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

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

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

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

available.”

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Letter to Congress:

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

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

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

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

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

Sincerely,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Take Action

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

Post Your Comment by January 19:

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

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

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

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

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

Source: Florida Phoenix, Center for Biological Diversity

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you.

Sincerely,

Letter to U.S. Senators:

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

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

Please support hearings on a Green New Deal.

Thank you.

Sincerely,

(Beyond Pesticides, January 4, 2019) First, the good news: plaintiffs in a 2013 lawsuit against the Environmental Protection Agency (EPA) can allow themselves a small victory dance. In that suit, plaintiffs made a number of claims related to EPA’s failure to protect pollinators from dangerous pesticides, its poor oversight of the bee-killing pesticides clothianidin and thiamethoxam, and its practice of “conditional registration,” as well as labeling deficiencies. The parties in the suit negotiated a settlement, as directed by a federal judge (see below), that was signed in October 2018 and portends some positive movement in curtailing the use of some toxic pesticides [12 products, each of which contains chlothianidin or thiamathoxam as an active ingredient] that harm pollinators in particular, as well as other organisms and the environment. It also establishes a public process for EPA to consider requiring whole formulations of pesticide products during registration, and redefining EPA’s interpretation of law that allows seeds treated with bee-toxic pesticides to escape regulation as a pesticide.

The suit was brought by a number of individual beekeepers and several organizations, including Beyond Pesticides, Center for Food Safety (CFS), Sierra Club, and Center for Environmental Health, and named as defendants Steven Bradbury, then-director of the Office of Pesticide Programs and Bob Perciasepe, then–acting administrator and deputy administrator of EPA. Since the initial filing of the suit, the plaintiffs have added to the original complaint with subsequent, amended complaints that challenged EPA’s denial of a request to suspend the registration of products containing clothianidin. The language of the second amended complaint noted that the subject pesticides “have been shown to adversely impact the survival, growth, and health of honey bees and other pollinators vital to U.S. agriculture” and have “harmful effects on other animals, including threatened and endangered species.”

Neonicotinoids are highly toxic insecticides that damage insects’ central nervous systems, causing death even at very low doses. Use of these compounds has swelled in the past decade-plus; these pesticides are now used on more than 150 million acres of U.S. cropland. Yet their dominant application is as a seed coating for crop seeds. Because neonicotinoids persist in soil and easily become airborne, the chemicals spread far beyond target crops and can contaminate nearby plants, water, and soil, thus posing additional threats to pollinators. In addition, neonicotinoids can harm non-target organisms, such as birds and beneficial invertebrates.

In May 2017, a federal judge ruled that EPA violated the Endangered Species Act (ESA) when it issued 59 neonicotinoid insecticide registrations between 2007 and 2012 for pesticide products containing clothianidin and thiamethoxam. U.S. District Judge Maxine Chesney rejected the claims of intervenors (pesticide producers) that the plaintiffs had not established causation between the subject pesticides and the harm to plaintiffs. But rather than order EPA to work with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) — a requirement when a pesticide is registered (so as to reduce risks to endangered species) — the judge directed the parties, including the plaintiffs, defendant EPA, and intervenor Bayer CropScience, to move forward with a settlement conference to resolve the disputes.

At the time of that ruling, Center for Food Safety Legal Director George Kimbrell called it “a vital victory,” saying, “Science shows these toxic pesticides harm bees, endangered species and the broader environment. More than 50 years ago, Rachel Carson warned us to avoid such toxic chemicals, and the court’s ruling may bring us one step closer to preventing another Silent Spring.”

That settlement process occurred, and a final document (a “joint stipulation”), agreed to in the summer of 2018, was signed by current parties in the suit: plaintiff beekeepers Steve Ellis, Tom Theobald, Jim Doan, and Bill Rhodes, and the organizations identified above; defendants Andrew Wheeler (current EPA administrator), Richard Keigwin, director of EPA’s Office of Pesticide Programs; and defendant-intervenors Bayer CropScience LP, Syngenta Crop Protection, LLC, Valent USA, LLC, and CropLife America. (It is noteworthy that in the five years since the filing of the original lawsuit, the Office of Pesticide Programs at EPA has had three different directors.) Pursuant to the settlement, the U.S. District Court for the Northern District of California, San Francisco Division, issued a stay in the case. (A “stay” is a suspension of progress of a case; said stay can subsequently be lifted by a court, based on events subsequent to the issuance of the stay.)

The settlement sets in motion a number of actions and expectations, among which is the potential cancellation of the 59 pesticide registrations. The first public action was the posting in the Federal Register of two notices of EPA seeking public comment on petitions from CFS. One requests the revision of testing requirements for pesticides prior to their registration — including requiring “testing for whole pesticide formulations to account for the toxicological effects of inert and adjuvant ingredients and the testing of tank mixes to assess the interaction between pesticide ingredients. CFS believes this change is needed to meet the applicable safety standards of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).” The second requests that EPA “initiate a rulemaking or issue a formal Agency interpretation for planted seeds treated with systemic insecticides. CSF believes that the Agency [EPA] has improperly applied the treated article exemption in exempting these products from registration and labeling requirements under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).” Comments on both, which are due on or before March 21, 2019, can be directed as described here.

EPA will also need to post notice and invite public comment on the settlement agreement itself, after which, according to plaintiffs’ counsel, “The FIFRA cancelation process for the 12 products [each of which contains chlothianidin or thiamathoxam as an active ingredient] that the intervenors agreed to cancel will occur. This is the first time ever [that] the industry has agreed to such a term in any pesticide ESA settlement of this kind, so it quite precedential. . . . [T]he ESA deadlines [will] follow over the next few years. Importantly, the Court . . . will retain jurisdiction to enforce the settlement through all its steps, both the product cancellations [and] the ESA consultation steps, to ensure their completion.”

The less-good news? Even given these developments, the major neonicotinoids will continue to be used for some time. EPA typically uses a “negotiated” process to move hazardous pesticides off the market via voluntary manufacturer withdrawal (which is only then codified by EPA product cancellations), rather than take direct regulatory action. (Read commentary on this, by Beyond Pesticides Executive Director Jay Feldman, and about another example of this phenomenon here.)

Such regulatory action would inevitably invite industry challenge and force EPA into lengthy court proceedings. But this negotiation process also typically produces less-robust protections of public and environmental health than would more-direct regulatory action. The settlement is a small victory in a big sea of health and environmental risks of pesticide use. Stay abreast of developments on federal, state, and municipal efforts to rein in the use of toxic pesticides through the Beyond Pesticides Daily News Blog.

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

Sources: https://www.centerforfoodsafety.org/files/2013-05-31-dkt-17-0–pls–amended-complaint_71924.pdf and https://www.centerforfoodsafety.org/files/2017-5-8-dkt-269–order–granting-and-denying-in-part-msjs_54860.pdf

(Beyond Pesticides, January 3, 2019) Bee-toxic pesticides banned for consumer use by the state of Maryland are still being sold in hardware and garden stores, according to reports from beekeeper and consumer watchdog groups. In 2016, Maryland passed the Pollinator Protection Act, which limited the use of neonicotinoids, insecticides implicated in the global decline of pollinator populations, to only certified applicators. According to spot checks by the Maryland Pesticide Education Network (MPEN) and the Central Maryland Beekeepers Association (CMBA), state enforcement agencies still have a ways to go to ensure retailers are complying with the law.

From May to October 2018, six volunteers visited 30 Maryland stores along the Baltimore-Washington corridor to see whether they are complying with the law by removing bee-toxic neonicotinoids from retail consumer sale. Eleven of the 30 stores were not in compliance, ranging from local home and garden stores to national big-box chains.

“I’ve taken bottles off the shelf and taken them up to an employee or a manager, and said, ‘You really need to stop selling this stuff — it’s illegal,’” said Steve McDaniel, a master beekeeper in Carroll County to the Bay Journal.

The state, for its part, indicates that staffing problems at the Maryland Department of Agriculture have led to the weak roll-out in enforcement during the law’s first year. MDA pesticide manager Dennis Howard told the Bay Journal, “They should be behind the counter, for the folks who can actually apply it under the legislation. I told the inspectors to try to do as many as they can,” he said, “… and speak to the managers of stores, so sales people won’t let [consumers] purchase it.”

But Ruth Berlin, executive director of MPEN, says that many retailers have been antagonistic when asked to remove bee-toxic products. “They said, ‘So what? It’s OK. No one’s going to make us take it away,” Berlin indicated to the Bay Journal.

Beekeepers and other advocates are right to be concerned about the slow roll-out. Passage of the Maryland law was hard-fought, with beekeepers donning suits to the state General Assembly, and overcoming the threat of a veto from Governor Hogan. According to the Bee Informed Partnership, Maryland beekeepers have lost an average of roughly 40% of their hives each year since the start of this decade.

“Most people, they really feel like because we got the law passed, we’re out of the woods on bee deaths,” said Bonnie Raindrop with CMBA. “What we’re seeing is a trend that’s getting worse.”

Getting compliance in line is critical to protecting pollinators, according to experiences in other countries. The City of Amsterdam in the Netherlands has seen significant success in protecting pollinators as a result of policies that banned consumer use of neonicotinoids and improved habitat.

Neonicotinoids are systemic insecticides which, once applied, are taken up by the plant and expressed in the pollen, nectar, and dew drops the plant produces. Chemicals not immediately taken up will either remain in the soil, where they have the potential to re-contaminate next year’s plantings, or work their way through the groundwater table and present a threat to aquatic species.

To date, Maryland and Connecticut are the only states to have joined the dozens of localities that have that restricted neonicotinoids use and enacted pollinator protection policies. With the start of the New Year, and new legislative sessions, now is the time to reach out to your local, state, and federal elected officials and ask them whether they’ll introduce or support legislation to protect pollinators. Contact Beyond Pesticides for information and assistance in speaking with your elected officials.

In Maryland, beekeepers will continue to watchdog MDA’s enforcement of the new law. “If they’re still carrying it next spring, we’re going to come down on [them] with both feet,” said Master Beekeeper Steve McDaniel.

More information on how to help pollinators in your community can be found on the Bee Protective webpage.

Source: Bay Journal

(Beyond Pesticides, January 2, 2019) The “indoor microbiome” of yoga studios and other athletic facilities often contain significant levels of antibacterial chemicals like triclosan, which show up in dust and breed antibiotic resistance, according to research published last month in the journal mSystems. Triclosan may be banned from hand soaps, but its continued use in a myriad of other products, from disinfectant sprays to impregnated clothing, yoga mats, and other work-out equipment makes it difficult to avoid this now-ubiquitous chemical. This is a public health concern because these antibacterial or antimicrobial chemicals are link to antibiotic-resistant bacteria. Antibiotic resistance kills over 23,000 people each year, according to the Centers for Disease Control and Prevention (CDC). In addition to the CDC, the World Health Organization has cited this escalating problem as become one of the biggest public health challenges of our time.

Many people may suspect their gym or yoga study is not a germ-free location, but attempts to address these germs through antibacterial sprays or impregnated yoga mats and other surfaces, may be exacerbating the issue—doing much more harm than good. The continued detection of triclosan and its impacts at new and unexpected locations are feeding renewed calls for a complete ban on its use by the U.S. Environmental Protection Agency (EPA).

As study co-author Erica Hartmann, PhD explains, “There are many products with triclosan that are not labeled because they are within the purview of the EPA instead of the FDA [Food and Drug Administration].”  “These things might include antimicrobial gym equipment, such as yoga mats and textiles.”

Using industrial vacuums, the authors of the study took dust samples from 42 different athletic facilities (yoga, martial arts, dance studios and public rec centers) throughout the Portland, OR area in 2016. These areas were chosen because of the close contact patrons have with floor mats and other surfaces, as well as their propensity to regularly use antibacterial sprays to clean these surfaces. Researchers took these dust samples and split them: one part was analyzed for the presence of antibacterials, and another for the presence of microbes.

Every antibacterial chemical tested by researchers showed up in every facility investigated. Gyms, rooms with higher moisture levels, and those with carpeted flooring all had elevated levels of antibacterials compared to other facilities.

The range of microbes detected in the dust from the various facilities was surprisingly diverse. According to the study, only 26% of microbes were detected in more than one building.

Most concerning is the finding that the number of microbes with antibiotic resistant genes was higher in facilities with elevated concentrations of triclosan and its chemical cousin triclocarban. And the type of resistance microbes display is not limited to triclosan—they exhibit a diverse range of resistance measures. “Those genes do not code for resistance to triclosan,” Dr. Hartmann clarifies. “They code for resistance to medically relevant antibiotic drugs.”

The drive to create germ-free spaces has amplified the potency of the infectious bacteria that people are likely to come into intimate contact with. But the solutions are frustratingly simple: “The vast majority of microbes around us aren’t bad and may even be good,” said Dr. Hartmann. “Wipe down gym equipment with a towel. Wash your hands with plain soap and water. There is absolutely no reason to use antibacterial cleansers and hand soaps.”

Triclosan was first registered for use as a surgical scrub in 1972, but quickly made its way from hospitals to the consumer over-the-counter market, where it began being added to soaps advertised for their antibacterial properties. Widespread use of the chemical led to widespread contamination—CDC indicates that roughly 75% of U.S. residents contain triclosan in their bodies. Over the years, more and more evidence came to light that triclosan is not only unnecessary in soaps, it is also causing a range of hazards. Scientific evidence has demonstrated a variety of adverse health impacts of triclosan and triclocarban, including skin irritation, allergies, endocrine disruption, damage to the thyroid, and an increased risk of asthma and eczema in children. It is one of the most frequently detected synthetic compounds in waterways, and is usually not filtered out from water treatment facilities. A 2013 study found that the influx of triclosan into streams alters the microbial community and increases resistance. Beyond Pesticides raised concerns about the health effects of triclosan in 2004 in its piece The Ubiquitous Triclosan, and petitioned the agency to ban the chemical in 2005.

After over a decade of advocacy in which Beyond Pesticides was joined by a range of health and consumer rights groups, in early Fall 2016, FDA announced a final ruling on triclosan’s use in consumer soaps and other washing products. FDA banned 19 specific ingredients, including triclosan and triclocarban, saying they were no longer “recognized as safe and effective,” and no better than using simple soap and water,  citing risks to health and contributions to the problem of bacterial resistance. FDA went further this year, determining that even health care uses of triclosan should be eliminated, though many other regrettable substitutions remain on the market.

And although its use in soaps has been eliminated, it is evident from this recent research that other uses have not been addressed by regulators. FDA continues to allow triclosan to be used in toothpaste like Colgate Total, despite evidence that brushing with these products causes levels of the chemical to spike in children, and accumulates in toothbrushes, causing repeated exposure unless brush heads are thrown out after use is discontinued.

FDA’s ban did nothing to address uses regulated by EPA, which allows it to be incorporated into a range of consumer products with little to no disclosure. Many products containing triclosan are marketed as “microban,” but microban may contain triclosan, or a number of regrettable substitution chemicals, making it even more difficult for consumers to know what they’re being exposed to.

Although EPA in 2015 denied petition by Beyond Pesticides and Food and Water Watch to remove remaining triclosan uses, as new evidence accumulates on the danger of this chemical, calls to ban its use are growing louder. Get informed about triclosan and other unnecessary chemicals in our environment, as well as steps you can take to eliminate their use at home, workplaces, schools, and gyms by visiting Beyond Pesticides’ Antimicrobials and Antibacterials program page. For a more complete history of the regulation of this chemical, see Beyond Pesticides’ triclosan timeline, as was as previous Daily News articles.

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

Source:  Northwestern University Press Release, mSystems (peer-reviewed journal)

(Beyond Pesticides, December 21-31, 2018)  As we look ahead to the new year, we wish you good health, extend our appreciation for your being a part of the Beyond Pesticides network, and ask you to consider a contribution to Beyond Pesticides. Your support is critical to our program and deeply appreciated.

We approach the new year with a sense of optimism that we will advance our collective will to solve devastating environmental problems. We believe it can be done! But, it takes us all joining together with a strong voice and unified action to stop hazardous practices, while putting safe and sustainable alternatives in place. With your support of Beyond Pesticides, we strive to reverse the destructive environmental and public health path that we’re on.

As a grassroots organization, we work with community-based campaigns and organizations to put organic land management practices in place—in our parks, on playing fields, school grounds, and throughout communities. Together, we eliminate practices that contaminate waterways, put poisons in the air, degrade and destroy life in the soil, and expose us to pesticides that cause or contribute to a range of dreaded diseases like cancer—Parkinson’s, diabetes, reproductive disorders, autism, and more.

• We can change the current course—take the glyphosate/Roundup out of communities, remove the bee-toxic pesticides, eliminate pesticides that kill the soil and aquatic food webs, as well as our gut microbiome—and begin to restore the health of people and the environment.
• We can do this without spending more moneyat the community level because life-sustaining management of our parks and communities utilizes ecosystem services by supporting ecological balance and cycling nutrients in the soil, instead of relying on expensive, synthetic, fossil fuel-based, toxic pesticides and fertilizers.
• We work on the interconnectedness of issues and stress holistic solutionsto the range of seemingly insurmountable environmental problems that we face. We do this through our efforts to push for an urgent transition to organic practices from chemical-intensive land and building management in communities across the country.
• We are helping to establish model communities that show it can be done, like in the city of South Portland, Maine. There, the city council passed a law a couple of years ago to eliminate toxic pesticides throughout the entire municipality, and this year began implementing it with information, factsheets, staff training, plan development, and the launching of a terrific website.

We are making progress in advancing our strategic goal to eliminate toxic pesticide use, with examples in dozens of communities nationwide that are establishing organic land management programs. Your support will help us to reach more communities in the next year.

With your support, we (i) develop community plans to transition to organic management practices, (ii) nurture complex biological communities in nature, in all its beauty and public health and environmental benefits, (iii) train local government staff to understand and adopt soil-based cultural practices for managing parks and playing fields, (iv) protect local and regional waterways, and (v) create an alignment and alliance with the business community (like the local ACE hardware store in Maine, where the owner has transitioned the store’s lawn and garden department to advance organic practices and products).

Your support helps Beyond Pesticides bring to communities the resources necessary to put the organic changes in place. Your support helps us to stop pesticide use and advance organic practices with our programs that:

• Make science on the pesticide problem and solution understandable to the public;
• Support and empower people in their communities;
• Influence decision makers; and,
• Implement on-the-ground practices in communities nationwide

Please check out the latest issue of our journal, Pesticides and You. Our feature article, Pesticide Exposure and the Obesity Pandemic, exemplifies the importance of getting the science out, and this issue adds more evidence of the need for the organic transition.

To further align our work with the medical community, we are co-convening the 37th National Pesticide Forum, Organic Strategies for Community Environmental Health: Eliminating pesticides where we live, work, learn, and play, with the Center for Children’s Environmental Health at the Icahn School of Medicine at Mt. Sinai, April 5-6, 2019 in New York City. Please consider joining us!

Thank you for considering supporting Beyond Pesticides at the end of the year. For a $150 donation, we will send you Beyond Pesticides’ organic canvas tote bag or our new Organic Landscape sign that displays our blue dragonfly logo.

All best wishes for the holiday season and new year!

(Beyond Pesticides, December 21, 2019) A study at the University of Maine (UMaine) finds that adding blackberry leaf litter in stormwater catch basins creates an “ecological trap,” enticing mosquito females to lay eggs in sites unsuitable for larvae survival. Employing this new and incredibly viable “attract-and-kill’ tool for mosquito control shows potential for preventing the breeding of mosquitoes that may carry insect-borne diseases, especially in urban environments. Stormwater catch basins regularly accumulate leaf litter, which serve as habitat for the mosquito species Culex pipiens (Cx. Pipiens) that may carry West Nile virus.

Previous University of Maine research discovered decomposing leaf litter from Amur honeysuckle (Lonicera maackii) and common blackberry (Rubus allegheniensis) produces chemical compounds that attracts and stimulates Cx. Pipiens female to oviposit, or lay eggs.

Investigating the attractiveness and lethality of varying catch basin conditions to mosquitoes, researchers hypothesized that blackberry leaf litter could be shown to be lethal to developing mosquito larvae, and, therefore, act as a natural ecological trap for Cx. Pipiens.

Five varying treatments were applied to a total 50 catch basins. Treatments included (1) all debris dredged weekly throughout the duration of the study, (2) no change to debris naturally occurring in catch basins, (3) ecological trap: naturally occurring debris dredged prior to administering 100 grams of fresh blackberry leaves submerged underwater in mesh bags, (4) attractants only: same as previous, except 100 grams of fresh honeysuckle leaves submerged, (5) toxins only: common larvacide Bacillus thuringiensis var. israelensis (Bti) administered, with no additional change to debris.

Catch basins were those on street edges in relatively standard residential neighborhoods. Larvae in catch basins were counted once prior to and four times after treatments had been administered. Floating emergence traps were placed to capture adult mosquitoes. Experiments were repeated across two years to confirm findings.

Results show catch basins with the ecological trap (blackberry leaves) have consistently higher numbers of Cx. pipiens eggs, but very low larvae survival.  Honeysuckle, however, showed high larvae survival and high adult emergence. Most strikingly, ecological trap catch basins showed reduced larvae survival even when combined with equal parts honeysuckle.

In addition, with decomposing leaf litter previously shown to attract Cx. pipiens oviposition, the study also confirms that survival of mosquito larvae, being filter-feeding invertebrates, is dependent mainly on the aquatic habitat containing the appropriate bacterial community to suit the larvae’s nutritional needs. However, suitable bacteria, unlike decomposing leaf litter, do not create chemical attractants. This means Cx. pipiens females select oviposition sites based solely on the presence of decomposing leaf litter, regardless of whether the appropriate bacterial community may be lacking. Thus, researchers suggest Cx. pipiens can be tricked to oviposit in sites incompatible for ensuring larvae survival.

“The abundance of mosquitoes in aquatic habitats and the efficacy of conventional insecticides for juvenile mosquito control are strongly influenced by variables such as rainfall, water chemistry, and the species and structure of terrestrial vegetation in the surrounding environment,” says Allison Gardner, PhD, an assistant professor of arthropod vector biology at UMaine and lead author of the study. “This suggests that ecologically based strategies could [be exploited] for environmentally safe and sustainable mosquito abatement,” Dr. Gardner continued.

Dr. Gardner’s study confirms the importance of understanding the suitability of potential habitat for unwanted insect species. Managing conditions conducive for mosquito species’ proliferation prevents human exposure to mosquito-borne pathogens, as mosquitoes do not travel far from where they hatch.

Conversely, broad-spray, conventional management approaches create insecticide resistance among mosquitoes. They also create toxic conditions that harm non-target species like pollinators, including harms to pets and children.

Meet with elected officials to discuss Beyond Pesticides’ public health mosquito management strategy. Tell them to fix the problem conditions that lead to mosquito proliferation in your neighborhood and not to waste more time and money on routine insecticide spraying. Help them understand what attracts mosquitoes to an area, and what sustains them. Talk with city officials about developing novel and intuitive “attract-and-kill” mosquito management strategies that include blackberry leaves. Teach them that corralling Cx. pipiens eggs into simultaneously attractive and inhospitable habitats would be effective for mosquito management and disease prevention, as it adversely affects Cx. pipiens egg production and reduces larvae survival.

Exploiting ecological traps holds potential for new jobs and volunteer opportunities. Encourage the planting of blackberry bushes in your community. Collect fallen leaves and devise ingenious ways to administer the leaves into catch basins (such as being submerged underwater in mesh bags).

When speaking with neighbors, emphasize the ineffectiveness of pesticides at controlling mosquito populations. Discuss the safer choice. Purchase Beyond Pesticides mosquito doorknob hangers and teach neighbors simple mosquito reduction steps, such as: removing unnecessary debris on your property, and cleaning rain gutters in the spring and fall.  Offer to help elders and disabled members of your community. Work with friends to create a system for effective mosquito prevention.

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

Sources: Phys.org, and The Royal Society

(Beyond Pesticides, December 20, 2018) Using low doses of the herbicide paraquat and common proteins found in food called lectins, researchers were able to recreate the symptoms of Parkinson’s disease in rats. Results of this study, published in the journal Parkinson’s disease, provide scientists with fresh insights into the development of the disease, and a new model to test potential remedies. Paraquat, a neurotoxic herbicide with a well-established body of literature linking it to Parkinson’s disease, is currently undergoing a registration review by the U.S. Environmental Protection Agency, and groups like the Michael J Fox Foundation are calling for its ban.

Researchers based their study on the Braak Staging hypothesis of Parkinson’s, which posits that the disease is brought on by foreign agents entering the body through the gut or nose and making their way to the brain. Rats were exposed to low doses of paraquat combined with lectin every day for a week. After two weeks, the animals’ motor function was tested and compared to an unexposed control group.

Rats exposed to lectin and paraquat exhibited Parkinson-like symptoms. Primary author R. Alberto Travagli, PhD, notes, “After observing that these animals did indeed show symptoms of Parkinsonism, we wanted to double check and make sure we weren’t looking at animals that had these symptoms for another reason.” To check, Dr. Travalgi indicates, “We administered levodopa, which is a common medication for Parkinson’s disease. We saw a return to almost normal types of motor responses, which was a clear indication that we were looking at some sort of Parkinsonism.”

Lectin, which is often found in healthy foods like raw vegetables, eggs, and dairy, combined with paraquat in the gut and triggered the formation of a misfolded protein called alpha-synuclein, a foreign agent that likely plays a role in the development of Parkinson’s. Alpha-synuclein travels from the gut to the brain via the vagus nerve. Thus, to confirm the etiology of the symptoms exposed rats were experiencing, researchers removed the vagus nerve of a population of test rats and administered the same combination of lectin and paraquat. No rats within this group developed Parkinson-like symptoms.

“We were able to demonstrate that if you have oral paraquat exposure, even at very low levels, and you also consume lectins — perhaps in the form of uncooked vegetables, dairy or eggs — then it could potentially trigger the formation of this protein alpha-synuclein in the gut,” said study coauthor Thyagarajan Subramanian. “Once it’s formed, it can travel up the vagus nerve and to the part of the brain that triggers the onset of Parkinson’s disease.”

Scientists also administered both paraquat and lectin alone to rat populations, but did not see the same pathology in either groups tested.

Researchers indicate that these results provide new avenues for intervention to prevent Parkinson’s in humans. For example, there could be dietary changes that could delay onset, or drugs (including antibiotics), such as squalamine, that act to remove alpha-synuclein from the gut.

Any herbicide implicated in the development of a disease, which is expected to double in diagnosis over the next 20 years, raises serious questions about compliance with safety standards. A large body of scientific studies strongly implicates this chemical in the development of Parkinson’s disease. Earlier this year, research published in the journal Cell Reports implicated paraquat for its ability to create senescent cells that cause inflammation in the brain.

Beyond Pesticides strongly supports the Michael J. Fox Foundation’s stance that paraquat should be banned for use in the United States. The chemical has already been banned in the European Union since 2007, yet the United States still imports the chemical from throughout the world.

Join us in urging Congress and EPA to ban the use of paraquat by sending a letter today. And for more information on the connection between pesticides and Parkinson’s see Beyond Pesticides’ Pesticide Induced Diseases Database.

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

Source: Penn State Press Release,  Parkinson’s Disease (peer-reviewed journal)

(Beyond Pesticides, December 19, 2018) As the dust still settles on the final Farm Bill, which passed the U.S. Senate and House of Representatives last week, it is clear that neither the substance nor the process on a range of issues meet the urgent need to address key sustainability issues that put the future in peril.

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

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

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

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

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

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

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

After the new 116^th Congress begins on January 3, 2019, you will be hearing from Beyond Pesticides on a range of critical issues that have gotten unsatisfactory attention in the Farm Bill and other legislation and regulations.

(Beyond Pesticides, December 18, 2018) The ingredients not listed on a pesticide product are not fully reviewed for their adverse effects may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to disclose and test all ingredients in pesticide products, as well as the full formulation that includes “inert” or nondisclosed ingredients. While glyphosate/Roundup is obviously not allowed to be used in organic production, this research reaffirms the need to evaluate full formulations of substances allowed for use in organic.

The research on glyphosate tested the toxicity of the herbicide glyphosate, “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, the researchers studied a number of other pesticides.

Tell NOP and USDA that “inerts” used in organic production must receive full review by the NOSB.

“Inert” ingredients are allowed in pesticides used in organic production as well as those used in chemical-intensive production. The National Organic Program (NOP) allows “inerts,” permitted in conventional production and formerly listed on EPA’s List 4, “inerts of minimal concern,” as well as a few formerly listed on List 3, “inerts of unknown toxicity,” to be used in organic production. Because the standards of the Organic Foods Production Act (OFPA) are much more restrictive than those used by the U.S. Environmental Protection Agency (EPA) to regulate pesticides, and given changes in how the agency categorizes “inerts,” the National Organic Standards Board (NOSB) has adopted a series of recommendations since 2010 that established a substance review process as part of the five-year cycle of sunset review. The NOSB has voted overwhelmingly to require review of all individual “inerts” used in organic production, but NOP has refused to move forward.

Although GBH products are not permitted in organic production, the results of the Defarge et al. study are relevant to decisions concerning materials used in organic crops and livestock. The scientists found that for GBH products, glyphosate was not the major toxic component–to either plants or human cells–and that formulations, as well as glyphosate alone, are endocrine disruptors at low concentrations. Glyphosate alone did not show herbicidal effects on tomato plants for five days following application. Formulations that included POEA (polyethoxylated tallowamine) are the most toxic to plants and human cells, and POEA itself is highly toxic to plants and animals. GBH formulations are no more toxic to plants than the formulants (“inert” ingredients). The researchers concluded, “Hence G [glyphosate] did not appear to be the main active substance of the herbicide, but rather the formulants.”

The researchers also identified a number of other toxic substances in the products, including arsenic, chromium, cobalt, nickel, and lead. Arsenic was present in almost all samples.

This research calls into question the fundamental principles embodied in federal pesticide law, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which distinguishes  “active” ingredients, those ingredients in pesticide products for which pesticidal activity is claimed, from “inert” ingredients, now labeled “other ingredients.” “Inert” ingredients receive minimal review (to establish tolerances), compared to “active” ingredients, and are protected from disclosure on the product label as proprietary manufacturer information. It reinforces why the NOSB and NOP cannot rely on the standards that govern the use or allowance of pesticides under pesticide law.

This research also challenges the apparent assumption by NOP that “inert” ingredients are less important to review than “active” ingredients. The “active” ingredients in pesticide products used in organic production receive intense scrutiny before the NOSB allows their use. However, “inert” ingredients –which, as the Defarge et al. study demonstrates, may actually be the active ingredients— have not received any scrutiny by the NOSB for compliance with OFPA criteria.

NOP must act on the NOSB recommendations that “inert” ingredients used in organic production be reviewed by the NOSB according to OFPA criteria by putting review of these materials on the NOSB work agenda.

Tell NOP and USDA that “inerts” used in organic production must receive full review by the NOSB.

Letter to National Organic Program, Agricultural Marketing Service, and Agriculture Secretary Sonny Perdue:

I am concerned that the National Organic Program (NOP) has not followed through with recommendations from its advisory board, the National Organic Standards Board (NOSB), to fully review “inert” ingredients in pesticide products used in organic production according to the standards of the Organic Foods Production Act. Recent research underlines the importance of this review.

The ingredients not listed on a pesticide product are not fully reviewed for their adverse effects may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to disclose and test all ingredients in pesticide products, as well as the full formulation that includes “inert” or nondisclosed ingredients. While glyphosate/Roundup is obviously not allowed to be used in organic production, this research reaffirms the need to evaluate full formulations of substances allowed for use in organic.

The research on glyphosate tested the toxicity of the herbicide glyphosate, “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity.

“Inert” ingredients are allowed in pesticides used in organic production as well as those used in chemical-intensive production. NOP allows “inerts” permitted in converntional production and formerly listed on EPA’s List 4, “inerts of minimal concern,” as well as a few formerly listed on List 3, “inerts of unknown toxicity,” to be used in organic production. Because the standards of the Organic Foods Production Act (OFPA) are much more restrictive than those used by the U.S. Environmental Protection Agency (EPA) to regulate pesticides and given changes in how the agency categorizes “inerts,” the NOSB has adopted a series of recommendations since 2010 that established a substance review process as part of the five year cycle of sunset review. The NOSB has voted overwhelmingly to require review of all individual “inerts” used in organic production, but NOP has refused to move forward.

Although GBH products are not permitted in organic production, the results of the Defarge et al study are relevant to decisions concerning materials used in organic crops and livestock. The researchers also identified a number of other toxic substances in the products, including arsenic, chromium, cobalt, nickel, and lead. Arsenic was present in almost all samples.

This research calls into question the fundamental principles embodied in federal pesticide law, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which distinguishes  “active” ingredients, those ingredients in pesticide products for which pesticidal activity is claimed, from “inert” ingredients, now labeled “other ingredients.” “Inert” ingredients receive minimal review (to establish tolerances), compared to “active” ingredients, and are protected from disclosure on the product label as proprietary manufacturer information. It reinforces why the NOSB and NOP cannot rely on the standards that govern the use or allowance of pesticides under pesticide law.

This research also challenges the apparent assumption by NOP that “inert” ingredients are less important to review than “active” ingredients. The “active” ingredients in pesticide products used in organic production receive intense scrutiny before the NOSB allows their use. However, “inert” ingredients –which, as the Defarge et al. study demonstrates, may actually be the active ingredients— have not received any scrutiny by the NOSB for compliance with OFPA criteria.

I request that NOP act on the NOSB recommendations that “inert” ingredients used in organic production undergo NOSB review by putting an assessment of these materials on the NOSB work agenda.

Sincerely,

(Beyond Pesticides, December 17, 2018) Cardiovascular disease is a major cause of poor health and mortality across the world. Much is known about congenital and behavioral contributors to the disease, yet to date, little research has focused on potential environmental factors, including the possible contribution to cardiovascular disease (CVD) of exposures to toxic chemicals in the workplace. A recent study of CVD incidence among Hispanic and Latino workers, by Catherine Bulka, PhD, et al., has evaluated associations of self-reported exposures to organic solvents, metals, and pesticides with CVD.

The study was published in the journal Heart on December 11, 2018, and is first to evaluate the role of chemical exposures in the workplace in the incidence of CVD in this demographic sector. As do many scientific investigations, this one points to a need for further study of the links that emerged between such exposures and compromised cardiovascular health.

In an editorial in that same issue of Heart, commenting on the study, Dr. Karin Broberg of the Karolinska Institutet in Stockholm, Sweden, noted that “exposure to metals and pesticides is common worldwide, and this study highlights the need to better understand the risks that these exposures cause, and to limit exposure in the workplace, thus promoting cardiac health.” She also reminded readers that some pesticides cause oxidative stress, and that it, as well as other mechanisms, are likely to be important in understanding the impacts of such exposures. Oxidative stress is implicated as a mechanism of harm from pesticides, as noted by Beyond Pesticides in November 2018 in Daily News.

CVD has any number of risk factors, such as age, hypertension, obesity, elevated cholesterol levels, family history, and behavioral factors, such as smoking, diet, physical activity, alcohol consumption, and others. Chief among the types and outcomes of cardiovascular disease are coronary, peripheral, and carotid artery disease; heart failure; stroke; myocardial infarction (heart attack); cardiomyopathy; and cardiac arrhythmias.

The Heart study assessed data from health questionnaires completed by, and clinical examinations of, nearly 7,500 workers, aged 18–74, from a variety of occupations and industries. More than two-thirds of the study subjects had been in their current work positions for an average of 10 years. Researchers determined that 4.7% of the subjects — workers in Chicago, Miami, New York, and San Diego — are currently exposed to pesticides, 6.5% are exposed to organic solvents, and 8.5% are exposed to metals through their job activities. The research found a positive correlation between those exposures to pesticides (and to metals, to a lesser degree) and development of CVD; no such correlation appeared for organic solvents. (Metals exposure was significantly correlated only with atrial fibrillation.)

Of the multiple sub-types of CVD, the study finds the strongest correlation between pesticide exposures, and coronary heart disease and atrial fibrillation. For individuals who work with pesticides, prevalence for any CVD is 2.18%; for coronary heart disease, 2.20%; for cerebrovascular disease, 1.38%; for heart failure, 0.91%; and for atrial fibrillation, 5.92%. These figures reflect control for sociodemographic, acculturation, lifestyle, and occupational characteristics. As Science Daily reports, “After taking account of potentially influential factors, including lifestyle and workplace factors, exposure to pesticides was associated with nearly six-fold higher odds of atrial fibrillation, while exposure to metals was associated with nearly four-fold higher odds.”

The study authors noted that, “metal and pesticide exposures in the workplace were cross-sectionally associated with marked elevations in the prevalence of CVD. These results should be considered preliminary and interpreted with caution given the limitations of our study design; namely, our reliance on self-reported exposure status and cross-sectional data.” That said, the reports of CVD in subjects were shown to have high validity and were combined with electrocardiographic evidence. Because this study was observational, it cannot establish cause. But it does point researchers to the need to investigate further pesticide exposure as a risk factor for development of cardiovascular disease.

A 2016 meta-review of research by Azizah Wahab, et al., and published in the International Journal of Community Medicine and Public Health, concluded that, “individual pesticide evaluation revealed significant associat[ion] with non-fatal myocardial infarction. Organochlorine [pesticides are] significantly associated with peripheral arterial disease and stroke. In severe poisonings, [the] general impression is that cardiac abnormalities are common. This systematic review suggests that pesticide exposure is associated with increased risk of CVD and CVD mortality.”

Beyond Pesticides has previously written about the relationship between pesticide exposures and cardiovascular disease. In 2011, a Daily News article reviewed research that shows a relationship between exposure to organochlorine pesticides and the development of atherosclerosis, a precursor to CVD. Beyond Pesticides maintains its Pesticide-Induced Diseases Database to chronicle the range of diseases linked to pesticides through epidemiologic studies. The database, which contains hundreds of entries about epidemiologic and laboratory exposure studies, is regularly updated to track emerging knowledge.

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

Sources: https://www.sciencedaily.com/releases/2018/12/181211190008.htm and https://heart.bmj.com/content/early/2018/10/23/heartjnl-2018-313463

(Beyond Pesticides, December 14, 2018) The richness, diversity, and abundance of wild bumblebees in Vermont has plummeted over the last century, according to an analysis from researchers at the University of Vermont and Vermont Center for Ecostudies (VCE). This research adds fresh evidence to the growing realization that mankind is witnessing and contributing to, as the New York Times recently labeled, a worldwide insect apocalypse. “We’re losing bumblebees even before we fully understand their benefits to our economy and well-being, or how they fit into ecosystems,” said Kent McFarland, study coauthor and conservation biologist at VCE in a press release.

Researchers conducted surveys with the help of 53 trained citizen scientists. Alongside the researchers, these individuals surveyed bumblebee populations through a combination of photos of wild bees and net collections. In total, over 81% of the state’s municipalities were included in the survey, representing all of Vermont pollinator’s biophysical regions.

These data, consisting of over 10,000 bee encounters, were then compared to a database of almost 2,000 historical public and private insect collections amassed by researchers. With the first records beginning at 1915, scientists are able to compose a century-long assessment of pollinator populations in Vermont.

“These collections are priceless,” said coauthor Sara Zahendra of the historic bee collections used in the study. “Decades ago, students and biologists likely had no idea that some of the species they were collecting would completely disappear. Without these collections, we wouldn’t know how our bee populations have changed.”

According to the results, of the 17 bumblebee species considered native to Vermont, four showed evidence of significant declines, and four are simply not detected, leading researchers to the conclusion they are likely to be locally extinct.

Of note are two species, Bombus affinis, the rusty patched bumblebee, and Bombus ashtoni, the Ashton’s Cuckoo Bumblebee, which researchers found to be historically prevalent but locally extinct per the recent count. The rusty patched bumblebee was recently listed as endangered under the endangered species act, surviving a reevaluation of the decision by the Trump administration. “This investigation confirms our fear that the Rusty-patched Bumble Bee is almost certainly extinct in Vermont and may never be back,” said Mr. McFarland. “We hardly knew it – and now it’s gone.” Alongside the local extinction of the rusty patched is the extirpation of a dependent species, the Ashton’s Cuckoo, which survived by infiltrating rusty patched bumblebee colonies, and enslaving workers to feed its own young.

Researchers indicate that although some species, such as Bombus impatiens, the common eastern bumblebee are expanding in part due to their use as managed pollinators in agriculture, overall Vermont’s pollinators experienced significant declines in species richness (the number of different species found), abundance (the number of pollinators found), and diversity (a measure of species richness and relative abundance).

“Our next step is to move from investigation toward solutions,” said Mr. McFarland. “But those solutions will take hard work and partnerships among federal and state agencies, conservation research groups like ours, and the public.”

Overwhelming research indicates that neonicotinoids and other systemic insecticides are critical factors in the decline of both managed and native pollinator populations throughout the world. Neonicotinoid pesticides are particularly dangerous to bees because plants absorb them through the roots, rendering all plant parts toxic to insects,” said Leif Richardson, PhD, an ecologist with UVM’s Gund Institute for Environment and Rubenstein School of Environment and Natural Resources. “This includes pollen and nectar, essential components of the bee diet.”

The Vermont state legislature has begun to take steps to address the use of these pesticides as seed treatments, which put nearby wild and managed pollinators at risk of toxic dust drift during the planting process, but has failed to take a broader comprehensive response to the crisis as nearby Connecticut did in 2016.

The scope of this crisis cannot be underestimated. Evidence is mounting that pollinators are simply the canary in the coal mine – the most charismatic examples of an insect world that is experiencing apocalyptic levels of decline.

A recent New York Times article on this crisis provides a sober outlook from renown ecologist E.O Wilson:
“E.O. Wilson has written of an insect-free world, a place where most plants and land animals become extinct; where fungi explodes, for a while, thriving on death and rot; and where “the human species survives, able to fall back on wind-pollinated grains and marine fishing” despite mass starvation and resource wars. “Clinging to survival in a devastated world, and trapped in an ecological dark age,” he adds, “the survivors would offer prayers for the return of weeds and bugs.”

There is still time to change our trajectory. More than ever, individuals must connect with their local, state, and federal elected officials and demand changes that protect pollinators and other insect populations. As evidenced by Connecticut and Maryland, and dozens of local pollinator protection policies, concerted efforts by beekeepers and grassroots advocates can create lasting positive change.

For more information on how to get active in you state or community to safeguard pollinators, visit Beyond Pesticides’ Bee Protective webpage or give the office a call at 202-543-5450.

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

Source: Phys.Org, Journal of Insect Conservation

(Beyond Pesticides, December 13, 2018) The U.S. is pushing back against international standards that restrict pesticides by appealing to the World Trade Organization (WTO) to intervene. At issue are new EU maximum residue levels (MRLs) on food for the following pesticides: buprofezin, diflubenzuron, ethoxysulfurom, ioxynil, molinate, picoxystrobin and tepraloxydim.

Advocates are concerned that a U.S. challenge to stronger EU standards could cause the WTO to force a weakening of standards internationally. Most significantly, EU proposed lowering its MRLs on imports. The EU said lower MRLs are needed to protect consumers, as research shows pesticides are shown to be carcinogenic, and that, contrary to chemical-industry claims, no level of allowable exposures can be assumed. Taking issue with the new MRLs – as with all other STCs mentioned above – the U.S. said new MRLs would cause barriers to trade, and therefore, must be rejected by the WTO. Advocates point to the introduction of GMOs as an example of the U.S. using the WTO to block standards that restrict potentially hazardous products.

Recently, the U.S. has been involved in four of five new specific trade concerns (STCs) raised before WTO. As part of reviewing the current agreement of the Committee on Sanitary and Phytosanitary – which works to ensure protections for humans, animals and plants while avoiding barriers to trade – one STC the U.S. disliked was the Vietnamese National Assembly’s Livestock Production Law. The proposed livestock law would impose an import ban on livestock products produced with the use of chemicals prohibited for domestic production in Vietnam.

The U.S. also expressed its dislike of an EU Court of Justice decision on “mutagenesis” – a process of inducing mutagenic changes –requiring that all organisms obtained through mutagenesis undergo the same risk assessment and review requirements, labeling, monitoring and traceability laws as those imposed on genetically-modified organisms (GMOs).

The EU has shown time and time again that it will enact stricter pesticide regulations than the U.S. Back in 2005, (EU) environment ministers agreed to uphold five national bans on GMOs. However, the U.S. once again claimed bans on GMOs were barriers to trade and must not be honored. “[EU countries] are overwhelmingly opposed to GM food,” said Friends of the Earth’s GM campaigner Emily Diamand in 2005, “[It] is outrageous that [the U.S. government] should try and stop other countries saying no to GM.”

In her book Stolen Harvest: The hijacking of the global food supply, Vandana Shiva, PhD, says, “The right to food, the right to safety, the right to culture, are all being treated as trade barriers that [for the continuation of the WTO] need to be dismantled.” Dr. Shiva continues, “[The WTO’s] Agreement on Agriculture legalizes the dumping of genetically-engineered foods on countries and criminalizes actions to protect the biological and cultural diversity on which diverse food systems are based.”

Whether by releasing GE/GMOs or rejecting the EU’s lower MRLs, advocates believe the move is the latest in a series of attempts by the U.S. to block other countries’ decisions to protect their environment, human health and social standards. Consequently, the WTO takes power away from the people and their local governments and allows corporations to overpower them. This is done all in the name of free trade, or what Dr. Shiva deems “forced trade.”

This holiday season, start your own local movement. Talk with your friends and family about sourcing foods from local organic farms. Talk with grocery store owners about where they source their produce, reminding them how organic food consumption lowers cancer risk. Request that they support local organic farmers and follow up to ensure progress is made. Live by the mantra “Think Globally, Act Locally” because, as Dr. Shiva states, “This food totalitarianism can only be stopped through major citizen mobilization for democratization of the food system.”

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

Source: Food Safety News

(Beyond Pesticides, December 12, 2018)  Costa Rica is currently experiencing exponential growth in its banana and pineapple farming industries and with it an increase in intensive pesticide applications. Recent studies in Costa Rica identified evidence of increasing fur discoloration in black mantled howler monkeys ((Alouatta palliata) as a result of their exposure to sulfur-based pesticides. Coloration in Howler monkeys are limited to black, gray, and dark brown, but researchers found several monkeys with yellow patches on their tails and legs. The change in pigmentation is directly correlated to the consumption of plants inadvertently exposed to sulfur-based pesticides sprayed at (and drifting from) nearby farms. The use of pesticides is not only hazardous to nearby wildlife, but communities as well. It is an issue that seems to play out repeatedly both in Costa Rica and in the U.S. The use of pesticides, and more importantly pesticide drift, continues to be a pervasive issue with severe human and environmental health consequences.

Pesticide drift occurs in the form of mist, particles, or vapor (gas) and are usually carried by air (and oftentimes water) currents. Typically, fumigants (gaseous pesticides) are most likely to drift.  When used, pesticides regularly spread further than the established application site and contaminate surrounding land and waterways through runoff.  Leaching of pesticides into waterways result in short-term and long-term detrimental impacts in and around tracks of treated farmland. With  continued investment and expansion in these industries, Costa Rica has seen a dramatic increase in the use of pesticides and other agrochemicals. Costa Rica is revered ecologically with over 52 percent forest cover and has one of the highest biodiversity densities in the world. It also has well established banana and pineapple industries that account for approximately $2 billion of its US $57.44 billion GDP that heavily employs agrochemicals in attempting to enhance growth and crop yield. Banana and pineapple farming are intensely managed agroecosystems with high inputs of synthetic chemicals, generally in the form of pesticides and fertilizers.

Exposure to excessive amounts of agrochemicals often results in internal and external damage to organisms exposed. Melanogensis, for example, is the process of providing pigmentation in animals and humans and when exposed to pesticides can cause in an alternation in the melanin from eumelanin (darker pigmentation) to pheomelanin (lighter pigmentation, i.e. yellow, red, or orange tones). In addition to altered pigmentation, excessive exposure often results in sensitivity to light, skin irritation and cancer. In addition to pigmentation bleaching, the use of pesticides in this region have adversely impacted surrounding communities resulting in increased incidences of epithelial damage, gastrointestinal issues, nervous system disorders, eye irritations and birth defects.

Costa Rica is not alone in its struggle to prevent adverse impacts associated with pesticide drift and the adverse side effects of exposure. Since pesticide drift is an unintended consequence of pesticide application, limiting or preventing drift falls solely on standards put in place by federal, state, and/or local governments. For the most part, current regulations in the U.S. have proved inadequate to prevent drift, but there are those attempting to move in the right direction. California, for example, is noted to have historical environmental justice concerns surrounding failures to prioritize community health over industry profits, while simultaneously having strict standards limiting applications to minimize drift on the books. Other areas, like Iowa, are having a difficult time gaining the support needed to pass protective measures.

Pesticide drift is a pervasive issue impacting communities surrounding intensive farming operations. The production of many cash crops, like pineapples and bananas, adversely impact human and environmental health. Supporting the use of alternative practices such as polyculture rather than monoculture; mulching around the base of the plant, animal integration and other organic practices can assist eliminate the need for pesticides and therefore the likelihood of pesticide drift.

For more information on the dangers of pesticide drift, see Beyond Pesticides Daily News sections for Pesticide Drift and Environmental Justice

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

Source: Science Magazine and NPIC

(Beyond Pesticides, December 11, 2018) Meltwater and runoff from Alaskan glaciers contain detectable levels of organochlorine pesticides that bioconcentrate in fish and put individuals at risk, according to a new study from researchers at the University of Maine (UMaine). DDT, lindane, and other organochlorines have been detected throughout the world, even in natural areas thought to be untouched, and pristine. As UMaine scientists show, the atmospheric transport and ubiquitous deposition of these pesticides continues to pose risks to U.S. residents long after regulations banned their use.

Although most of the highly toxic class of organochlorine pesticides like DDT were banned in the early 1970s, some chemicals retained certain uses. Lindane, for example, had its pest management uses phased out gradually until 2007, but is still allowed today as a scabies and lice shampoo. While use of these pesticides has declined in the U.S., much of the developing world, including many Asian countries, such as China, India, and North Korea, still report use. This results in atmospheric transport of the pesticides, and relevant to the UMaine research, increases the likelihood that the chemicals will eventually be deposited onto Alaskan glaciers through snow or rain.

The UMaine research team investigated the amount of DDT and lindane historically and recently deposited into the Jarvis Glacier, located in Eastern Alaska northwest of Juneau. Researchers analyzed glacial meltwater and ice core samples down to the bedrock.

Results found that ice core samples taken between 20 and 45 feet contained the highest concentrations of organochlorines, with concentrations decreasing closer to bedrock. Meltwater generally contains slightly higher levels of pesticides than any ice core sample taken. Although concentrations detected are low and none exceeded 1.12 ng/L, researchers indicate that the risk is not direct exposure, but the bioconcentration of these chemicals up the food chain.

In UMaine’s press release, study coauthor Kimberly Miner, PhD, indicates that even with low levels of organochlorines, both adults and children who regularly consume fish in contaminated streams are at increased risk of cancer, as their consumption levels are likely to exceed EPA thresholds. She indicates that children are particularly vulnerable, and as climate change accelerates the rate of melting, these concerns are only likely to intensify. “This secondary impact of climate change will be felt most strongly by children, and needs to be addressed in a comprehensive way,” Dr. Miner said. Organochlorine contamination not only puts individuals at health risks, it jeopardizes the traditions and subsistence way of life for many Alaskan native peoples, necessitating significant investment in culturally appropriate solutions.

Research published earlier this year links mothers’ DDT exposure to increased rates of autism in their children. In 2016, a similar study found that mothers with organochlorine contamination in the highest 25^th percentile had an 80% increased risk of giving birth to a child that develops autism. DDT and its breakdown products are known endocrine disruptors and have been linked to breast cancer, and early menopause. Lindane is considered by the world health organization to be in the highest cancer classification – carcinogenic to humans (Group 1), but, despite this, risk is still allowed for use by the Food and Drug Administration (FDA).

The dangers posed by long-banned pesticides highlights the ongoing deficiencies in regulating persistent pesticides. For example, DDT, though banned for use in the U.S. in 1972, continued to be produced in the U.S. and exported throughout the world into the late 1980s. This is the case with a number of toxic pesticides – banned for use in the U.S., but not for export to other countries. It is incumbent on U.S. lawmakers and regulators to enact protections in a manner that makes us a model for the world, rather than shifting hazards to developing countries. To the extent that we are aware of the hazards of pesticides, have cancelled some or all of their uses, and are aware of a country’s limited capacity to enforce label restrictions on use, training, and protective equipment, it is unconscionable to export hazardous pesticides. As this study reveals, such failures to stop the exportation of hazardous pesticides are likely to come back to harm us in the long run.

For more information on the dangers posed by long-banned pesticides, see Beyond Pesticides Daily News sections for DDT and lindane.

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

Source: Water-OpenAccessJournal,  University of Maine PR

(Beyond Pesticides, December 10, 2018) The Senate Agriculture Committee has cleared the way for the whole U.S. Senate to vote on the confirmation of Scott Hutchins, PhD, recently retired from research and management at what is now the agricultural division of DowDuPont, as chief scientist at the U.S. Department of Agriculture (USDA). If confirmed, he will become the third member of Dow’s pesticide and seed division to hold a high-level position in the Trump administration’s USDA. 

Tell your U.S. Senators to Reject Dow’s Hutchins as USDA Chief Scientist.

Dr. Hutchins has a history of defending toxic pesticides like Dow’s chlorpyrifos, which makes him unsuitable for leading USDA’s research on the future of the U.S. food system. The chief scientist at USDA can determine the direction of USDA research–which should be shaped by an organic, rather than a chemical-intensive, vision. USDA needs a chief scientist who will help farmers get off the pesticide treadmill and adopt organic practices that address critical issues of protecting farmer and farmworker health, water resources, biodiversity, and soil health, while reducing the escalating crisis in global climate change. USDA’s research mission must be focused on sustainability and protect farmers, families, and the environment.

Since 1987, Dr. Hutchins has worked in addressing problems with chemical solutions at Dow AgroSciences’ pesticide and seed division, renamed Corteva Agriscience last year when it was spun off from the newly-merged DowDuPont, where Hutchins held the position of Corteva’s global leader of integrated field sciences, after serving as Dow AgroSciences’ global director for crop protection R&D.

Dow, which contributed $1 million to Trump’s inauguration in March 2017, got paid back when the EPA reversed its ban of chlorpyrifos. Other former high-level Dow employees appointed to the Trump USDA are former Dow AgroSciences lobbyist Ted McKinney, confirmed as USDA undersecretary for trade, and Ken Isley, appointed without need for Senate confirmation as head of the Foreign Agricultural Service. Rebekah Adcock, an advisor to Secretary Perdue, who was a lobbyist at CropLife America, a pesticide industry lobby group that includes Corteva. At EPA, former Dow lawyer Peter Wright has been nominated as assistant administrator of the EPA office that manages the Superfund program and other chemical hazards programs

Tell your U.S. Senators to Reject Dow’s Hutchins as USDA Chief Scientist.

Letter to Senators:

I am writing to urge you to reject the nomination of Scott Hutchins, PhD as USDA Chief Scientist. If confirmed, he will become the third member of Dow Chemical’s pesticide and seed division to hold a high-level position in the Trump administration’s USDA.

Dr. Hutchins has a history of defending toxic pesticides like Dow’s chlorpyrifos, which makes him unsuitable for leading USDA’s research on the future of the U.S. food system. Since 1987, Hutchins has worked in addressing problems with chemical solutions at Dow AgroSciences’ pesticide and seed division, renamed Corteva Agriscience last year when it was spun off from the newly-merged DowDuPont, where Hutchins holds the position of Corteva’s global leader of integrated field sciences, after serving as Dow AgroSciences’ global director for crop protection R&D.

The chief scientist at USDA can determine the direction of USDA research–which should be shaped by an organic, rather than a chemical-intensive vision. The USDA needs a chief scientist who will help farmers get off the pesticide treadmill and adopt organic practices that address critical issues of protecting farmer and farmworker health, water resources, biodiversity, and soil health, while reducing the escalating crisis in global climate change. USDA’s research mission must be focused on sustainability and protect farmers, families, and the environment.

Thank you.

Sincerely,

(Beyond Pesticides, December 7, 2018) As medicinal and recreational marijuana continue to be legalized in various states, concerns about the safety of the burgeoning industry — how the substance is grown, harvested, processed, distributed, sold, and used — have emerged. Colorado’s recent experience is a case in point: in early December, the state’s Marijuana Enforcement Division (MED) announced two recalls on cannabis products out of concern about their contamination by pesticide residues.

In both cases, the recall announcements from the Colorado Department of Revenue, in conjunction with the Colorado Department of Agriculture (CDA) and the Colorado Department of Public Health and Environment, said that the state agencies “deem it a threat to public health and safety when pesticides that are not on the list of approved pesticides for marijuana use as determined by CDA are applied in a manner inconsistent with the pesticide’s label.” Three off-label pesticides were listed in the recall announcement. Pyriproxyfen was found in samples tested from Colorado Wellness Centers LLC (dba Lush), and bifenthrin and diuron were found in samples from Crossroads Wellness LLC (dba Boulder Botanics). None of those compounds is approved by Colorado for use on marijuana; two are listed as possible carcinogens by the U.S. Environmental Protection Agency (EPA).

At roughly the same time came news out of California of a decidedly human glitch in that state’s recreational cannabis rollout: when the state’s new, mandated, and rigorous cannabis testing protocols became operational on July 1 of 2018, a lab director — at Sequoia Analytical Labs of Sacramento — allegedly began to falsify analyses of hundreds of batches of cannabis that went out to retailers. The alleged fraud continued for some months, without the knowledge of anyone else at the company, until — suspicious because of an unusual format of test reports that were submitted to it — the Bureau of Cannabis Control conducted an unannounced inspection of Sequoia’s laboratory. Reportedly, the lab director acknowledged that he’d falsified the reports, saying that some testing equipment was not functioning, and that he “just kept thinking [he] was going to figure it out the next day,” according to Sequoia’s general manager. The lab director was fired the day after the inspection, and the company voluntarily surrendered its cannabis testing license for 2018, although it hopes to regain it for 2019.

It is somewhat heartening that Colorado’s recalls represent a relatively cautious approach in response to the discovery of the three prohibited pesticide residues. John Scott of the CDA’s Pesticide Division, remarked, “No one’s done the risk assessments to determine that this specific parts per million on cannabis would still be safe. . . . That’s really the unknown and why we’ve taken the approach — a very precautionary approach.” He also noted that MED may issue more recalls if its enhanced mandatory pesticide testing for growers evidences the need. As increasing numbers of states were legalizing medical marijuana, Beyond Pesticides laid out the concerns — health and safety, and environmental — related to contamination of cannabis with pesticides, as well as a survey of what states were doing by way of regulation, in the Winter 2014–2015 issue of its journal, Pesticides and You.

There are multiple (and confusing) layers to the legal cannabis landscape. For starters, legalization of medical or recreational cannabis by states happens within a federal legal system that continues to designate marijuana as a Class I illegal substance. Legal, legislative, and regulatory scrambling in the states — to catch up to a growing industry with which legislation and regulation have not kept abreast — arises in part from this federal conundrum.

Beyond Pesticides has maintained that pesticide use on cannabis is illegal. Because cannabis is not a legal agricultural crop under relevant federal law (FIFRA, the Federal Insecticide, Fungicide, and Rodenticide Act), EPA has not evaluated the safety of any pesticide on cannabis plants. EPA has established no restrictions for pesticides used in cannabis production, and no tolerances, nor any exemptions from tolerances, for allowable pesticide residues on cannabis. As a result, EPA-permitted pesticide labels do not contain allowances for pesticide use in cannabis production.

As Beyond Pesticides wrote in 2015, “In the absence of federal regulations governing pesticides in cannabis production, the use of pesticides not registered by [EPA] is understood to be illegal. Several states have codified this understanding by adopting policies that prohibit all federally registered pesticides. Other states have taken the position that state policy is unnecessary, since EPA has not registered any pesticides for cannabis production and registered pesticide use is illegal. A review of state laws conducted by Beyond Pesticides finds a patchwork of regulations with varying degrees of protection for consumers and the environment.”

Beyond Pesticides wrote to the Colorado Department of Agriculture in 2015 to detail its objection and highlight the nature of the problem with the agency’s March 2015 issuance of its memo, Criteria for Pesticides Used in the Production of Marijuana in Colorado — a document that set out the parameters of permitting for use of certain pesticides on cannabis crops. Subsequently, Governor John Hickenlooper issued an Executive Order “directing state agencies to address public safety concerns related to pesticide-contaminated cannabis. The next day, the state of Oregon adopted new rules strengthening its requirements for laboratory testing of cannabis for pesticides.”

Colorado, Washington State, and Oregon have all taken steps to list “allowable” pesticides for marijuana cultivation. California began in June 2018 to set out parameters for testing of cannabis; at this juncture, all cannabis for medical and recreational use must be tested for 66 different proscribed pesticides, as well as for other contaminants, such as E. coli,  feces, mold, insect and rodent parts, mycotoxins, terpenoids, and heavy metals. The regulatory matrix in the states is dynamic, and events such as Colorado’s recalls and California’s fraudulent lab reporting may spur further adjustments.

A genuinely precautionary approach would go well beyond catching prohibited pesticide (and other) contaminants in cannabis. Particularly absent thorough federal testing of potential effects of the use of pesticides on cannabis for consumers, producers, and the environment, states should provide clear rules for sustainable production practices that would protect public health and the environment. Beyond Pesticides recommends that states establish laws and/or regulations that mandate a systems-level approach to cannabis production. A requirement, for example, that growers and processors follow the dictates of national organic standards would be prudent, precautionary, and a positive trajectory for the cannabis industry. Read more about Beyond Pesticides’ coverage of cannabis and pesticides here and at its Daily News archival page on the topic.

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

Sources: http://www.kunc.org/post/state-taking-precautionary-approach-pesticides-found-marijuana#stream/0 and https://www.leafly.com/news/industry/sequoia-analytics-surrenders-license-for-faking-lab-data

(Beyond Pesticides, December 6, 2018) A recent analysis of annual drinking water quality reports has revealed that many community drinking water systems in the Midwest have seasonal exceedances of the allowable limit for the herbicide atrazine. Atrazine, linked to endocrine disruption, neuropathy, and cancer, is the second most widely used pesticide in corn growing areas, with over 73 million pounds applied to agricultural fields each year.  A 2009 study by Paul Winchester, MD, professor of clinical pediatrics at Indiana University School of Medicine and a neonatologist at St. Francis Hospital in Indianapolis, linked birth defects to time of conception, with the greatest impact on children conceived when concentrations of atrazine and other pesticides are highest in the local drinking water. (See Reproductive Effects Peak with Pesticide Exposure.)

During peak use, atrazine levels in drinking water have been recorded at three to seven times above the legal limit. In addition to the well documented impact on the environment, recent  studies have linked prolonged pesticide exposure to not only shortened gestation and preterm birth for women, but also neurodevelopment delays in children. Ultimately, these unreported seasonal peaks may result in persistent adverse health impacts in impacted communities.

The Safe Drinking Water Act (SDWA), enacted in 1974, was developed with the mission to ensure the quality of the nation’s drinking water. This statute authorized EPA to set national drinking water standards in order to protect citizens against the health effects of harmful contaminant exposure. Unfortunately, while SDWA requires utilities to frequently test drinking water (hourly, monthly, quarterly, and annually, depending on the location and size of the public water system), the statute only requires compliance testing once a year. SDWA requires water utilities to report annual averages of testing for chemicals and pesticides.  The summary of this annual testing is then compiled and released within its Consumer Confidence Report (CCR) to its customers. This is problematic since many pesticides are used seasonally resulting in seasonal spikes over established legal limits and the impacted communities are not notified during the time of exposure.  Instead these peaks are buried under scores of data collected.

Water utilities are familiar with persistent pollution from atrazine application. In 2012, water utilities settled a class action lawsuit against the manufacturer of atrazine, Syngenta, to clean up atrazine contamination of its treated water. Even at levels established as “safe” or acceptable by EPA drinking water standards, atrazine is linked to endocrine disrupting effects. EPA is not adequately assessing the effects of atrazine by using high dose testing models, which are not appropriate for hormonally-active substances that often show effects at minute doses of endocrine disruptors. Studies by Tyrone Hayes, Ph.D., University of California, Berkeley, and others have shown that concentrations as little as 0.1ppb interferes with mammary gland development in the breast of mammals and is linked to certain birth defects like gastroschisis and choanal atresia, which are significantly increased for pregnant women with high levels of atrazine exposure in agricultural areas and from urban streams.

The European Union and many countries have banned atrazine, however EPA continues to put U.S. citizens and the environment in harm’s way, allowing nonstop use of this toxic chemical.

The evidence is clear. Not only does atrazine adversely affect human and environmental health, but both regulatory agencies and water utilities are failing to ensure that the drinking water distributed is devoid of hazardous chemicals and pesticides. SDWA must be updated to require water quality data information and notification on seasonal spikes of hazardous chemicals like atrazine when it occurs. To allow for delays and inaction jeopardizes both human and ecological health.

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

Source: Environmental Working Group