(Beyond Pesticides, January 9, 2024) A “landscape-level” study finds that typical risk assessment studies used by the U.S. Environmental Protection Agency (EPA) and European regulators fail to “safeguard bees and other pollinators that support agricultural production and wild plant pollination.” The study, published in Nature (November 2023), evaluates the health of bumble bees (Bombus terrestris) as a sentinel species placed in 106 agricultural landscapes across Europe. The authors’ conclusions challenge “the current assumption of pesticide regulation—that chemicals that individually pass laboratory tests and semifield trials are considered environmentally benign”—calling into question EPA’s persistent failure to adequately regulate mixtures of chemicals to which organisms are exposed in the real world. This study adds to the body of science on pesticide mixtures adversely affecting bee and pollinator health. See here, here, and here. The failure to capture real-world exposure to pesticide mixtures in its regulatory assessments extends to EPA’s systemic failure to evaluate a range of serious adverse impacts, as noted by the agency’s Office of Inspector General (OIG) report. And, aquatic environments also have documented mixtures of pesticides, with the U.S. Geological Survey finding 90 percent of water samples containing at least five or more different pesticides. “We can take no comfort […]

(Beyond Pesticides, January 5, 2024) The 28th United Nations Climate Change Conference of the Parties (COP28) wrapped up in Dubai on December 13 with what some hailed as a breakthrough agreement among almost 200 countries to reduce fossil fuel consumption that signals “the eventual end of the oil age.” To be successful and assure human survival, eliminating oil, gas, and coal use, Beyond Pesticides is calling for the elimination of petrochemical pesticides and fertilizers and support for organic, regenerative agriculture around the world. Because of the insurmountable crises that are caused or exacerbated by petrochemical pesticides and fertilizers, the adoption of organic land management practices and the need for foundational change in federal, state, and local policies and practices has come into focus. Under organic management, healthy soil can absorb and store 1,000 pounds of carbon per acre foot of soil annually. This translates to about 3,500 pounds of carbon dioxide per acre drawn down from the air and sequestered into organic matter in soil. (It is noteworthy that use of synthetic fertilizers actually compromises the carbon-capture ability of some kinds of terrain, such as salt marshes.) A fact often overlooked by policy makers in generating climate strategies is that carbon-sequestering soil practices […]

(Beyond Pesticides, December 18, 2023) Since nearly three-quarters of the country’s fruits and nuts are grown in California, new regulations being proposed by the California Department of Pesticide Regulation (DPR), governing public disclosure of pesticide use, concern all food eaters. Food consumers are increasingly concerned about not only the residues of pesticides and other toxic materials in their food, but the impact of the production practices to the workers, the communities, and the environment where their food is grown. While the precedent-setting DPR proposal is an important step in providing the public with information on the chemicals used in California food production, advocates are asking that the regulations include information on the exact location of planned pesticide applications so that people in the toxic chemical application area can take protective action. Tell DPR to require exact field locations for dangerous pesticide applications and commit to improvements based on community input. The DPR proposal, while precedent-setting in providing Californians with the basic right-to-know about planned use of toxic chemicals in their neighborhoods, will not provide the exact location of planned pesticide applications. Under the DPR proposal, the public would be provided with an application location of one square mile—even though the […]

(Beyond Pesticides, December 15, 2023) Drawing on a recent gathering of international scientists, a group of 34 scientists published a call for much stricter scrutiny of researchers’ conflicts of interest by agencies that regulate and register chemicals, with recommendations for the newly formed Intergovernmental Science Policy Panel. Writing in Environmental Science & Technology, the authors, led by Andreas Schäffer of Aachen University in Germany and Martin Scheringer of Masaryk University in the Czech Republic, cite an abundance of examples of chemical companies and their trade associations manufacturing doubt via an array of techniques, resulting in agencies such as the U.S. Environmental Protection Agency (EPA) dropping certain provisions from rulemaking, ignoring scientific consensus, and keeping chemicals on the market—and in the environment—that many scientists say should be entirely banned. The authors produced the article in response to this webinar to discuss how to ensure that U.N. panels dealing with global crises get the most sound scientific advice conducted by the International Panel on Chemical Pollution. Over the last four decades or so, the notion that conflicts of interest affect the validity of scientific research and professional opinions has been steadily eroded. Regulators wallow in compromised research, hamstrung by political pressure and […]

(Beyond Pesticides, December 13, 2023) A study published in Environmental Health finds occupational (work-related) exposure to pesticides increases the risk of endometrial (uterine) cancer development. Endometrial cancer is the most common cancer of the female reproductive system and the fourth most common cancer among women, primarily affecting the uterine lining rather than the uterus itself, like uterine sarcoma. Despite data predicting the disease rate to increase, few studies evaluate the connection environmental contaminants have on endometrial cancer occurrence. Like most cancers, non-genetic factors account for a majority of endometrial cancer risk, including diabetes, age, contraceptive (birth-control) use, and hormone (endocrine) disruption. However, three percent of all cases are hereditary, primarily from Lynch syndrome. The study notes, “Identifying other modifiable risk factors may help develop strategies to reduce the expected increasing incidence of these neoplasms.” Many pesticides have a long history associated with endocrine-disrupting properties that induce various molecular changes, prompting disease development. The International Agency for Research on Cancer (IARC) classifies many of these chemicals as potent carcinogens in animal studies. Cancer development also depends on genetic susceptibility, as impaired genes responsible for xenobiotic detoxification (elimination) increase disease risk sensitivity. Adding to the science, a review published in Environmental Exposure, Biomonitoring, and Exposure […]

(Beyond Pesticides, December 8, 2023) Nine pesticides have been found in nearly 40% of nonorganic conventional baby foods tested, according to a study conducted by Environmental Working Group (EWG). The study found no residues of the pesticides studied in a sample of certified organic baby food. While the study finds no traces of the highly neurotoxic insecticide chlorpyrifos, associated with brain damage in children, the chemical has been allowed back on the agricultural market after being removed in 2021—raising an alarm for parents who purchase baby food with ingredients grown in chemical-intensive (“conventional”) agriculture. In November 2023, a three-judge panel of the Eighth Circuit Court of Appeals reversed a 2021 U.S. Environmental Protection Agency (EPA) decision to ban chlorpyrifos’ agricultural uses, which came after a 2021 Ninth Circuit Court of Appeals decision found that the agency’s inaction violated federal pesticide law. Because of its neurotoxic effects on children, EPA had in 2000 negotiated Dow Chemical’s voluntary cancellation of most residential uses of the chemical, but left virtually all of the chemical’s agricultural uses in place. While the EWG study focuses on pesticide residues in food and the hazards associated with ingestion of dangerous chemicals, raising alarms, purchasing baby food processed with nonorganic […]

(Beyond Pesticides, November 30, 2023) Scientists at Minami Kyushu University in Japan have made a groundbreaking discovery of a new biological control for a target insect. They have identified a virus in tobacco cutworms that kills males, creating all-female generations. The discovery was described in a recent issue of the Proceedings of the National Academies of Sciences and The New York Times as evidence that multiple viruses have evolved to kill male insects. This “male-killing” virus could be added to the growing attempts to control unwanted insects with biological, as distinguished from genetically engineered (GE) solutions. Efforts range from the introduction of natural predators, to radiation-based sterilization of insects, CRISPR-based genetic mutations, and other techniques. While the GE approach has run into controversy because of unanswered questions associated with their release into natural ecosystems, some approaches have also run into resistance problems. Nearly a decade ago, researchers found armyworm resistance to Bacillus thuringiensis (Bt)-incorporated genetically engineered (GE) maize in the southeastern region of the U.S., calling this evolution of insect resistance to a naturally occurring soil bacterium engineered into crops “a serious threat to the sustainability of this technology.” The general population knows to avoid eating raw eggs because the bacteria salmonella, […]

(Beyond Pesticides, November 14, 2023) One of the Environmental Protection Agency’s (EPA) strongest tools for avoiding responsibility is delay—a tactic that kept cancellation of the neurotoxic pesticide chlorpyrifos at bay for 21 years—until May 2021, when a three-judge panel of the Ninth Circuit Court of Appeals, responded to a petition filed in 2007 by the Natural Resources Defense Council, Pesticide Action Network, and numerous other groups. The Ninth Circuit ordered the agency to quit lollygagging and acknowledge chlorpyrifos’s threat to human health, something the agency had acknowledged already. The Ninth Circuit instructed EPA to either revoke the “safe” tolerances the agency had set for chlorpyrifos’s residue in various foods or demonstrate that they are actually safe. Finally capitulating, EPA issued a final rule in August 2021 revoking all food tolerances for the neurotoxicant. Tell your governor and mayor to adopt policies that support organic land management.  This looked like progress until February 2022, when a different set of petitioners—pesticide companies, U.S. farmer groups, and other countries’ agricultural interests—filed an action in the Eighth Circuit Court of Appeals. On November 3 of this year, a three-judge panel of the Eighth Circuit reversed EPA’s decision, thereby neutralizing the Ninth Circuit’s opinion. Chlorpyrifos, […]

(Beyond Pesticides, November 3, 2023) California joined 10 other states that have laws partially restricting use of bee-toxic neonicotinoid (neonic) insecticides with the enactment of CA AB 363 into law in October, 2023.  California’s new law will ban over-the-counter sales of lawn and garden neonics by 2025, limiting their use to licensed pesticide applicators. The legislation gives the state’s Department of Pesticide Regulation (CA EPA) until June 30, 2029 to take broader action on neonics, if it determines restrictions are necessary. CA 363 will take neonics out of the hands of homeowners, while allowing lawn care companies to continue use. The California law falls short of the strongest state laws in Nevada, New Jersey, and Maine that eliminate all outdoor (nonagricultural) uses of these chemicals, even by lawn care companies. In June, 2023 Nevada became the third state to ban lawn and garden uses of neonics, while Colorado prohibited homeowner use of land and garden neonic products, similar to laws in Maryland, New York, Massachusetts, Rhode Island, and Vermont.  Minnesota recently banned neonic use on state lands and granted its home-rule subdivisions the authority to ban “pollinator-lethal pesticides” (those with bee warning labels) under its state law preempting local authority […]

(Beyond Pesticides, October 23, 2023) As the immediate threat of a government shutdown has temporarily subsided, concerns are mounting over the potential threats to food safety in the United States if the government shuts down in mid-November. Experts are warning that a shutdown could jeopardize critical food safety inspections and oversight. A partial government shutdown in 2019 disrupted federal oversight of food monitoring for various pathogens and pesticides, as labs were shuttered, with agency employees furloughed. See Beyond Pesticide’s reporting about food safety risks during the last government shutdown. However, it should be noted that residues of pesticides in food continue to raise concerns about safety of food grown in chemical-intensive (conventional) farming operations. The U.S. Department of Agriculture’s (USDA) contingency plans dictate that the Food Safety and Inspection Service (FSIS) continue its regulatory inspection of meat, poultry, and egg products, as mandated by law. However, it is important to note that the FSIS will operate with a reduced workforce, with a portion of employees deemed “essential personnel” for food safety operations. Meanwhile, the Department of Health and Human Services (HHS), which includes the Food and Drug Administration (FDA), is also preparing for a potential shutdown. According to HHS’s contingency […]

(Beyond Pesticides, October 19, 2023) The second session of the 40th National Forum, Forging a Future with Nature, will focus on environmental justice and offer a unique conversation with the United Nations Rapporteur on Toxics and Human Rights and an environmental justice history professional. Both celebrated speakers have studied and written about the long-standing social, economic, and health problems related to pesticides and disproportionate harm to people of color. The Forum will take place at 2:00 pm EDT on Tuesday, October 24, 2023. (See free registration information HERE.)   Beyond Pesticides brings together this Forum session with the inspiration of the words of Dr. Martin Luther King, Jr., who wrote in Letter from a Birmingham Jail (1963), “Injustice anywhere is a threat to justice everywhere. We are caught in an inescapable network of mutuality, tied in a single garment of destiny. Whatever affects one directly, affects all indirectly.” Sixty years later, people of color—in the U.S. and around the world—still struggle with those same inequities that impose disproportionate risks interwoven in the fabric of economic and social systems in the United States and worldwide. The Forum takes place in the context of widespread toxic chemical exposure throughout communities and all strata […]

(Beyond Pesticides, October 17, 2023) In the past month, Paris, France has witnessed a surge in bed bug populations. From public transportation to hotels, hostels, and movie theatres, bed bugs are posing a threat to the city’s two million residents and potentially a broader global population as the infestation spreads.   This resurgence of bed bugs in Paris is not unique. For centuries, these pests have been both adaptable and persistent, presenting an enduring challenge to pest control. However, the current surge in bed bug infestations is not merely a revival of a longstanding problem; it is a complex issue intertwined with the development of resistance to insecticides, mainly through a mechanism known as knockdown resistance. This mechanism, along with three other main resistance mechanisms, has enabled these insects to defy chemical-intensive control methods  Knockdown resistance is a significant factor contributing to the resistance exhibited by bed bugs to insecticides, especially pyrethroids. The mechanism plays a central role in countering the action of these insecticides, which target the nervous system of bed bugs, causing paralysis and eventual death. Knockdown resistance provides the genetic adaptation that provides bed bug populations with resistance to insecticides. It inhibits the effectiveness of certain insecticides. Bed […]

(Beyond Pesticides, October 16, 2023) After six years, the Environmental Protection Agency (EPA) finally responded to a citizen petition requesting that the agency evaluate complete formulations of pesticide products, not just the ingredients the manufacturer claims attack the target pest (so-called “active” ingredients). EPA’s response: No. Nowhere in EPA’s denial of the need for a more robust toxicological analysis is the problem more evident than in its refusal to require analyses of the so-called “inert ingredients” or “adjuvants” included in various formulations of pesticide products. The citizen petition [see more background] was followed by a lawsuit for the same purpose in 2022. Inerts and formulants are substances that enhance the distribution or adhesion of the active ingredient; adjuvants enhance the effectiveness of the active ingredient. These terms suggest that those chemicals have no effect on anything in the area where the pesticide is applied—a wildly inaccurate implication. At least as early as 1987, EPA had recognized that some inerts and adjuvants were “of toxicological concern,” yet it still requires very few toxicological tests of whole-formula pesticides or their purportedly inactive components. EPA responded to the petition as follows: “[T]he Agency appropriately assesses, as part of its review, the impacts to […]

(Beyond Pesticides, October 13, 2023) Will the chemical industry and pesticide-dependent service industry (e.g., conventional landscaping industry) trample democratic rights and force the allowance of pesticide use against the will of communities across the U.S.? The answer is unequivocally yes, they are trying. In fact, the industries’ campaign is now playing out in the U.S. Congress, as members deliberate on the next Farm Bill. Members of Congress who advocate the pesticide lobby’s anti-democratic position are telling constituents that they do not support their right to restrict pesticides more stringently than the federal government. Please urge your U.S. Representative to sign the Congressional “Dear Colleague” Letter and uphold the right of local governments and states to restrict pesticides. Time sensitive: Please take action today (Friday, October 13, 2023) or as soon as possible. Thank you! Advocates are clearly telling members of Congress that the long-held federal-state balance of local, state, and federal authority will be broken if the federal government steps in to deny localities the authority to control pesticide use more stringently than federal law. The history is clear. The U.S. Supreme Court in Wisconsin Public Intervenor v. Mortier (1991) found, “[The Federal Insecticide, Fungicide and Rodenticide Act] FIFRA nowhere […]

(Beyond Pesticides, September 29, 2023) In unsurprising news, the Environmental Protection Agency (EPA) has reversed itself and decided not to ban a dangerous pesticide: tetrachlorovenphos (TCVP) used in pet flea collars and other flea products. This is despite its own earlier decision to ban TCVP in pet collars and scathing criticism of its methods and conclusions by the courts. First registered in 1966, TCVP belongs to the notoriously toxic organophosphate chemical family and is classified by the World Health Organization as “possibly carcinogenic to humans.” It was originally registered to Shell Chemical, then to E.I. duPont de Nemours, then to Hartz Mountain Corporation and Fermenta Animal Health Company.  Early on, it was registered for use on food crops and livestock, but the crop uses were voluntarily de-registered in 1987. It is still widely used on pets and farm animals. In 1995, EPA issued the opinion that “all uses of tetrachlorvinphos, with the exception of oral feed-through larvicide treatment to livestock intended for food use, will not cause unreasonable risk to humans or the environment.” Since then, the agency has contorted itself repeatedly to allow TCVP to remain on the market. There is little research available on TCVP’s human health effects; the […]

(Beyond Pesticides, September 11, 2023) A future supported by the natural environment depends on our effective involvement in decisions in our homes, communities, states, and at the federal level to ensure that we are taking the steps necessary to protect against existential threats to health, biodiversity, and climate. The 40th National Forum Series is an important opportunity to hear from those working as scientists, advocates, land managers (from gardens, parks, and play fields to farms), and public decision makers about steps being taken and action needed to prevent catastrophic collapse of the natural systems that sustain life. The goal of the Forum—to enable a collective strategy to address the existential health, biodiversity, and climate threats and chart a path for a livable and sustainable future. We come together to empower effective action.   We are honored to begin this year with two international experts in their fields as they discuss steps that can and must be taken in our communities around the globe: Internationally renowned researcher and author David Goulson, PhD, is able to draw together essential scientific research on the elements of nature that we must cherish, support, and enhance if we are to have a future. The data, […]

(Beyond Pesticides, September 8, 2023) In a united effort, climate and environmental justice movements from around the world have come together to announce a global “end to fossil fuels,” including the end of pesticides. The “March to End Fossil Fuels” is scheduled for September 17 and the Secretary General’s Summit in New York City on September 20. See the full map for other marches around the world. At the Beyond Pesticides, 2022 National Forum session on climate (November, 2022), we discussed the science and the urgent need for a strategic response to the climate crisis as part of a constellation of crises that intersect. Whether we are talking about a health crisis borne out of chemical-induced diseases, the collapse of life-sustaining biodiversity, or the dramatic catastrophes caused by greenhouse gases and rising temperatures—the interconnectedness of the crises requires strategic solutions that are holistic and nurturing of our relationship with nature —a relationship we have minimized as a matter of policy and practice. The data on climate calls on us to be audacious in our demand for urgent change in our households and communities, and from decision makers at all levels of government. At Beyond Pesticides, our audacious goal is to […]

(Beyond Pesticides, September 6, 2023) In late August, the Office of the Inspector General (OIG) at the U.S. Environmental Protection Agency (EPA) released a report concluding that EPA “took a siloed approach” to the cumulative impacts of chemical exposures and the disproportionate nature of those exposures. This approach keeps different parts of the EPA from coordinating their efforts and hinders understanding of the breadth and depth of chemical exposures. OIG reached this disturbing finding despite the issuance of several executive orders by President Biden requiring EPA to develop policies and actions to assess cumulative impacts of chemical exposures across departments, laws, and environmental media (air, water, bodies, food etc.) and to pay more attention to environmental justice. Beyond Pesticides has stressed that the whole constellation of chemical exposures and effects should be considered when governments set public policies and regulations. Just last March, Daily News covered another OIG report castigating EPA for betraying its mission by failing to address the fact that very high levels of per- and polyfluoroalkyl compounds known as “forever chemicals” have been found in some common pesticides. OIG also berated EPA for succumbing to Donald Trump’s interference with setting toxicity values for the “forever chemical” perfluorobutane […]

(Beyond Pesticides, September 5, 2023) Lincoln County, Oregon  community members are fighting a plan announced by a private landowner to aerially spray 473 acres of clear-cut forest over the Beaver Creek watershed with a pesticide mixture containing carcinogenic glyphosate (commonly found in Roundup).  The aerial spraying is slated to take place approximately one mile from a water intake at Seal Rock Water District, which supplies water to 5,500 residents. Beyond the risks to human health, residents are concerned about the impacts on wildlife in the creek valley. Local advocates describe the area to include native wetland plants, birds, and fish, including the federally protected Coho Salmon and Marbled Murrelet, beaver, river otter, and roaming elk herds. Beavercreek is also a protected state natural area, where families paddle and walk along the state park marshlands.  Neighbors of Beaver Creek and the surrounding community are organizing phone banking, public art displays, and a petition urging Governor Tina Kotek to put a moratorium on the spray operation. One of the efforts displays the message “legalized poisoning of 5,500 people” through lights projected onto a basalt rock formation at Seal Rock State Park. The community has gathered over 2,000 petition signatures and over 100 […]

(Beyond Pesticides, August 29, 2023) A study published in Insect Biochemistry and Molecular Biology finds the widely used azole fungicide, tebuconazole, has damaging impacts on the redox homeostasis (the process of maintaining balance between oxidizing and reducing reactions) and fatty acid composition in honey bees’ brain via oxidative stress. Acute, field-realistic sublethal exposure to tebuconazole decreased the brain’s antioxidant capacity, key antioxidant defense systems, and oxidative degradation and alteration of lipids (fats) in the brain. Thus, this study adds to the scientific literature on the adverse effects of chemical exposure on pollinator health, especially in sublethal concentrations. Degenerating cognitive skills can threaten honey bee survivability, decreasing colony fitness and individual foraging success. Much research attributes the decline of insect pollinators (e.g., commercial and wild bees and monarch butterflies) over the last several decades to the interaction of multiple environmental stressors, from climate change to pesticide use, disease, habitat destruction, and other factors. Pollinator declines directly affect the environment, society, and the economy. Without pollinators, many plant species, both agricultural and nonagricultural, will decline or cease to exist, as U.S. pollinator declines, particularly among native wild bees, depress crop yields. In turn, the economy will take a hit, since much of the economy (65%) depends upon the […]

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

(Beyond Pesticides, August 23, 2023) Researchers are investigating a cutting-edge method to identify the impact of pesticides on reproductive health—shrinking the wait time from months to weeks. Scientists at the University of California, Davis, are developing a method for identifying harmful chemicals in pesticides with the help of glowing fish. This scientific breakthrough could revolutionize pesticide research and help prevent long-term health problems caused by exposure to these chemicals.  Pesticide exposure can cause acute and long-term health problems for the human endocrine system, the hormone system that regulates many biological processes from reproduction to blood sugar, growth, and more. Beyond Pesticides has written about the connections between EPA-registered pesticides and involuntary abortions, reproductive cancers, pregnancy loss, early-onset puberty, and more.   The American Academy of Pediatrics (AAP) has expressed concern over the limited or missing data regarding the health effects of pesticides and food additives on infants and children, who are more vulnerable to chemical exposures. AAP has identified several compounds as being of particular concern, including bisphenols, which are commonly used in the lining of metal cans; phthalates, which are used in adhesives and plasticizers; nonpersistent pesticides, which have been addressed in a previous AAP policy statement; perfluoroalkyl chemicals (PFCs), […]

(Beyond Pesticides, August 14, 2023) Marijuana regulators in the state of Washington issued administrative holds on 18 licenses due to pesticide-contaminated marijuana, forcing producers and processors to cease operations until now. This shutdown of legal marijuana businesses serves as a window into a broader historical backdrop of pesticide issues within the marijuana industry. Within Washington, pesticide concerns have been growing since a study in 2018 of legal marijuana farms in the state had 84.6% (of 26 samples) with significant quantities of pesticides including insecticides, fungicides, miticides, and herbicides. Last year, a national study identified a list of contaminants in 36 states and the District of Columbia and found 551 pesticides within cannabis products. For over a decade, Beyond Pesticides has sounded the alarm about the highly-concentrated levels of pesticides in marijuana products, calling on state officials to require organic marijuana, especially in the context of medical marijuana. The absence of federal regulations for pesticides in cannabis production has raised significant concerns about exposure risks for recreational and medicinal use, exposure risks to workers, and potential environmental contamination impacting wildlife. Since marijuana is classified as a Schedule 1 narcotic under the Controlled Substances Act, the EPA does not regulate pesticides in […]