(Beyond Pesticides, September 20, 2023) Higher concentrations of a pyrethroid metabolite (3-PBA) in the body have an association with increased osteoarthritis (OA) risk among US adults, according to a study published in BMC Public Health. Regardless of analysis sensitivity and population subgroup (e.g., sex, socioeconomic status, etc.), the association between pyrethroid exposure and OA remains. Osteoarthritis is a degenerative joint disease resulting from the degradation (breakdown) of joint cartilage and underlying bone. This disease affects 1 in 7 U.S. adults and is the fourth leading cause of disability in the U.S. Unfortunately, OA is one of the most recently attributed pesticide-induced diseases associated with this dangerous class of chemical insecticides—harm to individual Americans that the U.S. Environmental Protection Agency (EPA) is not considering when it registers pesticides.

To remedy the significant deficiencies in EPA’s reviews and protect residents from chronic disease, more and more communities are transitioning to safer, organic pest management practices that do not require pyrethroids and other toxic synthetic pesticides. Thus, this study and others like it highlight the need for increased monitorization of pyrethroid exposure among the general population.

Using data from the 1999–2002 and 2007–2014 National Health and Nutrition Examination Survey (NHANES), this study explores the relationship between pyrethroid exposure and osteoarthritis. NHANES is a long-running monitoring program that began in the early 1960s and has since become a continuous program focused on American health and nutrition measurements. The researchers gathered urine samples from the participants, with 650 out of the 6,523 participants having OA, and examined the samples for levels of 3-phenoxybenzoic acid (3-PBA), the primary metabolite of pyrethroids. Multivariable logistic regression models allowed researchers to investigate the association between pyrethroid exposure and OA. The results demonstrate that the higher the levels of urinary 3-PBA, the greater the odds of OA in U.S. adults, highlighting the importance of routinely monitoring pyrethroid exposure among the general population.

Synthetic pyrethroids are one of the most frequently detected chemicals in Americans’ bodies. Prior NHANES data shows that 78 percent of adults and 79 percent of children have some level of 3-PBA in their urine. Avoiding pyrethroid exposure can be difficult as synthetic pyrethroids are increasingly the first choice for mosquito management in many communities nationwide. These chemicals have increasingly replaced organophosphate insecticides in homes, food production, local parks, and playing fields. Often characterized by the chemical industry as “safe as chrysanthemum flowers,” they are less acutely toxic than organophosphates. Still, it is increasingly evident that they pose insidious, chronic risks to health that are no less concerning than the hazardous pesticides that came before them. Beyond Pesticides urges government agencies to avoid using these insecticides, primarily because of the risk to young children, pregnant mothers, and communities of color already exposed to disproportionate pesticide use. At the same time, a 2021 study finds that disease-carrying mosquitoes are found at higher rates in lower socioeconomic areas, and a study published earlier 2022 finds that children’s exposure to pyrethroid mosquito control operations is associated with significant increases in the risk of allergies and respiratory diseases. Much of this exposure can occur from a diet laden with these toxic pesticides. However, those who switch from a conventional to an organic diet can significantly reduce the amount of pesticide in their body, as evidenced by drastic drops in urinary 3-PBA after going organic. In fact, children who eat organic are more likely to score higher on cognitive tests than those who consistently eat conventional, pesticide-contaminated food. However, for many low-income and Black, Indigenous, and People of Color (BIPOC) communities around the country, eating organic is not likely to limit all exposures. In public housing, synthetic pyrethroids are often used as insect sprays for common household pests that would not have been a problem with proper building maintenance and upkeep. Research finds that, after sprayed, synthetic pyrethroids can remain on surfaces for up to a year, representing a continuous source of re-exposure. This data tells a story of low-income communities and children being sprayed more often and placed at greater risk due to a lack of investment in maintenance and infrastructure that would prevent pest problems before they begin.

This study is one of the first to identify the association between chronic exposure to pyrethroids and OA. The study suggests pyrethroids’ adverse impact on thyroid hormones plays a significant role in OA development, affecting cell secretions of cartilage and enzyme activity in joints. Additionally, a study within the last year by the same researchers found that pyrethroids are also associated with rheumatoid arthritis (RA). This autoimmune disease causes systemic inflammation throughout the body, progressively damaging an individual’s joints. Thus, exposure to pyrethroids can induce co-occurring impacts on the skeletal structure through autoimmune disruption and degenerative disease, making it possible to have both OA and RA. Like past studies, this study suggests possible sex-specific effects from pyrethroid exposure, especially among men. However, this study shows pyrethroids and their metabolites may have anti-estrogenic activity in humans, further implicating potential endocrine (hormone) disruption from exposure. The anti-estrogenic activity can lead to type II collagen degradation and structural changes in the joints of exposed females.

With many diseases in the U.S. associated with pesticide exposure, reducing pesticide use is critical to safeguarding public health and addressing cost burdens for local communities. Policies should enforce stricter pesticide regulations and increase research on the long-term impacts of pesticide exposure. Beyond Pesticides tracks the most recent studies on pesticide exposure through our Pesticide-Induced Diseases Database (PIDD) and Daily News Blog. The adverse health effects of pesticide exposure and the aggregate risk of pesticides showcase a need for more precise research surrounding occupational and residential pesticide exposure to make complete determinations and the importance of fully recognizing uncertainty in precautionary regulatory decisions. Existing information, including this study, supports the clear need for a strategic shift away from pesticide dependency. For more information on pesticide-related illnesses, see PIDD pages on immune system disorders, including arthritis.

Arthritis disease has no cure, but preventive practices like organics can eliminate exposure to toxic arthritis-inducing pesticides. Organic agriculture represents a safer, healthier approach to crop production that does not necessitate pesticide use. Beyond Pesticides encourages farmers to embrace regenerative, organic practices. A compliment to buying organic is contacting various organic farming organizations to learn more about what you can do. 

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

Source: BMC Public Health

(Beyond Pesticides, September 19, 2023) Farmworkers in Paarl, South Africa took to the streets on Friday, September 8, demanding an end to the indiscriminate importation and use of pesticides, herbicides, and fungicides containing substances prohibited by the European Union (EU). This protest is part of a broader global trend of outcry against systemic issues of environmental racism that disproportionately burden communities with environmental and health risks.  

Organized by the Women on Farms Project, the protesters marched to the headquarters of Bayer. The German pharmaceutical, biotechnology, and pesticide company, responsible for producing and exporting agrochemicals known to be toxic to ecosystem and human health, has previously faced multiple lawsuits, including a multimillion-dollar one linking their glyphosate weed killer products (Roundup®) to non-Hodgkin Lymphoma. At the Bayer office, the protesters presented a memorandum demanding an end to the importation and use of EU-prohibited substances.   

Protesters sought to expose the hypocritical tactics European agrochemical companies use to sell products in developing nations, even when those products are deemed unsafe in their home countries. Numerous farmworkers, like victim-turned-activist Antie Dina, spoke out about their health issues from petrochemical exposure. In her talk, Dina emphasizes that, “… enough is enough, we do not want any more [pesticides].” Meanwhile, the chants of demonstrators echoed throughout: “We’re dying of asthma, we’re dying of cancer, we’re dying of heart attacks,” a reminder of the dire consequences of corporate actions like Bayer’s.   

This demonstration comes on the heels of a visit to South Africa by Marcos Orellana, PhD, the UN Special Rapporteur on toxics and human rights. Dr. Orellana’s report highlights discrepancies in South Africa’s handling of hazardous materials. Apartheid-era laws, such as the Hazardous Substance Act, No.15 of 1973, and the Fertilizers, Farm Seeds, and Seeds and Remedies Act 36 of 1947, persist and permit the use of chemicals that other nations deem too unsafe despite their recognition of health risks posed to agricultural workers.   

In the report, Dr. Orellana voices concerns about environmental racism in the country, highlighting the reality of a post-Apartheid legacy. He observes, “despite the efforts by Government in setting up institutions and laws to address this legacy of environmental racism, pervasive air, water and chemical pollution still imposes a heavy toll, especially on disadvantaged communities.” 

Dr. Orellana suggests addressing these challenges will require “significant additional efforts, including structural, legislative, economic and environmental changes,” especially against the backdrop of grave issues like children being poisoned and killed from handling toxic pesticides and the neglectful response of government and industry to hazardous waste incidents. 

Despite the avenues for improvement, Dr. Orellana commends South Africa for their efforts and states “I would like to congratulate South Africa for having ratified the key multilateral environmental agreements on chemicals and wastes (Basel, Rotterdam, Stockholm, and Minamata Conventions and the Montreal Protocol). I would also like to recognize South Africa’s leadership in the multilateral system and in capacity-building in the human rights and environmental areas. South Africa hosts the Regional Centre for English-speaking countries of the Basel and Stockholm Conventions. The country also supported a proposal to amend the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, to overcome the breakdown of the Convention’s science-policy interface mechanism. While South Africa has yet to become party to the Bamako Convention, which aims to ban the import of all hazardous substances into Africa, it has ratified the Basel Ban Amendment that prohibits the import of hazardous wastes from OECD (Organization for Economic Co-operation and Development) countries.” 

Although South Africa has ratified many key multilateral environmental agreements that are meant to prevent hazardous waste imports, enforcement has been deficient.  

Bayer’s updated website lists products like Antracol 70 WP (Propineb), Biscaya 240 OD (thiacloprid), Confidor (imidacloprid), and Gaucho (imidacloprid)—all of which are prohibited in the EU—as available for purchase in South Africa. These products, alongside many others containing terbufos and paraquat, are widespread in the country. The ongoing sale of EU-banned chemicals suggests the ratification of international agreements at times might be more symbolic than substantive in effect, and that more needs to be done.  

This issue of exporting toxic agrochemicals is not unique to Germany and South Africa. A previous Beyond Pesticides article identified the Netherlands, France, Spain, Switzerland, and Belgium as culprits, exporting prohibited chemicals to countries like Brazil, Mexico, Indonesia, and Ukraine. Advocates point to this behavior as indicative of the deep-rooted racism that allows racial and wealth disparity to thrive–the belief that the lives of the poor and non-white individuals in developing countries are worth less than the lives of Westerners.   

Western lawmakers and corporations often absolve themselves of any responsibility by suggesting the onus for protection lies with the receiving countries to enforce their own bans on toxic chemicals. This deflection, according to advocates, is especially egregious considering the lasting impact of European colonialism on many of these nations. After years of colonial dominance, resource extraction, and imposed economic structures, many of these countries still grapple with systemic challenges that make it difficult for them to resist or regulate such imports effectively.   

Action Needed: Considering the historical context, as we bear witness to the perseverance of South African farmworkers, we must genuinely commit to change and understand our collective responsibility. While those on the ground lead the change against systemic injustice, the EU must act quickly to close loopholes that enable manufacturers to distribute banned substances offshore. Yet, the most transformative and enduring solutions will be championed by these very farmers and workers. The voices from South Africa and similarly affected regions signal a grave sense of urgency against harmful practices. Advocates are urging countries victimized by international trade in toxins to join for a sustainable agricultural path forward with the tools, knowledge, and freedom to nurture their lands and people.  

Our active support of farmworkers worldwide—whether through legislative action, joining their cause in protest, or advancing agroecological and organic initiatives—amplifies the systems they have been advocating for abroad and at home. Many of the systemic injustices observed in South Africa parallel the challenges faced in the U.S agricultural sector, like in California’s Central Valley and Florida’s citrus groves where workers face some of the lowest wages and harshest conditions. These practices perpetuate environmental racism in the fallout of agricultural work, with pesticide drift and tainted water supplies constantly compounding health risks for those residing in farming-intensive regions. It is vital for readers to take actionable steps towards change. Please consider helping Beyond Pesticides advocate for the cessation of forever chemicals by urging senators to ratify the Stockholm Convention. Send a message to the EPA that persistent toxic pesticides should be deemed an unreasonable environmental risk under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).   

See Beyond Pesticide’s Agricultural Justice webpage and support farmworkers in the U.S. 

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

Source: Ground Up—Farmworkers march against pesticides

Image: CC BY-SA 3.0, via Wikimedia Commons

(Beyond Pesticides, September 18, 2023) Advocates for organic have consistently maintained that public engagement with the National Organic Standards Board (NOSB) is critical to protecting the values and principles embedded in the Organic Foods Production Act (OFPA). While the NOSB is a stakeholder board that reflects the sectors of the organic community—from consumers, farmers, processors, certifiers, retailers, and scientists—public interaction with the board offers critical input to the NOSB’s decision-making process. Ultimately, Board authority over the National List of Allowed and Prohibited Substances and its advisor relationship to the U.S. Secretary of Agriculture have a direct effect on the underlying decisions that determine the credibility of the U.S. Department of Agriculture (USDA) organic label that is now widely found on products in virtually all grocery stores. A major issue that continues to plague label integrity is the Board’s review of so-called “inert” ingredients in materials allowed in organic. These are potentially toxic ingredients that should be reviewed by the Board, substances not disclosed on labels of products that may be used in organic production or processing. The NOSB has access to the complete list of “inerts” used in organic materials, and advocates are urging the Board to begin immediately its National List review process for them.

The NOSB is now receiving written comments from the public that must be submitted by September 28, 2023. This precedes the upcoming public comment webinar on October 17 and 19 and the deliberative hearing October 24-26—concerning how organic food is produced. Sign up to speak at the webinar by September 29. Written comments must be submitted through Regulations.gov. by 11:59 pm EDT, September 28. Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October.

The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of OFPA, including the materials (substances) allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health.

The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and the Fall 2023 issues page. USDA’s National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA. Beyond Pesticides has advocated that the NOSB break down the hundred or so “inerts” of potential concern into groups of chemical families and common toxicological mechanisms to conduct its review over several years. For example, the ethoxylated compounds could be evaluated together. In fact, they are not permitted in EPA’s Safer Choice labeling program. (For a more in-depth discussion of the “inerts” in organics, please see “Inert” Ingredients Used in Organic Production.)

This is not a new issue for the NOSB and NOP, but one that needs resolution now.

Some crucial facts must be acknowledged by USDA:
* “Inert” ingredients are not necessarily biologically or chemically inert. The Beyond Pesticides report ”Inert” Ingredients in Organic Production compares the toxicity of active substances and “inert” substances used in organic production. In almost every category, there are more harmful “inerts” than active substances.

* OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application” based on a recommendation by the NOSB, following procedures in OFPA.

* The NOSB has repeatedly passed recommendations telling NOP to evaluate individual “inerts.”

We urge you to submit comments to the docket on the NOSB/NOP “Inerts Pre-Discussion Document” (under consideration at the upcoming NOSB meeting in October), incorporating the following points (feel free to cut-and-paste these comments you submit in the docket):

No issue is more important than the need for the NOSB to evaluate so-called “inert” ingredients in the products used in organic production to ensure that they meet the criteria in the Organic Foods Production Act (OFPA). The NOSB, which is responsible for giving direction to the National Organic Program (NOP), has passed repeated recommendations instructing NOP to replace the generic listings for EPA Lists 3, 4A, and 4B “inerts” with specific substances approved for the use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert” ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.

OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active” ingredients but not to “inert” ingredients, which make up the largest part of pesticide products—up to 90% or more.

A comparison of the hazards posed by active and “inert” ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts” than actives pose the hazard.

As a result, NOP and the NOSB have been allowing unknown toxic mixtures to be applied to organic crops and livestock. They are applied not only in products containing approved National List synthetic materials but also in products in which the active ingredient is nonsynthetic, which require no NOSB review.

The NOSB and NOP must address this fatal threat to organic integrity by immediately compiling and posting in the Federal Register a list of all “inert” ingredients used in organic production, as recommended by the NOSB in 1999. They must develop a process for beginning the evaluation of those “inerts” before the next sunset date.

The value of organic in eliminating hazardous pesticides and fertilizers has been widely documented as the most effective alternative to chemical-intensive agriculture and land management. These “inert” ingredients and many even more hazardous ones are used in chemical-intensive or conventional food production that consumers buy and feed to their families every day. The continued use of hazardous “inerts” is an anomaly in organic and must be corrected now. Ignoring this issue will undermine public trust in the USDA organic label.

Submit Comments Now.

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

(Beyond Pesticides, September 15, 2023) The U.S. Environmental Protection Agency suspended the registration of the herbicide dimethyl tetrachloroterephthalate (DCPA) (also widely known as Dacthal), effective August 22, 2023 and leaves existing stocks (products containing DCPA manufactured before August 22) available on the market. The decision is one of a series of EPA attempts dating to 2013 to get more data from the manufacturer as the agency considers reregistration of DCPA. The suspension is toothless, however, since EPA did not totally close the book on this chemical. Six days before the suspension, EPA signed a settlement agreement with the sole manufacturer, AMVAC Corporation, to reinstate the registration upon receipt of the complete toxicological data—that is, animal and laboratory tests— needed to determine the chemical’s safety and how and where it can be used. DCPA is currently classified by EPA as a possible human carcinogen and has also been shown to be a thyroid hormone disrupter.

DCPA is regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Pesticides are supposed to undergo reregistration every 15 years to take new science into consideration, but this process is glacial. Congress amended FIFRA in 1988 to speed up reregistration of products registered before 1984, and the EPA issued a DCPA reregistration document in 1995. Originally registered only for crabgrass and other weeds in turf, by 1995 there were 83 registrations for products made with DCPA. EPA had issued three calls for additional data on DCPA between 1987 and 1992, including one in 1987 because of concerns about dioxin and furan contamination. The 1995 reregistration allowed all uses of DCPA except the original turf application. The agency could not decide on approval for turf because, “The risks of concern include carcinogenic risk to children playing on lawns post-treatment, carcinogenic risk through contaminated drinking water, chronic risks to wild mammalian species, including endangered species, and acute risks to freshwater and estuarine mollusks, including endangered species.”

When the DCPA review came before an administrative law judge last year, an EPA specialist in the Office of Pesticide Programs testified that by October 2020, “AMVAC had not satisfied approximately 41 [data call-in] requirements.”

AMVAC’s attitude has been particularly egregious. The EPA expert further testified, “AMVAC’s actions as to the [Data Call-In] are abnormally dilatory and repetitive. Following EPA’s denial of AMVAC’s requests to waive certain data requirements, AMVAC followed up with additional waiver requests, which usually provided rationales similar to the originals, often with only minor or insignificant changes. In some cases, AMVAC simply opposed the Agency’s denials and did not offer any additional, substantive rationale. During this cycle of waiver requests and denials, AMVAC did not initiate attempts to satisfy the subject data requirements.”

In its suspension notice, EPA recites its enforcement efforts only since 2013. But EPA’s tolerance for industry malfeasance goes much farther back than that. DCPA was first registered under the 1947 FIFRA law in 1958—65 years ago. The EPA did not exist. Since then, manufacturers of DCPA have undergone several mergers and acquisitions, but they have all disregarded their obligations to provide toxicology data. By the time the first EPA Registration Standard was issued in 1988, only one test had been submitted by the then-manufacturer, Fermenta Plant Protection Company.

The most recent EPA action is emblematic of the agency’s timid capitulation to industry pressure by allowing manufacturers to procrastinate on required testing, which enables EPA to delay decision-making. This pattern prevents protection of public health. EPA discourse uses terms like “partners” to describe pesticide companies whose products are collapsing the planet’s biosphere. Time and time again, instead of regulating under clear standards of protection, EPA negotiates settlements with the regulated industry. This is a troubling and deadly pattern that has plagued the agency since its creation, and certainly since the adoption of the 1972 amendments to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Beyond Pesticides has argued since its founding in 1981 that EPA should regulate and litigate against chemical manufacturers as it is charged with doing under FIFRA and should let the industry know that it will not compromise with the public’s health and the protection of the environment.

The U.S. General Accountability Office (formerly known as the U.S. General Accounting Office) has issued two documents critical of EPA’s handling of registrations. In 1993, GAO reported to Congress regarding delays in reregistrations of lawn and turf pesticides, which includes DCPA. This report cites repeated slippage in deadlines for reregistration because the pesticide companies failed to provide the required studies. GAO noted that EPA did not even have testing and assessment guidelines for human exposure occurring after lawn and turf pesticides were applied. The 2013 GAO analysis took EPA to task for issuing inappropriate conditional registrations and for sloppy recordkeeping. “Specifically, EPA does not have a reliable system, such as an automated data system, to track key information related to conditional registrations, including whether companies have submitted additional data within required time frames. As a result, pesticides with conditional registrations could be marketed for years without EPA’s receipt and review of these data,” the report stated.

The 1993 GAO analysis also noted that EPA had likely underestimated children’s exposures to lawn and turf pesticides while playing on grass. Exposures to DCPA are of critical importance for children, pregnant women, and people who work in agriculture or live near fields treated with DCPA. A recent study by a scientists at the University of California, Berkeley, and Oregon State University gave 100 Latina teenagers in the Salinas Valley silicon wristbands to wear over the summer in 2016. Such wristbands absorb chemicals their wearers are exposed to, and laboratory processing can reveal a wearer’s exposome. The agricultural pesticide found most frequently was DCPA, and a breakdown product of the flea treatment pesticide fipronil had the overall highest occurrence. There was a distinct difference in pesticide exposures between city and country, with rural girls having higher exposures than those who lived in Salinas. Proximity to a field or orchard was also a very large factor in exposures.

These results are consistent with many other studies showing agricultural workers bear the brunt of toxic pesticide exposures and suffer the worst health consequences. This makes EPA’s delays unconscionable, and the agency’s commitment to environmental justice lukewarm.

For the current reregistration cycle, the Endocrine Society, a global group of more than 18,000 endocrine clinicians and researchers, submitted a letter to the EPA saying its members are “extremely concerned about the results of the DCPA thyroid toxicity studies, which showed decreased levels of T3 and T4  [forms of thyroid hormone] in fetal rats at very low, biologically relevant levels, indicating that this chemical is an [endocrine disrupting chemical].” The society also urged adoption of the Precautionary Principle and called for restriction measures, “including cancelling the registration of all products containing DCPA.”

DCPA is a high concentration technical grade product used in the formulation of other commercial herbicide products with an alarming mechanism of action: It affects plants’ ability to reproduce by interfering with the formation of microtubules, a major structural element in every cell on the planet (with slightly different structures in multicellular organisms than in most bacteria and archaea). It is used widely in the cultivation of cabbage, broccoli, cilantro, strawberries, cotton, garlic, and onions, as well as on golf courses and athletic fields. The Yuma, Arizona area is a major DCPA hotspot which grows at least 80 percent of the nation’s winter vegetables and leafy greens, according to Raymond Griffin of Griffin Family Farms, in a comment to EPA protesting EPA’s threat of cancellation. DCPA use is also ubiquitous in California.

The DCPA toxicological results that are available from EPA archives contain disturbing contradictions that the manufacturer and the EPA both disregarded. An EPA analysis in 1994 shows unambiguous thyroid and liver tumors in both sexes of rats tested. Other EPA reports indicate effects on test animals that should have been red flagged. One in 1967 reviewing various dosages in rats, dogs and rabbits, noted significant effects in some dosage groups, such as “depression” in rats and low lactation in rat mothers, and included a remark that, “Data seems to indicate the animals are in poor physical condition. Reproductive indices are low.” Dogs were observed to lose their appetites, lose weight, and become lethargic, yet the various examinations of their internal organs found “no observable gross pathology.” Thus obvious health effects were disregarded in favor of registration.

In 1982, despite numerous detailed criticisms of the test methodologies, such as “[I]t is questionable that the integrity of test cultures was properly maintained in performing the assay,” the EPA’s deference to the DCPA manufacturer was obvious when it proposed to “discontinue establishing potable water tolerances…as an uncessary [sic] burden on applicants for registration of products which may be used in potable water supplies.”

All of this illustrates that EPA knew most of the major ecosystem and human health hazards associated with DCPA almost from the chemical’s first registration. As with the registrations for glyphosate, which disregarded early EPA scientists’ concerns in favor of allowing Roundup (glyphosate) to spread around the world, EPA has ignored DCPA’s clear hazards for decades. It is questionable whether EPA would even require reregistrations of many pesticides if it were not required by law to do so. As it is, EPA drags its feet at every opportunity.

Nathan Donley, PhD of the Center for Biological Diversity observes in a Brookings Institution article that as the U.S. shies away from rational regulation of pesticides, other parts of the world have moved far ahead. For example, in 2019 the U.S. used 322 million pounds of 70 agricultural pesticides that are banned in the European Union. Similarly, the U.S. uses 40 million pounds of pesticides banned or phased out in Brazil. Other countries are making similar decisions. Donley also points out that much of the time when EPA cancels a registration, it is because the company requests it; over the last 20 years, pesticide companies have voluntarily taken 60 pesticides off the market, but EPA has only removed five on its own authority.

Dr. Donley points out that pesticide users are shooting themselves in the foot economically by continuing to treat their products with chemicals banned in their overseas target markets. The U.S. is already losing about $17 million in revenue from the European Union annually. Thailand has banned chlorpyrifos and paraquat, costing U.S. producers $1.8 billion annually; France rejected cherries treated with dimethoate, costing U.S. growers about $5 million over four years; and Mexico is phasing out glyphosate. The failure to even apply enlightened self-interest to the pesticide issue, let alone altruism, is costly in lives, dollars and jobs.

One of the most egregious failings of EPA’s pesticide regulations—indeed, of all its chemical oversight—is its reliance on piecemeal and outdated toxicological concepts while ignoring a vast body of academic health effects research. One result of this is that EPA ignores the commonalities among various parts of the biosphere, such as between vertebrates and invertebrates, animals and plants, microbes and metazoans. DCPA is an outstanding example of this blindness.

DCPA’s interference with microtubules makes it an effective weed suppressor, but as with most pesticides, collateral damage is at least as dramatic. Importantly, DCPA is a phthalate, one of the most notorious reproductive hormone disrupters in the world. DCPA’s microtubular mechanism of action is common to about a quarter of all herbicides that have reached the market, and is not confined to members of the same chemical family. For example, carbendazim, a fungicide used on turf, fruits, and nuts, prevents mouse ova from maturing and damages male sperm production. Oryzalin, a dinitroaniline pesticide commonly used on soybeans, almonds, grapes, and other crops to control weed growth, suppresses microtubule synthesis in a complex process involving oxidative stress that prevents embryos from implanting.

It does not appear that the pesticide industry is able to make the obvious connection between biological interference in one type of organism with the same in other organisms, given that all life stems from a common ancestor and shares a great deal of DNA in common—humans and cabbages have about half their genes in common. It is not surprising that something that kills a cabbage or a dandelion might also injure a human.

The EPA should adopt the Precautionary Principle by assuming that it should not grant approval of groups of chemicals with similar structures if one member is already known to be harmful to humans and ecosystems; and by doing the same thing with chemicals with a common and harmful mechanism of action regardless of their structural families. As the DCPA saga proves, the EPA needs to apply balanced science in a timely manner to the registration of pesticides and stop treating the pesticide industry with kid gloves.

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

Source: EPA Issues Notice of Intent to Suspend the Herbicide DCPA

(Beyond Pesticides, September 14, 2023) As we celebrate National Organic Month this September, it is the perfect time to reflect on why you should consider going organic. Do you try to buy organic food when you can? Are you looking for a way to reduce your and your family’s exposure to toxic pesticides?

The benefits of choosing an organic lifestyle extend far beyond your diet or your own health. Beyond Pesticides is helping communities transition parks and public lands to organic land management. Here are some reasons why Beyond Pesticides believes in building organic communities:

Why Go Organic?

1. Health and Safety: Organic foods and parks are free from harmful pesticides, fossil-fuel-based substances, and toxic chemicals, making them safer and healthier for all ages. Visit Beyond Pesticide’s 40 Common Lawn and Landscape Chemicals page to learn more about the health impacts of pesticides in communities.
2. Environmental Stewardship: Opting for organic parks and products supports practices that protect pollinators, improve soil health, increase biodiversity, and reduce toxic runoff into water bodies. Learn more about how to protect pollinators in your community by reading BEE Protective.
3. Trust and Transparency: The USDA Certified Organic label ensures strict standards and regulations for organic products, providing trust and transparency for consumers worldwide. We provide oversight for parks that use organic land management. Visit Beyond Pesticide’s literature called Save Our Organic to learn more about the power of the organic label and use our Keeping Organic Strong page to keep USDA accountable to the principles and values in the Organic Foods Production Act.
4. Just Communities: Supporting organic farming practices can benefit local communities and economies, as well as promote responsible animal welfare and fair labor conditions. Organic parks are the ethical choice to promote environmental justice. The Black Institute’s Poison Parks report shines a spotlight on New York City’s previous reliance on glyphosate-based herbicides and that people of color communities, including landscapers, bear the burden of this toxic chemical’s impact.
5. Climate Resilience: Organic farming often exhibits better performance during droughts and challenging environmental conditions. Watering needs are very site-specific and the type of soil impacts drainage. Once established, a deep root system from organic land management requires less water and organic soil management results in the drawn down of atmospheric carbon, contributing to efforts to reduce the adverse efforts of carbon on climate.

How to Go Organic?

Each person’s organic journey is unique, with some emphasizing organic choices in their diet, lawn care, or community involvement. If you are interested in fostering an organic community, one impactful step is to initiate an organic park in your neighborhood. Become an organic parks advocate!

Fall is the best time to transition to organic land management, focusing on healthy soil and proper maintenance practices. Healthy soil leads to weed and pest-resistant grass. Transitioning from chemical-dependent lawns may require extra effort and attention to timing, but organic care saves resources and ensures safety for all. Here are some steps you can take to make your garden or park organic:

1. Mow High and Keep Sharp – Mowing with a dull blade makes the turf susceptible to disease and mowing too close invites sunlight in for weeds, so be sure to sharpen your mower blades frequently. For the last and first mowing, mow down to 2 inches to prevent fungal problems. For the rest of the year, keep it at 3-3.5 inches to shade out weeds and foster deep, drought-resistant roots.
2. Aerate – If a lawn is hard, compacted, and full of weeds or bare spots, aerate to help air, water, and fertilizer enter the soil. If you cannot stick a screwdriver easily into the soil, it is too compacted. Getting an aerator on the turf will be especially helpful. Once you have an established, healthy lawn, worms and birds pecking at your soil will aerate it for free!
3. Fertilize Without Fossil Fuels – Fertilizing in early fall ensures good growth and root development for your grass. Nitrogen, the most abundant nutrient in lawn fertilizers promotes color and growth. Adding too much nitrogen, or quick release synthetic petrochemical (fossil-fuel-based) fertilizers, will result in quicker growth and the need for more mowing. Too much nitrogen can also weaken the grass, alter the pH, and promote disease, insect, and thatch build-up. If applied too late, nutrients can leach directly into nearby surface waters. Be aware of local phosphorus or nitrogen loading concerns. Use safer fertilizers such as”
   1. Grass clippings contain 58% of the nitrogen added from fertilizers, improve soil conditions, suppress disease, and reduce thatch and crabgrass. So, leave the clippings on the lawn.
   2. Compost and compost tea is an ideal soil amendment, adding the much-needed organic content to the soil and suppressing many turf pathogens. In the fall and spring, preferably after aerating, spread ¼ inch layer of compost over your lawn. Compost tea and worm castings are also great additions. Learn more from Beyond Pesticides’ factsheet, Compost is Key to Successful Plant Management.
4. Overseed With the Right Grass Seed – Once again, fall is the best time to seed a lawn. Grass varieties differ enormously in their resistance to certain pests, tolerance to climatic conditions, growth habit and appearance. Endophytic grass seed provides natural protection against some insects and fungal disease —major benefits for managing a lawn organically. The local nursery will know the best seed for the area. Check to see the weed content of the grass seed and that there are no pesticide coatings.
5. Analyzing Soil is highly recommended to determine specific soil needs. Contact the university extension service to find out how to take and send in a soil sample. In addition to nutrients and pH, ask for organic content analysis, and request organic care recommendations. Ideal pH should be between 6.5-7.0, and organic content should be 5% or higher. Soil test results will ensure that only the materials that are needed are applied. Read Maintaining a Delicate Balance: Eliminating phosphorus contamination with organic soil management for in-depth information on the problem of fertilizer contamination, and how to apply fertilizer properly.
6. Develop Your Tolerance – Many plants that are considered weeds in a lawn have beneficial qualities. Learn to read your “weeds” for what they indicate about your soil conditions. Monocrops do not grow in nature and diversity is a good thing. See more information on our Least Toxic Control of Weeds factsheet.
7. Become an Organic Parks Advocate – Send the municipal parks department links to our factsheets on Establishing New Lawns and Landscapes and Maintaining Sustainable Lawns and Landscapes. Or print them out and take them to the parks manager. For more support from Beyond Pesticides, sign up to become an organic parks advocate!

There is a lot more at Lawns and Landscapes on the Beyond Pesticides’ website. For more information about becoming an advocate for organic parks, see Parks for a Sustainable Future and Tools for Change.

TAKE ACTION: In addition to priming your own lawns, and landscapes, tell your mayor or county executive to transition your public parks and lands to organic management practices!

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

Source: Parks for a Sustainable Future FAQ, Establishing New Lawns and Landscapes, It Is the Season to Transition Lawns and Landscapes to Organic for Municipalities, Schools, and Homes

(Beyond Pesticides, September 13, 2023) A study published in Global Change Biology finds climate change increases bees’ sensitivity to pesticide exposure, impairing the pollinators’ ability to respond to light (Ultra-Violet [UV] stimuli), reducing floral syrup consumption, and lessening longevity (length of life) up to 70 percent. Notably, the reduction in floral syrup consumption indicates nutritional stress that further impacts bee species’ fecundity (productiveness), driving bee declines. Unless more is done to combat the climate crisis, the current global warming scenario increasing bees’ sensitivity to pesticide exposure will continue to threaten all pollinator health.

The pervasiveness of pesticide exposure, combined with climate change, threatens global species biodiversity. As has been widely reported, pollinators (such as bees, monarch butterflies, and bats) are a bellwether for environmental stress as individuals and as colonies. Pesticides intensify pollinators’ vulnerability to health risks (such as pathogens and parasites), with pesticide-contaminated conditions limiting colony productivity, growth, and survival. The globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk, including pollinators. Pollinator declines directly affect the environment, society, and the economy. Without pollinators, many agricultural and nonagricultural plant species will decline or cease to exist as U.S. pollinator declines, particularly among native wild bees, depress crop yields. In turn, the economy will take a hit since much of the economy (65%) depends upon the strength of the agricultural sector. As the science shows, pesticides are one of the most significant stressors for pollinators. Additionally, the devastating impacts of pesticides on bees and other pollinators and the larger context of what scientists have called the “insect apocalypse.” In a world where the climate crisis shows no sign of abating, scientists have concluded that the globe cannot afford to continue to subject its critically important wild insects to these combined threats. Therefore, studies like this emphasize the need to consider how many stressors impact the survivability of essential species.

The study notes, “Our findings indicate that ongoing global warming may exacerbate the impact of pesticides on bee health and compromise bee reproductive success, with potentially important consequences on population dynamics. The magnitude of these impacts will depend on our ability to reduce the dependence of agriculture on pesticides and on the extent to which bee populations can adjust to the new climate scenario through adaptation and/or phenotypic plasticity.”

The study analyzes the synergistic (combined) effects of global warming and sublethal insecticide exposure in the solitary bee (European orchard bee/horned mason bee) Osmia cornuta. Using a simulated wintering treatment, the researchers exposed O. cornuta females to three different temperature scenario models: current scenario (2007–2012 temperatures), near-future (2021–2050 projected temperatures), and distant future (2051–2080). During the spring, the bees emerged, and researchers examined the pollinator’s sensitivity to a formulation of sulfoxaflor insecticide at two sublethal doses. Lastly, the researchers measured the combined impact of the various temperature scenarios and sublethal insecticide exposure on the phototactic response (response to light stimuli), feeding behavior, and longevity. The results find the temperature treatment has a profound effect on body weight, as increasing temperatures led to decreasing body weight in bees. This is concerning as body fat plays a crucial role in chemical detoxification. Although the temperature has little impact on phototactic response or feeding behavior, bees exposed to the warmest temperature scenario have shorter lifespans. Insecticide exposure negatively affects the phototactic response, feed behavior, and lifespan of bees, especially at higher doses. The combination of the warmest temperature and high insecticide exposure decreased longevity in bees by 70 percent. Thus, warming temperatures and insecticide exposure represent two significant drivers of bee decline that have important implications for the future of ecosystem services.

The scientific literature demonstrates pesticides’ long history of adverse environmental effects, primarily on wildlife, biodiversity, and human health. Most notably, pesticides are immensely harmful to pollinators. Over the last decade and a half, increasing scientific evidence shows a clear connection between the role of pesticides in the decline of honey bees and wild pollinators (e.g., wild bees, butterflies, beetles, birds, bats, etc.). For instance, monarchs are near extinction, and commercial beekeepers continue to experience declines that are putting them out of business. The continued loss of mayflies and fireflies disrupts the foundation of many food chains. Additionally, the reduction in many bird species has links to insect declines. Pollinators’ decline directly affects the environment, society, and the economy. The United Nations states that 80 percent of the 115 top global food crops depend on insect pollination, with one-third of all U.S. crops depending on pollinators, according to the U.S. Department of Agriculture (USDA). Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Hence, pesticide use fails to support the current ecosystem, decreasing agricultural and economic productivity and social (human/animal) and environmental well-being.

This study adds to the growing body of research supporting the adverse effects climate change and pesticide exposure have on pollinators, as these stressors already affect bee population dynamics. Warming temperatures alter the body composition of bees, reducing body fats. Bees are ectotherms and thus highly dependent on environmental temperatures for adequate growth, development, and reproduction, making these essential pollinators particularly vulnerable to global warming. Nevertheless, climate change and extensive use of pesticides, like neonicotinoids, sulfoxaflor, pyrethroids, fipronil, and organophosphates, increase the potential risk and indiscriminate threat to all insects. Research shows that residues from neonicotinoids (including seed treatments) and sulfoxaflor accumulate and translocate to pollen and nectar of treated plants. Pyrethroids and fipronil impair bee learning, development, and behavioral function, reducing survivability and colony fitness. However, inert ingredients in these products cause similar or more severe impacts on insect populations, such as disruption in bee learning behavior through exposure to low doses of surfactants. With the global reliance on pollinator-dependent crops increasing over the past decades, a lack of pollinators threatens food security and stability for current and future generations. It is increasingly clear that humanity’s continued use of fossil fuels and fossil fuel-derived pesticides are the core drivers of pollinator declines. These are not siloed but interacting crises, creating a positive feedback loop and compounding one another’s harmful effects. Despite these stressors, alternatives are within reach.

Pollinator protection policies need improvements to safeguard not only all pollinators but also the crops they pollinate. Beyond Pesticides holds that we must move beyond pesticide reduction to organic transition and commit to toxic pesticide elimination in our agricultural system to prevent the crop loss presented in this study. Pesticide elimination can alleviate the effect of these toxic chemicals on humans and wildlife. With EPA failing to take the most basic steps to protect declining pollinators, it is up to concerned residents to engage in state and community action and demand change. Moreover, the government should pass policies that eliminate a broad range of pesticides by promoting organic land management. Habitat in and of itself may assist, but it must be free of pesticides to protect wild pollinator populations. To protect wild bees and other pollinators, check out what you can do by using pollinator-friendly landscapes and pollinator-friendly seeds, engaging in organic gardening and landscaping, and supporting organic agriculture through purchasing decisions. Learn more about the science and resources behind the adverse effects of pesticides on pollinators and take action against the use of pesticides. Buying, growing, and supporting organic will help eliminate the extensive use of pesticides in the environment. Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. For more information on the organic choice, see the Beyond Pesticides webpages, Health Benefits of Organic Agriculture, Lawns and Landscapes, and Parks for a Sustainable Future. 

Learn more by registering for the virtual 40^th National Forum Series, Forging a Future with Nature: The Existential Challenge to end petrochemical pesticide and fertilizer use, starting on September 14, 2023. Go to the Forum website. Meet David Goulson, PhD—preeminent authority on bees, pollinators, and ecosystems; author of Silent Earth, researcher, and professor at the University of Sussex—at the Forum! And, learn from André Leu, PhD, director of Regeneration International, organic farmer, and author, about organic regenerative land management practices to protect community health, the environment, and the planet.

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

Source: Global Change Biology

(Beyond Pesticides, September 11, 2023) A future supported by the natural environment depends on our effective involvement in decisions in our homes, communities, states, and at the federal level to ensure that we are taking the steps necessary to protect against existential threats to health, biodiversity, and climate. The 40th National Forum Series is an important opportunity to hear from those working as scientists, advocates, land managers (from gardens, parks, and play fields to farms), and public decision makers about steps being taken and action needed to prevent catastrophic collapse of the natural systems that sustain life.

The goal of the Forum—to enable a collective strategy to address the existential health, biodiversity, and climate threats and chart a path for a livable and sustainable future. We come together to empower effective action.  

We are honored to begin this year with two international experts in their fields as they discuss steps that can and must be taken in our communities around the globe:

Internationally renowned researcher and author David Goulson, PhD, is able to draw together essential scientific research on the elements of nature that we must cherish, support, and enhance if we are to have a future. The data, as Dr. Goulson documents, describes the importance of nature in contributing to the web of life that sustains the rich diversity needed for a healthy planet. Dr. Goulson is a professor of biology at the University of Sussex in Great Britain, the founder of the Bumblebee Conservation Trust, a fellow of the Royal Entomological Society, a trustee of Pesticide Action Network UK, an ambassador for the UK Wildlife Trusts, and author of more than 300 scientific articles on ecology and conservation of insects. 

In his book, A Sting in the Tale (2013), Dr. Goulson writes, “We need worms to create soil; flies and beetles and fungi to break down dung; ladybirds and hoverflies to eat greenfly; bees and butterflies to pollinate plants to provide food, oxygen, fuel and medicines and hold the soil together; and bacteria to help plants fix nitrogen and to help cows to digest grass. . . [yet] we often choose to squander the irreplaceable, to discard those things that both keep us alive and make life worth living. Perhaps if we learn to save a bee today, we can save the world tomorrow?” He is also the author of the Sunday Times bestseller The Garden Jungle: or Gardening to Save the Planet (2019).

In his most recent book, Silent Earth: Averting the Insect Apocalypse (2021), he writes, “We have to learn to live in harmony with nature, seeing ourselves as part of it, not trying to rule and control it with an iron fist. Our survival depends on it, as does that of the glorious pageant of life with which we share our planet.” Furthermore, during an interview with The Guardian, Dr. Goulson offers a strategy for moving forward: “The UK has 22 million gardens, which collectively could be a fantastic refuge for wildlife, but not if they are overly tidy and sprayed with poisons. We just don’t need pesticides in our gardens. Many towns around the world are now pesticide-free. We should simply ban the use of these poisons in urban areas, following the example of France.” To that end, he supported a petition to ban urban pesticides in the UK. 

A leader in advancing organic agriculture, André Leu, DSc, is the international director of Regeneration International, with more than 370 partners in 70 countries, working with numerous agricultural systems—agroecology, organic permaculture, ecological agriculture, holistic grazing, biological agriculture, and organic agroforestry. The organization, founded in 2015, is cultivating an international movement united around a common goal: to reverse global warming and end world hunger by facilitating and accelerating the global transition to regenerative agriculture and land management. Its mission is to promote, facilitate, and accelerate the global transition to regenerative food, farming, and land management for the purpose of restoring climate stability, ending world hunger, and rebuilding deteriorated social, ecological, and economic systems. 

Dr. Leu previously served as president of IFOAM—Organics International, the international umbrella organization for the organic sector. IFOAM has about 850 member organizations in 127 countries. His most recent book, Growing Life: Regenerative Farming and Ranching, explores organic regenerative systems being adopted worldwide, which, he says, “require a shift in the mindset of the land manager and operator, away from being primarily reliant on external inputs such as fertilizers and pesticides, and toward dependence on knowledge, measurement, and management. He is the author of two other books, Poisoning Our Children (2018) and The Myths of Safe Pesticides (2014). Dr. Leu and his wife, Julia, own and manage an organic tropical fruit farm in Daintree, Australia. 

Jeff Moyer, CEO emeritus of the Rodale Institute, describes Growing Life: “In his powerful and well-written new book, André Leu introduces us all to the concepts of regenerative organic agriculture, asks provocative questions, then shares answers only decades of experience could possibly hope to inspire, and then finally invites us on a journey to, as André says, ‘Become your own researcher.’ Every farmer needs to read, discover, and realign their priorities to focus on the power of basic biological principles to feed us all while regenerating the soil resources we need to survive as a species. André has captured the very essence of the word regenerative by clearly and simply explaining the basic building blocks of healthy soil, showcasing how the science of biology dictates that we can improve the resource we need while using it to grow food. The science of regenerative organic agriculture uncovers how the systems are complex, but the implementation isn’t complicated.” Dr. Leu speaks to the need for clearly defined and enforceable regenerative, organic land management systems that are critical to meet the challenges of our time, lest we fall victim to empty words and promises that do not advance the urgent changes required for a livable future. 

The time is now! Don’t miss this EPIC meeting of the minds as we kick off our 40th iteration of the National Forum Series on Zoom THIS THURSDAY and move forward in the quest to end petrochemical pesticide and fertilizer use! You are part of the solution to these existential crises— be a part of the conversation!

CLICK HERE TO REGISTER TODAY!

Registration is Complimentary: Donations are requested, but not required. Your registration includes access to all three seminars for the fall!

Reach, Influence, Support—Join the following organizations to sponsor Beyond Pesticides’ 40th National Forum Series as we bring together an important and powerful group of movers and shakers—scientists, policymakers, educators, practitioners, advocates, and activists—to elevate with greater clarity the threats associated with environmental decline and collapse and the urgency with which we need to adopt solutions that are within our grasp.

Tax Deductions: All donations on this site are tax-deductible to the extent allowed by law and are processed in U.S. dollars. Beyond Pesticides is a U.S. nonprofit, tax-exempt charitable organization (tax identification number 521360541) under Section 501(c)(3) of the Internal Revenue Code.

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

(Beyond Pesticides, September 11, 2023) As environmental groups pursue a legal strategy to challenge the U.S. Fish and Wildlife Service (USFWS) for its failure to protect a wildlife refuge from industrial aquaculture, they are also urging the public to hold Refuge officials accountable to the Refuge Improvement Act with a write-in campaign. (See Take Action campaign below.) Earlier this year, USFWS allowed the establishment of a commercial aquaculture operation that cultivates 34 acres of non-native Pacific oysters within a 50-acre tideland parcel leased  from the Washington State Department of Natural Resources within the Dungeness National Wildlife Refuge. The failure to fully evaluate the compatibility of this use with the purposes of the refuge raises concerns of compliance with the law governing National Wildlife Refuges throughout the country. Beyond Pesticides has said, “USFWS is willing to allow, for private profit, the industrialization of refuge lands for shellfish operations.” 

Refuges are critical habitat throughout the U.S. that protect critical ecosystems. According to the lawsuit, the Dungeness National Wildlife Refuge shelters a bay rich in marine life. Eelgrass beds attract brant, shorebirds feed on the tideflats, and ducks find sanctuary in the calm waters. The Refuge is a preserve and breeding ground for more than 250 species of birds and 41 species of land animals. Dungeness Spit protects nutrient-rich tideflats for migrating shorebirds in spring and fall; a quiet bay with calm waters for wintering waterfowl; an isolated beach for harbor seals and their pups; and abundant eelgrass beds for young salmon and steelhead nurseries and some duck species, such as the Black Brant.

Tell the U.S. Fish and Wildlife Service and U.S. Secretary of Interior Deb Haaland that the Dungeness National Wildlife Refuge lease for industrial aquaculture must be rescinded.

In spite of demonstrated harm to birds, salmon, forage fish, and shellfish, and a recommendation by the National Marine Fisheries Service that “an alternative site be identified in a location that results in less potential impacts to wildlife that is more appropriate for aquaculture and meets the goals of the tribe,” USFWS approved a lease for an industrial oyster farm inside the Dungeness National Wildlife Refuge. This decision, which is in violation of the Clean Water Act and the Migratory Bird Treaty Act, must be reversed. 

In the words written within an October 2022 USFWS internal memorandum, “Forgoing a compatibility determination in order to facilitate incompatible commercial activities by any entity would be a subversion of the fundamental requirements in the [USFWS] Improvement Act.” 

We are targeting the most recent case of the USFWS’s permissiveness in one of the country’s most pristine nature lands, the Dungeness National Wildlife Refuge in the small rural town of Sequim Washington, just below the Olympic National Park. In this case, the shellfish corporation raises shellfish on other sites. They do not need to operate in a national refuge and deny wildlife their feeding and breeding grounds. 

The Dungeness National Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” The front page of the Refuge website states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture.  

Industrial shellfish aquaculture is known to reduce or eliminate eelgrass with the use of pesticides. Shellfish aquaculture also involves large-scale use of plastics—PVC tubes and plastic netting—that are hazardous to marine organisms and can trap and entangle wildlife. Commercial shellfish aquaculture is a major industry in Washington state that has significant impacts on the nearshore marine environments, which provide essential habitat for many species, including invertebrates, fish (including herring and salmon), and birds (migratory and shorebirds). 

Among the negative impacts of this project are: 50% reduction in bird primary feeding grounds;  plastic oyster bags that exclude the probing shorebird flocks from feeding deeply into the substrate, entrap fish and birds, add macro- and micro-plastic bits to the sediment throughout the refuge, and shift the benthic community composition; diminishing of the ecological benefits provided by eelgrass to threatened fish and birds, such as nourishment and cover from predators; and increased algal blooms that will leave a graveyard of dead oysters. These detrimental effects to the Dungeness National Wildlife Refuge are NOT minimal. Decisionmakers should not place financial benefits to the corporation above the long-term and cumulative impacts to the refuge. Half of the world’s 10,000-odd bird species are in decline. One in eight faces the threat of extinction. 2.9 billion breeding adult birds have been lost from the United States and Canada in only 50 years. 

Let’s raise our national voice and try and stop this refuge destruction with public persuasion. This is a public space we pay to protect. For more information, check out the Daily News post from last August, “Groups Sue U.S. Interior Department to Protect the Dungeness National Wildlife Refuge from Industrial Aquaculture.” 

This action follows a lawsuit filed by three environmental organizations against the U.S. Department of Interior for failing to protect the Dungeness National Wildlife Refuge from industrial aquaculture. The groups, including Protect the Peninsula’s Future, Coalition to Protect Puget Sound Habitat and Beyond Pesticides, filed their complaint in the U.S. Western District Court of Washington State. The complaint states that the U.S. Fish and Wildlife Service (USFWS), U.S. Department of Interior, must “take action that is required by the Refuge Improvement Act and conduct a compatibility determination and require a special use permit for a proposed industrial aquaculture use” that will abut and impact the Refuge. The plaintiffs are represented by the Seattle, WA law firm of Bricklin and Newman LLP. 

Tell the U.S. Fish and Wildlife Service and U.S. Secretary of Interior Deb Haaland that the Dungeness National Wildlife Refuge lease for industrial aquaculture must be rescinded.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Secretary of State.  

Thank you for your active participation and engagement!

Letter to Hugh Morrison, Regional Director for the Pacific Region USFWS, and U.S. Secretary of Interior Deb Haaland: 

As a citizen and taxpayer of the United States, I strongly oppose your support for allowing a for-profit shellfish operation in the Dungeness National Wildlife Refuge. It is upsetting to learn that USFWS would have operations known to be destructive of the wildlife refuge and refuse to abide by its own compatibility determination regulations. 

In spite of demonstrated harm to birds, salmon, forage fish, and shellfish, and a recommendation by the National Marine Fisheries Service that “an alternative site be identified in a location that results in less potential impacts to wildlife that is more appropriate for aquaculture and meets the goals of the tribe,” UFWS approved a lease for an industrial oyster farm inside the Dungeness National Wildlife Refuge. This decision, which is in violation of the Clean Water Act and the Migratory Bird Treaty Act, must be reversed. 

The Dungeness National Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” The front page of the Refuge website states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture.  

Industrial shellfish aquaculture is known to reduce or eliminate eelgrass with the use of pesticides. Shellfish aquaculture also involves large-scale use of plastics—PVC tubes and plastic netting—that are hazardous to marine organisms and can trap and entangle wildlife. Commercial shellfish aquaculture is a major industry in Washington state that has significant impacts on the nearshore marine environments, which provide essential habitat for many species, including invertebrates, fish (including herring and salmon), and birds (migratory and shorebirds). 

Among the negative impacts of this project are: 50% reduction in bird primary feeding grounds;  plastic oyster bags that exclude the probing shorebird flocks from feeding deeply into the substrate, entrap fish and birds, add macro- and micro-plastic bits to the sediment throughout the refuge, and shift the benthic community composition; diminishing of the ecological benefits provided by eelgrass to threatened fish and birds, such as nourishment and cover from predators; and increased algal blooms that will leave a graveyard of dead oysters. These detrimental effects to the Dungeness National Wildlife Refuge are NOT minimal. Decisionmakers should not place financial benefits to the corporation above the long-term and cumulative impacts to the refuge. 

Please let me know that you will write an honest compatibility determination. 

Thank you. 

(Beyond Pesticides, September 8, 2023) In a united effort, climate and environmental justice movements from around the world have come together to announce a global “end to fossil fuels,” including the end of pesticides.

The “March to End Fossil Fuels” is scheduled for September 17 and the Secretary General’s Summit in New York City on September 20. See the full map for other marches around the world.

At the Beyond Pesticides, 2022 National Forum session on climate (November, 2022), we discussed the science and the urgent need for a strategic response to the climate crisis as part of a constellation of crises that intersect. Whether we are talking about a health crisis borne out of chemical-induced diseases, the collapse of life-sustaining biodiversity, or the dramatic catastrophes caused by greenhouse gases and rising temperatures—the interconnectedness of the crises requires strategic solutions that are holistic and nurturing of our relationship with nature —a relationship we have minimized as a matter of policy and practice.

The data on climate calls on us to be audacious in our demand for urgent change in our households and communities, and from decision makers at all levels of government.

At Beyond Pesticides, our audacious goal is to ban petroleum-based pesticides and fertilizers by 2032 and transition to a society and world committed to organic management practices. To do this requires a change in public understanding of what is possible. And, it will take a fair amount of public outrage that we are not moving fast enough to embrace this goal in all sectors.

Leveraging the science, we need to show with hands-on examples what change looks like. That process has begun, and today we will hear about some of what’s possible now. But the change will take people working together locally across the country and around the world. The audacious goal is achieved through on-the-ground work that becomes mainstream. If we buy or grow food, use a park or a playing field, buy consumer products, advocate for change, or hold elective office or advisory positions, we all play a critical role.

Our work at Beyond Pesticides offers daily insight into the destruction that is being wrought by holding on to practices and toxic chemical dependencies that are defined by piecemeal approaches, antithetical to holistic thinking. As a matter of policy, we are neither preventive nor precautionary. We too often accept the underlying premise of statutory and regulatory frameworks that have been created with this thinking –the thinking that has brought us to this moment of existential crises.

Many see the solution in building resilience— and apply a narrow definition of the word.  

In the United Nations Intergovernmental Panel on Climate Change (IPCC) report, Climate Change 2022: Impacts, Adaptation and Vulnerability, they write: 

“Resilience in the literature has a wide range of meanings. Adaptation is often organized around resilience as bouncing back and returning to a previous state after a disturbance. More broadly, the term describes not just the ability to maintain essential function, identity and structure, but also the capacity for transformation.”

The IPCC continues:

“The drivers of transformation are multidimensional, involving social, cultural, economic, environmental, technical and political processes. The combination of these creates the potential for abrupt and systemic change . . . .”

In the U.S., the foundation of our agriculture and the management of our built environment is intricately tied to polluting practices, with disproportionate harm affecting segments of our society and world who are exploited, low income, in ill-health, and disproportionately people of color. We have a responsibility to find a different path and we can.

We do not have to be theoretical about this. We have organic systems in place, governed by a clear definition and requirements for compliance with standards. Under the Organic Foods Production Act (in the U.S. and similar statutes worldwide), those selling products as organic are required to adhere to a legal definition of soil management practices, a list of allowed and prohibited substances, a certification and inspection system that establishes compliance with defined organic standards, and a participatory public decision-making process for continuous improvement. This approach, whether in agriculture or in our parks and playing fields, eliminates the reliance on fossil fuel-based toxic chemicals that release greenhouse gases. It also employs the ability of healthy soil, rich in biodiversity, to draw down atmospheric carbon. To this end, Beyond Pesticides advances the continuous improvement of organic agriculture (see Keeping Organic Strong) and the development of Parks for a Sustainable Future. Both programs advance in real-time and with urgency the elimination of petrochemical pesticides and fertilizers. See how you can get involved and to make a difference along with thousands of others.

Our goal must be to adopt productive land management systems that do not use toxic petrochemical pesticides and fertilizers—substances that we can no longer use, if we are to sustain life.

Despite a growing global consensus on the urgency of addressing the climate crisis, the Biden administration has sanctioned several major fossil fuel projects, ensuring the United States maintains its status as the world’s foremost oil and gas producer and exporter. In 2023 alone, the administration approved multiple liquefied natural gas (LNG) export facilities in Alaska and along the Gulf Coast, conducted a substantial oil and gas lease sale in the Gulf of Mexico, and expedited the Mountain Valley Pipeline. Furthermore, more onshore and offshore oil and gas lease sales are slated for this year.

 Over 500 groups, including Beyond Pesticides, are calling on President Biden to:

1. STOP FEDERAL APPROVALS for new fossil fuel projects and REPEAL permits for climate bombs like the Willow Project and the Mountain Valley Pipeline.
2. PHASE OUT FOSSIL FUEL DRILLING  on our public lands and waters.
3. DECLARE A CLIMATE EMERGENCY to halt fossil fuel exports and investments abroad, and turbo-charge the build-out of more just, resilient distributed energy (like rooftop and community solar).
4. PROVIDE A JUST TRANSITION to a renewable energy future that generates millions of jobs while supporting workers’ and community rights, job security, and employment equity. Our renewable energy future must not repeat the violence of the extractive past. Justice must ground the transition off fossil fuels to redress the climate, colonialist, racist, socioeconomic, and ecological injustices of the fossil fuel era.

To learn more about the September 17th Climate March to stop fossil fuels, visit https://www.endfossilfuels.us/

The climate crisis is part of a broader set of interconnected crises, including health issues from pesticide-induced diseases, the loss of biodiversity, and catastrophic climate change events.  A study in the journal Nature finds, “The interaction between indices of historical climate warming and intensive agricultural land use is associated with reductions of almost 50% in the abundance and 27% in the number of species within insect assemblages relative to those in less-disturbed habitats with lower rates of historical climate warming.” A study in Environmental Health Perspectives finds the loss of pollinators, “3%–5% of fruit, vegetable, and nut production is lost due to inadequate pollination, leading to an estimated 427,000 (95% uncertainty interval: 86,000-691,000) excess deaths annually from lost healthy food consumption and associated diseases.” That study also finds the economic value of crops to be “12%–31% lower than if pollinators were abundant.”

To address these crises, we need holistic and nature-based solutions, as our relationship with the natural environment has often been overlooked in policy and practice. At Beyond Pesticides, our audacious goal is to eliminate petroleum-based pesticides and fertilizers within a decade, transitioning to organic management practices. Like the transition off of fossil fuels, achieving this goal requires changing public perceptions of what’s possible and generating public outrage over the slow pace of change.

In this moment of international environmental momentum, we must work together locally and globally, whether it’s buying or growing food, advocating for change, or holding elective office. We must examine the destructive consequences of maintaining toxic chemical dependencies and piecemeal approaches that lack a preventive or precautionary stance.

We need to embrace holistic thinking, recognizing that resilience involves not just bouncing back but also transforming our systems. Organic systems offer a path forward, with clear standards and a focus on healthy soil and biodiversity, reducing reliance on toxic petrochemicals and contributing to carbon sequestration. Our ultimate goal is to sustain life without the use of harmful chemicals that threaten our planet.

For more information on the dangers ongoing pesticide use poses to our ability to combat climate change, see talks from Beyond Pesticides climate change webinar, featuring Rachel Bezner Kerr, PhD, Cornell University professor and co-author of the definitive United Nations (UN) report on climate and food production and Andrew Smith, PhD, chief operating officer of the Rodale Institute and coauthor of several landmark reports on soil biology and carbon sequestration in organic agricultural production. As reported in Beyond Pesticides Daily News in 2022, the longest-running — four-decade — investigation comparing organic and chemical-intensive grain-cropping approaches in North America yields impressive results for organic. In 2022, the Rodale Institute’s Farming Systems Trial — 40-Year Report reports on these outcomes: (1) organic systems achieve 3–6 times the profit of conventional production; (2) yields for the organic approach are competitive with those of conventional systems (after a five-year transition period); (3) organic yields during stressful drought periods are 40% higher than conventional yields; (4, 5, and 6) organic systems leach no toxic compounds into nearby waterways (unlike pesticide-intensive conventional farming), use 45% less energy than conventional, and emit 40% less carbon into the atmosphere. And, as the Rodale Institute reports, “Healthy soil holds carbon and keeps it out of the atmosphere.“ Beyond Pesticides reported in 2019 on similar results, from the institute’s 30-year project mark, which have been borne out by another three years of the trials.

Think global and act local: Join the global climate march on September 17th, 2023 and transition your local park to organic land management to end fossil fuels.

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

Source: March to End Fossil Fuels

(Beyond Pesticides, September 7, 2023) During Organic Month, the importance of organic practices is brought into sharp focus by a study published in July in Environmental Health Perspectives, which emphasizes the importance of an organic diet and location to residues of pesticides in the body. The study finds urinary levels of the weed killer glyphosate significantly decrease through an organic diet for pregnant individuals living further than 0.5km (~1640ft) from an agricultural field. However, the study finds that adopting an organic diet among pregnant individuals living closer than 0.5km to an agricultural area does not significantly decrease glyphosate levels, indicating alternative sources of contamination outside of diet. Although past studies prove time and time again that an organic diet can reduce the levels of pesticides in the body, far too few studies investigate how the intervention of the organic diet can alter glyphosate levels among pregnant individuals living near or far from agricultural fields on which the herbicide is used. Furthermore, pesticides’ presence in the body affects human health, especially during vulnerable life stages like childhood, puberty, pregnancy, and old age.

The study raises the complexity of fully tracking multiple exposures to glyphosate and other pesticides and the need for a more holistic or systemic solution, as embraced by those transitioning to organic management practices and/or the need for regulatory decisions that eliminate the use of toxic chemicals based on the availability of nontoxic alternative practices and products.

Pesticide exposure during pregnancy is of specific concern as health effects for all life stages can be long-lasting. This study highlights the importance of where you live and the associated exposure patterns. In the study population, the primary source of chemical exposure appears to differ among vulnerable populations depending on rural-urban location. Suppose rural communities’ primary exposure source comes from agricultural uses, while urban communities mainly encounter glyphosate through diet. Or suppose that residential and urban populations get multiple glyphosate exposures from diet, landscaping, park and playing field use, and roadside or rights-of-way management. In these cases, as this study notes, “[I]t is necessary to understand sources of exposure in diverse populations to develop effective exposure-reduction recommendations.”

Conducted in Idaho, the researchers evaluated the urinary glyphosate concentrations of 39 pregnant individuals living near (0.5km or less; rural) and from (more than 0.5km; urban) agricultural fields routinely treated with pesticides. Randomly, participants receive a supply of organic or conventional (non-organic) groceries (grown with chemical-intensive practices) over two weeks to determine the glyphosate concentration in urine samples. The study compares the difference in urine sample glyphosate concentration between the organic and conventional grocery weeks, stratifying by proximity to agricultural fields. The results find urinary glyphosate levels among individuals furthest from agricultural fields (urban) are moderately lower than those of individuals living near agricultural fields (rural), with the concentrations decreasing when switching from a conventional to an organic diet. Thus, the study suggests that “diet is an important contributor to glyphosate exposure in people living >0:5 km from agricultural fields; for people living near crops, agriculture may be a dominant exposure source during the pesticide spray season.”

Glyphosate is the most commonly used active ingredient in the U.S. and worldwide, appearing in many herbicide formulations and readily contaminating soil, water, food, and other resources. As the active ingredient in the popular weed killer Roundup^TM, with use growing especially during the last few decades, extensive glyphosate use has put human, animal, and environmental health at risk. Four out of five U.S. individuals over six years have detectable levels of glyphosate in their bodies. Exposure to glyphosate has implications for the development of various health anomalies, including cancer, Parkinson’s disease, developmental and birth disorders, and autism. Although the U.S. Environmental Protection Agency (EPA) classifies glyphosate herbicides as “not likely to be carcinogenic to humans,” stark evidence demonstrates links to various cancers, including non-Hodgkin lymphoma. EPA’s classification perpetuates adverse impacts, especially among vulnerable individuals, like pregnant women, infants, children, and the elderly. Glyphosate’s ubiquity threatens 93 percent of all U.S. endangered species, resulting in biodiversity loss and ecosystem disruption (e.g., soil erosion, loss of services, and trophic cascades). Moreover, chemical use has been increasing since the inception of crops genetically modified to tolerate glyphosate.

Not only do health officials warn that continuous use of glyphosate will perpetuate adverse health and ecological effects, but that use also highlights recent concerns over antibiotic resistance. It is commonly used on crops grown from genetically engineered (GE) companion seeds for various staple crops (e.g., soybeans, cotton, and corn). These GE seeds are glyphosate-tolerant, whose attribute has allowed growers to apply the herbicide and expect that it will kill weeds and not harm the crop. This calculation is changing, however, as weeds develop resistance to glyphosate, causing the industry to double down on its chemical solutions.

This study is one of the first “to examine the effect of an organic diet intervention on glyphosate among people living near and far from agricultural fields.” Most notably, this study is the first to investigate the impact of an organic diet mediation on glyphosate exposure during pregnancy. Pregnancy is a critical window of susceptibility for exposure to glyphosate and other environmental chemicals, as prenatal exposure has associations with adverse birth outcomes that can impact subsequent generations.

Previous studies demonstrate a significant reduction (up to 70 percent for glyphosate) in urinary pesticide metabolites (breakdown products from parent compounds) achieved by a dietary shift from consuming conventionally grown food to organically grown foods in as little as a week. This subject research furthers the investigation of the impacts of an organic diet on pesticide exposure. Like this article, the paper, Organic Diet Intervention Significantly Reduces Urinary Glyphosate Levels in U.S. Children and Adults, reports on the second phase of a two-part study evaluating the same set of urine samples. 

Although the results of this study and others suggest an organic diet effectively reduces exposure to pesticides for most of the general population, rural areas have difficulty avoiding glyphosate exposure because of its use on farms. Thus, sources of glyphosate exposure in rural areas are far beyond diet. Organic agriculture is not magically “free” of all chemicals, given the reality of pesticide drift and background levels in the environment. However, the National List of Allowed and Prohibited Substances, overseen by the National Organic Standards Board and subject to public review and comment, establishes the prohibition of toxic pesticides in certified organic production under the USDA organic seal.

This September, celebrate National Organic Month to improve and sustain human, animal, and environmental health. Emissions from fossil-fuel-based synthetic pesticides and nitrogen fertilizers continue to threaten the ecosystem, fueling the climate crisis. A complete switch from chemical-intensive agriculture to regenerative organic agriculture can significantly reduce the threat of the climate crisis by eliminating petrochemical, synthetic fertilizers and toxic pesticide use. Furthermore, supporting the use of alternative practices such as polyculture rather than monoculture, mulching systems instead of herbicides for weed management, animal integration, and other organic practices assist in eliminating the need for pesticides and their movement through air (pesticide drift) and into waterways (runoff). 

As for glyphosate, Beyond Pesticides has challenged the registration of this chemical in court due to its impacts on soil, air, water, and our health. While legal battles press on, the agricultural system should eliminate the use of toxic synthetic herbicides to avoid the myriad of problems they cause. Instead, the main focus should be converting to regenerative-organic systems and using least-toxic pest control to mitigate harmful pesticide exposure, restore soil health, and reduce carbon emissions. Public policy must advance this shift, rather than allow unnecessary reliance on pesticides. Additionally, purchasing organic food whenever possible—which never allows glyphosate use—can help curb exposure and adverse health effects. Moreover, Beyond Pesticides provides tools, information, and support to take local action: check out our factsheet on glyphosate/Roundup and our report, Monsanto’s Roundup (Glyphosate) Exposed. Contact us for help with local efforts and stay informed of developments through our Daily News Blog and our journal, Pesticides and You. Additionally, check out Carey Gillam’s talk on Monsanto’s corruption in glyphosate/Roundup at Beyond Pesticides’ 36th National Pesticide Forum. Help to take glyphosate and other toxic pesticides and fertilizers out of your community by collaborating with Beyond Pesticides through our Parks for a Sustainable Future program.

As we forge ahead, converting local parks and playing fields to organic land management practices to make them safer for kids (and pets!) to play in via our Parks for a Sustainable Future program, Beyond Pesticides is also honored to partner with Natural Grocers for Organic Month! As part of their Organic Month Headquarters® campaign, Natural Grocers is donating $2 for every Ladybug Love pouch sold and $1 for every “Organic Month Headquarters” bag sold at all in-store locations to Beyond Pesticides! With your support, we can say YES to the livable future we are working to achieve! 

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

Source: Environmental Health Perspectives

(Beyond Pesticides, September 6, 2023) In late August, the Office of the Inspector General (OIG) at the U.S. Environmental Protection Agency (EPA) released a report concluding that EPA “took a siloed approach” to the cumulative impacts of chemical exposures and the disproportionate nature of those exposures. This approach keeps different parts of the EPA from coordinating their efforts and hinders understanding of the breadth and depth of chemical exposures.

OIG reached this disturbing finding despite the issuance of several executive orders by President Biden requiring EPA to develop policies and actions to assess cumulative impacts of chemical exposures across departments, laws, and environmental media (air, water, bodies, food etc.) and to pay more attention to environmental justice.

Beyond Pesticides has stressed that the whole constellation of chemical exposures and effects should be considered when governments set public policies and regulations. Just last March, Daily News covered another OIG report castigating EPA for betraying its mission by failing to address the fact that very high levels of per- and polyfluoroalkyl compounds known as “forever chemicals” have been found in some common pesticides. OIG also berated EPA for succumbing to Donald Trump’s interference with setting toxicity values for the “forever chemical” perfluorobutane sulfonic acid. These failures, Beyond Pesticides reported, were owing to a “deeper problem afflicting EPA: industry influence on career staff, and an unwillingness from the EPA to address it.”

Although the new OIG study does not focus on pesticides, its findings also apply to populations exposed to pesticides. The report says that EPA has developed neither the procedural protocols for analyzing chemicals across different environmental media and exposure routes nor the proper scientific tests to study chemical mixtures. Among the laws that require cumulative risk assessments for chemicals with a common mechanism of toxicity is the Food Quality Protection Act of 1996 (FQPA), an amendment to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), which specifically requires EPA to consider cumulative risk in setting tolerances for pesticides.

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

Encouraged by the pesticide industry, EPA only requires the “active” ingredient to be tested, and not the other elements of the mixture, because the latter supposedly has no effect. However, according to Drs. Sprinkle and Payne-Sturges, “In July 2016, an intensive search of applications for patents on pesticide formulations had reported that 96 of 140 (69 percent) had been described by their respective manufacturers as demonstrating ingredient synergies. These synergies, rather than going unmentioned out of fear that their documentation would increase regulatory scrutiny, were being presented to strengthen claims of novelty and, hence, patentability.” EPA could check patent records periodically to find honest industry information.

Tests used to justify the registration of pesticides are usually paid for and conducted by manufacturers or their subcontracted consultancies and laboratories. There is a fairly standard battery of animal tests in laboratories using regulatory toxicological protocols. But, Drs. Sprinkle and Payne-Sturges wrote that this approach “could not be expected to succeed at an integrative task, an environmental-ecological-epidemiological task. Yet laboratory toxicology remained the empirical arbiter of toxicant regulation.”

Moreover, EPA only considers the cumulative effects of groups of chemicals with the same mechanism of action, so any effects must be additive. It does not look for effects from combined chemicals and different mechanisms of action, even though there are many studies demonstrating this. As Patrick Masseo wrote in Environmental Health News, “[O]ur government still lacks a thorough and adequate process to conduct assessments of and to collect critical information about, the cumulative risk and impact of co-exposures such as vinyl chloride via air pollution and dioxins through groundwater contamination.”

Poor people of color often take the brunt of these co-exposures, and environmental justice is often ignored, even though the EPA has both legal obligations and executive instructions to support it. FQPA is a step forward in that it requires taking into account dietary and nondietary exposures, but it also has a huge loophole because it does not include occupational exposure. This omission has a disproportionate effect on people of color, particularly farmworkers and landscapers and their families.

EPA also ignores parts of the Superfund law, formally known as the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), which entails analyzing the effects of many chemicals at once because almost all Superfund sites contain multiple contaminants and nearby residents are exposed to them.

In its August report, OIG used EPA Region 4’s actions at the 35^th Avenue Superfund site in Birmingham, Alabama as a case in point. Although it has been partially remediated, there has been substantial industry interference with the process. Numerous industries, including two coal-fired coke plants, a cast iron pipe company, a paint and coatings company, an aluminum company, and several other industries are located there. These companies have emitted arsenic, lead, polycyclic aromatic hydrocarbon (PAH) benzo(a)pyrene, and other pollutants for more than 100 years. Three neighborhoods cluster around the Superfund site, and the EPA investigation found that soil from the largest coke plant had been used as yard fill on many home lots. The EPA has removed soil from about 650 homes in the three neighborhoods and spent about $46 million so far.

This area of North Birmingham was crucial to the Civil Rights Movement of the 1950s and 1960s. Bethel Baptist Church in the Collegeville neighborhood was a gathering spot for participants in the Freedom Rides. The church was bombed three times during the era. This hard-fought history may be one reason why some residents want to stay in the neighborhood and see it thoroughly cleaned up rather than moving elsewhere.

The Agency for Toxic Substances and Disease Registry (ATSDR), part of the Centers for Disease Control and Prevention, conducted a public health consultation with the 35^th Street community. The investigation covered only surface soil and garden produce exposures and only measured levels of arsenic, lead, and benzo(a)pyrene in residents’ blood, even though the pollution in the area contains many other substances. Nor did the ATSDR consider the cumulative impacts of these toxicants combined.

While ATSDR did not find blood lead levels above the EPA reference value of 5 µg/dL, the agency also noted that, even below that threshold, children are at risk of decreased academic achievement, lowered IQ, attention deficits, hearing problems, and delayed growth and puberty. Lead also crosses the placenta and can create a risk of miscarriage, premature birth, low birth weight, and damage to a fetus’s brain, kidney, and nervous system. Children who play in dirt and ingest it are at particular risk. In adults, lead contributes to kidney problems, hypertension, cardiovascular disease, and cognitive dysfunction.

Notably, ATSDR’s “next steps” section of its consultation lists seven actions to be taken, five of them directed at parents, such as “prevent[ing] their children from intentionally or inadvertently eating soil, especially for those yards with elevated arsenic, lead, and PAH levels that have not yet been cleaned up and for those yards that have not yet been tested.” These recommendations shift the burden of public health once again to individuals.

The industry has brought further cleanup to a standstill. In 2018, a Birmingham attorney and a vice president of the coke plant responsible for most of the emissions, now owned by the Drummond Company, were convicted of bribing a state legislator to prevent EPA from adding the site to the National Priorities List.  A listing would have enabled long-term cleanup of the area. The EPA could send the bill to the company, and the State of Alabama would have to pay 10% of the cost, which it wanted to avoid. The state environmental director argued that “the site did not pose a health hazard to people living there,” according to AL.com. To keep the state out of the costs of cleanup, the lawyer and the executive bribed the legislator with a $375,000 contract to work against the listing. To date, the 35^th Street Superfund site has not been added to the NPL.

In its August report, OIG states EPA has not coordinated efforts across divisions responsible for enforcing various laws like the Clean Water Act, TSCA, the Clean Air Act, and FQPA because, preposterously, it did not think it had executive or legislative authority to do so. EPA is divided into sections based on these laws, and the sections do not have a history of talking to each other despite the clear legal obligations. This inertia contributes to delays in providing environmental justice to exposed communities and resolving the glaring issue of chemical mixtures.

There is one federal agency that seems to get it. In the mid-2000s, the National Institute of Environmental Health Sciences (NIEHS) began addressing the mixtures problem and its implications for environmental justice. According to Drs. Sprinkle and Payne-Sturges, under the directorship of Linda Birnbaum, PhD, NIEHS began to support research into the “exposome,” meaning “the totality of an individual’s exposure before conception onwards through the lifespan, plus the microbiome plus the genetic and epigenetic diversity of human vulnerability.”

However, since 2016, the undertow of political interference has restricted its ability to achieve this goal. Its reach is also limited because the NIEHS is not a regulatory body and is without the requisite authority to make substantive policy changes. In the meantime, interference with regulatory actions at the EPA is likely to yo-yo again unless there is stability in the executive branch.

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

Source: The EPA Needs to Further Refine and Implement Guidance to Address Cumulative Impacts and Disproportionate Health Effects Across Environmental Programs, Office of Inspector General, U.S. Environmental Protection Agency, 23-P-0029, Aug.22, 2023.

(Beyond Pesticides, September 5, 2023) Lincoln County, Oregon  community members are fighting a plan announced by a private landowner to aerially spray 473 acres of clear-cut forest over the Beaver Creek watershed with a pesticide mixture containing carcinogenic glyphosate (commonly found in Roundup). 

The aerial spraying is slated to take place approximately one mile from a water intake at Seal Rock Water District, which supplies water to 5,500 residents. Beyond the risks to human health, residents are concerned about the impacts on wildlife in the creek valley. Local advocates describe the area to include native wetland plants, birds, and fish, including the federally protected Coho Salmon and Marbled Murrelet, beaver, river otter, and roaming elk herds. Beavercreek is also a protected state natural area, where families paddle and walk along the state park marshlands. 

Neighbors of Beaver Creek and the surrounding community are organizing phone banking, public art displays, and a petition urging Governor Tina Kotek to put a moratorium on the spray operation. One of the efforts displays the message “legalized poisoning of 5,500 people” through lights projected onto a basalt rock formation at Seal Rock State Park. The community has gathered over 2,000 petition signatures and over 100 public comments to the Oregon Department of Forestry in opposition to the pesticide spraying. A group of residents from the Seal Rock Water District and the neighbors of Beaver Creek basin have also set up a Go-Fund-Me fundraising webpage for expenses and legal fees.

A press release by Stop the Spray, a coalition of community members in the Beaver Creek watershed, says, “The question is whether the people who live in Beaver Creek and downstream have a right to decide what goes into the water they drink… So many have been asking, ‘How is this even legal?’ The community response seems to be, We don’t know, but we’re about to change it.”

The Seal Rock Water District (SRWD) issued a press release in response to residents’ concerns about the anticipated aerial pesticide spraying. The statement said SRWD plans to develop a management plan to protect the water system including: 

1. Shutting the Beaver Creek intake pump station off during the application of herbicides,
2. Allowing the flow in the creek to “move through the stream beyond the POD” (point of diversion), 
3. Sample the raw water and “if results are non-detect, the district will resume operation”
4. If hazardous chemicals are detected the district will report results to the Department of Environmental Quality and Pesticide Educational Resource Collaborative (PERC). PERC is a collaboration between the EPA’s Office of Pesticide Programs, the University of California Davis Division of Continuing and Professional Education, and Oregon State University.  

The statement says SRWD has a “5-day supply of water depending on the time of year.” At the time of this writing, the SRWD website displays a drought warning about low streamflow, high temperatures, and “drier-than-normal conditions” since August 2nd, 2023. 

Residents in Lincoln County have been battling aerial pesticide spraying and drift since the 1970s.  More than five years ago, in an effort to establish more protective pesticide regulations than those provided by the state, voters in Lincoln County approved a ballot measure to establish a county-wide ban on aerial spraying of pesticides.  

In 2017, the issue of whether the state of Oregon has the legal authority to stop a locality from adopting stronger restrictions than the state went to the courts. Landowners Rex Capri and Wakefield Farms, LLC, both of whom use aerial spraying on their properties, filed a legal challenge to the ordinance.

The issue of who has the authority to restrict “toxic trespass” came up in an interview with Ann Kneeland, an attorney for the case’s defendant, Lincoln County Community Rights. Attorney Kneeland said in the Oregon Constitution, all power is inherent in the people, who may reform or abolish the government. Proponents of the ban claim, that the power to self-govern is stated in the Oregon Constitution, which supersedes state laws that preempt (limit the authority of) local governments. 

In 2019, A Circuit Court judge in Lincoln County overturned the county ban on aerial spraying of pesticides, citing the preemption of state law over any local ordinance. Beyond Pesticides commented, “This is a very interesting story in American democracy. How did we get to this point in the history of the [U.S.] that we have taken away the local police powers of our local jurisdictions to protect the local public health of our people? This challenges a basic tenet that this country is based on — local governance.”

Now that the county ban on aerial spraying has been lifted, private landowner Sorn Nymark has received a permit to spray in early September and can be active for 90 days after the start date. In a letter to Mr. Nymark, the Lincoln County Board of Commissioners said, “Oregon law makes the decision to spray or not to spray yours. Your ownership of our precious natural resources also comes with a clear ethical, if not legal, obligation to protect them. We urge you to seek alternative means to control unwanted vegetation.”

To learn more about this local battle to protect residents, visit the “Stop the Spray” coalition website here.

Beyond Pesticides has highlighted and advocated against the poisoning and contamination caused by aerial pesticide spray drift since its inception in 1981, addressed in Getting the Drift on Chemical Trespass. The organization’s monitoring of drift issues is ongoing and can be seen in its “Pesticide Drift” archives. The long history of nontarget exposure, contamination, and poisoning teaches that drift is a function of pesticide use, but not considered adequately by regulators who allow the marketing of poisons that are known to move through the environment uncontrolled.

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

Source: Oregon Coastal Community Braces for Pesticide Spray Over Watershed

(Beyond Pesticides, September 1, 2023) As we celebrate Labor Day—a day of acknowledging workers and the work of labor unions—it is essential to remember workers’ contributions to society and consider the challenges they face. Recent reports of Hollywood writer and actor strikes, and Starbucks and Amazon store union petitions have created a sense of a booming union movement. However, there is an ongoing decline in the percentage of the unionized workforce. Although public-sector unionization has experienced slight fluctuations (dropping from 36.7 percent to 33.1 percent between 1983 and 2022), the most significant decrease has occurred in the private sector, where rates dwindled from 16.8 to 6 percent.

While the decline of labor unions is a significant challenge, there is hope for the future if we work to enact meaningful reforms that empower workers and strengthen the labor movement. That’s why, this Labor Day, it is especially appropriate that we continue to express gratitude to all workers—healthcare workers, farmworkers, landscape workers, food processors, grocery workers, and others who put their lives on the line every day.

But our gratitude does not protect anyone’s health. Nobody should have to risk their health for a job. As we as a nation recognize that systemic change is needed to fight racial and economic injustice, we are faced with questions that go to the core of our society—the distribution of wealth, a livable wage, investment in and access to education and health care, protection of the right to vote, and a workplace and environment that sustains life.

The community must renew our commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color who suffer elevated levels of harm. We can do this through the adoption of local, state, and national policies that eliminate toxic pesticide use, which disproportionately affects workers. This is a moment for building coalitions in our communities to advance policies that ensure all aspects of a healthful life and environment, supported by our social structures. In doing this, we recognize that we must join together to build the necessary power to effect meaningful and transformational change that confronts the existential public health (including worker health), climate, and ecological crises.

Beyond Pesticides’ work to advance systemic change will continue to seek changes in underlying policies that codify disproportionate harm, such as federal pesticide law that is built on a foundation that allows elevated and disproportionate risk to workers who are excluded from EPA’s cumulative risk assessment (under the Food Quality Protection Act, amendments to the Federal Food, Drug and Cosmetic Act and the Federal Insecticide, Fungicide, and Rodenticide Act), which aggregates dietary and nondietary exposure, but explicitly does not include occupational exposure to pesticides, while including a mandate to protect children. With this, the law effectively requires the U.S. Environmental Protection Agency (EPA) to allow higher rates of harm for workers, particularly farmworkers, landscapers (workers who are disproportionately people of color), and others occupationally exposed to pesticides. As we rethink our approach to pesticide reform, we ask: Should a science-based, public health-oriented, occupational safety-focused, children-concerned, ecologically protective society allow the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? The answer, of course, is “no.”

Now is the time to eliminate worker and community hazards by adopting organic land management practices and policies in all our communities. We can eliminate petroleum-based, toxic pesticides and fertilizers, protect workers, and achieve beautiful landscapes and safe playing fields and parks. With increased momentum nationwide, in all parts of the country, all communities can make the transition, as we work with states and the federal government to eliminate our unnecessary dependence on toxic pesticides.

Labor Day is a time to reflect on the progress that has been made in the labor movement and to consider the challenges that workers face today. The holiday is an opportunity to reflect on the labor movement to come from and where it can go.

With this understanding, we must rethink our approach to pesticide reform, including a legislative proposal before Congress introduced earlier this year, that, while well-intentioned, reaffirms institutional biases that codify environmental racism by not embracing changes that question the need for pesticides in view of the availability of nontoxic and organic alternatives.

The time for systemic change is now. In our communities, let’s protect the workers, public health, and the environment. To discuss transitioning your community to organic land management, see Beyond Pesticides’ Parks for a Sustainable Future, and contact [email protected].

Source: Union Member Summary, Labor unions aren’t “booming.” They’re dying., History.com

(Beyond Pesticides, August 31, 2023) A study published in Environmental Research finds glyphosate levels in the body adversely affect neurological health. Specifically, oral intake (e.g., eating contaminated foods), inhalation, and dermal exposure to glyphosate lowered cognitive function scores, heightened likelihood of severe depressive symptoms, and impaired auditory (hearing) function. Thus, this study provides some of the first evidence linking glyphosate exposure to specific neurological health outcomes among the general U.S. population, indicating the need for further studies on mechanisms driving neurotoxicity and the medical significance over time. Although this study is among the first to highlight specific neurological effects from glyphosate exposure among the general population, this study is not the first to identify potential neurotoxicity from glyphosate exposure. (Previous research cited below.)

The ubiquity of glyphosate uses in agriculture—which leaves residues of the toxic chemical in food—and in public areas (e.g., parks, and walkways) may mean that exposures to it represent a significant risk factor for the disease. Glyphosate is already implicated or proven in developing numerous health anomalies, including cancer.

The neurological system, including the brain, spinal cord, and a vast network of nerves and neurons, is responsible for many bodily functions—from sensation to movement. However, pesticides play various roles in causing or exacerbating negative health outcomes like neurotoxic effects and chemical damage to the nervous system. The impacts of pesticides on neurological function are hazardous, especially for chronically exposed individuals (e.g., farmworkers) or during critical windows of vulnerability and development (e.g., childhood, pregnancy). Mounting evidence over the past years shows that chronic exposure to sublethal (low) levels of pesticides adversely affects the central nervous system (CNS) and neural receptors, such as connections between nerves, the brain, enzymes, and DNA. Specifically, researchers identify agricultural chemical exposure as a cause of many adverse CNS impacts and neurological diseases, including Alzheimer’s, amyotrophic lateral sclerosis (ALS), and Parkinson’s disease. Therefore, it is essential to understand how toxic chemical exposure can potentially damage neurological function, ultimately leading to more severe health anomalies among future generations.

The study notes, “While the directionality and clinical significance of these associations require further investigation, our findings underscore the need for continued research on the potential neurological effects of glyphosate exposure in adults. Such research can inform public health policy and regulatory decisions regarding glyphosate use and ultimately contribute to the protection of human health.”

Although occupational studies find links between neurological impairment and glyphosate exposure, much less research focuses on general population exposure as the general public still encounters glyphosate exposure through various mediums (e.g., contaminated food and water, proximity to pesticide-treated areas). Using data from the 2013–2014 National Health and Nutrition Examination Survey (NHANES), glyphosate exposure (through urinary sample analysis) and cognitive function, depressive symptoms, disability, and neurological medical conditions among the U.S. population. The study examines 1523 individuals aged 18–80 years old. The study finds 80.4% of participants have detectable levels of glyphosate in their urine.  The analysis finds a significant association between urinary glyphosate levels and memory impairment as established by the Consortium to Establish a Registry for Alzheimer’s Disease Word List Memory Test (CERAD-WLT). Regardless of glyphosate levels, the presence of glyphosate in urine indicates an increased risk for severe depressive symptoms. Lately, this study finds serious hearing difficulties arose in individuals with higher urinary glyphosate concentrations.

Glyphosate is the most commonly used active ingredient worldwide, appearing in many herbicide formulations and readily contaminates soil, water, food, and other resources. Decades of extensive glyphosate herbicide use (e.g., Roundup) have put human, animal, and environmental health at risk. Four out of five U.S. individuals over six years of age have detectable levels of glyphosate in their bodies. Exposure to glyphosate has implications for the development of various health anomalies, including cancer, Parkinson’s disease, developmental and birth disorders, and autism. Although the U.S. Environmental Protection Agency (EPA) classifies glyphosate herbicides as “not likely to be carcinogenic to humans,” stark evidence demonstrates links to various cancers, including non-Hodgkin lymphoma. EPA’s classification perpetuates adverse impacts, especially among vulnerable individuals, like pregnant women, infants, children, and the elderly. Glyphosate’s ubiquity threatens 93 percent of all U.S. endangered species, resulting in biodiversity loss and ecosystem disruption (e.g., soil erosion, loss of services, and trophic cascades). Moreover, chemical use has been increasing since the inception of crops genetically modified to tolerate glyphosate. Not only do health officials warn that continuous use of glyphosate will perpetuate adverse health and ecological effects, but that use also highlights recent concerns over antibiotic resistance. Therefore, as glyphosate persists in the environment through continuous use, threats to human, animal, and environmental well-being will only grow.

Regarding other findings linking glyphosate to neurotoxic effects, a 2022 Arizona State University (ASU) study found that glyphosate successfully crosses the blood-brain barrier, accumulating in the brain in a dose-dependent manner. Glyphosate accumulation in brain matter has the potential to elevate the expression of TNFα and accumulation of soluble beta-amyloid (Aβ) proteins commonly present in immune, inflammatory, and neurodegenerative diseases like Alzheimer’s disease (AD). Thus, the ASU study provides a potential mechanism and medically significant outcomes associated glyphosate and neurological impairment that researchers can apply to the current study to determine how glyphosate induces neurotoxicity.

The detectable levels of glyphosate in over 80 percent of patients raises concerns over unaccounted exposure sources since the elimination half-life of glyphosate is between 5.5 and 10 hours. Additionally, this study highlights that aminomethylphosphonic acid (AMPA), the metabolite of glyphosate, is commonly present in soil through degradation. However, AMPA is just as toxic as glyphosate and poses the same health risks. Therefore, transitioning pest management—in agriculture, land management, and household and personal care contexts—to nontoxic and organic approaches to eliminate ecosystem contamination is the critical step to take to protect the health and sustainability of all on Earth.

There is a lack of complete understanding of the etiology of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiological data. Pesticides themselves can possess the ability to disrupt neurological function. Pesticides’ impact on the nervous system, including the brain, are especially of concern for chronically exposed individuals or during critical windows of vulnerability and development. Therefore, studies related to pesticides and neurological disorders can help scientists understand the underlying mechanisms that cause neurodegenerative diseases. Although occupational and environmental factors, like pesticide exposure, adversely affect human health, regulatory reviews are plagued by numerous limitations in defining real-world poisoning, as captured by epidemiologic studies in Beyond Pesticides’ Pesticide-Induced Diseases Database (PIDD) and Daily News Blog. The adverse health effects of pesticides, exposure, and the aggregate risk of pesticides showcase a need for a precautionary approach to the regulation of pesticides as more precise research is conducted on occupational and residential pesticide exposure—allowing more complete determinations. Existing information, including this study, supports the clear need for a strategic shift away from pesticide dependency. For more information on the effects of pesticide exposure on neurological health, see Beyond Pesticides’ PIDD pages on brain and nervous system disorders, including dementia-like diseases, such as Alzheimer’s, and other impacts on cognitive function. 

Organic agriculture represents a safer, healthier approach to crop production that does not necessitate pesticide use. Beyond Pesticides encourages farmers to embrace regenerative, organic practices, consumers to purchase organic, and gardeners and municipalities to adopt organic land management practices. A complement to buying organic is contacting various organic farming organizations to learn more about what you can do. 

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

Source: Environmental Research

(Beyond Pesticides, August 30, 2023) Invasive yellow-legged hornets have been spotted near Savannah, Georgia, causing concern among agriculture officials. These hornets are known for their ability to prey on honeybees and other pollinators, and their presence in the United States is a cause for alarm. This is the first time a live specimen of this species has been detected in the open United States, according to the Georgia Department of Agriculture.

The hornets, which are native to Southeast Asia, have been spotted in other parts of the world, including Europe, where they have caused significant damage to bee populations. They are considered “invasive,” which means the hornet is not native and officials expect their introduction to result in economic, environmental, or health-related damage to humans, animals, plants, or the environment. In response to the sighting in Georgia, officials are taking action to eradicate the hornets before they can cause any harm to US agriculture.

One of the methods being used to eradicate the hornets is the localized use of the highly toxic insecticide cypermethrin on nests. The pesticide has been registered for use in agriculture and residential pest control since the 1970s. It kills insects such as mosquitoes, flies, ticks, and agricultural pests like boll weevils and bollworms. The Incident Data System published over 1,400 reports of harm caused by pesticides containing cypermethrin. The chemical has been classified as a Class C possible human carcinogen, and there is evidence that it can cause a range of health problems in humans, including skin irritation, respiratory problems, and neurological effects.

Cypermethrin belongs to the class of pesticides known as pyrethroids, which is gaining popularity despite raising concerns. A preponderance of the evidence shows that pyrethroids, such as cypermethrin, pose several concerning risks to human health. A 2014 study conducted by the University of California, Davis, revealed that homes with detectable levels of pyrethroids in floor wipe tests were associated with elevated levels of pyrethroids in urine. This suggests that exposure to these chemicals occurs within the household environment and enters the human body. The study included both adults and children in California communities, with 63% of participants having detectable pyrethroid levels in their urine.

The presence of pyrethroids in the body has been linked to adverse health effects. A 2013 Canadian study found a correlation between the use of pesticides in or around homes and higher scores on emotional difficulties and conduct problems tests in children. This was further supported by a French study, which strengthened the connection between childhood behavioral disorders and pyrethroid pesticide exposure.

Another significant concern is the impact on early childhood development. A 2017 study demonstrated that higher urinary metabolite levels of cypermethrin, a specific pyrethroid, were associated with an earlier onset of puberty in boys. This suggests that pyrethroid exposure might disrupt normal hormonal development, potentially leading to developmental issues. Additionally, the use of pyrethroids has been associated with an increased risk of cancer. A 2013 study found that termite applications of pyrethroids within a year of pregnancy doubled the risk of a child developing a brain tumor.

The persistence of pyrethroids within the home environment contributes to the high frequency of detections in the general population. Since these chemicals break down slowly, even a single application can remain present for an extended period. A 2019 study applied a pyrethroid in a test home and measured the concentration at 89.6% of the original concentration after 112 days after the application of the pesticide. Subsequent applications contribute to the accumulation of pyrethroids in the household. This persistence is particularly concerning for young children, who are more susceptible to exposure due to activities such as crawling and hand-to-mouth behaviors.

Beyond Pesticides Executive Director Jay Feldman commented, “Removal of opportunist colonizers, like the yellow-legged hornet, may be necessary based on an ecological assessment and an evaluation of the options to ensure a long-term solution compatible with environmental health, but we quickly need to develop biological tools, utilize traps, and adopt cultural practices, rather than rely on the use of toxic chemicals like cypermethrin.”

The discovery of the yellow-legged hornets in Georgia is a reminder of the importance of understanding the toxic chemicals, like cypermethrin, that are used to control unwanted and invasive species. Agriculture officials are urging the public to report any sightings of the hornets to help prevent their spread. In Georgia, you can email [email protected] or submit this form. In Florida, you can email [email protected] or call the Florida hotline 1-888-397-1517.

For almost every pest issue faced today, there exist effective alternatives to synthetic insecticides such as pyrethroids. The ManageSafe tool by Beyond Pesticides offers a comprehensive, step-by-step manual to assist individuals in pest management, covering various pests ranging from cockroaches and bed bugs to head lice and ants. To learn more about the balance between managing invasive species and the risks of using toxic pesticides read Meeting the Invasive Species Challenge.

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

Source: An invasive hornet that hunts honeybees is spotted in the U.S. for the first time, Chemical Watch Factsheet: Cypermethrin, Meeting the “Invasive Species” Challenge

(Beyond Pesticides, August 29, 2023) A study published in Insect Biochemistry and Molecular Biology finds the widely used azole fungicide, tebuconazole, has damaging impacts on the redox homeostasis (the process of maintaining balance between oxidizing and reducing reactions) and fatty acid composition in honey bees’ brain via oxidative stress. Acute, field-realistic sublethal exposure to tebuconazole decreased the brain’s antioxidant capacity, key antioxidant defense systems, and oxidative degradation and alteration of lipids (fats) in the brain. Thus, this study adds to the scientific literature on the adverse effects of chemical exposure on pollinator health, especially in sublethal concentrations. Degenerating cognitive skills can threaten honey bee survivability, decreasing colony fitness and individual foraging success. Much research attributes the decline of insect pollinators (e.g., commercial and wild bees and monarch butterflies) over the last several decades to the interaction of multiple environmental stressors, from climate change to pesticide use, disease, habitat destruction, and other factors.

Pollinator declines directly affect the environment, society, and the economy. Without pollinators, many plant species, both agricultural and nonagricultural, will decline or cease to exist, as U.S. pollinator declines, particularly among native wild bees, depress crop yields. In turn, the economy will take a hit, since much of the economy (65%) depends upon the strength of the agricultural sector. As the science shows, pesticides are one of the most significant stressors for pollinators. Additionally, the devastating impacts of pesticides on bees and other pollinators and the larger context of what has been called by scientists as the “insect apocalypse.” In a world where habitat loss and fragmentation show no sign of abating, scientists have concluded that the globe cannot afford to continue to subject its critically important wild insects to these combined threats. Therefore, studies like these emphasize the need for improved assessment for environmentally relevant levels of chemical exposure to honey bees.

The study notes, “[R]edox imbalance and oxidative stress-related negative consequences may be factors of crucial importance in the background of neurotoxicity and cognitive impairment observed by the abovementioned research groups in tebuconazole-exposed bees. Therefore, it is vital to understand whether tebuconazole may have a negative impact on the redox homeostasis of honeybees, possibly contributing to the development of further pathological conditions.”

Using adult honey bees, the researchers exposed the bees to acute sublethal, field-realistic concentrations of tebuconazole in high, medium, and low doses. The researchers analyze the fatty acid composition and oxidative factors in the brain of honey bees, including total antioxidant capacity (TAC), state of the glutathione defense system, the activity of glucose-6-phosphate dehydrogenase (G6PDH), superoxide dismutase (SOD), and xanthine oxidase (XO), and the production of malondialdehyde (MDA).

The results show tebuconazole has a profound impact on oxidation in the brain. It decreases antioxidant capacity, reducing the ratio of oxidized glutathione for preventing damage to important cellular components and disrupting antioxidant enzymatic defense systems, inducing lipid (fat) peroxidation (oxidative degeneration of fats) through elevated malondialdehyde levels.  This alters the fatty acid profile in honey bee brains.

The scientific literature demonstrates pesticides’ long history of adverse environmental effects, especially on wildlife, biodiversity, and human health. Most notably, pesticides are immensely harmful to pollinators. Over the last decade and a half, increasing scientific evidence shows a clear connection between the role of pesticides in the decline of honey bees and wild pollinators (e.g., wild bees, butterflies, beetles, birds, bats, etc.). Pollinators’ decline directly affects the environment, society, and the economy Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Hence, pesticide use fails to support sustainability goals, decreasing agricultural and economic productivity and social (human/animal) and environmental well-being.

The study emphasizes oxidative stress’ role in pesticide toxicity among nontarget species. An alteration in redox homeostasis has an association with many diseases and neurodegenerative disorders and may be a significant factor in regulating cell growth, senescence, and aging. Tebuconazole is a (tri)azole compound that can directly impact cellular metabolic processes like antioxidation. The chemical also has a history of affecting bee behavior, foraging effectiveness, pollination, learning, and colony development, indicating impact on the brain. Behavioral changes and an overall decrease in cognitive function have a strong correlation with triazole-induced oxidative stress.

Although literature on oxidative stress, neurodegenerative disorders and honey bees is lacking, this study provides evidence that future studies must assess how pesticides impact cognitive function among invaluable insects. Additionally, triazole fungicides can work synergistically with other bee-toxic pesticides, like neonicotinoids (insecticide), amplifying adverse effects on health. In fact, systemic neonicotinoid insecticides put 89% or more of U.S. endangered species at risk. The study attributed pesticide toxicity to the ongoing pollinator crisis, highlighting that more extensive research on triazole-mediated health effects is essential for the conservation of honey bees and endangered pollinators. The researchers say, “[T]he negative impact of tebuconazole on honeybees and contributes to the understanding of potential consequences related to azole exposure on pollinator insects’ health, such as the occurrence of Colony Collapse Disorder (CCD).”

Pollinator protection policies need improvements to safeguard all pollinators and the crops they pollinate. Beyond Pesticides holds that we must move beyond pesticide reduction to organic transition and commit to toxic pesticide elimination in our agricultural system to prevent the crop loss presented in this study. Pesticide elimination can alleviate the effect of these toxic chemicals on humans and wildlife. With EPA failing to take the most basic steps to protect declining pollinators, it is up to concerned residents to engage in state and community action and demand change. Moreover, the government should pass policies that eliminate a broad range of pesticides by promoting organic land management. Habitat in and of itself may assist, but it must be free of pesticides to protect wild pollinator populations.

To protect wild bees and other pollinators, check out what you can do by using pollinator-friendly landscapes and pollinator-friendly seeds, engaging in organic gardening and landscaping, and supporting organic agriculture through purchasing decisions. Learn more about the science and resources behind the adverse effects of pesticides on pollinators and take action against the use of pesticides. Buying, growing, and supporting organic will help eliminate the extensive use of pesticides in the environment. Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. For more information on the organic choice, see the Beyond Pesticides webpages, Health Benefits of Organic Agriculture, Lawns and Landscapes, and Parks for a Sustainable Future. 

Learn more by registering for the virtual 40th National Forum Series, Forging a Future with Nature: The existential challenge to end petrochemical pesticide and fertilizer use, starting on September 14, 2023. Visit our to Forum website.

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

Source: Insect Biochemistry and Molecular Biology

(Beyond Pesticides, August 28, 2023) As the need to eliminate petrochemical fertilizers looms large in the context of existing existential crises relating to health threats, biodiversity collapse, and the climate emergency, the leadership of the U.S. Environmental Protection Agency (EPA) is under increasing public scrutiny. One program that is being closely watched is the agency’s Safer Choice product labeling program which could, according to advocates, be strategic in differentiating in the marketplace those products that are not contributing to the climate crisis, biodiversity collapse, and dramatic health effects.

Beyond Pesticides is advocating, in response to a request for public comment from EPA (due September 11, 2023), that EPA (under its Safer Choice program) evaluate fertilizers for compatibility with natural systems, protection of soil organisms, waterways, human health, and helping to mitigate the climate and biodiversity crises. With the Safer Choice label, consumers—from farmers, landscapers, to gardeners—could determine at the point of sale which fertilizer products are not contributing to the floods, fires, and loss of life associated with the climate crisis.

Beyond Pesticides previously initiated an action urging that EPA’s Safer Choice program be more holistic and in sync with natural systems, not just a product substitution program. This week, Beyond Pesticides is taking action (see below) on a specific request to EPA that it labels certain fertilizers as Safer Choice for meeting standards that support the sustainability of life in agriculture, landscaping, and gardening as opposed to introducing (i) petrochemical fertilizers that contribute to the climate emergency, biodiversity collapse, and the destruction of biological systems, or (ii) biosolids that disperse hazardous contaminants. Written comments are due by September 11, 2023 (instructions below). 

EPA is considering expanding its Safer Choice program (not to be confused with Beyond Pesticides’ pre-existing Safer Choice program). EPA’s Safer Choice is a non-regulatory program that identifies alternative chemicals for a number of uses that meet expanded safety criteria. (For pesticidal uses, the program is called Design for the Environment (DfE), which has so far been limited to disinfectants.)  

Tell EPA to add fertilizer products to Safer Choice. | Comment text at the bottom of the page.

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. 

However, sometimes the choice of material drives the choice of system—as is the case for fertilizers. Chemical fertilizers—those granular, powdered, or liquid products identified by NPK (the percentages of nitrogen, phosphorus, and potassium)—consist of highly-soluble chemical salts that feed plants directly, but poison soil microorganisms. The choice of such fertilizers rules out an organic system in which fertility inputs feed organisms in the soil, which release substances that feed plants. Chemical fertilizers also contribute to climate change because they are produced with fossil fuels and limit the ability of soil to draw down (sequester) atmospheric carbon, thus undermining efforts to mitigate the climate emergency and the horrific fire and flooding events that destroy life. Chemical fertilizers, in addition, produce weak growth that invites insects to feed on the plants. Aphids, for example, have long been known to increase on plants fertilized with soluble nitrogen fertilizer. 

EPA encourages the land application of biosolids (sewage sludge), noting benefits to soil fertility and structure and other “economic and waste management benefits (e.g., conservation of landfill space; reduced demand on nonrenewable resources like phosphorus; and a reduced demand for synthetic fertilizers).” However, as summarized by the Guardian, “Now the practice is behind a growing number of public health problems. Spreading pollutant-filled biosolids on farmland is making people sick, contaminating drinking water and filling crops, livestock, and humans with everything from pharmaceuticals to PFAS.” Biosolids used as fertilizer also contribute plastic to the soil. Unfortunately, many products derived from biosolids are sold as “organic” fertilizers. 

The wise gardener or farmer chooses soil amendments that are not toxic to the soil, environment, or consumers. One way to ensure freedom from chemical fertilizers or biosolids is to look for the OMRI (Organic Materials Review Institute) seal. Organic standards specifically prohibit the use of sewage sludge (aka biosolids), but the home gardener may not always be able to discern the materials from which “organic” fertilizers are made. In addition, “organic” fertilizers sourced from composted manure generally come from nonorganic confined animal feeding operations (CAFOs) and may also contain undesirable contaminants, such as antibiotics, antibiotic resistance genes, pesticide degradants, or heavy metals. Since these contaminants are not regulated, Safer Choice could offer an additional indicator of safety for gardeners and farmers. 

Dates:

•  Virtual Listening Session: August 29, 2023, 2:00–3:00 p.m. EST. To receive the webcast meeting link and audio teleconference information before the meeting, you must register by 5 p.m. EST on August 28, 2023. 
• Special Accommodations: To allow EPA time to process your request for special accommodations, please submit the request on or before August 22, 2023. 
• Written Comments: Comments must be received on or before September 11, 2023. 

Tell EPA to add fertilizer products to Safer Choice. | Comment text at the bottom of the page.

This action uses Regulation.gov to submit comments to EPA’s docket. Comments must be submitted by September 11, 2023. Beyond Pesticides urges the public to consider submitting comments (copying and pasting the following is an option).

Comments to EPA

As EPA considers expanding the Safer Choice program, I request that it add the category of fertilizers or soil amendments.  

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. 

However, sometimes the choice of material drives the choice of system—as is the case for soil amendments. Chemical fertilizers—those granular, powdered, or liquid products identified by NPK (the percentages of nitrogen, phosphorus, and potassium)—consist of highly-soluble chemical salts that feed plants directly, but poison soil microorganisms. The choice of such fertilizers rules out an organic system in which fertility inputs feed organisms in the soil, which release substances that feed plants. Chemical fertilizers also contribute to climate change because they are produced with fossil fuels and limit the ability of soil to draw down (sequester) atmospheric carbon, thus undermining efforts to mitigate the climate emergency and the horrific fire and flooding events that destroy life. Chemical fertilizers, in addition, produce weak growth that invites insects to feed on the plants. Aphids, for example, have long been known to increase on plants fertilized with soluble nitrogen fertilizer. 

EPA encourages the land application of biosolids (sewage sludge), noting benefits to soil fertility and structure and other “economic and waste management benefits (e.g., conservation of landfill space; reduced demand on nonrenewable resources like phosphorus; and a reduced demand for synthetic fertilizers).” However, as summarized by the Guardian, “Now the practice is behind a growing number of public health problems. Spreading pollutant-filled biosolids on farmland is making people sick, contaminating drinking water and filling crops, livestock, and humans with everything from pharmaceuticals to PFAS.” Biosolids used as fertilizer also contribute plastic to the soil. Unfortunately, many products derived from biosolids are sold as “organic” fertilizers. 

The wise gardener or farmer chooses soil amendments that are not toxic to the soil, environment, or consumers. One way to ensure freedom from chemical fertilizers or biosolids is to look for the OMRI (Organic Materials Review Institute) seal. Organic standards specifically prohibit the use of sewage sludge (aka biosolids), but the home gardener may not always be able to discern the materials from which “organic” fertilizers are made. In addition, “organic” fertilizers sourced from composted manure generally come from nonorganic confined animal feeding operations (CAFOs) and may also contain undesirable contaminants such as antibiotics, antibiotic resistance genes, pesticide degradants, or heavy metals. Since these contaminants are not regulated, Safer Choice could offer an additional indicator of safety for gardeners and farmers. 

Please add the category of fertilizers or soil amendments to Safer Choice. 

Thank you. 

(Beyond Pesticides, August 22, 2023) A U.S. Geological Survey (USGS) and National Park Service collaborative survey report finds a harmful mixture of pollutants, including pesticides, pharmaceuticals, caffeine, methylparaben, algal toxins, and fecal and parasitic bacteria, in Pipestone Creek at Pipestone National Monument in Minnesota, U.S.— adding to evidence of widespread pesticide contamination in waterways across the U.S. Pesticide contamination in waterways is historically commonplace. A 1998 USGS analysis revealed pesticides are commonly found in all U.S. waterways, with at least one pesticide detectable. Thousands of tons of pesticides enter rivers and streams around the US from agricultural and nonagricultural sources, which contaminate essential drinking water sources, such as surface water and groundwater. As the number of pesticides in waterways increases, it has detrimental impacts on aquatic ecosystem health, especially as some pesticides work synergistically with others to increase the severity of the effect. Reports like these are significant tools for determining appropriate regulatory action to protect human, animal, and environmental health. 

The survey collected water samples from Pipestone Creek, the pipestone quarries, and Winnewissa Falls, all of which are on the U.S. Environmental Protection Agency’s (EPA) list of impaired waters for turbidity (reduced water clarity) and fecal coliform bacteria (E. coli). Turbidity and fecal coliform levels are high enough to suggest a probable health hazard.

With 21 water-quality samples from eight creek sites and three quarries, the researchers analyzed the samples for over 250 water-quality parameters and contaminants. All sample concentrations for nitrate, total nitrogen in Pipestone Creek, and some sample concentrations of total phosphorus in quarries exceed Minnesota standards and EPA nutrient criteria. Measurable concentrations of pollutants are present in samples, including 13 pesticides, five pharmaceuticals, two other types of micropollutants (caffeine and methylparaben), two algal toxins (cyanotoxins), three fecal indicator bacteria, and parasitic bacterium. The pesticides atrazine, deethylatrazine, metolachlor ethanesulfonic acid, and total coliform bacteria (fecal coliform and Escherichia coli [E. coli]) are detectable in all 21 samples. Although none of the pollutant concentrations exceed any Minnesota standards or EPA aquatic life benchmarks, except the acute toxicity benchmark for atrazine in nonvascular plants, federal regulation fails to consider the potential synergistic and additive threats of these chemicals and pathogens to ecosystems and organisms.

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

Previous USGS reports demonstrate that pesticides are ubiquitous in the aquatic environment and a pervasive contaminant of freshwater ecosystems. Many of the most commonly used pesticides in the U.S. are detectable in both surface and groundwater, which serve as drinking water sources for half of the U.S. population. However, Pipestone Creek reinforces an all too familiar pattern of pesticide contamination in waterways, not only across the U.S. but the globe. Pesticide-contaminated rivers and streams can discharge polluted water into oceans and lagoons like the Great Barrier Reef (GBR), where a mixture of over 20 different pesticides are present in 99.8% of GBR samples. Additionally, water quality surveys usually detect the presence of more than one pesticide compound in waterways and the possible toxicity on marine organisms. 

Pesticides can adversely affect terrestrial organism health (e.g., endocrine disruption, reproductive defects, neurotoxicity, cancer, etc.), exacerbating infectious disease prevalence, especially in these aquatic environments. For instance, pesticide pollution, attributed to runoff from agricultural farms, indirectly increased the rate of the tropical disease schistosomiasis in Kenya, infecting over 280 million people (2018). Schistosomiasis (snail fever), or bilharzia, is a tropical disease caused by parasitic flatworms (trematodes) in the genus Schistosoma and transmitted via freshwater snail (genus Biomphalaria) to its definitive human host. While the snail could withstand pesticide contamination, the chemical killed off predators of the freshwater snail, resulting in an unabated increase in freshwater snails as an intermediate host for the parasitic flatworms. Additionally, pesticides like glyphosate have antimicrobial properties that indiscriminately kill bacteria, most often living behind resilient, pathogenic bacteria like E. coli and Salmonella. These glyphosate-resistant strains alter gene function to enhance the outflow of glyphosate from the bacterial cell. Thus, this resistance mechanism can encourage cross-resistance against antibiotics for pathogenic bacterial species like E. coli and Salmonella.

Pesticide use can also create bacteria-dominant ecosystems as these chemicals cause “vacant ecological niches, so rare organisms become abundant and vice versa.” The bacteria outcompete beneficial fungi, improving soil productivity and increasing carbon sequestration capacity. The resulting soil ecosystem is unhealthy and imbalanced, with a reduction in the natural cycling of nutrients and resilience. Thus, like humans, plants grown in such conditions are more vulnerable to parasites and pathogens. 

Water is the most abundant and important chemical compound on earth, essential to survival and the main component of all living things. Less than three percent of that water is freshwater, and only a fraction of that freshwater is groundwater (30.1%) or surface water (0.3%) readily available for consumption. However, ubiquitous pesticide use threatens to reduce the amount of available freshwater as pesticide runoff, recharge, and improper disposal tend to contaminate adjacent waterways, like rivers, streams, lakes, or underground watersheds. With rivers and streams only accounting for 2% of surface waters, protecting these vulnerable ecosystems from further degradation, including aquatic biodiversity loss and a decrease in water quality/drinkability, is essential.

To protect the nation’s and world’s waterways and reduce the number of pesticides that make their way into your drinking water, reliance on pesticides must cease. Beyond Pesticides has long advocated for protective federal regulation that considers potential synergistic and additive threats to ecosystems and organisms from admixtures of pesticides — whether in formulated products or “de facto” in the environment. Unfortunately, current administration regulations fail to consider the environment holistically, thus creating limitations in the ability to enact widespread change that improves ecosystem health. However, advocating for local and state pesticide reform policies can protect you and your family from pesticide-contaminated water. Furthermore, organic/regenerative systems conserve water, nurture fertility, reduce surface runoff and erosion, reduce the need for nutrient input, and critically eliminate the toxic chemicals that threaten many aspects of human and ecosystem life, including water resources.

For more information about pesticide contamination in water, see the Threatened Waters program page and Beyond Pesticides’ article Pesticides in My Drinking Water? Individual Precautionary Measures and Community Action. Tell the U.S. Environmental Protection Agency to “turn off the tap” on forever chemicals and persistent toxic pesticides must be considered to pose an “unreasonable risk to the environment under FIFRA, resulting in the cancellation of their registrations.

Source: USGS

(Beyond Pesticides, August 23, 2023) Researchers are investigating a cutting-edge method to identify the impact of pesticides on reproductive health—shrinking the wait time from months to weeks. Scientists at the University of California, Davis, are developing a method for identifying harmful chemicals in pesticides with the help of glowing fish. This scientific breakthrough could revolutionize pesticide research and help prevent long-term health problems caused by exposure to these chemicals. 

Pesticide exposure can cause acute and long-term health problems for the human endocrine system, the hormone system that regulates many biological processes from reproduction to blood sugar, growth, and more. Beyond Pesticides has written about the connections between EPA-registered pesticides and involuntary abortions, reproductive cancers, pregnancy loss, early-onset puberty, and more.  

The American Academy of Pediatrics (AAP) has expressed concern over the limited or missing data regarding the health effects of pesticides and food additives on infants and children, who are more vulnerable to chemical exposures. AAP has identified several compounds as being of particular concern, including bisphenols, which are commonly used in the lining of metal cans; phthalates, which are used in adhesives and plasticizers; nonpersistent pesticides, which have been addressed in a previous AAP policy statement; perfluoroalkyl chemicals (PFCs), which are used in grease-proof paper and paperboard food packaging; perchlorate, an antistatic agent used for packaging in contact with dry foods with surfaces that do not contain free fat or oil; nitrates and nitrites; and artificial food coloring. In 2012, AAP issued a statement on childhood exposures to pesticides concluding that reducing pesticide exposures in foods may be significant for children. AAP also noted that choosing organic food, which has significantly lower toxic pesticide residues, is also beneficial to larger environmental issues, as well as human health impacts like pollution and global climate change. 

These risks to reproductive health and multigenerational impacts is where the red- and green-glowing zebrafish come in. Sean Burgess, PhD and Bruce Draper, PhD are developing a new approach with a genetically modified strain of zebrafish called Danio rerio. The modified or “transgenic” strains of fish have been developed through a process of altering the fishes’ DNA by combining it with DNA from other organisms or inserting foreign DNA. Fluorescent genes can be added to aid in tracking proteins, cells, and organs (like gonads and ovaries). The new strain of zebrafish, Danio rerio, displays their sex through color coding, with green fluorescent protein produced by Sertoli cells found only in the male gonad and red fluorescent protein produced by oocytes found only in the female gonad. By exposing a few dozen zebrafish larvae to a chemical and waiting several weeks to see if their sex ratio is skewed toward males, scientists can quickly determine if the chemical is harmful. 

The new method, developed by Dr. Burgess and Dr. Draper, is much faster than traditional methods, which require waiting until 90 days post-fertilization to distinguish sexually-mature male and female zebrafish visually. The UC Davis researchers claim that the fishes’ color-coded gonads should allow scientists to determine the sex of the genetically modified zebrafish within 10-20 days post-fertilization.  

Dr. Burgess, a professor in the Department of Molecular and Cellular Biology, studies the reproductive toxicity that can result in infertility, repeated miscarriages, or children with increased risk for Down syndrome and other chromosome disorders. Dr. Burgess said, “[The new method is] way more efficient than anything else out there right now. We have high expectations that this is going to work.” 

Traditional testing methods for pesticide impact on reproduction are often time-consuming and costly, as they rely on dissecting mice to find the chemical effects on reproductive tissues. To avoid this process, Zebrafish are freshwater fish native to South Asia and they are frequently used to study the early stages of human development. Dr. Draper said, “Seventy percent of the genes in zebrafish have human counterparts, called orthologs.” 

The researchers hope to begin using their “GloNad” assay for toxicity screening in a pilot experiment to screen nine of the most commonly used pesticides in California for reproductive effects. This initial test could eventually pave the way for broader use of the GloNad assay. Critics of transgenic strains, like the Danio rerio, have voiced moral, environmental, and public health concerns about genetic modification. However, Dr. Burgess and Dr. Draper are not planning to release the fish into the natural environment or sell them for consumption, rather they are being used for pesticide research alone.  

Ninety pesticides are currently known to the state of California to cause birth defects or reproductive harm and require cancer warnings under Prop65. But these toxicities could potentially be linked to a broader range of pesticides and other chemicals, such as the aforementioned bisphenols, which are used in manufacturing some plastics. 

The method developed by Dr. Burgess and Dr. Draper could benefit millions of people in California’s Central Valley, who are at elevated risk for exposure to pesticides because they live or work near agricultural production sites. With the help of red- and green-glowing zebrafish, scientists may be able to identify harmful chemicals far more quickly and prevent the long-term health impacts of pesticides. Read more about the connection between reproductive health and pesticides in Beyond Pesticides’ Daily News archives here.  

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

Source: Using Glowing Fish to Detect Harmful Pesticides 

(Beyond Pesticides, August 23, 2023) The use of pesticides on pets for fleas and ticks (parasiticides) has been traced to environmental contamination in a study that confirms earlier work both by the authors and internationally, according to researchers Rosemary Perkins, a veterinary surgeon, and David Goulson, PhD at the University of Sussex. The results are published in their recent study, “To flea or not to flea: survey of UK companion animal ectoparasiticide usage and activities affecting pathways to the environment,” which concludes that, “[T]he potential cumulative impact of parasiticide emissions [into the environment] from many millions of pets treated multiple times each year is of serious concern.”

The UK provides an opportunity to pinpoint water contamination from pet use for ectoparasites (e.g., fleas and ticks) of hazardous pesticides since, unlike in the U.S., the country has banned outdoor use of those chemicals commonly detected—the insecticides fipronil and imidacloprid (the same neonicotinoid bug killer tied to devastating losses of bees and other organisms). These findings confirm the historical peer reviewed scientific literature and defy the assumption of regulators that home or veterinary use of pesticides do not reach levels of concern for environmental contamination, either through exposure from down-the-drain (DTD) contamination or direct environmental transfer.

As the authors point out:

“Both fipronil and imidacloprid have been restricted for agricultural use in the UK due to concerns regarding their impact on non-target invertebrates. Fipronil’s approval for use as a plant protection product ended in 2017 (European Commission, 2019a) and the outdoor use of imidacloprid was banned in 2018 (European Food Safety Authority, 2018a). At present no plant protection products containing fipronil or imidacloprid are registered for use in the UK (Health and Safety Executive, 2022).” 

In 2016, a study of eight San Francisco Bay (San Francisco, CA, USA) wastewater treatment plants (WWTPs) reached a dramatic conclusion: “This first regional study on fiprole and imidacloprid occurrences in raw and treated California sewage revealed ubiquity and marked persistence to conventional treatment of both phenylpyrazole and neonicotinoid compounds. Flea and tick control agents for pets are identified as potential sources of pesticides in sewage meriting further investigation and inclusion in chemical-specific risk assessments.” In 2020, a team of researchers, including Dr. Goulson, found widespread contamination of English waterways with imidacloprid and fipronil, which they attributed to veterinary use, given the fact, in part, that the chemicals had by that time been banned for outdoor uses in the UK.

In the study, the authors identify numerous environmental exposure routes from ectoparasiticide (to treat insects on the body’s surface) pet use through: down the drain and waste water treatment plants, swimming and bathing after application, urine and stool after systemic absorption of the chemicals, washing of treated animals’ bedding and other contacted textiles, owners’ washing of hands, and shedding hair and skin. The data cited in the literature identifies significant environmental exposure that is overlooked or simply assumed to be low by regulators. As the authors note: “Further studies are required to quantify the load entering the environment through various pathways for the different parasiticides—including studies providing reliable emissions fractions for the routes and activities described above, and studies investigating the frequency of emitting activities. This study aims to shed light on the frequency of activities that are likely to lead to transfer of ectoparasiticides from pets to the environment, with a focus on DTD and direct pathways to waterways, including bathing of dogs (Teerlink, Hernandez & Budd, 2017), washing of their bedding (Jacobs et al., 2001) and swimming (Diepens et al., 2023).”

In the U.S., the cumulative environmental exposure pathway associated with pet use of pesticides raises issues of elevated exposure to aquatic system and adverse impact on the aquatic food web. As disclosed in the Beyond Pesticides piece Poisoned Waterways, alarms began to go off when the EPA found in its 2017 risk assessment for the most widely used neonicotinoid, imidacloprid, that, “[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates.” (USEPA. 2017. Preliminary Aquatic Risk Assessment to Support the Registration Review of Imidacloprid. Office of Chemical Safety and Pollution Prevention. Washington DC.) The agency evaluated an expanded universe of adverse effects data and finds that acute (short-term) and chronic (long-term) toxicity endpoints are lower (adverse effects beginning at 0.65 µg/L (micrograms per liter)-acute and 0.01 µg/L-chronic effects) than previously established aquatic life benchmarks (adverse effects from 34.5 µg/L-acute and 1.05µg/L-chronic effects). In its 2017 risk assessment, EPA finds risks from imidacloprid exposure to ecologically important organisms not previously evaluated as part of its regulatory review. Despite its acknowledgement that current benchmarks are not adequately protective, EPA describes its review process as requiring studies of the most sensitive organisms and a range of publicly available environmental laboratory and field studies. The addition of the veterinary use exposure pathway raises serious concerns in an environment that is already at or beyond the threshold of concern for aquatic life.

The pet study sets up a framework for quantifying the pathways of contamination as a result of veterinary use of parasiticides. The study authors generated 1,009 complete questionnaire responses on ectoparasiticide use data, looking at both use of oral medications (more popular among dog owners) and spot-on treatments (more popular among cat owners). This followed a pilot survey of 155 respondents (sample size of 385 people/household) from June to July, 2020. Participants were recruited from social media, over 18 years old, and included a mix of cat and dog owners. Over 81% of pet owners report that they were advised by veterinarians to use prophylactic flea/tick treatment throughout the year. Over 7% were advised to only use the chemicals during the warmer months. The study documents frequency of bathing and swimming of treated pets, and bed washing. The authors estimate the volume of use of the pesticides, with 9.4 million doses of imidacloprid (the most popular ectoparasiticide), with over one-third treated pets swimming at least once a month and over half being bathed once a month.

The study is indicative of exposure pathways of ectoparasiticides that, if not considered in the regulatory review of these chemicals, are missed as critical issues of environmental impact by regulators.

For information on caring for pets without toxic chemical exposure, see Beyond Pesticides’ Pets and Pesticides: Keeping Our Campanions Safe webpage. And always check out Beyond Pesticides’ Gateway on Pesticides Hazards and Safe Pest Management when using specific pesticide products to find out the toxicological and environmental information on pesticides, as well as alternatives to their use.

You have an exciting and unique opportunity to meet Dr. Goulson live at Beyond Pesticides 40^th National Forum, Forging a Future with Nature, September 14, 2023, 1:00-3:30pm(Eastern-US). You can register here.

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

Source: To flea or not to flea: survey of UK companion animal ectoparasiticide usage and activities affecting pathways to the environment

(Beyond Pesticides, August 22, 2023) A recently completed study (available in preprint before peer review) identifies the development of what the authors term “Toxicant-Induced Loss of Tolerance” (TILT), the constellation of symptoms associated with chemical exposures. The authors describe a two-part process. First, during initiation, a person is exposed at an acute level or repeated low-level doses to a toxicant, such as an organophosphate pesticide or a natural substance like mold, that triggers immune reactions from mast cells, which are crucial immune system regulators. Stage 2, or triggering, is when exposure to previously tolerated substances causes the mast cells to degranulate, or release many inflammatory molecules such as histamines and cytokines into the cellular environment. The work is spearheaded by Claudia B. Miller, M.D., immunology professor emeritus at the University of Texas Health Science Center at San Antonio, along with Nicholas Ashford, PhD, professor of technology at the Massachusetts Institute of Technology, and other researchers. Dr. Miller’s talk on the subject is found at Beyond Pesticides 2022 National Forum site (go to 7:50 time stamp).

Western medicine, for all its spectacular successes, has tended to view the human body as separate from its environment. Further, it divides the body into various systems and zones, which, though understood to be interrelated, have their own sets of symptoms, derangements, and diseases. In addition, the discipline of toxicology—especially regulatory toxicology—until very recently has been unable to account for exposure to multiple toxicants—pesticides, building materials, medical equipment, antibiotics, and molds—simultaneously or in series.

The last couple of decades, however, have begun to shed light on the consequences of exposure to many different chemicals that may affect different body systems and result in constellations of symptoms and disorders previously unconnected in the medical mind. Now people with what has been called Multiple Chemical Sensitivity (MCS) or Chemical Intolerance (CI) have a framework that begins to explain their problems. Some 15 percent to 36 percent of U.S. adults have reported symptoms of these disorders. Medical practitioners do not currently agree on the causes, development, or treatment of MCS/CI.

Dr. Miller finds that clinicians’ “failure to ask patients about possible initiating events has caused confusion concerning the origins of other comorbid conditions such as ADHD, autism, asthma, irritable bowel syndrome, migraine headaches, depression, anxiety, brain fog, and other cognitive and mood difficulties.” Moreover, Dr. Miller and colleagues note that in concurrent exposures to different toxicants, many symptoms are common to more than one, resulting in a “masking” effect. Once someone develops TILT, intolerances to structurally different chemicals may arise, ranging from pesticides and paints to anesthetics and hairdressing chemicals. Notably, women develop TILT more than men, possibly because women are more likely to use fragranced cosmetics, soaps, sprays, fragranced cleaning, and laundry products, usually in confined spaces. However, men are formally diagnosed with MCS more often, possibly reflecting medical gender bias.

In 2021 Beyond Pesticides reported on a study in which the researchers investigated initiating events by studying eight groups with chemical intolerance who had known exposures to different toxicants: EPA workers in offices where new carpet was installed; Gulf War veterans; casino workers exposed to organophosphate pesticides; pilots and cabin crews breathing aircraft oil fumes; World Trade Center first responders and others in close proximity to the buildings; breast and other implant recipients; people exposed to mold at home; and tunnel workers breathing benzene. Among these groups, volatile organic compounds (VOCs), which were present in nearly all the toxicants studied, were the most common initiators.

Some of the most egregious exposures were suffered by military members during the Gulf War, who were required to swallow pyridostigmine bromide to help defend against possible chemical weapons. This compound’s effects resemble those of organophosphate pesticides. Some 100,000 soldiers were directly exposed to sarin and cyclosarin when the U.S. blew up an Iraqi weapons depot. In addition, soldiers’ uniforms were saturated with lindane, an organophosphate pesticide and member of the Stockholm Dirty Dozen now banned for U.S. agricultural use but still allowed as a second-line treatment for lice and scabies. Permethrin, a pyrethroid insecticide, was also used on uniforms, and in combination with the insect-repellent DEET (also given to soldiers), it has neurotoxic effects.

In this previous study, the authors noted that the post-World War Two expansion of petrochemicals into pesticides, solvents, dyes, and fragrances mushroomed, and in the 1970s building construction became more airtight even as Americans spent more and more of their time indoors—the latter proportion now at 90 percent. This has resulted in more people being exposed to a staggering array of synthetic chemicals (defined by the authors as compounds not found in nature) and molds, which release naturally-occurring VOCs.

The authors of the current study also take the medical profession and research scientists to task for two things. Many clinicians dismiss chemical sensitivities as “Medically Unexplained Symptoms” or psychosomatic issues, sometimes labeled “idiopathic environmental intolerance.” Dr. Miller and colleagues are pushing to replace these terms with TILT. They provide two questionnaires, available on the University of Texas website, that individuals can complete and present the results to their medical caregivers. The advantage of TILT, they say, is that it provides both a suggested mechanism by which sensitivity is started and an explanation for how exposures to different toxicants result in common symptoms stemming from the activity of mast cells, which have broad influence over immune responses to many different challenges.

Scientific tunnel vision has affected the way medicine defines and diagnoses chemical intolerances. “Allergy and toxicology as currently practiced appear to have overlooked the two steps of TILT and the fact that toxic exposures can sensitize mast cells,” according to the current study. Mast cells are part of the innate immune system, which responds to acute or persistent infections or injuries. They signal other immune cells using the inflammatory biomarkers cytokines and chemokines. Dr. Miller and colleagues note that mast cells are present in large numbers in the gut, also home to trillions of microbes that are disrupted by antibiotics and pesticides. They add, “Future research should explore the mechanism by which exposures and/or alterations in the gut microbiome may compromise our ancient mast cells and innate cell-mediated tolerance.”

The study was based on 10,981 responses to a 2020 Survey Monkey questionnaire that used the same questions as those available on the University of Texas Health Science Center website. These ask participants about medical diagnoses, exposures to chemicals, antibiotic use, and the timing of the onset of their condition. The survey also asked the participant to identify what they believed was the condition’s cause.

More than half of the respondents were women, most of them under 60. Two-thirds of respondents were unable to identify an initiating event. For respondents reporting more than one initial exposure, each additional event tripled the chance they would have TILT.

Overall, a fifth of respondents met the study criteria for TILT. The most frequent initiating exposure was reported as mold, with pesticides second, and in decreasing order, new construction or remodeling materials, medical procedures, fires, and implants. Antibiotics used for long periods to treat infections in several organs were also associated with the onset of TILT.

The researchers stressed that we need “policies and practices that reduce initiating exposures as well as ubiquitous and often unavoidable triggers such as fragranced personal care, cleaning, and laundry products in multi-occupant housing, workplaces, medical settings, schools, places of worship, and all public buildings—literally anywhere air is shared.”

The current study does have limitations. Although it does have a large number of participants, it is based on individual self-reporting and not a direct measurement of the physiological processes associated with TILT. The participants were not randomly selected, and there was no control group. Also, only around half of the participants could attribute their initial symptoms to a specific event. Despite these constraints, the cumulative evidence Dr. Miller has produced finds that people in large numbers are suffering the consequences of the “exponential increase in exposures to toxicants derived from fossil fuels and biological sources, coupled with reduced fresh air in buildings” and the authors conclude that “TILT has become epidemic.” [Emphasis in original.]

Finally, Dr. Miller and colleagues emphasize that fossil fuels “are assaulting humans and other animal species both from within via mast cell sensitization and from without via climate change.” [Emphasis in original.] A low-carbon civilization, relying on ecosystem-level biochemistry rather than a single protein, an insidious and harmful source of energy and materials, might both survive climate catastrophe and enjoy a drastic improvement in human health.

For more information:

• Take the questionnaires used in the studies
• See a video from Beyond Pesticides’ 2022 Virtual Seminar featuring a talk with Dr. Miller and Kaipo Kekona, an indigenous Hawaiian working to restore traditional farming techniques
• Read a transcript of a talk given by Doris Rapp, MD published in our Pesticides and You newsletter
• Visit the University of Texas, San Antonio website for the Hoffman TILT program
• View a presentation by Dr. Miller at the Hoffman TILT program

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

Source: What Initiates Chemical Intolerance? Findings from a Large Population-Based Survey of U.S. Adults

(Beyond Pesticides, August 21, 2023) As the U.S. Environmental Protection Agency’s (EPA) Safer Choice program asks for public input into the expansion of its work to label green chemicals, the need to recognize the importance of holistic management systems in sync with nature looms large. Will simple chemical substitution ignore the value of natural processes that require nurturing for sustainable future? EPA’s Safer Choice is a non-regulatory program that identifies alternative chemicals for a number of uses that meet expanded safety criteria.

Tell EPA and Congress that substituting chemicals alone is not the Safer Choice. Use Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers can look for products with the Safer Choice label, which requires that EPA review all chemical ingredients that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/Design for the Environment (DfE) program performs alternatives analyses on chemicals and identifies chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. [For pesticidal uses, the program is called Design for the Environment (DfE), which has so far been limited to disinfectants.]

Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA), is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural (nonsynthetic) or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food.

The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by available organic methods.

Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.” There are two ways that the Safer Choice program could improve CWA implementation. First, the chemical and toxicological analyses required by Safer Choice could identify priorities for elimination. Second, the Safer Choice alternatives analyses could identify alternative processes that could eliminate those substances and create a list of substances for which NPDES permits might be allowed for specified uses—analogous to the National List in NOP.

In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program.

These applications are consistent with policies of EPA and the Biden administration. EPA characterizes Safer Choice as being part of the agency’s pollution prevention (P2) program, which EPA defines as “any practice that reduces, eliminates, or prevents pollution at its source prior to recycling, treatment, or disposal.” EPA says, ““Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer and industrial sectors. Prevention practices are essential for preserving wetlands, groundwater sources and other critical ecosystems – areas in which we especially want to stop pollution before it begins.” P2, in concert with President Biden’s Executive Order 14057 on catalyzing American clean energy industries and jobs through Federal sustainability and accompanying Federal Sustainability Plan, establishes a framework for applying Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

Note: Beyond Pesticides will continue the discussion on Safer Choice in future postings, both in the context of suggesting an expansion of the program, as well as in the context of what is needed to meet the challenges of severe health threats, biodiversity collapse, and the climate emergency—systemic change in the way synthetic chemicals are regulated.

Tell EPA and Congress that substituting chemicals alone is not the Safer Choice. Use Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

Letter to U.S. Representative and Senators:
EPA is considering expanding its Safer Choice program—a non-regulatory program that identifies alternative chemicals that meet expanded safety criteria for specified uses. Substituting chemicals alone is not the safer choice. Safer Choice should be expanded and used to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, which must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice program does an admirable job of performing alternatives analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods.

Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA) is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food.

The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by organic methods.

Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.” The Safer Choice program could improve CWA implementation by identifying priorities for elimination and identifying alternative processes that could eliminate those substances. Analogous to the National List in NOP, a list of allowable discharges could be created.

In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program.

These applications are consistent with current policies. EPA characterizes Safer Choice as being part of the agency’s pollution prevention (P2) program. EPA says, “Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer and industrial sectors.”

Please encourage EPA to use P2, in concert with President Biden’s Executive Order 14057 and Federal Sustainability Plan, to apply Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

Thank you.

Suggested comment for EPA, which can be submitted at Regulation.gov through EPA’s docket: Please consider copying and pasting the following into your comment here:

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, which must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternatives analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to organic methods.

Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA) is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural (nonsynthetic) or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food.

The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by organic methods.

Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.” There are two ways that the Safer Choice program could improve CWA implementation. First, the chemical and toxicological analyses required by Safer Choice could identify priorities for elimination. Second, the Safer Choice alternatives analyses could identify alternative processes that could eliminate those substances and create a list of substances for which NPDES permits might be allowed for specified uses—analogous to the National List in NOP.

In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program.

These applications are consistent with policies of EPA and the Biden administration. EPA characterizes Safer Choice as being part of the agency’s pollution prevention (P2) program, which EPA defines as “any practice that reduces, eliminates, or prevents pollution at its source prior to recycling, treatment, or disposal.” EPA says, ““Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer and industrial sectors. Prevention practices are essential for preserving wetlands, groundwater sources and other critical ecosystems – areas in which we especially want to stop pollution before it begins.” P2, in concert with President Biden’s Executive Order 14057 on catalyzing American clean energy industries and jobs through Federal sustainability and accompanying Federal Sustainability Plan, establishes a framework for applying Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

Please expand Safer Choice and use it to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

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

Note: Beyond Pesticides began its Safer Choice program prior to EPA’s.

(Beyond Pesticides, August 18, 2023) Yesterday, three environmental organizations filed a lawsuit against the U.S. Department of Interior for failing to protect the Dungeness National Wildlife Refuge from industrial aquaculture. The groups, including Protect the Peninsula’s Future, Coalition to Protect Puget Sound Habitat, and Beyond Pesticides, filed their complaint in the U.S. Western District Court of Washington State. The complaint states that the U.S. Fish and Wildlife Service (USFWS), U.S. Department of Interior, must “take action that is required by the Refuge Improvement Act and conduct a compatibility determination and require a special use permit for a proposed industrial aquaculture use” that will abut and impact the Refuge. The plaintiffs are represented by the Seattle, WA law firm of Bricklin and Newman LLP.

The shellfish operation leases 50 acres of Washington State bottomlands; 34 acres to be covered with up to 80,000 plastic bags of non-native shellfish and staked into the bottomlands, potentially killing all benthic life underneath and snaring wildlife in the netting. This operation would shift the natural year-round-sediment movement, directing the sediment into the eelgrass beds – beds protected for rearing salmon for whales and nourishing particular migratory ducks. Additionally, the plastic bags will cover primary feeding grounds for residential and migratory birds.

“Despite knowing the gravity this portends, unfortunately, the USFWS has side-stepped its authority to consider the compatibility of the industrial shellfish operation with the Refuge and residual harm to the wildlife and their habitat,” said Laura Hendricks, executive director of Coalition to Protect Puget Sound Habitat.

“Migratory birds suffer much on their lengthy journeys each fall and winter – air pollution, water pollution, toxic fumes. Now they face starvation as their reliable feeding grounds will be taken. This cannot be allowed,” said Darlene Schanfald with Protect the Peninsula’s Future.

“The USFWS is supposed to protect the species and habitats, not enable their peril. We are asking the court to tell the agency to do its job,” said Jay Feldman, executive director of the Washington, D.C. organization Beyond Pesticides. “This is also troubling because it will set a precedent for all other national refuges to allow industrial shellfish operations,” Mr. Feldman said.

The Dungeness National Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” The Refuge provides habitat, a preserve, and breeding grounds for more than 250 species of birds and 41 species of land animals.

The front page of the Refuge website states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture.

Contact: Darlene Schanfald, Protect the Peninsula’s Future, 360-681-7565, [email protected]
Laura Hendricks, Coalition to Protect Puget Sound Habitat, 253-509-4987
Jay Feldman, Beyond Pesticides, 202-255-4296, [email protected]