeper $289 million for proving the spray caused him to develop non-Hodgkin’s lymphoma.” Indeed, insurer (and perhaps re-insurer) concern may well increase in light of the firehose of lawsuits glyphosate use has triggered.

This move on insurers’ part is a big deal. Weber Gallagher, a law firm that works on defense for many corporations and industries, anticipated the implications of the 2018 landmark California case when it commented, very shortly after the verdict, in an article on its website titled, “Big Monsanto Loss Signals Glyphosate Litigation Headache for Policyholders, Insurers and Reinsurers.” The concluding text was this: “Without a doubt, like all other mass tort litigation (asbestos, environmental, toxic tort), the issues raised by current and inevitable future glyphosate lawsuits present overwhelming exposures for policyholders, insurers and reinsurers on such key issues such as trigger of coverage, number of occurrences, allocation of loss and the insurability of punitive damages. One only has to ask regarding who is going to pay for last month’s Monsanto verdict to understand the enormity of the issue.” If this is the first in a series of dominoes to fall, it could spell disaster for Bayer’s product.

The next development of note adds to the scientific evidence of functional health impacts of glyphosate in mammals. A recent study by Fabiana Manservisi, Corina Lesseur, et al., published in Environmental Health on March 12, investigated impacts of glyphosate-based herbicides on development and endocrine systems in rats. Two groups of Sprague Dawley rats (a variety commonly used in research) were exposed to the rat equivalent of the U.S. human ADI (Acceptable Daily Intake) of, respectively, glyphosate or a glyphosate-based herbicide (such as Roundup), beginning in utero and continuing through adulthood. Impacts of exposures at these “safe” levels nevertheless induced endocrine impacts (e.g., distorted hormone levels) and anomalous reproductive morphology (with a skew toward androgen-like effects in both sexes, but especially in females). Of particular note is that exposure to the glyphosate formulation (Roundup Bioflow) evinced more, and more-pronounced, effects than glyphosate itself. The study adds to the evidence that exposure to glyphosate, particularly in the matrix of other ingredients in formulations such as Roundup, is associated with endocrine disrupting and reproductive impacts.

Finally, on March 1 the City of Miami established a ban, which went into immediate effect, on the use of any glyphosate-based herbicides (including Roundup compounds) by the city and any of its contractors. This follows an earlier proscription by the city of glyphosate use in any city or contracted landscape and maintenance activities; it also follows bans by other Florida cities, including Miami Beach and Stuart, that have already stopped the use of glyphosate products.

One of Miami’s City Commissioners, Ken Russell, commented on the move: “Water quality issues are so important to the city of Miami, and we can be one of the worst polluters as a municipality. We ask for residents to make a change in their habits and that they be conscious of what they put in their gardens, but when I realized the totality of what the city uses at any given time, we had to change our habits.” Local water advocacy group Miami Waterkeeper lauded the move, saying, “Banning the use of glyphosate is a great first step to take in improving water quality. It is also beneficial to public health, as citizens of the city of Miami won’t be exposed to harmful chemicals.”

Pesticides and herbicides, including the extremely popular glyphosate-based Roundup compounds, represent health risks beyond direct and indirect terrestrial exposures; they also get into waterways. Water quality is a huge issue in much of Florida, given its extensive coastline, low-lying land mass, and extremely high water table. Much of the state’s drinking water sources, as well as its ocean waters, are under assault from a variety of threats, including: agricultural runoff of pesticides, herbicides, fungicides, and fertilizers (the last of which contribute mightily to toxic algal blooms from excess nutrients dumped into freshwater bodies or oceans); use of pesticides and herbicides to manage turf (parks, playing fields, and — this being Florida — golf courses); and dumping of partially or poorly treated sewer effluent into the ocean, contributing to the development of so-called “dead zones” offshore — areas of low-oxygen caused by nutrient pollution from human activity. A year ago, the Florida Legislature approved a plan to allow the dumping of “treated” sewage into the Biscayne aquifer — the primary source of Miami’s drinking water. The hurdles to improved public health and environmental integrity are very often political.

Momentum in the effort to constrain use of glyphosate-based herbicides — in the wake of the landmark California decision and the many other pending suits, and the mounting scientific evidence of the dangers of glyphosate — may be gaining. Beyond Pesticides will continue to monitor developments, which are easy to track via its Daily News Blog and its journal, Pesticides and You. Though the transition to a system of pest management that does not rely on toxic chemicals likely represents a slog against the entrenched and monied chemical industry, calls to restrict or eliminate glyphosate’s use are mounting nationally and globally, and recent developments may signal that glyphosate’s days are numbered. Beyond Pesticides will work tirelessly for its final elimination from use and a transition to pest management approaches that do not threaten human or environmental health.

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

Sources: https://www.turfnet.com/news.html/harrells-discontinues-sale-of-products-containing-glyphosate-r1196/ and https://ehjournal.biomedcentral.com/articles/10.1186/s12940-019-0453-y#Sec16 and https://www.miaminewtimes.com/news/city-of-miami-bans-use-of-herbicides-containing-glyphosate-11100953

(Beyond Pesticides, March 14, 2019) A study, supported by the USDA’s National Institute of Food and Agriculture, finds that state pesticide preemption laws “compromise public health and economic well-being” by preventing localities from enacting pesticide use restrictions on private property that are more restrictive than their state’s regulations. In the words of the authors, “By eliminating the ability of local governments to enact ordinances to safeguard inhabitants from health risks posed by pesticides, state preemption laws denigrate public health protections.”

The study, Anti-community state pesticide preemption laws prevent local governments from protecting people from harm, published in the International Journal of Agricultural Sustainability, reviews scientific and historical evidence of the failure of state and federal pesticide laws to protect localities from pesticide poisoning, and highlights the inability of localities to compensate for that failure under present laws. Communities seeking to protect their residents would typically issue community-wide restrictions to ensure protection of shared community resources, including air, land, and waterways, from pesticide drift, runoff, and other nontarget effects —as is the case with other community decisions on recycling, smoking, and zoning. The study’s authors document how industry influence led to the adoption of state laws that undermine the ability of localities to enact protective pesticide standards they determine are necessary to protect public health and the environment. In the absence of this broad public and environmental health authority, localities focus on the management of public property, including parks, playing fields, schools, and rights-of way.

Drawing on Beyond Pesticides’ research and long-standing involvement in this issue, as well as other independent studies, the authors trace the history of state preemption. In 1991, the Supreme Court decision in Wisconsin Public Intervenor vs. Mortier affirmed the right of  local governments to restrict pesticides on private and public property under federal pesticide law, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), with federal and state law serving as a floor for minimum protective standards. However, over several years beginning in 1993, groups representing industry successfully lobbied state legislatures in 43 states to override local authority. In the words of the study authors, “For the past 50 years, agricultural interest groups have supported anti-community preemption laws covering a variety of topics because they interfered with business arrangements and tended to increase costs.”

Currently, twenty-nine states have explicit preemption, and only six states are free of state preemption law. Most of the state laws defining preemption use nearly identical preemption language that explicitly preempts local authority. Most states’ preemption clauses read similar to the American Legislative Exchange Council’s (ALEC) Model State Pesticide Preemption Act, which states,

“No city, town, county, or other political subdivision of this state shall adopt or continue in effect any ordinance, rule, regulation or statute regarding pesticide sale or use, including without limitation: registration, notification of use, advertising and marketing, distribution, applicator training and certification, storage, transportation, disposal, disclosure of confidential information, or product composition.”

The authors cite previous work by their own as well as other research groups, finding that the most frequent justification for these state preemption laws is the desire for “economies of scale,” centralizing control and thereby minimizing “costly administrative redundancy.” Based on evidence of industry influence over state policies, the researchers hold the position that these justifications are a guise for more perverse economic motivations.

Another common justification for state preemption laws, put forward for example by ALEC, is that state control prevents localities from electing less restrictive or less protective policies. Authors note that this position is false, as localities would still have to follow federal law, thus precluding the establishment of less protective local laws.

The study delivers the clear message that when it comes to protections, more expansive local authority is actually needed. In their discussion, the researchers highlight several specific areas of pesticide regulation that demonstrate a clear need for local restrictions to increase protections. Citing the 2017 EPA decision to forgo revoking chlorpyrifos tolerances, for example, authors suggest that localities should be able to enact protections to prevent local exposure to one of the most neurologically toxic pesticides on the market.

Researchers highlight the need for protective policies that account for geographic and demographic conditions unique to a given locality. Referencing the endocrine disrupting effects of atrazine-contaminated drinking water on pregnant women and fetuses, for example, the authors argue that communities with young families should have the authority “to safeguard pregnant mothers from the risks of preterm delivery” by setting their own restrictions. Similarly, chlorpyrifos bans are particularly important for localities dominated by agricultural land, where use is still prevalent. Chlorpyrifos was banned from residential use in 2000, but because of ongoing farm use of this potent brain-damaging chemical, communities in rural, agricultural areas are still heavily exposed.

As the discussion makes clear, the impact of repealing state preemption laws, or preventing their further spread, would be far-reaching. Localities could enforce stronger protections for pollinators by enforcing stricter restrictions of neonicotinoids, for example. Local jurisdictions could ban the use of glyphosate based on extensive evidence for its link to non-Hodgkin lymphoma. Rural districts where farmers are suffering losses due to herbicide drift could enact stricter limits on the use of herbicides such as dicamba.

Indeed, in those few states that do not restrict locality authority over pesticide use, there are classic examples of a democratic decision making process yielding increased public health and environmental protections. A number of localities have restricted pesticide use on public and private property. Montgomery County recently banned the use of glyphosate-based herbicides in parks, in advance of a complete ban throughout the community. A 2015 Montgomery County ban limits allowable turf management pesticides (on public or private property within the county’s jurisdiction) to those permitted for use in organic production, or identified by the Environmental Protection Agency (EPA) as “minimum risk pesticides” under FIFRA.  Takoma Park, a city within Montgomery County, passed a similar ordinance in 2013, as did Ogunquit, Maine in 2014. South Portland, Maine followed Ogunquit by roughly a year, as did Portland, Maine (2018) in passing an ordinance quite like Montgomery County’s 2015 “public and private” ban. And where local authority is limited, communities are taking action to restrict pesticide use on public land. In September 2018, Miami Beach instituted a ban, similar to bans in dozens to communities nationwide, on any use of glyphosate-based herbicides by city employees and contractors in landscaping and maintenance work on all city-owned properties.

Working with local elected officials nationwide, and in collaboration with other organizations, Beyond Pesticide successfully pushed to remove a provision in the 2018 Farm Bill that would have amended FIFRA to preempt local jurisdictions from restricting pesticides. This protects the status-quo, as many states consider repealing preemption law in their states. In 2017 in the state legislature of Maine, a state that affirms local authority to restrict pesticides community-wide, the chemical industry unsuccessfully pushed to institute preemption and take away local authority that numerous jurisdictions have exercised.

Beyond Pesticides looks toward a future when federal, state, and local governments are all accountable to the people they serve; when pesticide use across the board is recognized as unacceptably hazardous; when agrochemicals are rendered unnecessary due to the regeneration of healthy soils and resurgence of beneficial insect and microbial communities brought about by the widespread adoption of organic practices; when health is a right and not a choice for some. As a step toward that endpoint, localities must be able to build the models we need to follow nationally and globally to ensure our future on this planet.

Join Beyond Pesticides in advocating for local authority to enact stronger protections against pesticide use. Inform yourself of your own state’s preemption status by consulting our State Preemption Law page, and stay abreast of the latest updates by following the Beyond Pesticides Daily News Blog.

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

Source: Anti-community state pesticide preemption laws prevent local governments from protecting people from harm. Centner and Heric, 2019.

(Beyond Pesticides, March 13, 2019) A study on the impact of two neonicotinoid pesticides shows differential gene expression in bumblebees (Bombus terrestris) after exposure. Considering the current worldwide plight of insects, the authors of point to the cutting edge research as both a reason and a methodology to more carefully examine the effects of pesticides.

“Caste- and pesticide-specific effects of neonicotinoid pesticide exposure on gene expression in bumblebees” was published in the journal Molecular Ecology in early March. Researchers fed variable colonies with clothianidin or imidacloprid-laced sucrose. They analyzed gene expression in the heads of worker bumblebees and colony queens using RNA sequencing (RNA-seq), inspired by biomedical techniques. This approach allowed for new insight on what genes and pathways are affected by neonicotinoid exposure.

Study author Yannick Wurm, PhD, stated in a press release, “Our work demonstrates that the type of high-resolution molecular approach that has changed the way human diseases are researched and diagnosed, can also be applied to beneficial pollinators. This approach provides an unprecedented view of how bees are being affected by pesticides and works at large scale. It can fundamentally improve how we evaluate the toxicity of chemicals we put into nature.”

Clothianidin had a stronger impact on bumblebee colonies, changing the expression of 55 genes in worker bees and 17 genes in queens. The affected genes are involved in important biological processes such as mitochondrial function. Researchers noted with interest that there was almost no overlap between the genes that were impacted in queens versus workers. Comparatively, imidacloprid altered expression of only one gene in workers. The divergent effects of these two similar pesticides indicates distinct genetic mechanisms of toxicity.

Previous studies of neonicotinoids have found sublethal effects on bee learning and memory, cognition and problem solving, motor function, foraging performance, navigation abilities, and immune system – but have not delved deeply into the genetic process by which these deleterious effects occur.

“While newer pesticide evaluation aims to consider the impact on behaviour, our work demonstrates a highly sensitive approach that can dramatically improve how we evaluate the effects of pesticides,” says Dr. Wurm.

This study focuses on one type of bumblebee and finds diverse impacts, even within a colony. The novel finding highlights how little is known about the effects of pesticides on various insects. Lead author Joe Colgan, PhD, stated, “We examined the effects of two pesticides on one species of bumblebee. But hundreds of pesticides are authorised, and their effects are likely to substantially differ across the 200,000 pollinating insect species which also include other bees, wasps, flies, moths, and butterflies.”

The European Union banned the use of neonicotinoids in 2018, but these pesticides are still widely used in the U.S. and elsewhere. Beyond Pesticides holds the position that we must commit to complete transformation of our agricultural system if we hope to stave off the dire fate of total, devastating insect decline.

Beyond Pesticides is a resource for activists pushing to end pesticide use and adopt least-toxic, organic practices. Join the movement to end destructive pesticide use by engaging at the local, state and federal levels to transform our agricultural system. Our tools for change serves as a resource to help individuals organize their communities.

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

Sources: Queen Mary University of London, EcoWatch

(Beyond Pesticides, March 12, 2019) Fifty years after the end of the Vietnam War, the Agent Orange byproduct dioxin continues to contaminate Vietnam’s soils and wildlife, and subsequently affect human health. In their review, scientists at Iowa State and the University of Illinois focus on the locations where hot spots and contaminated sediments have persisted after 130,000 fifty-five gallons drums of toxic herbicides were sprayed over Vietnam’s farm fields and jungle canopies during the war.

“Existing Agent Orange and dioxin research is primarily medical in nature, focusing on the details of human exposure primarily through skin contact and long-term health effects on U.S. soldiers,” says Ken Olson, PhD, co-author on the article. “In this paper, we examine the short and long-term environmental effects on the Vietnamese natural resource base and how persistence of dioxin continues to affect soils, water, sediment, fish, aquatic species, the food supply, and Vietnamese health.”

While public attention has generally focused on the “rainbow herbicides,” such as Agent Orange, used during the Vietnam war, it is the dioxin TCDD (2,3,7,8 tetrachlorodibenzodioxin), a byproduct of Agent Orange’s manufacturing process, that has caused the most lasting damage within the country. While the breakdown period for Agent Orange herbicides 2,4-D and 2,4,5,-T can be measured in months, TCDD can persist for decades and likely even centuries in water sediments and jungle soils. And the chemical, one of the most toxic man-made substances on earth, can cause significant health impacts and birth defects at levels as low as parts per trillion.

Herbicide applications occurred throughout Vietnam’s jungle canopy, as part of U.S. efforts to eliminate cover for Viet Cong soldiers. But according to researchers, over 40% of herbicides used during the war were sprayed on farm fields in attempts to destroy the food of opposing troops. These farms were owned primarily by civilians, resulting in famine, malnourishment and other lasting damage to agricultural regions of the country.

“The pathway begins with the U.S. military spraying in the 1960s, absorption by tree and shrub leaves, leaf drop to the soil surface (along with some direct contact of the spray with the soil), then attachment of the dioxin TCDD to soil organic matter and clay particles of the soil,” author Wright Morton, PhD, indicates.

Rains and other factors then move this contaminated soil off-site, into marshes, rivers, lakes, streams, and other wetland areas. TCDD dioxin is then taken up by aquatic benthic organisms like shrimp and fish. Accumulating in fatty tissue, it moves up the food chain and eventually becomes a hazard for public health. Although there are widespread fishing bans in Vietnam, fish represent a significant source of food and protein for many in the country, and despite the risks, the bans are difficult to enforce.

Researchers also identified specific hot spots where TCDD dioxin contamination presents particularly pronounced risks. “The worst dioxin-contaminated site in Vietnam is Bien Hoa airbase, which is 30 miles north of Ho Chi Minh City,” Dr.Olson says. “After President Nixon ordered the U.S. military to stop spraying Agent Orange in 1970, this is the site where all the Agent Orange barrels remaining in Vietnam were collected. The barrels were processed and shipped to Johnston Island in the Pacific Ocean, where they were incinerated at sea in 1977.”

Researchers indicate that incineration remains the only truly effective measure to eliminate dioxin contamination from soils. The process is costly, requiring significant resources, labor, and construction equipment, but is the prevailing method used in environmental clean-up. Many superfund sites in the U.S. are addressed through this method, for example. According to the study, there are ten U.S. air force bases that are in need of this level of remediation.

As this study shows, in many ways the Vietnam War is still being fought. Not only are the Vietnamese people still being impacted by horrific birth defects and other health effects caused by dioxin exposure, U.S. service members that applied Agent Orange or even simply used aircraft that once stored drums of the chemicals are still fighting for compensation.

The Vietnamese government has recently gone after Monsanto (now Bayer’s Monsanto), demanding that the company pay damages to victims of TCDD dioxin contamination. As the study shows, there are significant costs that continue to be borne by the people that both Bayer’s Monsanto and the U.S. government have a responsibility to address.

For more information about the legacy of Agent Orange, see previous Daily News stories on the issue, or view Beyond Pesticides’ Pesticide Induced Diseases Database. Help veterans in your community by supporting veteran owned businesses and nonprofit organizations. Veterans looking to go into the organic industry after their service can explore Rodale Institute’s Veteran farmer training program.

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

Source: University of Illinois Press Release, Scientific Research (peer-reviewed journal)