(Beyond Pesticides, April 5, 2023) A collective of Mayan beekeepers (Colectivo de Comunidades Mayas) in Mexico are implicating chemical industry giant Bayer/Monsanto in a massive die-off of more than 300,000 bees among their combined apiaries. According to Mexico News Daily, the total value of losses represent a staggering $663,000 U.S. dollars (12 million pesos). The incident is the latest instance of the pesticide  and agrichemical industry setting up shop in a local community and wrecking the health of the local ecology. Mayan beekeepers explain that Bayer/Monsanto recently started operations on a ranch near Crucero Oxá in the southern Mexican state of Campeche. A local businessman placed the 50 hectare ranch on loan to the company. Since that arrangement, the company has aerially sprayed row crops like corn and soy with undisclosed chemicals. “One of Bayer’s engineers or technicians allowed us to take samples from one of their crops after the bees started to die,” said beekeeper José Manuel Poot Chan, to the newspaper La Jornada Maya. “We are exhausting all possible legal instances, while members of the Welfare Ministry already came to offer humanitarian social aid to cover part of the damages.” Beekeepers suspect that the company is using the […]

(Beyond Pesticides, March 27, 2023) In a move labeled “risk mitigation”—that is, mitigation of the risk to its shareholders—Bayer-Monsanto announced in 2021 that it would phase out Roundup™ products containing glyphosate for the residential lawn and garden market as of January 2023. In taking this action, Bayer-Monsanto is making no admissions, and glyphosate products will still be available to farmers. However, Lowe’s and Home Depot are still selling the glyphosate-based lawn and garden products. Tell Lowe’s and Home Depot to eliminate Roundup™ and other toxic pesticides, promote organic practices, and sell organic compatible products.  In fact, since this is a voluntary reformulation, and Bayer-Monsanto has decided its own timing, the company cannot be held accountable to anything. The company could change its mind, and stores can continue to sell the glyphosate-based products as long as they want. And keep in mind that replacement versions of Roundup™ products are also toxic. Roundup® Dual Action, for example, contains the following active ingredients: triethylamine salt of triclopyr, fluazipop-P-butyl, diquat dibromide, and ammonium salt of imazapic. Thus, Bayer/Monsanto announces that it is changing the formulation of Roundup and moving away from glyphosate, while continuing to sell Roundup™ products formulated both with and without glyphosate—leaving consumers unaware of their risks. The U.S. Environmental Protection Agency (EPA) has […]

(Beyond Pesticides, March 7, 2023) Exposure to glyphosate (Roundup) and its breakdown products is associated with an increased risk of liver and metabolic disorders in children and young adults, according to research published in Environmental Health Perspectives earlier this month. While glyphosate has developed a well-deserved reputation as a carcinogen, research is finding that cancer is one of a myriad of chronic diseases associated with the notorious chemical. As this body of literature grows, growing awareness by the public is increasing pressure on the U.S. Environmental Protection Agency to cancel its allowed uses. Researchers began their investigation concerned about the rise of liver disorders and metabolic syndrome among young people. This trend has been pronounced among populations of color. The worrying increase has led many to consider synthetic chemical exposure as a contributing factor, as lack of diet and exercise is unlikely to account for the entirety of the increase. To better understand these impacts, researchers enrolled existing participants in the CHAMACOS (Center for the Health Assessment of Mothers and Children of Salinas) study, a long running cohort of mothers and their children born between the years 2000 and 2002 in the Salinas Valley of California. Enrolled participants consistent mostly […]

(Beyond Pesticides, March 2, 2023) Populations experiencing higher levels of environmental pollutant exposure, specifically pesticides, also experience a higher rate of irritable bowel syndrome (IBS), according to a study published in Environmental Toxicology and Pharmacology. IBS is a gastrointestinal disorder that causes abdominal pain or discomfort and changes in bowel behaviors. IBS affects 25 to 45 million individuals in the U.S., mostly female (two-thirds). Additionally, a quarter to half of all gastrointestinal-related visits are for IBS symptoms. Despite the unknown etiology of IBS, ample evidence demonstrates environmental contaminants, like pesticides, negatively affect the gut microbiota, causing a microorganism imbalance and resulting in inflammation associated with IBS. The gut, also known as the “second brain,” shares similar structural and chemical parallels to the brain. The microbiota in the gut plays a crucial role in lifelong digestion, immune and central nervous system regulation, as well as other bodily functions. Although studies show how chemical exposures affect overall human health, a growing body of peer-reviewed scientific literature is now questioning how these toxic chemicals influence gut health and the subsequent occurrence of diseases. The study notes, “These findings may help to understand the relationship between pesticide exposure and IBS; however, more epidemiological and experimental research is needed to understand […]

(Beyond Pesticides, February 15, 2023) Glyphosate use in grassland pastures reduces crop yield and impedes climate change mitigation, finds two studies (1,2) published this month from the University of Turku, Finland. While massive public relations campaigns by the agrichemical industry have poured in millions of dollars to convince politicians and the public that pesticides are necessary to ‘feed the world’ and address the climate crisis, the data does not support these claims. “Only in recent years, we have started to realise that intensive agriculture and agrochemical pollution in fact contribute to a reversal of the intended purpose. Soils are polluted with pesticides and at the same time, extreme weather events erode soil nutrients,” says study coauthor Benjamin Fuchs, PhD. Researchers approached their investigation through two separate experiments on the grass Festuca pratensis, an important forage crop grown for grazing animals throughout the world. The first experiment was conducted in an enclosed greenhouse, while the second took place in a field setting. For both experiments, plots were separated between glyphosate-sprayed and unsprayed controls. All plots received three different approaches to cutting the grass: one group that was intensely cut to two inches (5cm), the second group cut to six inches (15cm), […]

(Beyond Pesticides, February 8, 2023) Spraying pesticides around one’s garden negatively impacts local bird populations, according to research published by scientists at the University of Sussex, UK in Science of the Total Environment. Although this reasoning sounds common sense to those versed in the works of Rachel Carson, it underscores the immense importance of carrying on the legacy of her work and continuing to educate the public about the ongoing dangers posed by modern pesticides. As the study authors write, “Overall, our study shows that garden bird abundance and richness is strongly influenced by both extrinsic and intrinsic factors, and suggests that garden management, particularly regarding pesticide use, has a significant effect on bird life.” Researchers collected data by partnering with the British Trust for Ornithology, which conducts annual citizen-science counts of bird populations in UK gardens. Nearly 24,000 residents participate in the survey, which also includes information about the urbanization level surrounding their gardens, and other habitat characteristics. A group of these volunteers were provided with a questionnaire about their pesticide practices between 2020-2021, recording information on how often the pesticides were applied, as well as the pesticide brand name. After removing incomplete or unusable data, 615 individual gardens […]

(Beyond Pesticides, January 31, 2023) Glyphosate exposure induces oxidative stress in the body, a key biomarker known to heighten an individual’s risk of cancer, according to research published in the Journal of the National Cancer Institute by a team of scientists from the National Institutes of Health. The findings, which tracked study participants’ past use of glyphosate and exposure levels through urine, are particularly concerning in light of recent data showing that four out of five (81.6%) U.S. residents have detectable levels of glyphosate in their bodies. Despite these concerning data, evidence of widespread exposure to a carcinogen has so far failed to sway regulators at the U.S. Environmental Protection Agency, necessitating meaningful change by elected officials to reform pesticide regulation. Scientists began with the determination from the International Agency for Research on Cancer (IARC) that there is epidemiological evidence associating glyphosate with blood cancers like non-Hodgkin lymphoma, and strong evidence of carcinogenicity in laboratory animal research brought on by genotoxicity (DNA damage) and oxidative stress. “Oxidative stress occurs when the production of reactive oxygen species (ROS) and other free radicals exceeds the body’s antioxidant defense mechanisms, causing damage to DNA, proteins, and lipids,” the study explains. This process can […]

(Beyond Pesticides, January 30, 2023) Because antibiotics and fungicides are widely used in agriculture (except organic), they contribute significantly to the increasing efficacy problems with antimicrobial (antibiotic and antifungal medicines) use in health care, contributing to a growing crisis. According to Tedros Adhanom Ghebreyesus, PhD, World Health Organization Director-General, “Antimicrobial resistance undermines modern medicine and puts millions of lives at risk.”  Microorganisms—including bacteria, fungi, and viruses—are notoriously quick to evolve resistance to antimicrobial medicines. We know that selection for resistance is directly related to the frequency and intensity of antimicrobial use, so medical practitioners try to avoid using those medicines unless they are necessary. Tell EPA to cancel all uses of a pesticide when resistance is discovered or predicted to occur. Tell Congress to ensure that EPA protects public health from deadly antifungal and antibiotic resistance. Unfortunately, the medical profession lacks complete control over the use of antimicrobials. Many of the same chemicals used in human medicine are also used in agriculture. These may show up in or on treated food, but can also spread antimicrobial resistance through horizontal gene transfer. So, in addition to ingesting antibiotics in our food, the movement of resistant bacteria and fungi in the environment […]

(Beyond Pesticides, January 27, 2023) The U.S. Department of Agriculture (USDA), through its Agricultural Marketing Service (AMS), announced on January 19 its final rulemaking, the Strengthening Organic Enforcement Rule (SOE). The new requirements aim to strengthen the integrity of the National Organic Program (NOP) through both enhanced oversight and enforcement of existing program regulations, and the introduction of new ones to address occurrences of fraud in organic supply chains. Beyond Pesticides welcomes this important step in increased rigor for the burgeoning organic sector; the organization has long advocated for strong enforcement of the provisions of the 1990 Organic Foods Production Act (OFPA), the statute that gave rise to the NOP. It must also be noted that there is a significant difference between the (appropriate) attention being paid to oversight and enforcement in organic, and the long-standing lack of same in regard to the U.S. Environmental Protection Agency’s (EPA’s) pesticide regulations, weak as they are. Beyond Pesticides Executive Director Jay Feldman commented, “It is difficult to have a balanced conversation about any weaknesses in organic enforcement — which must be strengthened — without assessing the entire food system. The NOP provides the structure and the requirements for compliance with the OFPA. […]

(Beyond Pesticides, January 26, 2023) A study published in Food Safety and Toxicology finds that the widely used fungicide azoxystrobin (AZO), used in food production and turf management, can disrupt the function of the intestinal (colonic) barrier responsible for the absorption of nutrients and defense against harmful substances. This and other similar data are important because the U.S. Environmental Protection Agency (EPA), with its required pesticide testing protocol, says that the chemical has “low acute and chronic toxicity to humans, birds, mammals, and bees,” and speaks to the need for the agency to modernize its registration requirements. [The agency does note that AZO is “is highly toxic to freshwater fish, freshwater invertebrates, and estuarine/marine fish, and very highly toxic to estuarine/marine invertebrates.] AZO is a broad-spectrum chemical used in wheat, barley, oats, rye, soya, cotton, rice, strawberry, peas, beans, onions, and a long list of other vegetables, as well as on lawns and golf courses, on a range of fungal diseases. The intestinal (colonic) barrier prevents the internal environment from damage caused by exogenous toxins to ensure internal homeostasis, impeding incidences of systemic inflammatory response syndrome (SIRS), sepsis, and multiple organ dysfunction syndrome (MODS). The intestines host a group of microorganisms that form […]

(Beyond Pesticides, January 19, 2023) Research published in Environmental Health Perspectives finds the presence of nine various neonicotinoids (neonics) and six neonic metabolites within human cerebrospinal fluid (CSF). CSF is an essential part of the central nervous system (CNS), especially for CNS development. Specific chemical biomarkers (measurable indicators of biological state), like pesticides, found in CSF are useful for diagnosing and evaluating numerous neurological diseases. The nervous system is an integral part of the human body and includes the brain, spinal cord, a vast network of nerves and neurons, all of which are responsible for many of our bodily functions—from sensed to movement. However, mounting evidence over the past years shows that chronic exposure to sublethal (low) levels of pesticides can cause neurotoxic effects or exacerbate preexisting chemical damage to the nervous system. The impacts of pesticides on the nervous system, including the brain, are hazardous, especially for chronically exposed individuals (e.g., farmworkers) or during critical windows of vulnerability and development (e.g., childhood, pregnancy). Researchers identify the role agricultural chemicals play in CNS impacts causing neurological diseases, like amyotrophic lateral sclerosis (ALS) and Parkinson’s disease, dementia-like diseases such as Alzheimer’s, and other effects on cognitive function. Over 300 environmental contaminants and their byproducts, including pesticides, are chemicals commonly present in human blood […]

(Beyond Pesticides, January 13, 2023) The pastoral image that “farming” may still conjure for many will suffer a shock as Beyond Pesticides reports, in this Daily News Blog, about developments in the agricultural universe, including massive consolidation in the industries that supply seeds and agrochemicals to conventional farmers. A January 2023 report from Philip H. Howard, PhD updates previous work of his (see here and here) on these trends during the past couple of decades, and focuses on the most-recent (2018–2022) developments. The net conclusion is that the four largest agrochemical companies — Bayer (Monsanto), BASF, Corteva, and Sinochem (which recently subsumed ChemChina/Syngenta) — are exerting increasing leverage over an agricultural system that concentrates power and wealth, while threatening health, the environment, and access to food. The machinations of these industries for profit, power, market penetration, and privatization of aspects of the natural world are hardly new. The National Sustainable Agriculture Coalition (NSAC) summarizes some aspects of the situation in saying, “Land and seed once belonged to no one and were shared by all, replicating the giving essence of the natural world. Today, these precious resources are tightly controlled and commoditized inputs. The modern U.S. food and agriculture system is designed to […]

(Beyond Pesticides, January 12, 2023) Exposure to certain pesticides among individuals diagnosed with Parkinson’s disease (PD) can increase the risk of symptom progression. According to a study published in Science of the Total Environment, nearly 20 percent of pesticides associated with the onset of PD also increase the risk of faster decline in motor and non-motor function. Several studies find exposure to chemical toxicants, like pesticides, has neurotoxic effects or exacerbates preexisting chemical damage to the nervous system. Past studies suggest neurological damage from oxidative stress, cell dysfunction, and synapse impairment, among others, can increase the incidence of PD following pesticide exposure. Despite the association between PD onset via pesticide exposure patterns, few epidemiologic studies examine the influence pesticides have on worsening motor and non-motor symptoms in PD. Parkinson’s disease is the second most common neurodegenerative disease, with at least one million Americans living with PD and about 50,000 new diagnoses annually. The disease affects 50 percent more men than women, and individuals with PD have a variety of symptoms, including loss of muscle control and trembling, anxiety and depression, constipation and urinary difficulties, dementia, and sleep disturbances. Over time, symptoms intensify, but there is no current cure for this fatal disease. While […]

(Beyond Pesticides, January 9, 2023) The Biden EPA still needs a new vision in order to meet the existential crises in public health, climate change, and biodiversity. The Trump Environmental Protection Agency (EPA) reversed in four years much of the progress made by the EPA in decades. Despite a broad new perspective embodied in President Biden’s Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office, the Biden EPA has not adopted a new direction for regulating pesticides. Tell President Biden, EPA, and Congress to adopt a new direction for pesticide regulation. Immediately following his inauguration, President Joe Biden issued the EM, which directs the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This EM could reverse the historical trend of status-quo regulatory reviews required by the White House Office of Management and Budget (OMB) that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers). The President’s EM sets the stage for the adoption of agency policy across government to […]

(Beyond Pesticides, December 22, 2022) International health and environmental groups submitted an urgent letter to  the United Nations Food and Agriculture Organization (FAO) late last month demanding “greater transparency and accountability” through termination of the agency’s two-year-old partnership with CropLife International (CLI), a global trade association representing the world’s biggest pesticide manufacturers. Addressed to FAO Deputy Director Beth Bechdol ahead of FAO Council 171 session in Rome and COP15, the letter outlines a unique opportunity for the organization to lead the phaseout of fossil-fuel based food systems and use of agrochemicals while upholding the agency’s responsibility to act in response to conflicts of interest and human rights violations.   The original Letter of Intent (LOI), signed between CLI President and CEO Guilia Di Tommaso and FAO Director-General Qu Dongyu in October 2020, framed the partnership as a means to ensure humanity’s freedom from hunger while advancing Sustainable Development Goals. However, according to PAN Europe Policy Officer Manon Rouby, “While the private sector has been working with FAO for years, this official agreement with CropLife directly threatens FAO’s work on supporting farmers in the transition towards agroecology, while reducing the harms of synthetic pesticides worldwide. With CropLife members being the largest agrichemical […]

(Beyond Pesticide, December 20, 2022) A meta-analysis published in Chemosphere finds prenatal pesticide exposure, or pesticide exposure during pregnancy has a positive association with autism spectrum disorder (ASD) and attention deficit/hyperactive disorder (ADHD). Particularly, exposure to chemical classes organophosphate (OP) and pyrethroid (PYR) insecticides, in addition to the mother’s age during pregnancy (≥30 years old), increased the risk factor of ASD. ADHD risk increases among offspring whose mothers encounter organochlorine pesticides (OCPs) during gestation. The etiology or cause of ASD and ADHD involves the interaction of multiple components, including lifestyle and genetics. However, emerging evidence indicates that environmental contaminants like pesticides (e.g., occupational exposures, air pollution, solvents, dietary residues, etc.) play a role in disease etiology. Pesticide contamination is widespread in all ecosystems, and chemical compounds can accumulate in human tissues resulting in chronic health effects.  ADHD is estimated to affect 8-12% of school-age children worldwide. While it is a complex disease, and genetics may play a role, no specific genes have been identified, and there is increasing evidence that environmental factors like pesticide exposure facilitate the development of the condition. Additionally, U.S. Centers for Disease Control and Prevention (CDC) estimates that 1 in 54 children have been diagnosed with an autism spectrum […]

(Beyond Pesticides, December 19, 2022) As the new 118th Congress convenes on January 3, 2023, one of the key issues on the agenda led by Republicans in the U.S. House of Representatives is preemption of local authority to restrict pesticide use—undercutting the local democratic process to protect public health and safety. In the 117th Congress, H.R. 7266 was introduced to prohibit local governments from adopting pesticide laws that are more protective than federal and state rules. If H.R. 7266 were to pass or be incorporated into the 2023 Farm Bill, as the pesticide industry and proponents of the legislation plan to do, this bill would overturn decades of precedent as well as prevent local governments from protecting their residents from hazardous chemicals in their environment.   This is a direct assault on nearly 200 communities across the country that have passed their own policies to restrict the use of toxic pesticides. Communities must maintain the right to restrict pesticides linked to cancer, water-contamination, and the decline of pollinators to protect their resident’s health and unique local ecosystems.   Take action today and tell your U.S. Representative and Senators to support communities by opposing H.R. 7266 (and successor legislation in the new Congress) […]

(Beyond Pesticides, December 16, 2022) A report released last week — Merchants of Poison: How Monsanto Sold the World on a Toxic Pesticide — exposes not only Bayer/Monsanto malfeasance in its “promotion” of its glyphosate-based herbicide products, including the notorious Roundup®, but also, the broader landscape of corporate efforts to white- or green-wash products that companies know are harmful to people and the environment. The report was issued by U.S. Right to Know (USRTK, a nonprofit investigative research group focused on promoting transparency for public health), Friends of the Earth (FOE), and Real Food Media. It carries the pithy subtitle, “A case study in disinformation, corrupted science, and manufactured doubt about glyphosate,” a description cited by the Friends of the Earth press release as “at the core of the pesticide industry’s public relations playbook.” Beyond Pesticides welcomes this report, which comports with much of our previous coverage of the pesticide industry’s egregious misbehavior, and of glyphosate, the world’s most widely used herbicide. FOE calls the report the “first comprehensive review” of the Bayer/Monsanto “defense strategy” employed in attempts to deny science, manufacture doubt, and discredit critics who have researched, reported on, and/or advocated against the company’s flagship glyphosate products because […]

(Beyond Pesticides, December 5, 2022) A petition filed last week with the U.S. Fish and Wildlife Service (USFWS) urges increased protections for the West Indian manatee after dramatic declines in its population over recent years. In 2017, USFWS downgraded the classification of the manatee from endangered—a category that broadly protects against “take,” defined as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct”—to threatened, for which an “acceptable” level of “take” is allowed. Following the downlisting of the species, manatee populations have declined dramatically. Tell the U.S. Fish and Wildlife Service to upgrade the Florida manatee to endangered and require protection from chemical pollution. Tell your Congressional Representative to cosponsor H.R. 4946 and your Senators to introduce identical legislation. Tell Florida’s Fish and Wildlife Conservation Commission to protect manatees. Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years, weigh up to 1,200 lbs, and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat […]

(Beyond Pesticides, November, 30, 2022) A petition filed last week with the U.S. Fish and Wildlife Service (USFWS) urges increased protections for the West Indian manatee after dramatic declines in its population over the last several years. In 2017, the USFWS downgraded protections for the manatee, a move that was widely criticized by conservation groups as premature. That sentiment has become a reality, with nearly 2,000 manatees dying over the last two years from a range of preventable factors. West Indian manatees, a species of manatee that includes the Florida and Antillean Manatee subspecies, were first listed under the Endangered Species Act (ESA) in 1973, at a time when there were less than 1,000 individual animals in the United States. By 2017, the number of manatees had increased to over 6,000, leading then-Interior Secretary Ryan Zinke to downlist (downgrade) the animals from endangered to threatened under ESA. ESA works to protect species by listing them as either threatened or endangered. A species classified as endangered is in danger of extinction throughout all or a significant a portion of its range and a threatened classification means the species is likely to be endangered within the foreseeable future.  Endangered species are given […]

(Beyond Pesticides, November 25, 2022) A study published in Chemosphere adds to the growing body of research demonstrating the endocrine (hormone) disrupting effects of glyphosate play in breast cancer development. Exposure to the herbicide glyphosate and other glyphosate-based herbicides (GBHs) at high concentrations mimics the estrogen-like cellular effects of 17β-estradiol (E2), altering binding activity to estrogen receptor α (ERα) sites, thus causing fundamental changes in breast cancer cell proliferation (abundance).  Glyphosate is the most commonly used active ingredient worldwide, appearing in many herbicide formulas, not just Bayer’s (formerly Monsanto) Roundup®. The use of this chemical has been increasing since the inception of crops genetically modified to tolerate glyphosate over two decades ago. The toxic herbicide readily contaminates the ecosystem with residues pervasive in food and water commodities. In addition to this study, literature proves time and time again that glyphosate has an association with cancer development, as well as human, biotic, and ecosystem harm. Therefore, advocates point to the need for national policies to reassess hazards associated with disease development and diagnosis upon exposure to chemical pollutants. The researchers note, “The results obtained in this study are of toxicological relevance since they indicate that glyphosate could be a potential endocrine disruptor in the mammalian system. Additionally, […]

(Beyond Pesticides, November 24, 2021) On Thanksgiving, thank you for being a part of Beyond Pesticides and sharing and contributing to the vision necessary to protect the web and the fragility of life. We believe that there is no time like Thanksgiving to think about how we can more effectively join together as families and communities across divisions and different points of view to find a common purpose in protecting the health of the environment and all that inhabit it. Unfortunately, a host of pesticides, genetically engineered materials, and others in conventional Thanksgiving foods impact human health and threaten the environment. With far too many adverse health and ecological effects associated with toxic chemicals, organic practices are viable solutions to mitigate pesticide contamination and subsequent exposure. Read on as we consider the range of challenges we must confront and the solutions that can bring us all together. Additionally, you can help Beyond Pesticides in educating and building a movement that will bring long-needed protection to humans, animals, and the entire environment by attending the third seminar on November 29 on Climate during the 2022 National Forum Series, Health, Biodiversity, and Climate: A Path for a Livable Future. The National Forum […]

(Beyond Pesticides, November 21, 2022) Once again, the Environmental Protection Agency (EPA) has registered a new pesticide without performing a thorough review of its impacts on biodiversity as well as threatened and endangered species. Inpyrfluxam was registered in 2020 and only after being sued by the Center for Biological Diversity for failure to comply with the Endangered Species Act (ESA) did EPA commit to completing draft effects determinations by Fall 2022. Once again, EPA’s draft biological evaluation is incomplete and inadequate. EPA is accepting comments on its draft biological evaluation at Regulations.gov.  Tell EPA and Congress that Pesticide Registrations Require Complete Science. The Review of Inpyrfluxam is Incomplete and Inadequate.  The agency’s draft effects assessment is flawed and incomplete. We share the details because it shows that EPA is out of step with the science and its regulatory responsibility when it comes a thorough review for ecosystem effects of pesticides.   The agency used fish early life stage (ELS) tests to estimate chronic fish toxicity. This is inappropriate. The fish ELS is a sub-chronic test of sensitive life stages. Although it is often used as a surrogate or predictor of chronic toxicity, it does not adequately address potential adverse effects on reproduction or transfer of the test chemical to eggs/offspring […]