(Beyond Pesticides. January 7, 2022) Unbeknownst to most Americans when they woke up on New Year’s Day 2022, a new labeling system for genetically modified-engineered foods— promulgated in 2019 — which does not mention genetically engineered or GMO ingredients, went into effect. Consumer, food, and environmental advocates say that the new label is misleading, insufficiently transparent, discriminatory, rife with loopholes, and confusing for consumers. The new labeling requirement mandates that genetically engineered foods bear labels that indicate that they have been “bioengineered” or that provide a text-messaging phone number or a QR code as avenues for further information. (“Additional options such as a phone number or web address are available to small food manufacturers or for small and very small packages.”) The new labeling rule from the U.S. Department of Agriculture (USDA) aims, according to the agency, to eliminate the crazy quilt of labels affixed to foods and ingredients that have been scientifically altered. According to an agency spokesperson, the rule is designed to “balance the need to provide information to consumers with the interest in minimizing costs to companies.” Genetically altered food items and ingredients have heretofore been called, and labeled as, “genetically engineered” (GE) or “genetically modified” (GM), […]

(Beyond Pesticides, January 6, 2022) Seeds treated with neonicotinoid insecticides contaminate honeydew, often the biggest source of food for pest predators, according to recent research published in the journal Environmental Pollution. Concerned advocates for pollinators and pesticide reform are likely familiar with fact that neonicotinoids are systemic, and once applied to a seed or sprayed on a plant are taken up by the plant and distributed throughout the pollen, nectar and dew drops that a plant produces. But there is another systemic effect that is not included in that picture, and in monoculture crops, it could be the biggest source of carbohydrates for beneficial pest predators – honeydew. Honeydew is produced from phloem-feeding (sap sucking) pests like aphids, whiteflies, leafhoppers, and other hemipteran insects. The waste that these insects produce is liquid, and full of sugars. “This rich carbohydrate source is a common food for many beneficial insects, including pollinators, such as bees and flies, and some natural enemies of pests, such as ants, wasps and beetles,” said John Tooker, PhD, coauthor of a recent literature review published in Biological Reviews. “Honeydew often is more abundant than nectar in agroecosystems.” In 2019, a study published in the Proceedings of the […]

(Beyond Pesticides, December 10, 2021) In a win for pollinators, a California Superior Court has issued a ruling that sulfoxaflor, a systemic pesticide that is “field legal” but “bee lethal,” can no longer be used in the state. The suit was brought by the Pollinator Stewardship Council and the American Beekeeping Federation. The ruling of the Superior Court of the State of California for Alameda County finds that the argument of the petitioners — that sulfoxaflor approval decisions by the California Department of Pesticide Regulation (DPR) violated the California Environmental Quality Act (CEQA) — is valid. Eliminating this highly bee-toxic pesticide from use in the state is expected to protect not only native bees and other pollinators (including Monarch butterflies in early Spring), but also, the many millions of managed-colony bees that are transported to California for pollination of almond and other crops. The suit was filed against DPR, Corteva inc., Dow Agrosciences LLC, the Siskiyou County Department of Agriculture, and James E. Smith as Siskiyou County Agricultural Commissioner. Having found for the petitioners’ request for a Writ of Mandate (a court order requiring a lower court or public authority to perform its statutory duty), the court instructed the petitioners to […]

  (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 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, there are a host of pesticides, genetically engineered materials, and others in conventional Thanksgiving foods that not only impact human health, but 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. The Climate As climate impacts grow, an increase in uses of synthetic pesticides in agriculture is likely — because of waning efficacy (pesticide resistance) of these compounds, and mounting pest pressure (i.e., increasing insect population and metabolism). Production of pesticides contributes to greenhouse gas emissions gas (e.g., nitrous […]

(Beyond Pesticides, November 12, 2021) Omnivorous readers may have encountered an article, in the November 15 issue of The New Yorker magazine, titled — at best misleadingly, and certainly sensationally — “The Great Organic-Food Fraud.” The subhead comports with the tone of the headline: “There’s no way to confirm that a crop was grown organically. Randy Constant exploited our trust in the labels — and made a fortune.” The piece, by Ian Parker, tells a complex tale of the machinations of dishonest and greedy people who saw, in the commerce in organic grains, an opportunity to misrepresent nonorganic crops as organic and make a boatload of money in doing so. What the article fails to do is render any comprehensive picture of how National Organic Program certification and inspection work, and the underlying principles, values, and standards in federal law (the Organic Foods Production Act), nor does it review either the benefits of organic agriculture broadly or the massive harmful impacts of conventional, chemical-intensive agriculture in the U.S. Beyond Pesticides provides ballast, in this Daily News Blog article, to the failings of the New Yorker article and the damage it might do to the organic movement. It is worth noting […]

(Beyond Pesticides, October 13, 2021) Pesticide use in conventional chemical-intensive farming is so pervasive that weeds are developing resistance to herbicides they have never encountered before. According to research published in Plant and Cell Physiology and New Phytologist, the notoriously difficult-to-control weed waterhemp (Amaranthus tuberculatus) is outpacing commercial crops in its ability to detoxify after herbicide exposure. “This is probably the first known example where waterhemp has evolved a detox mechanism that a crop doesn’t have. It’s using a completely different mechanism, adding to the complexity of controlling this weed,” says Dean Riechers, PhD, study co-author and professor at University of Illinois. Researchers found waterhemp resistant to the chemical syncarpic acid-3 (SA3). SA3 is one of the earliest versions of a 4-Hydroxyphenylpyruvate dioxygenase (HPPD) inhibiting herbicide. HPPD inhibiting herbicides, which include herbicides like isoxaflutole and mesotrione, are selective (ie plant-specific) and break down amino acids that are required for plant growth and development. Corn generally tolerates HPPD-inhibiting chemicals, detoxifying them through different channels depending upon the specific type of HPPD herbicide. Weeds that grow in and around corn fields where these chemicals are regularly sprayed, like waterhemp, have likewise evolved the ability to detoxify HPPD-inhibitors, mostly mimicking the process that […]

(Beyond Pesticides, October 6, 2021) Agricultural soils under monoculture cropping systems are not as healthy as soils with diverse plantings, finds research recently published in the journal Agrosystems, Geosciences and Environment. Soil and soil quality are declining rapidly in the United States and around the world, with recent data indicating that the U.S. Corn Belt has lost 35% of its topsoil. Advocates say it is critical that the response to this problem focus on practices that conserve and improve the soil health by building organic matter and healthy microbial populations. “Understanding the management practices that lead to healthier soils will allow farmers to grow the same crops while reducing costly chemical inputs (fertilizers, pesticides, herbicides) and protecting the environment,” said study coauthor Lori Phillips, PhD. To investigate disparities in soil health between cropping systems, researchers analyzed a long-term cropping system that includes 18 years of continuously grown soy, corn, and perennial grasses. Each cropping system was evaluated for its bacterial and fungal population, as well as a test called CNPS, which measures the enzymes produced by microbes specifically related to the soil’s carbon, nitrogen, phosphorous, and sulfur cycles. Researchers indicate that these measurements create “a holistic measure of biological activity,” […]

(Beyond Pesticides, July 30, 2021) Bayer (Monsanto), the maker of the deadly herbicide glyphosate/Roundup, after hinting in May that it would end the weed killer’s residential uses in the U.S., made it official yesterday. With its announcement to shareholders, Bayer puts an end to residential uses beginning in 2023 and allocates $4.5 billion to cover “the company’s potential long-term exposure” from lawsuits by those harmed by the chemical. At the same time, the company announced it is seeking a U.S. Supreme Court hearing to reverse significant jury verdicts (from $289 million to $2 billion) for individuals who have suffered health damage they tie to glyphosate exposure. Bayer claims that it will argue that federal pesticide law preempts litigation against products that it has registered with the U.S. Environmental Protection (EPA). Similar arguments have been tried before, most notably in Bates v. Dow Agrosciences (2005), and the Supreme Court has found that federal pesticide law does not protect “manufacturers of poisonous substances.” (See more below.) Despite the extensive scientific review (see Pesticide Gateway) of glyphosate/Roundup and a “probable” cancer causing ranking by the World Health Organization/International Agency for Research on Cancer in 2015, Bayer says, “This move is being made exclusively […]

(Beyond Pesticides, June 18, 2021) As the U.S. Environmental Protection Agency (EPA) continues to drag its feet on protective regulation of neonicotinoid pesticides, states continue to step up to restrict their use. In April, the Maine legislature passed, and Governor Janet Mills has now signed, a new law that will prohibit use of neonicotinoid pesticides with the “active ingredient[s] dinotefuran, clothianidin, imidacloprid or thiamethoxam used for application in outdoor residential landscapes such as on lawn, turf or ornamental vegetation” [links by Beyond Pesticides]. Though short of an outright ban, this law is a solid step forward for Maine in reining in use of these compounds, which are neurotoxicants widely implicated in pollinator (and other insect, bird, and mammal) harms or declines. Until a federal ban happens, Beyond Pesticides offers guidance on avoiding use of neonicotinoid pesticides through its fact sheet, Managing Pests Safely Without Neonicotinoids, and its Bee Protective web pages. This new Maine law does, however, include exemptions for wood preservation, indoor pest control, use on pets, treatment of structure foundations, and controlling invasive insect pests, such as the Asian long-horned beetle, emerald ash borer, and hemlock wooly adelgid. The statute leaves other large loopholes that will permit continued use […]

(Beyond Pesticides, May 28, 2021) A report by the Office of the Inspector General for the U.S. Environmental Protection Agency (EPA) concludes that scientific analyses by the agency were altered so as to favor top Trump administration officials’ policy choices in the 2018 reapproval of the highly toxic and problematic pesticide, dicamba. The report, “EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision,” was publicly released on May 24. It confirms aspects of what Beyond Pesticides and many others in the science, advocacy, public health, and environmental communities have been saying and reporting since 2016: the Trump administration executed a wholesale assault on scientific integrity in federal decision making. In its research on the matter, the Inspector General’s office (OIG) reviewed EPA’s 2016 and 2018 decisions on dicamba’s registration, documentation that purported to support those decisions, and the concerns forwarded in the ruling by the U.S. Court of Appeals for the Ninth Circuit and by many stakeholders. (See more in figure below.) It also reviewed EPA internal procedures and guidance on pesticide registration, and agency scientific integrity materials; interviewed career scientists and other agency staff; and communicated with EPA’s Scientific Integrity (Science Advisor) program staff. As reported […]

(Beyond Pesticides, April 16, 2021) Recent research, published in Environmental Pollution in late 2020, examines levels and persistence of pesticide pollution in recreational lakes. The study finds: (1) concentrations of the neonicotinoid imidacloprid at levels exceeding ecotoxicity limits for aquatic invertebrates in a recreational lake that receives predominately urban runoff, and (2) that pesticide residues persist in the studied lakes throughout the growing season. Based on their findings, the scientists emphasized the importance of stricter regulation of insecticide compounds, and of better education about their impacts. Beyond Pesticides maintains that neonicotinoid pesticides should be banned for several reasons, not least of which is the extreme damage they cause to pollinators. The goal of the study was to evaluate potential ecosystem exposure to pesticide contamination in Midwestern recreational lakes, as well as the persistence of pesticide residues in those water bodies over the course of the growing season. Study authors hypothesized that watersheds with significant agricultural land uses would have higher concentrations of pesticides compared to largely urban and herbaceous watersheds. This research, out of the University of Nebraska–Lincoln and the University of Kentucky, looked to evaluate the occurrence of neonicotinoid and organothiophosphate insecticides, and some fungicides, in three lakes with differing […]

(Beyond Pesticides, April 8, 2021) Pesticide use threatens aquatic and terrestrial invertebrates and plants more than ever, despite declining chemical use and implementation of genetically engineered (GE) crops in the U.S., according to a University Koblenz-Landau, Germany study. Since the publication of Rachel Carson’s Silent Spring (1962), many environmental agencies have banned the use of pesticides like organochlorines, organophosphates, and carbamates for their devastating toxic—sometimes lethal—effects, particularly on vertebrates, including humans. However, this ban created a pathway for a new generation of pesticides (e.g., neonicotinoids, pyrethroids) to take hold. Although these pesticides are more target-specific, requiring lower chemical concentrations for effectiveness, they have over double the toxic effects on invertebrates, like pollinators.  Invertebrates and plants are vital for ecosystem function, offering various services, from decomposition to supporting the food web. Furthermore, invertebrates and plants can act as indicator species (bioindicators) that scientists can observe for the presence and impact of environmental changes and stressors. Therefore, reductions in invertebrate and plant life have implications for ecosystem health that can put human well-being at risk. Study lead author Ralf Schulz, PH.D., notes, “[This study] challenge[s] the claims of decreasing environmental impact of chemical pesticides in both conventional and GM [genetically modified or genetically engineered (GE)] crops and […]

(Beyond Pesticides, March 23, 2021) Earlier this month, the Arkansas State Plant Board (ASPB) voted to loosen regulations curtailing use of the highly drift-prone herbicide dicamba. With an 8-7 vote, ASPB eliminated measures advanced in 2016 that protect growers from dicamba drifting off of genetically engineered (GE) soybean fields. Farmer, health, and environmental advocates are encouraging groups and individuals to submit testimony in opposition to the changes should the state’s Governor continue the proposal to a 30-day comment period. Dicamba has been the subject of intense debate and scrutiny over the last several years—most prominently in Southern and Midwestern states where extensive cotton and soybean monocultures are grown. Due to rampant weed resistance to glyphosate herbicides in GE crop fields, Bayer/Monsanto developed new seeds capable of growing into plants that can withstand repeated sprayings of both glyphosate and dicamba. The company released these new seeds in the mid-2010s without waiting for the U.S. Environmental Protection Agency (EPA) to approve a corresponding herbicide formulation Bayer/Monsanto claimed would reduce drift problems. Farmers began using older, unapproved dicamba formulations, but ultimately even after receiving approval, new formulations proved too drift-prone and problematic to be used without incident. In response, ASPB instituted changes that […]

(Beyond Pesticides, January 11, 2021) Treatment of chemical companies as clients rather than regulated entities is not new at the Environmental Protection Agency (EPA), but corruption reached new highs during the Trump administration. With a new administration, it is time to end the rule of corporate deception at EPA. This goes beyond the use of the Congressional Review Act to reverse individual rules (adopted in the last six months) that defy scientific findings and compliance with environmental and public health standards. We can no longer rely on bad science and unscrupulous chemical manufacturers that put profits above concerns for the health of people and the environment. EPA must audit pesticide registrants for integrity to scientific process and set a moratorium on future pesticide registration until the agency can assure the public that their science is not corrupt, as it has been in the past. Tell President-elect Biden and Congress to clean up the corruption of science at EPA and set a moratorium on future pesticide registrations—until the agency can assure the public that the chemical manufacturers’ science supporting pesticide registrations is not corrupt. The Midwest Center for Investigative Reporting published a story in early December on yet another example of the […]

(Beyond Pesticides, December 21, 2020) The toxic herbicide dicamba is once again at the center of a larger story about states’ authority to regulate pesticides more stringently federal dictates and a response to corporate corruption in the marketing of pesticide products. The Trump EPA (U.S. Environmental Protection Agency) has just made it much harder for state regulations to be more protective than federal rules. It did so via a footnote embedded in dozens of pages of regulatory documents related to EPA’s registration of three new dicamba products.  Tell the Biden transition team that EPA must respect states’ rights to protect people and property in their states. Meanwhile, a report by the Midwest Center for Investigative Reporting found Monsanto and BASF, a German chemical company that worked with Monsanto to launch the system coupling dicamba with resistant crops, knew their dicamba herbicides would cause large-scale damage to fields across the U.S., but decided to push them on unsuspecting farmers anyway, in a bid to corner the soybean and cotton markets with their dicamba-resistant seeds. For nearly 30 years, state regulators have used Section 24 (“Special Local Needs” section) of FIFRA, the Federal, Insecticide, Fungicide and Rodenticide Act—the law that gives EPA […]

(Beyond Pesticides, December 18, 2020) The Midwest Center for Investigative Reporting published a story in early December on yet another example of the corporate malfeasance that exalts profit far above concerns for safety, health, and ecosystems. The Midwest Center’s investigation finds that Monsanto and BASF, makers of the extremely problematic herbicide dicamba, engaged in a variety of deceitful, unethical, and possibly fraudulent practices to enable its use. The bottom line is that the companies knew, before they released dicamba, about the massive damage it would cause — and then put it on the market. Beyond Pesticides has reported on the corporate greed that fuels the downstream public health, environmental, and economic devastation these pesticides cause, and advocated for their removal from the market. Such unscrupulous behavior is not confined to these companies; Bayer (which now owns Monsanto) and Syngenta are also implicated in similar actions related to other pesticides: glyphosate and atrazine, respectively. Over the course of the past couple of decades, large agrochemical corporations have pursued not only extreme market penetration for their toxic products, but also, vertical integration that, in the case of Bayer/Monsanto, “represents a near-monopoly on the agriculture supply chain.” Corporate ownership of the patent on genetically […]

(Beyond Pesticides, November 4, 2020) Despite a recent court ruling voiding the registration of drift-prone dicamba herbicides on genetically engineered (GE) cotton and soybeans, EPA has renewed  the registration of these chemicals. The court’s ruling stated that EPA, “substantially understated risks that it acknowledged and failed entirely to acknowledge other risks,” in regards to the herbicides XtendiMax and Eugenia (dicamba), produced by agrichemical corporations Bayer and BASF for their genetically engineered (GE) crops. In announcing the decision, Administrator Andrew Wheeler said the agency made its decision “[a]fter reviewing substantial amounts of new information, conducting scientific assessments based on the best available science, and carefully considering input from stakeholders.” Yet, it is evident that the most important stakeholders for EPA continues to be chemical corporations. The history of dicamba’s use in GE agriculture reveal this to be the case. In the mid-2010s, Bayer’s Monsanto developed new dicamba-tolerant seeds and received approval to sell them from the U.S. Department of Agriculture. EPA had not yet approved its corresponding herbicide, but nonetheless, Bayer’s Monsanto urged farmers to plant its seed, claiming they would increase yields. The results of this were predictable: farmers began to use older, unapproved dicamba formulations on their new GE […]

(Beyond Pesticides, September 18, 2020) In late August, Consumer Reports magazine (CR) issued a report titled, “Stop Eating Pesticides,” which offers consumers a rating system CR developed and employed to help them “get the health benefits from fruits and vegetables while minimizing [the] risk from toxic chemicals.” In addition to providing its analysis and ratings of the pesticide risk of a variety of produce items, CR recommends eating organically grown and raised foods whenever possible. It also makes a host of recommendations on federal pesticide policies and emphasizes the importance of maintaining the integrity of the National Organic Standards (of the USDA-housed National Organic Program). Beyond Pesticides appreciates that this mainstream publication has arrived at many shared, science-based assessments of the risks of pesticides. That said, a wholesale transition to organic and regenerative agriculture — rather than making the public figure out which fruits and vegetables are “safer” or “less safe” — is the real answer to the health risks of pesticides in the food supply, according to Beyond Pesticides. The CR analysis used data from the U.S. Department of Agriculture’s (USDA’s) Pesticide Data Program for 2014–2018. Those pesticide residue data were compiled from tests of approximately 450 pesticides across 24,000 […]

(Beyond Pesticides, August 21, 2020) A foundational study of the toxic insecticide chlorpyrifos left critical data out of its analysis, resulting in decades of an Environmental Protection Agency (EPA) “safe exposure limit” that is flat out wrong, new research says. That 1972 study concluded that the amount of the chemical to which a human could be exposed before adverse effects showed up (the “no observed adverse effect level,” or NOAEL) was more than twice as high as should have been determined had the study not ignored critical data. In addition, the study points to the perennial “fox and hen house” issues at EPA, which include using research commissioned, funded, or even conducted by industry as any basis for regulation. For years, Beyond Pesticides has rung the alarm on this very dangerous pesticide, and advocated for its ban nationwide. News of this omission from the 1972 “Coulston Study” comes from a team out of the University of Washington. The researchers re-analyzed that human intentional dosing study using both the original statistical methods and modern computational tools that did not exist in the 1970s. (An important side note: such a study is unethical by current research standards.) The new analysis finds two significant […]

(Beyond Pesticides, August 13, 2020) Levels of the notorious herbicide compound glyphosate in the human body are reduced by 70% through a one-week switch to an organic diet, finds a new, peer-reviewed study published in August 2020 in the journal Environmental Research. This result emphasizes both the ubiquity of this compound in the human body, and diet as the primary source of exposure for most people. It also adds to the evidence for Beyond Pesticides’ assertions that: (1) chemical-intensive agriculture must be abandoned, for a variety of reasons that include human health, and (2) in the lead-up to a transition to organic and regenerative agriculture, consuming organic foods as much as is practicable is powerful protection from glyphosate, and from the assault of multiple chemical pesticides to which most people are exposed. Glyphosate is the active ingredient in the popular weed killer RoundupTM, which has been used intensively in the U.S. and around the world, especially during the last couple of decades. It is very commonly used on crops grown from genetically engineered (GE) companion seeds for a variety of staple crops (e.g., soybeans, cotton, and corn). These GE seeds are glyphosate-tolerant, whose attribute has allowed growers to apply the herbicide and […]

(Beyond Pesticides, August 11, 2020) Petitioners who mounted a legal challenge to the Environmental Protection Agency’s (EPA’s) registration of Enlist Duo, a relatively new and highly toxic pesticide product, recently learned of a mixed decision from the U.S. Ninth Circuit Court of Appeals in the case. The good news is that Judge Ryan D. Nelson, writing the opinion for the court, found that EPA, in registering the herbicide Enlist Duo, had failed to protect monarch butterflies, which are under consideration as a threatened species under the Endangered Species Act (ESA). On the other and disturbing hand, the court concluded that EPA registration of the product was otherwise lawful — which means that this toxic compound will for now remain on the market. As one of the plaintiffs in the case, Beyond Pesticides is adamant that this product should not be registered for use by EPA. George Kimbrell, Legal Director of Center for Food Safety and Lead Counsel for the plaintiffs, commented on the decision in the organization’s July 22 press release on the decision: “The panel majority’s unprecedented decision is contrary to controlling law and established science, and Center for Food Safety is analyzing all legal options, including seeking a full […]

(Beyond Pesticides, August 7, 2020) Research out of the Silent Spring Institute identifies 28 registered pesticides linked with development of mammary gland tumors in animal studies. Study authors Bethsaida Cardona and Ruthann Rudel also report that many of the pesticides they investigated behave as endocrine disruptors; breast cancers in humans are significantly influenced by hormones generated by the endocrine system. The Environmental Protection Agency (EPA) acknowledges that nine of these 28 pesticide compounds cause mammary tumors, but dismisses the evidence of the other 19. The results of this research, published in the journal Molecular and Cellular Endocrinology, evince Beyond Pesticides’ long-standing argument that the risk assessment process used by EPA for its pesticide registration process is substantially inadequate to protect human health. The co-authors cite, as the catalyst for this research project, a Cape Cod resident’s outreach to the Silent Spring Institute several years ago, asking for information about the herbicide triclopyr because utility companies wanted to spray it on vegetation below local power lines. (The compound has also been used by the logging industry in the Pacific Northwest.) They reviewed more than 400 EPA pesticide documents on the health impacts of many registered pesticides for this research, conducted as part […]

(Beyond Pesticides, July 31, 2020) On July 22, the New York State Legislature passed Senate 6502 / Assembly 732-B — a bill that would ban the use of all glyphosate-based herbicides on state properties. The bill now awaits Governor Andrew Cuomo’s signature, which would make it law effective December 31, 2021. Beyond Pesticides considers this a hopeful development in the glyphosate “saga” and has urged the governor ought to sign it. Nevertheless, such piecemeal, locality-by-locality initiatives represent mere “drops” of protection in an ocean of toxic chemical pesticides to which the U.S. public is exposed. A far more effective, protective solution is the much-needed transition from chemical-intensive agriculture and other kinds of land management to organic systems that do not use toxic pesticides. The bill — titled “An Act to amend the environmental conservation law, in relation to prohibiting the use of glyphosate on state property” — was introduced in 2019 and sponsored by New York State Assembly Member Linda B. Rosenthal (D/WF-New York) and State Senator José Serrano. It would add a new subdivision to section 12 of the state’s environmental conservation law, proscribing “any state department, agency, public benefit corporation or any pesticide applicator employed thereby as a contractor […]