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Action of the Week

Action of the week is intended to provide you, our supporters and network, with one concrete action that you can take each week to have your voice heard on governmental actions that are harmful to the environment and public and worker health, increase overall pesticide use, or undermine the advancement of organic, sustainable, and regenerative practices and policies. As an example, topics may include toxic chemical use, pollinator protection, organic agriculture and land use, global climate change, and regulatory or enforcement violations.

06/01/2020 — Tell the National Organic Program that Inaction on “Inert” Ingredients Is Unacceptable

During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of the National Organic Program at USDA to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. The NOSB has only one alternative left to force USDA action—denying relisting at the Fall meeting.

>>Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now.

Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.”

In fact, the ingredients not listed on a label of a pesticide product—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to disclose and test all ingredients in pesticide products, as well as the full formulation. The research tested the toxicity of the herbicide glyphosate, so-called “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, they studied a number of other pesticides.

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

The researchers also identified a number of other toxic substances in the products, including arsenic, chromium, cobalt, nickel, and lead. Arsenic was present in almost all samples. This research challenges the apparent assumption by NOP that “inert” ingredients are less important to review than “active” ingredients. The “active” ingredients in pesticide products used in organic production receive intense scrutiny before the NOSB allows their use. However, “inert” ingredients –which, as the Defarge et al study demonstrates, may actually be the active ingredients— have not received any scrutiny by the NOSB for compliance with OFPA criteria.

In the Beyond Pesticides report “Inert” Ingredients Used in Organic Production, we summarize what is known about the toxicity of the 127 “inerts” then known to be used in organic production, compared to the 39 synthetic active ingredients on the National List. More “inerts” than active ingredients used in organic production have been shown to be acutely toxic, neurotoxic, carcinogenic, nephrotoxic or hepatotoxic, sensitizers, endocrine disruptors, and toxic to aquatic organisms.

NOP must respond to the NOSB recommendations that “inert” ingredients used in organic production be reviewed by the NOSB according to OFPA criteria by initiating actions to carry out NOSB recommendations.

>>Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now.

Letter to Secretary Perdue, Administrator Tucker, NOP Deputy Administrator Tucker:

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

During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of NOP to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. NOP inaction leaves NOSB with only one alternative—denying relisting at the Fall meeting.

Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.”

In fact, ingredients not listed on a pesticide product label—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, reported in “Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides” (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini, tested the toxicity of the herbicide glyphosate, so-called “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, they studied a number of other pesticides.

Although GBH products are not permitted in organic production, the results of the Defarge et al study are relevant to decisions concerning materials used in organic crops and livestock. The scientists found that for GBH products, glyphosate was not the major toxic component–to either plants or human cells–and that formulations, as well as glyphosate alone, are endocrine disruptors at low concentrations. The researchers concluded, “Hence G [glyphosate] did not appear to be the main active substance of the herbicide, but rather the formulants.”

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

In the report “Inert” Ingredients Used in Organic Production, Beyond Pesticides summarizes what is known about the toxicity of the 127 “inerts” then known to be used in organic production, compared to the 39 synthetic active ingredients on the National List. More “inerts” than active ingredients used in organic production have been shown to be acutely toxic, neurotoxic, carcinogenic, nephrotoxic or hepatotoxic, sensitizers, endocrine disruptors, and toxic to aquatic organisms.

NOP must respond to the NOSB recommendations that “inert” ingredients used in organic production be reviewed by the NOSB according to OFPA criteria by initiating actions to carry out NOSB recommendations.

Thank you.

05/22/2020 — Take Action: Tell USDA to Crack Down on “Organic” Livestock Factories

For years, USDA has been looking the other way as giant corporate agribusinesses, primarily producing conventional eggs and poultry, have squeezed family-scale farmers out of the market and misled and defrauded consumers.

Due to a lawsuit challenging the Trump administration on the scuttling of new rules that would make it harder for factory farms to qualify for organic status, USDA is seeking input on what was previously an error-filled and biased economic assessment of the rulemaking.

Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings.

If you would prefer to write your own custom comment you can submit it on Regulations.gov.

Letter to National Organic Program (Jenny Tucker, Ph.D.

To the National Organic Program:

Please include my comment below in evaluating the economic analysis report pursuant to the Organic Livestock and Poultry Practices rulemaking.

Docket number: AMS-NOP-20-0037

Both the current and previous OLPP analyses include the following misstatements and omissions:

  1. It is a misconception to refer to, and judge, the economic impacts of the OLPP as if the requirement for outdoor access was a new and onerous regulation. In fact, from the beginning of the USDA organic program, “all” organic livestock have been required to have access to the outdoors. The new proposed rule does nothing more than create some enforceable benchmarks to facilitate oversight by USDA and its accredited third-party certifiers. 

  2. Analyzing the economic impact, as if this were a new regulatory obligation, is misdirected. All organic livestock producers should have been providing meaningful outdoor access from day one. 

  3. Factoring in impacts on retail pricing is not germane to this decision-making. The size of the market is irrelevant. When consumers pay a premium for organic eggs and poultry, they expect that the birds are being managed in accordance with the law, which requires outdoor access and promotion of the natural instinctive behaviors of the animals. 

  4. True organic management of meat birds and laying hens is not currently possible in the massive industrial-sized buildings that USDA has allowed to be certified. Investments were made in these structures while it was known that elements in the organic industry were challenging the legality of the operations and, thus, their investments have always been at risk. 

  5. In England and the European Union, organic birds have always had access to the outdoors in smaller flocks. Subsequently, the price differential between conventional and organic eggs has been greater. However, the market share for organic in many of those countries surpasses that of the United States. Organic consumers already assume that they are buying eggs and poultry produced with a higher level of animal welfare. They are currently being defrauded. The question of their willingness to pay a premium is irrelevant. 

  6. If some of the larger operators are forced to exit, entrepreneurs will quickly scale-up to meet new market demand. The shift to producers who comply with both the spirit and letter of the law should not be a factor in implementing the new rulemaking. 

  7. Regardless of how much outdoor space is provided, it is not possible to offer legitimate access when birds are housed in giant, multitiered aviary systems.  Buildings housing as many as 100,000-200,000 birds prevent the expression of instinctual behavior, a regulatory requirement, as it would be necessary to walk over thousands of other birds in order to access a door. Believing otherwise is a myth perpetuated by corporate interests in egg production. 

  8. Because USDA’s analysis starts from the wrong baseline—one that is not consistent with the law–the analysis omits the economic injury to family-scale farmers who are currently complying with the regulations by allowing birds meaningful access to the outdoors that continues when the OLPP is not implemented. Furthermore, there are many family farmers who have been prevented from entering the organic market for poultry meat and eggs because, as it has grown, market share has been dominated by giant conventional ag companies that have gamed the system to achieve lower operating costs and higher profitability.

 

In conclusion, any economic analysis of the impact of new rulemaking should be viewed through the prism of the Organic Foods Production Act and its current regulations. To do otherwise places family farmers at a competitive disadvantage and perpetuates a fraudulent myth that the majority of organic poultry, managed by corporate agribusiness, is truly “organic.”

Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings.

05/18/2020 — Tell USDA and Congress: #DoBetterUSDA and Support Small Organic Farmers

In response to the coronavirus pandemic, the United States Department of Agriculture (USDA) is putting forth a Coronavirus Food Assistance Program (CFAP) that funnels money from the Coronavirus Aid, Relief, and Economic Security (CARES) Act and other sources directly to farmers. However, agricultural justice advocates are questioning just who is going to benefit from the aid packages. Due to corporate and governmental interplay, we know that the agrichemical industry and big commodity crop farmers are at the top of the list. It remains unclear how small, diversified farms can apply for financial assistance. There is little to no mention of equity in USDA aid distribution that considers farmers of color, farmworkers, or assistance for organic farms. As it stands, large, chemical-intensive commodity farmers may benefit while many of our neighbors get left behind

>> Turn up public pressure to help small, organic farmers: Tell USDA to #DoBetterUSDA

CARES specifies that USDA must support “producers of specialty crops, producers that supply local food systems, including farmers markets, restaurants, and schools, and livestock producers, including dairy producers.” Despite this, USDA's action plan to implement the CARES Act does very little to address the needs of local, diversified, and organic agriculture.

There are two parts to the CFAP funding:

  1. $16 billion in direct payments to commodity growers, specialty crop farmers, and livestock and dairy producers. Payments will be based on actual losses. Farmers can collect no more than $125,000 per commodity, and there is an overall limit of $250,000. The commodity must have experienced at least a 5% decline in price since January.
  2. $3 billion in direct purchases of meat, dairy, and specialty crops. USDA is paying for food from farmers to fill food boxes for families in need. Fresh food is being prioritized, but there is no mention of organic agriculture.

The further distribution of funds and coordination for this program is unclear, as the rule is still pending approval by the White House Office of Management and Budget (OMB). However, the following preliminary breakdown of direct payments has been reported:

  • $9.6 billion – livestock and dairy producers
  • $3.9 billion – row crop producers (i.e. corn, soybeans, cotton)
  • $2.1 billion – specialty crops (i.e. fruits, vegetables, nuts)
  • $500 million – other crops (i.e. hemp, horticulture, goats, sheep)

USDA offered a short webinar on May 14th, mainly describing paperwork requirements for farmers to document their income and recent, pandemic-induced losses. Farmers are to contact their local Farm Service Agency (FSA) to apply for funding.

Proving loss is much more difficult for diversified, small, and organic farmers than commodity crops. Additionally, some small farms are actually seeing an increase in revenue, and therefore will not qualify for funding, though they may need help scaling up to meet new demand.

Bobby Pahia, a Maui farmer (Hoaloha Farms) says, “I'd appreciate an aid package that helps small farms grow through this crisis, instead of just calculating loss—aid  that funds solutions instead of paying for failures. We could improve distribution streams during this crisis, and beyond. Let's put systems in place that better connect farms to schools and communities. Let's find the failures in the current system, and then use aid packages to fund solutions. If we use these historic aid packages to build a strong foundation of support for small farmers, we can improve the long term health of communities and our environment, all while responding to Covid-19 shutdowns.”

According to the National Sustainable Agriculture Coalition, “Right now, the program [CFAP] isn't set up to account for farmers who sell into local/regional markets, diversified farmers, or organic farmers. It doesn't have a thorough outreach plan or reserved funding for underserved producers (including farmers of color). It doesn't reflect realistic timelines for farmers' losses or their increased expenses in addition to their losses. And it does not focus aid on independent, family-scale livestock producers who need help (instead of large corporate operations). In short, we have many questions, and we need answers to ensure this program reaches all farmers impacted by the current crisis.”

John Dobovan, a Maui farmer (Kulahaven Farms), says, “If we are going to have a truly sustainable agricultural economy, we have to make it a priority to take care of small family farms. They are more resilient and adaptable, keep more money circulating in our local economies, produce more nutrient dense food with fewer environmental problems, house and employ more people than big ag, and get the least amount of federal support. As a small island farmer who directly supplies our local food chain, I'm really counting on funding packages that favor small family farms to keep us afloat.”

As Congress begins work on its newest coronavirus aid package, it is more important than ever to remind USDA that it cannot ignore mandates from Congress to support local food systems. In this distribution effort and in the future, the agency must:

  • Immediately offer farmers clarity on distributions of funds.
  • Provide alternative ways of showing loss that makes sense for small, diversified, and organic farmers.
  • Support growth of local, diversified, organic farms; don't just subsidize loss.
  • Increase aid and outreach that addresses systemic inequities; prioritize underserved, local, and organic producers, not large commodity agriculture. This means helping make connections with local farms when addressing food programs.
  • Complete rulemaking that ensures the integrity of organic products on organic enforcement, origin of livestock, and organic livestock and poultry practices.
  • Allow SNAP and WIC payments to be made online, directly to farms.
  • Make organic foods, which are more nutritious and not grown with toxic pesticides, available to at-risk communities that stand to benefit most.
  • Provide funds for farms that are quickly moving to set up “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction as farmers markets may be limited, or even farmers feel unsafe selling at farmers markets.

>> Turn up public pressure to help small, organic farmers: Tell USDA to #DoBetterUSDA

If you are a farmer, you can use the National Sustainable Agriculture Coalition's guide for calling decision makers, tweeting, and posting on Facebook. Also, please see our list of pandemic resources for farmers.

Letter to USDA:

The CARES Act specifically prioritized direct payment assistance for “producers that supply local food systems, including farmers markets, restaurants, and schools.” Despite this, USDA’s action plan to implement the CARES Act does very little to address the needs of that sector of agriculture. The distribution of funds and coordination of the Coronavirus Food Assistance Program is, as of yet, still unclear.

Because proving loss is more difficult for diversified, small, and organic farmers than commodity crops, it remains difficult for small, diversified farms to apply for financial assistance. Additionally, some small farms are actually seeing an increase in revenue as demand for farm to door community supported agriculture. These farmers will not qualify for funding, though they may need help scaling up to meet the new demand.

There is little to no mention of equity in USDA aid distribution that considers farmers of color, farmworkers, or assistance for organic farms. As it stands, large, chemical-intensive commodity farmers may benefit while many of our neighbors get left behind.

Bobby Pahia, a Maui farmer (Hoaloha Farms) says, “I’d appreciate an aid package that helps small farms grow through this crisis, instead of just calculating loss. Aid that funds solutions instead of paying for failures. We could improve distribution streams during this crisis, and beyond. Let’s put systems in place that better connect farms to schools and communities. Let’s find the failures in the current system, and then use aid packages to fund solutions. If we use these historic aid packages to build a strong foundation of support for small farmers, we can improve the long term health of communities and our environment, all while responding to COVID19 shutdowns.”

USDA needs to do better for American farmers. Please:

● Immediately offer farmers clarity on distributions of funds.
● Provide alternative ways of showing loss that makes sense for small, diversified, and organic farmers.
● Support growth of local, diversified, organic farms; don’t just subsidize loss.
● Increase aid and outreach that addresses systemic inequities; prioritize underserved, local, and organic producers, not large commodity agriculture. This means helping make connections with local farms when addressing food programs.
● Complete rulemaking that ensures the integrity of organic products on organic enforcement, origin of livestock, and organic livestock and poultry practices.
● Allow SNAP and WIC payments to be made online, directly to farms.
● Make organic foods, which are more nutritious and not grown with toxic pesticides, available to at-risk communities that stand to benefit most.
● Provide funds for farms that are quickly moving to set up “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction as farmers markets may be limited, or even farmers feel unsafe selling at farmers markets.

A silver lining of the coronavirus pandemic wreaking havoc on our food system is that we have a novel opportunity to improve local agriculture and promote adaptive, healthy, and diverse communities. Please #dobetterUSDA, and help local farmers who in turn can support our health.

Thank you.

Letter to Congress:

The CARES Act specifically prioritized direct payment assistance for “producers that supply local food systems, including farmers markets, restaurants, and schools.” Despite this, USDA’s action plan to implement the CARES Act does very little to address the needs of that sector of agriculture. The distribution of funds and coordination of the Coronavirus Food Assistance Program is, as of yet, still unclear.

Because proving loss is more difficult for diversified, small, and organic farmers than commodity crops, it remains difficult for small, diversified farms to apply for financial assistance. Additionally, some small farms are actually seeing an increase in revenue as demand for farm to door community supported agriculture. These farmers will not qualify for funding, though they may need help scaling up to meet the new demand.

There is little to no mention of equity in USDA aid distribution that considers farmers of color, farmworkers, or assistance for organic farms. As it stands, large, chemical-intensive commodity farmers may benefit while many of our neighbors get left behind.

Bobby Pahia, a Maui farmer (Hoaloha Farms) says, “I’d appreciate an aid package that helps small farms grow through this crisis, instead of just calculating loss. Aid that funds solutions instead of paying for failures. We could improve distribution streams during this crisis, and beyond. Let’s put systems in place that better connect farms to schools and communities. Let’s find the failures in the current system, and then use aid packages to fund solutions. If we use these historic aid packages to build a strong foundation of support for small farmers, we can improve the long term health of communities and our environment, all while responding to COVID19 shutdowns.”

USDA needs to do better for American farmers. Please hold USDA accountable and include future legislation that they must:

● Immediately offer farmers clarity on distributions of funds.
● Provide alternative ways of showing loss that makes sense for small, diversified, and organic farmers.
● Support growth of local, diversified, organic farms; don’t just subsidize loss.
● Increase aid and outreach that addresses systemic inequities; prioritize underserved, local, and organic producers, not large commodity agriculture. This means helping make connections with local farms when addressing food programs.
● Complete rulemaking that ensures the integrity of organic products on organic enforcement, origin of livestock, and organic livestock and poultry practices.
● Allow SNAP and WIC payments to be made online, directly to farms
● Make organic foods, which are more nutritious and not grown with toxic pesticides, available to at-risk communities that stand to benefit most.
● Provide funds for farms quickly moving to set up “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction as farmers markets may be limited, or even farmers feel unsafe selling at farmers markets.

A silver lining of the coronavirus pandemic wreaking havoc on our food system is that we have a novel opportunity to improve local agriculture and promote adaptive, healthy, and diverse communities. Please make sure that USDA does better and helps local farmers, who in turn can support our health.

Thank you.

05/11/2020 — Tell EPA and Congress that ALL Ingredients in Pesticides Must Be Disclosed

Protecting ourselves from Covid-19 requires not only that we avoid contact with the virus, but also that we avoid exposing ourselves to chemicals that may disrupt our immune or respiratory systems. But when it comes to pesticide products—and disinfectants are pesticides—we encounter once again the problem of so-called “inert,” or nondisclosed, ingredients.

Tell EPA and Congress that ALL Ingredients in Pesticides Must Be Disclosed.

“Inert” ingredients are not necessarily chemically or biologically harmless. “Inert” or “other” ingredients—as distinguished from “active” ingredients—are generally the majority of the product formulation that makes up the liquid, spray, dust, or granule, but does not specifically attack the pest, according to the manufacturer. They include emulsifiers, solvents, carriers, aerosol propellants, fragrances, and dyes. Many “inerts” are quite toxic, and may be “active” ingredients in other products. “Inert” ingredients may also be described as “adjuvants” or “formulants.” “Inerts” are typically not listed on the label, and hence are often called “secret ingredients.”

Beyond Pesticides reviews the disinfectants on EPA’s List N, which are approved for use against the novel coronavirus, but it is only possible to review the active ingredients. One product on the list, for example, contains 99.7784% “other ingredients.” Unfortunately, although this product may contain mostly water, it also may be composed mostly of such “inert” ingredients as 4-chlorotoluene, ethylbenzene, or petroleum distillates, all of which (among others) can weaken the respiratory and/or immune systems, making an exposed person more susceptible to Covid-19. We don’t know.

While it has never been acceptable to hide product ingredients on pesticide products, the current pandemic makes this information crucial for consumers who want to protect themselves and their families. Whether it is disinfectants or pesticide products in use in the home, yard, and community the secrecy on this public health issue must end, and EPA has the authority to require labeling . Please urge EPA use its legal authority to require disclosure of all ingredients on pesticide labels to protect public health.

Tell EPA and Congress that ALL Ingredients in Pesticides Must Be Disclosed.

Letter to EPA Administrator and Office of Pesticide Program Director

I am writing you because the current pandemic has brought home to me the importance of disclosure of all ingredients in pesticide products that can exacerbate the public’s vulnerability to Covid-19. Protecting ourselves from Covid-19 requires not only that we avoid contact with the virus, but also that we avoid exposing ourselves to chemicals that may disrupt our immune and respiratory systems. But when it comes to pesticides—and disinfectants are pesticides—I encounter the problem of so-called “inert” ingredients.

“Inert” ingredients are not necessarily chemically or biologically inert. Many are quite toxic, and may be “active” ingredients in other products. “Inert” or “other” ingredients—as distinguished from “active” ingredients—are simply those for which the pesticide manufacturer does not make a pesticidal claim. “Inerts” are typically not listed on the label, and hence they are “secret ingredients.” They include emulsifiers, solvents, carriers, aerosol propellants, fragrances, and dyes.

In deciding on a disinfectant to use in my home, I review products on EPA’s List N, which are approved for use against the novel coronavirus, but it is only possible to review the active ingredients. One product on the list, for example, contains 99.7784% “other ingredients.” Unfortunately, although this product may contain mostly water, it also may be composed mostly of such “inert” ingredients as 4-chlorotoluene, ethylbenzene, or petroleum distillates, all of which (among others) can weaken my respiratory and/or immune systems, making me more susceptible to Covid-19. I don’t know because “inert” ingredients are not disclosed.

While it has never been acceptable to hide product ingredients on pesticide products, the current pandemic makes this information crucial for consumers who want to protect themselves and their families. Whether it is disinfectants or pesticide products in use in the home, yard, and community the secrecy on this public health issue must end, and EPA has the authority to require labeling. Please require disclosure of all ingredients on pesticide labels as a matter of public health protection.

Thank you.

Letter to U.S. Senators and Representative

I am writing you because the current pandemic has brought home to me the importance of disclosure of all ingredients in pesticide products that can exacerbate the public’s vulnerability to Covid-19. Protecting ourselves from Covid-19 requires not only that we avoid contact with the virus, but also that we avoid exposing ourselves to chemicals that may disrupt our immune and respiratory systems. But when it comes to pesticides—and disinfectants are pesticides—I encounter the problem of so-called “inert” ingredients.

“Inert” ingredients are not necessarily chemically or biologically inert. Many are quite toxic, and may be “active” ingredients in other products. “Inert” or “other” ingredients—as distinguished from “active” ingredients— are simply those for which the pesticide manufacturer does not make a pesticidal claim. “Inerts” are typically not listed on the label, and hence they are “secret ingredients.” They include emulsifiers, solvents, carriers, aerosol propellants, fragrances, and dyes.

In deciding on a disinfectant to use in my home, I review products on EPA’s List N, which are approved for use against the novel coronavirus, but it is only possible to review the active ingredients. One product on the list, for example, contains 99.7784% “other ingredients.” Unfortunately, although this product may contain mostly water, it also may be composed mostly of such “inert” ingredients as 4-chlorotoluene, ethylbenzene, or petroleum distillates, all of which (among others) can weaken my respiratory and/or immune systems, making me more susceptible to Covid-19. I don’t know because “inert” ingredients are not disclosed.

While it has never been acceptable to hide product ingredients on pesticide products, the current pandemic makes this information crucial for consumers who want to protect themselves and their families. Whether it is disinfectants or pesticide products in use in the home, yard, and community the secrecy on this public health issue must end, and EPA has the authority to require labeling.  Please urge EPA to require disclosure of all ingredients on pesticide labels, as a matter of public health protection.

Thank you.

05/04/2020 — Protect Farmworker Children

Exemptions to the Fair Labor Standards Act allow children to work unlimited hours in agriculture at the age of 12 and allow child farmworkers to perform hazardous work at the age of 16. These exemptions apply only to farm labor and are significantly less stringent than law applying to other sectors. U.S. Representative Lucille Roybal-Allard of California has reintroduced H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety (CARE) to correct these inconsistencies, which harm farmworker children.

Tell your Congressional Representative to co-sponsor H.R. 3394. Thank those who are co-sponsors of the bill.

Currently, children ages 12-13 may not be employed outside the home in non-agriculture labor, but may work in agriculture outside of school hours. Children ages 14-15 may work in non-agriculture only with strict limitations on time of day and hours per week, but may work in agriculture outside of school hours without any restrictions. The minimum age for hazardous work in agriculture, such as pesticide handling, is 16, but is 18 for non-farm labor. H.R. will make the restrictions for agriculture child labor consistent with non-agriculture labor. The bill does not apply to the sons and daughters of farmers working on their family farm.

The worker protection standard (WPS) is an EPA regulation that includes restrictions to protect farmworkers applying pesticides. In 2015, the WPS was revised to set a minimum age of 18 for pesticide application. In 2018, after being sued for not implementing the minimum age requirement, EPA proposed lowering the age to 16EPA dropped its proposal to lower the age for pesticide handlers after negotiating with Congress. Despite EPA’s reversal, a change in the statute such as that proposed in H.R. 3394 would prevent the agency or the courts from allowing 16-year-olds to be hired to apply pesticides in the future.

Children of farmworkers are those most threatened by this discrepancy. The health of children of farmworkers is at risk in other ways from the use of toxic pesticides. Doctors annually diagnose up to 20,000 poisonings among agricultural workers – and that statistic only represents what is publicly reported. Working mothers are exposed to chemicals that can have long-lasting impacts on their unborn children, such as brain function damage. As a result of their working conditions, farmworker life expectancy is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s. We need to correct the injustices suffered by farmworkers and their families.

Tell your Congressional Representative to co-sponsor H.R. 3394. Thank those who are co-sponsors of the bill.

Letter to Congress – Request to Cosponsor

I am writing to ask you to cosponsor H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety, which will make the protection of children on farms consistent with that of children working in non-agricultural work.

Exemptions to the Fair Labor Standards Act allow children to work unlimited hours in agriculture at the age of 12 and allow child farmworkers to perform hazardous work at the age of 16. These exemptions apply only to farm labor and are significantly less stringent than law applying to other sectors. Representative Lucille Roybal-Allard of California has reintroduced H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety (CARE) to correct these inconsistencies, which harm farmworker children.

Currently, children ages 12-13 may not be employed outside the home in non-agriculture labor, but may work in agriculture outside of school hours. Children ages 14-15 may work in non-agriculture only with strict limitations on time of day and hours per week, but may work in agriculture outside of school hours without any restrictions. The minimum age for hazardous work in agriculture, such as pesticide handling, is 16, but is 18 for non-farm labor. H.R. 3394 will make the restrictions for agriculture child labor consistent with non-agriculture labor. The bill does not apply to the sons and daughters of farmers working on their family farm.

Children of farmworkers are those most threatened by this discrepancy. The health of children of farmworkers is at risk in other ways from the use of toxic pesticides. Doctors annually diagnose up to 20,000 poisonings among agricultural workers – and that statistic only represents what is publicly reported. Working mothers are exposed to chemicals that can have long-lasting impacts on their unborn children, such as brain function damage. As a result of their working conditions, farmworker life expectancy is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s. We need to correct the injustices suffered by farmworkers and their families.

Please cosponsor H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety.

Thank you for your attention to this important issue.

Thank You Letter to Current Cosponsors

I am writing to thank you for co-sponsoring H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety, which will make the protection of children on farms consistent with that of children working in non-agricultural work.

Children of farmworkers are those most threatened by the current discrepancy. The health of children of farmworkers is at risk in other ways from the use of toxic pesticides. Doctors annually diagnose up to 20,000 poisonings among agricultural workers – and that statistic only represents what is publicly reported. Working mothers are exposed to chemicals that can have long-lasting impacts on their unborn children, such as brain function damage. As a result of their working conditions, farmworker life expectancy is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s.

We need to correct the injustices suffered by farmworkers and their families.

Thank you for your support.

04/27/2020 — Tell Your Governor that Lawn Care Pesticides Are Not Essential and Increase Risk of COVID-19

Federal guidance and orders by most Governors have identified “landscaping” as an essential activity that is permitted in spite of stay at home or shelter in place requirements.

Tell Your Governor that Lawn Care Pesticides Are Not Essential and Increase Risk of COVID-19.

Most states follow some variation of guidance issued by the Department of Homeland Security, Memorandum on Identification of Essential Critical Infrastructure Workers During COVID-19 Response, in determining which industries are “essential” and can therefore remain in operation. DHS guidance identifies as essential, “Workers such as plumbers, electricians, exterminators, builders, contractors, HVAC Technicians, landscapers, and other service providers who provide services that are necessary to maintaining the safety, sanitation, and essential operation of residences, businesses and buildings such as hospitals, senior living facilities, any temporary construction required to support COVID-19 response.”

While some of the services provided by landscapers and exterminators may be necessary to maintaining safety, sanitation, and essential operations, pesticide application for cosmetic lawn care purposes is not. The hazards of pesticides may be amplified during this pandemic. Threats to the immune and respiratory systems posed by pesticides are likely to make those exposed more susceptible to the coronavirusGovernors should designate as essential outdoor maintenance, including vegetation, only when necessary to prevent spoliation, avoid imminent damage, or address emergency repairs. No pesticide application is essential unless it is necessary to address a public health emergency.

Tell Your Governor that Lawn Care Pesticides Are Not Essential and Increase Risk of COVID-19.

Letter to Governor

As you seek to protect residents of our state from the COVID-19 pandemic, it is important that you allow essential work to continue, but do not allow activities that may make us more susceptible to the disease.

Most states follow some variation of guidance issued by the Department of Homeland Security (DHS), “Memorandum on Identification of Essential Critical Infrastructure Workers During COVID-19 Response,” in determining which industries are “essential” and can therefore remain in operation. DHS guidance identifies as essential, “Workers such as plumbers, electricians, exterminators, builders, contractors, HVAC Technicians, landscapers, and other service providers who provide services that are necessary to maintaining the safety, sanitation, and essential operation of residences, businesses and buildings such as hospitals, senior living facilities, any temporary construction required to support COVID-19 response.”

While some of the services provided by landscapers and exterminators may be necessary to maintaining safety, sanitation, and essential operations, pesticide application for cosmetic lawn care purposes is not [bp-dc.org/landcare]. The hazards of pesticides may be amplified during this pandemic. Threats to the immune and respiratory systems posed by pesticides are likely to make those exposed more susceptible to the coronavirus [bp-dc.org/coronavirus].

Please designate as essential outdoor maintenance, including vegetation, only when necessary to prevent spoliation, avoid imminent damage, or address emergency repairs. No pesticide application is essential unless it is necessary to address a public health emergency.

Thank you.

04/20/2020 — Tell USDA that Organic Production Matters to Nutrition Guidelines

As USDA takes public comments on its updated dietary guidelines, it important that sustainable, regenerative organic food production practices are an integral part. Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations intended to promote public health and prevent chronic diseases. The next review and a draft updated version, the 2020–2025 Dietary Guidelines for Americans, is currently underway.

USDA says that the dietary guidelines provide “information that helps Americans make healthy choices for themselves and their families.” In order to make healthy food choices, the guidelines must go beyond the traditional parameters to include how the food is produced. How food is produced affects the health of Americans not only as a result of the nutritional quality of the food, but also due to environmental contamination.

Sign the petition to USDA and send a letter to Congress. Tell them that organic food must be emphasized in new dietary guidelines.

Although research on the nutritional density of organic produce is equivocal, showing some higher levels of antioxidants, results are decidedly clear for animal products. Pastured organic animal products—including beef, lamb, pork, dairy, poultry, and eggs—have been shown to be superior to that of products of chemical-intensive crops and confined animals in their distribution of fatty acids.

The differences to consumers go beyond nutritional value. Organic food is generally free of residues of pesticides and antibiotics. Pesticide residues are found in 70% of the food sold in the U.S., and residues of antibiotics are common in nonorganic milk. These residues may not exceed EPA tolerances, but lower levels may still have health effects. EPA does not take into account the combined effects of different pesticides that may occur on an item of produce (or in a meal), which often exceed the sum of the residues. It does not take into account the combined effects of all the ingredients of a single pesticide product. Despite a requirement in the Food Quality Protection Act that EPA implement screening of pesticides for endocrine disrupting chemicals (EDCs) by 1999, pesticides are still not evaluated for their endocrine disruption potential, which can occur at levels far below those that cause the effects for which EPA tests.

Among the endocrine disruptors that are particularly relevant in the context of these guidelines are obesogens. As stated in an article by Drs. Amanda Janesick and Bruce Blumberg, “Recently, EDCs have been implicated in metabolic syndrome and obesity. Adipose tissue is a true endocrine organ and, therefore, an organ that is highly susceptible to disturbance by EDCs. A subset of EDCs, called ‘obesogens,’ promote adiposity by altering programming of fat cell development, increasing energy storage in fat tissue, and interfering with neuroendocrine control of appetite and satiety.”

In addition to the direct impacts of pesticide food residues on consumers, chemical-intensive agriculture contaminates air, water, and land, affecting the health of Americans in other ways. Pesticides in the air can aggravate asthma and other respiratory problems. Pesticides run off into streams and leach into groundwater, contaminating drinking water. Farmworkers should also be protected by these food guidelines because their health is threatened by the poisons that are applied to fields where they work.

Organic food production sequesters more carbon in the soil than conventional chemical-intensive agriculture, helping to mitigate climate change. Health hazards of climate change range from injury and death from a higher frequency of more severe storms to northward migration of tropical diseases and their insect vectors.

USDA organic certification is the only system of food labeling that is subject to independent public review and oversight, assuring consumers that toxic, synthetic pesticides used in conventional agriculture are replaced by management practices focused on soil biology, biodiversity, and plant health. This eliminates commonly used toxic chemicals in the production and processing of food that is not labeled organic–pesticides that contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish and other wildlife.

The updated dietary guidelines should incorporate this information and recommend that Americans consume, to the extent possible, organic produce and organic pastured animal products.

Sign the petition to USDA and send a letter to Congress. Tell them that organic food must be emphasized in new dietary guidelines.

Petition to USDA

As USDA takes public comments on its updated dietary guidelines, it important that sustainable, regenerative organic food production practices are an integral part. Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations that are supposed, minimally, to promote public health and prevent chronic diseases. The next review and a draft updated version, the 2020–2025 Dietary Guidelines for Americans, is currently underway. The 2015 Dietary Guidelines Advisory Committee (DGAC) examined the evidence on sustainable diets for the first time, but this topic was not included within the scope of work for the 2020 DGAC. The 2015 committee concluded that “in general, a dietary pattern that is higher in plant-based foods, such as vegetables, fruits, whole grains, legumes, nuts, and seeds, and lower in animal-based foods is more health promoting and is associated with lesser environmental impact ([greenhouse gas] emissions and energy, land, and water use) than is the current average U.S. diet.” [1]

USDA says that the food guidelines provide “information that helps Americans make healthy choices for themselves and their families.” In order to make healthy food choices, the guidelines must go beyond the traditional parameters to include how the food is produced. How food is produced affects the health of Americans not only as a result of the nutritional quality of the food, but also due to environmental contamination.

Although research on the nutritional density of organic produce is equivocal, showing some higher levels of antioxidants [2], results are decidedly clear for animal products. Pastured organic animal products—including beef [3], lamb [4], pork [5], dairy [6], poultry [7], and eggs [8]—have been shown to be superior to that of products of chemical-intensive crops and confined animals in their distribution of fatty acids.

The differences to consumers go beyond nutritional value. Organic food is generally free of residues of pesticides and antibiotics. Pesticide residues are found in 70% of the food sold in the U.S., and residues of antibiotics are common in nonorganic milk. [9] These residues may not exceed EPA tolerances, but lower levels may still have health effects. EPA does not take into account the combined effects of different pesticides that may occur on an item of produce (or in a meal), which often exceed the sum of the residues. It does not take into account the combined effects of all the ingredients of a single pesticide product. Despite a requirement in the Food Quality Protection Act that EPA implement screening of pesticides for endocrine disrupting chemicals (EDCs) by 1999, pesticides are still not evaluated for their endocrine disruption potential, which can occur at levels far below those that cause the effects for which EPA tests.

Among the endocrine disruptors that are particularly relevant in the context of these guidelines are obesogens. As stated in an article by Drs. Amanda Janesick and Bruce Blumberg, “Recently, EDCs have been implicated in metabolic syndrome and obesity. Adipose tissue is a true endocrine organ and, therefore, an organ that is highly susceptible to disturbance by EDCs. A subset of EDCs, called ‘obesogens,’ promote adiposity by altering programming of fat cell development, increasing energy storage in fat tissue, and interfering with neuroendocrine control of appetite and satiety.” [10]

In addition to the direct impacts of pesticide food residues on consumers, chemical-intensive agriculture contaminates air, water, and land, affecting the health of Americans in other ways. Pesticides in the air can aggravate asthma and other respiratory problems. Pesticides run off into streams and leach into groundwater, contaminating drinking water. Farmworkers should also be protected by these food guidelines because their health is threatened by the poisons that are applied to fields where they work. [11]

Organic food production sequesters more carbon in the soil than conventional chemical-intensive agriculture, helping to mitigate climate change. [12] Health hazards of climate change range from injury and death from a higher frequency of more severe storms to northward migration of tropical diseases and their insect vectors.

USDA organic certification is the only system of food labeling that is subject to independent public review and oversight, assuring consumers that toxic, synthetic pesticides used in conventional agriculture are replaced by management practices focused on soil biology, biodiversity, and plant health. This eliminates commonly used toxic chemicals in the production and processing of food that is not labeled organic–pesticides that contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish and other wildlife.

The updated dietary guidelines should incorporate this information and recommend that Americans consume, to the extent possible, organic produce and organic pastured animal products.

References

[1] DGAC (Dietary Guidelines Advisory Committee). 2015. Scientific Report of the 2015 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Health and Human Services and the Secretary of Agriculture. Washington, DC: US Department of Agriculture.

[2] Bernacchia, R., Preti, R. and Vinci, G., 2016. Organic and Conventional Foods: Differences in Nutrients. Italian Journal of Food Science28(4).

[3] Bjorklund, E.A., Heins, B.J., DiCostanzo, A. and Chester-Jones, H., 2014. Fatty acid profiles, meat quality, and sensory attributes of organic versus conventional dairy beef steers. Journal of Dairy Science97(3), pp.1828-1834.

[4] Popova, T., 2007. Effect of the rearing system on the fatty acid composition and oxidative stability of the M. longissimus lumborum and M. semimembranosus in lambs. Small Ruminant Research71(1-3), pp. 150-157.

[5] Practical Farmers of Iowa, 2019. Research Report: Fatty acid comparisons of grain and forage-fed pork. https://practicalfarmers.org/wp-content/uploads/2019/04/18.L.Nutrient-Density-Profiles-for-Conventional-vs.-Pasture-Raised-Pork.pdf.

[6] Benbrook, C.M., Davis, D.R., Heins, B.J., Latif, M.A., Leifert, C., Peterman, L., Butler, G., Faergeman, O., Abel-Caines, S. and Baranski, M., 2018. Enhancing the fatty acid profile of milk through forage-based rations, with nutrition modeling of diet outcomes. Food science & nutrition6(3), pp.681-700.

[7] Tufarelli, V., Ragni, M. and Laudadio, V., 2018. Feeding forage in poultry: a promising alternative for the future of production systems. Agriculture8(6), p.81.

[8] Karsten, H.D., Patterson, P.H., Stout, R. and Crews, G., 2010. Vitamins A, E and fatty acid composition of the eggs of caged hens and pastured hens. Renewable Agriculture and Food Systems25(1), pp.45-54.

[9] Pesticide residues found in 70% of produce sold in US even after washing, The Guardian. March 20, 2019. Welsh, J.A., Braun, H., Brown, N., Um, C., Ehret, K., Figueroa, J. and Barr, D.B., 2019. Production-related contaminants (pesticides, antibiotics and hormones) in organic and conventionally produced milk samples sold in the USA. Public health nutrition22(16), pp.2972-2980.

[10] Janesick, A.S. and Blumberg, B., 2016. Obesogens: an emerging threat to public health. American journal of obstetrics and gynecology214(5), pp.559-565.

[11] https://beyondpesticides.org/resources/eating-with-a-conscience/overview.

[12] Ghabbour, E.A., Davies, G., Misiewicz, T., Alami, R.A., Askounis, E.M., Cuozzo, N.P., Filice, A.J., Haskell, J.M., Moy, A.K., Roach, A.C. and Shade, J., 2017. National comparison of the total and sequestered organic matter contents of conventional and organic farm soils. In Advances in Agronomy (Vol. 146, pp. 1-35). Academic Press.

Letter to Congress

Congress requires a review of its Dietary Guidelines—recommendations to promote public health and prevent chronic diseases—every five years. The 2020–2025 Dietary Guidelines for Americans review is currently underway. The 2015 Dietary Guidelines Advisory Committee (DGAC) examined the evidence on sustainable diets for the first time, but this topic was not included within the scope of work for the 2020 DGAC.

USDA says food guidelines provide “information that helps Americans make healthy choices for themselves and their families.” The guidelines must include production practices that affect the health of Americans not only through the nutritional quality of the food, but also due to environmental contamination.

Research on the nutritional density of organic produce shows some higher levels of antioxidants. Pastured organic animal products—including beef, lamb, pork, dairy, poultry, and eggs—have been shown to be superior to that of products of chemical-intensive agriculture in their distribution of fatty acids.

Organic food is generally free of residues of pesticides and antibiotics. Pesticide residues are found in 70% of the food sold in the U.S., and residues of antibiotics are common in nonorganic milk. Even when residues do not exceed EPA tolerances, they may have health effects. EPA does not take into account the combined effects of different pesticides or of all the ingredients of a single pesticide product. Despite a requirement in the Food Quality Protection Act that EPA implement screening of pesticides for endocrine disrupting chemicals (EDCs) by 1999, pesticides are still not evaluated for their endocrine disruption potential, which can occur at levels far below those that cause the effects for which EPA tests.

Among the EDCs that are particularly relevant in the context of these guidelines are obesogens. As stated in an article by Drs. Amanda Janesick and Bruce Blumberg, “Recently, EDCs have been implicated in metabolic syndrome and obesity. Adipose tissue is a true endocrine organ and, therefore, an organ that is highly susceptible to disturbance by EDCs. A subset of EDCs, called ‘obesogens,’ promote adiposity by altering programming of fat cell development, increasing energy storage in fat tissue, and interfering with neuroendocrine control of appetite and satiety.”

In addition to the impacts on consumers, pesticides in the air can aggravate asthma and other respiratory problems. Pesticides run off into streams and leach into groundwater, contaminating drinking water. The health of farmworkers is threatened by the poisons applied to fields where they work.

Organic food production sequesters more carbon in the soil than conventional chemical-intensive agriculture, helping to mitigate climate change. Health hazards of climate change range from injury and death from a higher frequency of more severe storms to northward migration of tropical diseases and their insect vectors.

USDA organic certification is the only system of food labeling that is subject to independent public review and oversight, assuring consumers that toxic synthetic pesticides used in conventional agriculture are replaced by management practices focused on soil biology, biodiversity, and plant health, protecting Americans from pesticides that contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife.

The updated dietary guidelines should incorporate this information and recommend that Americans consume, to the extent possible, organic produce and organic pastured animal products.

Thank you.

04/13/2020 — Our Food Supply Depends on Protecting Farmworkers

An op-ed in the New York Times asks, “What Happens if America's 2.5 Million Farmworkers Get Sick?” Without those farmworkers, the year-round supply of fresh fruits and vegetables that we take for granted would be impossible. The supply chain of those vital foods starts with the workers who plant, cultivate, and harvest them. Our society and everyone living in the U.S. depend on farmworkers.

>>Tell Congress to provide essential benefits to essential workers.

But farmworkers are at high risk from the coronavirus (COVID-19) pandemic. Living in crowded conditions, social distancing is impossible for them. They have little access to health care. Washing hands is often impossible in the field. With children home from school, they have additional childcare costs to pay with their low wages. They also have increased costs from using private transportation to avoid crowded buses.

And many farmworkers are exposed to respiratory hazards like pesticides and fungal spores that make them more susceptible to the coronavirus.

As the medical demand for personal protective equipment (PPE) increases, farmworkers are being faced with potential shortages of masks, gloves, and suits. Last month, a group of Washington farmworkers walked off a worksite because their employer was not offering sufficient PPE. No farmworker should be forced to apply pesticides without the necessary PPE. EPA and states must enforce this label requirement. On March 26, EPA issued a sweeping suspension of its enforcement program, putting farmworkers at even higher risk. U.S. agricultural producers are subject to an EPA worker protection rule governing enforcement of pesticide use restrictions, rather than labor laws under the Department of Labor.

At least 50% of farmworkers are undocumented, so they will not get the relief payment most other households will, even though they are U.S. taxpayers. Even their U.S. citizen children are left out. Farmworkers need our support because they do not have the personal protective equipment (PPE) and social safety nets that they need!

>>Tell Congress to provide essential benefits to essential farmworkers.

 

Sustainable agriculture includes support for agricultural workers. Farmworkers who are currently employed on a farm should receive the same payments as any other workers without questions about their status as citizens. They should be eligible for paid sick leave, SNAP (food stamps), health coverage, and workmen's compensation.

>>You can contribute directly to farm and food workers through these organizations:

04/06/2020 — Stop Dangerous Proposal to Allow GE Crops on National Wildlife Refuges in Southeast U.S.

The Trump administration’s U.S. Fish and Wildlife Service (USFWS) is moving forward with a proposal to grow genetically engineered crops (GECs) on National Wildlife Refuges in the Southeast United States, including 131 refuges in 10 states, Puerto Rico, and the U.S. Virgin Islands.

Ask Congress to help stop the dangerous proposal to allow genetically engineered crops on National Wildlife Refuges in the southeast United States.

The proposal is the subject of a draft environmental assessment and opens the door to escalating uses of GE crops and harmful pesticides in wildlife refuges.

In 2014, public pressure and lawsuits by environmental groups led to the Obama administration’s decision to phase out GE crops and ban neonicotinoid insecticide use on national wildlife refuges. On August 2, 2018, the Trump administration’s USFWS issued a memorandum that reversed the prohibition. The reversal allows the refuge system to make decisions on the use of GECs and neonics on a case-by-case basis in compliance with the National Environmental Policy Act (NEPA), which is also under attack by the Trump administration. The Center for Biological Diversity, Center for Food Safety, and others quickly challenged the 2018 reversal memorandum with a lawsuit.

National Wildlife Refuges are federal public lands specifically designated to protect fish and wildlife. The Southeastern Region is comprised of almost 4 million acres of refuge lands and waters that provide vital habitat for dozens of endangered species known to be imperiled by pesticide use—including bats, birds, freshwater mussels, and fish like the pallid sturgeon and Alabama cavefish. “It’s a no-brainer that this kind of pesticide-intensive agriculture shouldn’t be allowed on public lands that are critical to wildlife conservation and preservation of the unique ecosystems of the southeastern U.S.,” said Hannah Connor, an attorney at the Center for Biological Diversity.

Approximately 44,000 acres of refuge lands in the Southeastern Region currently incorporate to farming, with corn, soybeans and rice the most commonly farmed crops. Genetically engineered corn and soybeans are typically designed to survive spraying with herbicides like glyphosate, dicamba, and 2-4,D—allowing farmers to use these pesticides prophylactically after the crops have sprouted. Increased pesticide use often coincides with wildlife feeding and breeding times, when pesticides can be especially harmful.

Glyphosate use on GE crops have significantly contributed to monarch butterflies’ 80-90% decline over the past two decades. This is because the pesticide is a potent killer of milkweed, the monarch caterpillar’s only food.

USFWS’ Draft Programmatic Environmental Assessment notes the adverse impact of “commercial pesticides” (and their citations read “neonics”). Remarkably, the authors argue that genetically engineered crops, as opposed to “non-GEC,” use fewer commercial pesticides, an argument that has long been refuted—especially as most GECs are designed to be used with pesticides.

USFWS announced a public comment period for its proposal and Draft Programmatic Environmental Assessment. They will accept input through April 10, 2020. Comments and questions must be submitted in writing to [email protected] or mailed to Pamala Wingrove, Branch Chief, Conservation Planning, USFWS, Southeast Region, 1875 Century Boulevard NE, Atlanta, GA, 30345. Meanwhile, please ask your U.S. Representative and Senators to weigh in.

Ask Congress to help stop the dangerous proposal to allow genetically engineered crops on National Wildlife Refuges in the southeast United States.

Letter to Congress

I am appalled at the U.S. Fish and Wildlife Service (USFWS) proposal to allow the cultivation of genetically engineered crops on National Wildlife Refuges in the Southeast United States, including 131 refuges in 10 states, Puerto Rico and the U.S. Virgin Islands.

The proposal would open the door to escalating uses of GE crops and harmful pesticides in wildlife refuges. In 2014, public pressure and lawsuits by environmental groups led to the Obama administration’s decision to phase out GE crops and ban neonicotinoid insecticide use on national wildlife refuges. On August 2, 2018, the Trump administration’s FWS issued a memorandum that reversed the prohibition. The reversal allows the refuge system to make decisions on the use of GECs and neonics on a case-by-case basis.

National wildlife refuges are federal public lands specifically designated to protect fish and wildlife. The Southeastern Region is comprised of almost 4 million acres of refuge lands and waters that provide vital habitat for dozens of endangered species known to be imperiled by pesticide use—including bats, birds, freshwater mussels, and fish like the pallid sturgeon and Alabama cavefish.

Approximately 44,000 acres of refuge lands in the Southeastern Region currently incorporate farming, with corn, soybeans and rice the most commonly farmed crops. Genetically engineered corn and soybeans are typically designed to survive spraying with herbicides like glyphosate, dicamba, and 2-4,D—allowing farmers to use these pesticides prophylactically after the crops have emerged. Increased pesticide use often coincides with wildlife feeding and breeding times, when pesticides can be especially harmful.

USFWS’ Draft Programmatic Environmental Assessment notes the adverse impact of “commercial pesticides” (and their citations read “neonics”). Remarkably, the authors argue that genetically engineered crops, as opposed to “non-GEC,” use fewer commercial pesticides, an argument that has long been refuted—especially as most GECs are designed to be used with pesticides.

I request that you urge USFWS to abandon its proposal because it is unwise and dangerous to the species that the refuges are mandated to protect.

Thank you.

03/30/2020 — Tell Your Governor: Safer Disinfectants for Coronavirus Exist, Stop Toxic Chemicals as EPA Halts Protections

Faced with the COVID-19 (coronavirus) threat, there is tremendous pressure to use toxic disinfectants, despite the availability of safer products. In fact, while the Centers for Disease Control and Prevention (CDC) is recommending 70% alcohol for surface disinfection, the U.S. Environmental Protection Agency's (EPA) Office of Pesticide Programs is advising the use of unnecessarily toxic substances, and reducing standards that govern their allowance on the market. EPA's pesticide program allowed 70 new disinfectants yesterday, at the same time that the agency overall announced that it is waiving enforcement of environmental standards during the coronavirus outbreak—a devastating blow to public health and environmental protection.

In the absence of federal protections, it is critical that the governors of every state take action to protect the health and safety of people, most immediately with the use of safer disinfectants and sanitizers in response to COVID-19. Contact your Governor to let them know it is important to provide their residents with information on safer practices and products for preventing exposure to COVID-19 without toxic chemicals.

>> Tell Your Governor to Provide Residents with Information on Safer Disinfectants and Sanitizers for Coronavirus to Avoid Toxic Chemicals, as EPA Suspends Protections

Beyond Pesticides, in its factsheet, Protecting Yourself from COVID-19 (coronavirus) without Toxic Sanitizers and Disinfectants, says, “Fight the coronavirus with common sense prevention and safer disinfection products. Avoid products that increase vulnerability to respiratory problems.” (See the factsheet below.)

To some extent, the expanded allowance of disinfection products on top of the 281 disinfectants previously permitted has been made possible by relaxing oversight on so-called “inert” or other ingredients that are not disclosed on product labels and often highly toxic. The agency says it is allowing the use of these “inerts” with “no significant differences” compared to already-approved ingredients. Since inerts are not disclosed to the public and subject to limited EPA oversight, identifying potential contaminants or hazardous byproducts is critical to determining product safety.

According to The Hill newspaper, “EPA issued a sweeping suspension of its enforcement of environmental laws Thursday [March 26], telling companies they would not need to meet environmental standards during the coronavirus outbreak.” Specific to surface disinfectants, EPA announced the following yesterday:

“Today, the U.S. Environmental Protection Agency (EPA) took steps to provide additional flexibilities to manufacturers of disinfectants and other pesticides. EPA intends for these flexibilities to increase the availability of products for Americans to use against the novel coronavirus.”

EPA is responsible for regulating surface disinfectants, while the Food an Drug Administration regulates hand sanitizers. Without adequate regulations and given the availability of safer alternative disinfectants, people, as well as local and state governments, are urged to take protective action. See Beyond Pesticides factsheet.

___________

Protecting Yourself from COVID-19 (coronavirus) without Toxic Sanitizers and Disinfectants.

Fight the coronavirus with common sense prevention and safer disinfection products. Avoid products that increase vulnerability to respiratory problems.             

WHY THE CONCERN ABOUT TOXIC SANITIZERS AND DISINFECTION PRODUCTS

We have learned through the COVID-19 crisis that there are people who are more vulnerable to the effects of the virus. These are generally people who have a pre-existing condition or are of advanced age, who may have a weakened immune or respiratory system. With the management of viral and bacterial infections, it is always important that we do not exacerbate the risk to individuals in the process of avoiding or controlling the threat. In the case of COVID-19, we have measures of protection—both practices and products—that can protect us without using toxic products that increase risk factors.

PREVENTION

The good news is that toxic chemicals are not necessary to prevent exposure to COVID-19 and eliminate the virus. The Centers for Disease Control and Prevention (CDC) urges simple measures to prevent exposure:

  • Avoid close contact with people who are sick.
  • Avoid touching your eyes, nose, and mouth.
  • Stay home when you are sick.
  • Cover your cough or sneeze with a tissue, then throw the tissue in the trash.

 How it works: The best way to prevent any infectious disease transmission is to stay out of contact with those who have already contracted the disease.

HAND CLEANING AND SANITIZING

Eliminating the Virus on Hands

  • Wash your hands often with soap and water for at least 20 seconds. If soap and water are not readily available, use an alcohol-based hand sanitizer with at least 60% alcohol. (See list of products below.) Always wash hands with soap and water if hands are visibly dirty.

How it works: Soap breaks down the virus's fat membrane—and the infectious material falls apart—as long as you rub the soap on your hands for at least 20 seconds. Alcohol wipes with 60% alcohol do the same thing. These chemicals break down the virus by a similar process, by breaking down the lipid covering of the virus. [1]                                                       

Only products with active ingredients ethanol, isopropanol, or benzalkonium chloride can qualify as “hand sanitizers” according to the Food and Drug Administration (FDA). An alcohol-based hand sanitizer should contain at least 60% alcohol in order to be effective.[2] Glycerol or aloe as part of the remainder can help counter the drying effects of alcohol on the skin.

The Bad: Toxic Sanitizers

Avoid hand sanitizers containing benzalkonium chloride (BAC), which is a quaternary ammonium compound (or “quat”). It is an irritant that can cause asthmatic reactions and adversely affect the respiratory system.[3],[4] BAC is also associated with changes in neurodevelopment,[5] selection for antibiotic resistance,[6] and provoking irritant and/or contact dermatitis.[7]

DISINFECTING SURFACES

Eliminating the Virus on Surfaces

  • Clean and disinfect frequently touched objects and surfaces using a regular household cleaning sprays or wipes that contain 70% alcohol. (See list of products below.)

Like hand washing with soap or wipes with 60% alcohol, the virus on surfaces can be detached and broken down with soap and alcohol. [8]

The Good: Natural-based substances tend to be safer, while still effective at eliminating the virus on surfaces. Look for products with the following active ingredients (* indicates listed by EPA's Design for the Environment Program (DfE)[9]):

Citric acid*
Ethanol*
Isopropanol*
L-lactic acid*
Hydrogen peroxide*
Sodium bisulfate*
Thymol

The Bad: EPA has approved a long list of products[10] that will eliminate the COVID-19 virus on surfaces. The list includes products containing toxic chemicals, such as chlorine bleach, peroxyacetic acid, quaternary ammonium compounds or “quats,” sodium dichloro-s-triazinetrione, and hydrochloric acid. Exposure to these chemicals are associated with a long list of adverse effects, from asthma to cancer.[11],[12]

Avoid products containing:

Peroxyacetic acid (peracetic acid)[13]
Chlorine compounds (sodium hypochlorite, hypochlorous acid, sodium chlorite)
Sodium Dichloro-S-Triazinetrione
Quaternary Ammonium compounds (quats)
Phenolic compounds
Glycolic acid
Octanoic acid[14]

All of these ingredients are associated with harm to the respiratory system.[15],[16],[17],[18],[19],[20] In addition, some quats have been shown to cause mutations, lower fertility, and increase antibiotic resistance.[21] Phenolic compounds include a wide range of toxic chemicals, including cresols, hexachlorobenzene, and chlorophenols. Health effects from breathing or exposure to the skin include headaches, burning eyes, muscle tremors, skin burns, irregular heart beat, severe injury to heart, liver, kidneys, and lungs, cancer, and death.[22],[23]

STAY SAFE

It is important during public health emergencies involving infectious diseases to scrutinize practices and products very carefully so that hazards presented by the crisis are not elevated because of the unnecessary threat introduced with toxic chemical use.

References
[1] Pall Thordarson, 2020. The science of soap – here's how it kills the coronavirus. https://www.theguardian.com/commentisfree/2020/mar/12/science-soap-kills-coronavirus-alcohol-based-disinfectants. See also: https://www.youtube.com/watch?v=K2pMVimI2bw&feature=youtu.be.
[2] CDC Statement for Healthcare Personnel on Hand Hygiene during the Response to the International Emergence of COVID-19. https://www.cdc.gov/coronavirus/2019-ncov/infection-control/hcp-hand-sanitizer.html.
[3] https://prhe.ucsf.edu/sites/g/files/tkssra341/f/Fact%20Sheet_Information%20for%20Workers.pdf.
[4] Choi, H.Y., Lee, Y.H., Lim, C.H., Kim, Y.S., Lee, I.S., Jo, J.M., Lee, H.Y., Cha, H.G., Woo, H.J. and Seo, D.S., 2020. Assessment of respiratory and systemic toxicity of Benzalkonium chloride following a 14-day inhalation study in rats. Particle and Fibre Toxicology17(1), p.5. https://link.springer.com/article/10.1186/s12989-020-0339-8
[5] Herron, J.M., 2019. The Effects of Benzalkonium Chloride Disinfectants on Lipid Homeostasis and Neurodevelopment (Doctoral dissertation).
[6] Kim, M., Weigand, M.R., Oh, S., Hatt, J.K., Krishnan, R., Tezel, U., Pavlostathis, S.G. and Konstantinidis, K.T., 2018. Widely used benzalkonium chloride disinfectants can promote antibiotic resistance. Applied and environmental microbiology84(17), pp.e01201-18.
[7] Lachenmeier, D.W., 2016. Antiseptic Drugs and Disinfectants. In Side Effects of Drugs Annual (Vol. 38, pp. 211-216). Elsevier.
[8] Kampf, G., Todt, D., Pfaender, S. and Steinmann, E., 2020. Persistence of coronaviruses on inanimate surfaces and its inactivation with biocidal agents. Journal of Hospital Infection.
[9] https://www.epa.gov/pesticide-labels/design-environment-logo-antimicrobial-pesticide-products.
[10] https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2.
[11] https://prhe.ucsf.edu/sites/g/files/tkssra341/f/Fact%20Sheet_Information%20for%20Workers.pdf.
[12] Agency on Toxic Substances and Disease Registry, 2008. ToxFAQs for Chlorophenol. https://www.atsdr.cdc.gov/toxprofiles/tp107-c1.pdf.
[13] Peracetic acid is on EPA's DfE list, but is considered to pose an asthma risk.
[14]Octanoic acid is listed on EPA's Safer Chemical Ingredients List under surfactants, which are listed based on environmental toxicity and biodegradation. But it is corrosive to skin https://echa.europa.eu/registration-dossier/-/registered-dossier/15370/7/3/1.
[15] https://prhe.ucsf.edu/sites/g/files/tkssra341/f/Fact%20Sheet_Information%20for%20Workers.pdf.
[16] Holm, S.M., Leonard, V., Durrani, T. and Miller, M.D., 2019. Do we know how best to disinfect child care sites in the United States? A review of available disinfectant efficacy data and health risks of the major disinfectant classes. American journal of infection control47(1), pp.82-91.
[17] Agency on Toxic Substances and Disease Registry, 2008. ToxFAQs for Phenol. https://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=147&tid=27.
[18] Weiselberg, R. and Nelson, L.S., 2011. A Toxic Swimming Pool Hazard. EMERGENCY MEDICINEhttps://mdedge-files-live.s3.us-east-2.amazonaws.com/files/s3fs-public/Document/September-2017/043040019.pdf.
[19] Glycolic acid MSDS.
https://www.cdhfinechemical.com/images/product/msds/18_352140617_GlycolicAcid-CASNO-79-14-1-MSDS.pdf.
[20] European Chemicals Agency (ECHA), Octanoic Acid Registration Dossier. https://echa.europa.eu/registration-dossier/-/registered-dossier/15370/7/3/1
[21] Holm, S.M., Leonard, V., Durrani, T. and Miller, M.D., 2019. Do we know how best to disinfect child care sites in the United States? A review of available disinfectant efficacy data and health risks of the major disinfectant classes. American journal of infection control47(1), pp.82-91. https://www.ajicjournal.org/article/S0196-6553(18)30731-4/fulltext#sec0018.
[22] Agency on Toxic Substances and Disease Registry, 2008. ToxFAQs for Phenol. https://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=147&tid=27
[23] Agency on Toxic Substances and Disease Registry, 2008. ToxFAQs for Chlorophenol. https://www.atsdr.cdc.gov/toxprofiles/tp107-c1.pdf.

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

Source: The HillCDCEPA.

03/20/2020 — Tell Congress to Help Organic Farmers and Consumers Hurt by the Pandemic, Today!

Support Organic Farmers as They Provide Nutrition that Heals

As we all heed calls for social distancing to avoid spread of COVID-19, elected officials are looking for ways to support those who are suffering from adverse economic impact. In doing this, it is especially important to focus on those organic family farmers who grow our food and have had their markets disrupted.

Tell Congress to Help Organic Farmers Hurt by the Pandemic

Congress has already passed an $8 billion response package earlier this month and just passed H.R. 6201, the Families First Coronavirus Response Act, providing additional appropriations to address testing, emergency nutrition assistance, temporary paid leave, and increased federal funding for unemployment insurance. Now a much bigger, trillion-dollar economic stimulus bill is in the works.

Ideas for the trillion-dollar spending package are proliferating as fast as the virus. While direct payments to individuals have been mentioned, so have various subsidies to businesses. We need to warn politicians not to exploit the coronavirus pandemic to subsidize large corporations without protections for workers. Rather, our Representatives need to ensure that the money goes to help those who have been directly affected.

In a letter to House Speaker Nancy Pelosi, U.S. Representative Chellie Pingree detailed the impact of the COVID-19 pandemic on farmers in local and regional markets. Noting that trade mitigation payments have not benefited farmers who sell products through local and regional markets, Rep. Pingree urged Speaker Pelosi to take actions to support these farmers, including emergency disaster payments, emergency farm loans, and suspending FSA loan payments. “We should provide emergency disaster payments to farmers selling fresh and minimally processed foods in local and regional markets that have been negatively impacted by the COVID-19 pandemic,” wrote Rep. Pingree.

Organic farmers are among these who have been hardest hit. When asked to provide ideas for how organic farmers could be helped, in addition to the recommendations of Rep. Pingree, many representing organic farmers offer these suggestions:

  • Ensure that farmers markets and farm stands have the same status as retail stores when it comes to social gathering and loss of income.
  • Increase the cost share in organic certification, paid up front, and allow certifiers to waive fees until September
  • Help make connections with local farms when addressing food programs.
  • Establish a program to provide relief workers for sick farmers.
  • Disaster payments should cover both crops not harvested or sold, as well as those that can move to emergency food needs; organic is paid at the organic price.
  • Allow Supplemental Nutrition Assistance Program (SNAP) payments to be made on-line directly to farms.
  • Provide funds for farms quickly moving to set up “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction as farmers markets may be limited, or even farmers feel unsafe selling at farmers markets.

Tell Congress to Help Organic Farmers Hurt by the Pandemic

Letter to Congress

As we all heed calls for social distancing to avoid spread of COVID-19, we also see the need to support those organic family farmers who grow our food and have had their markets disrupted. Please ensure that the stimulus measures actually help those who need it.

Ideas for a trillion dollar spending package are proliferating as fast as the virus. While direct payments to individuals have been mentioned, so have various subsidies to businesses. Please avoid the temptation to exploit the coronavirus pandemic to subsidize large corporations without protections for workers. Rather, ensure that the money goes to help those who have been directly affected. Please put the money to work where it will help those who have been directly affected.

In a letter to House Speaker Nancy Pelosi, Representative Chellie Pingree detailed the impact of the COVID-19 pandemic on farmers in local and regional markets. Noting that trade mitigation payments have not benefited farmers who sell products through local and regional markets, Rep. Pingree urged Speaker Pelosi to take actions to support these farmers, including emergency disaster payments, emergency farm loans, and suspending FSA loan payments. “We should provide emergency disaster payments to farmers selling fresh and minimally processed foods in local and regional markets that have been negatively impacted by the COVID-19 pandemic,” she wrote.

Organic farmers are among these who have been hardest hit. When asked to provide ideas for how organic farmers could be helped, in addition to the recommendations of Rep. Pingree, many representing organic farmers offer these suggestions:

* Ensure that farmers markets and farm stands have the same status as retail stores when it comes to social gathering and loss of income.

* Increase the federal cost share in organic certification, paid up front, and allow certifiers to waive fees until September.

* Help make connections with local farms when addressing food programs.

* Establish a program to provide relief workers to assist sick farmers.

* Disaster payments should cover both crops not harvested or sold, as well as those that can move to emergency food needs; organic is paid at the organic price.

* Allow SNAP payments to be made on-line directly to farms.

* Provide funds for farms quickly moving to set up “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction as farmers markets may be limited, or even farmers feel unsafe selling at farmers markets.

I believe that these targeted suggestions will help all of us by helping farmers to provide the health-giving nutrition we need during these times.

Thank you.

Sincerely,

03/16/2020 — Take Action: Toxic Chemicals Unnecessary To Protect Against the Coronavirus; CDC Advises Preventive Measures


As the number of people infected with Novel Coronavirus Disease 2019 (COVID-19) increases, many people are looking for sound advice about how to protect themselves and their families. There is much uncertainty. “It's fair to say that as the trajectory of the outbreak continues, many people in the United States will at some point in time either this year or next be exposed to this virus, and there's a good chance many will become sick,” said Nancy Messonnier, M.D., director of the Centers for Disease Control and Prevention's (CDC's) National Center for Immunization and Respiratory Diseases. “But … based on what we know about this virus, we do not expect most people to develop serious illness.”

>> Tell EPA not to recommend toxic chemicals for disease prevention.

While people are seeking answers, EPA's published list, Registered Antimicrobial Products for Use Against Novel Coronavirus SARS-CoV-2, the Cause of COVID-19, does not offer helpful advice. The list contains products containing toxic chemicals such as chlorine bleach, peroxyacetic acid, alkyl dimethyl benzyl ammonium chlorides, didecyl dimethyl ammonium chloride, and other “quats,” sodium dichloro-s-triazinetrione, and hydrochloric acid. In addition to their outright toxicity, some of these can also trigger asthmatic attacks.

On the other hand, CDC's website makes it clear that such toxic chemicals are unnecessary. The common sense, nontoxic advice should be heeded:

  • Avoid close contact with people who are sick.
  • Avoid touching your eyes, nose, and mouth.
  • Stay home when you are sick.
  • Cover your cough or sneeze with a tissue, then throw the tissue in the trash.
  • Clean and disinfect frequently touched objects and surfaces using a regular household cleaning spray or wipe.
  • Wash your hands often with soap and water for at least 20 seconds. If soap and water are not readily available, use an alcohol-based hand sanitizer with at least 60% alcohol. Always wash hands with soap and water if hands are visibly dirty.

Soap and water—or, if washing is not possible, using a hand sanitizer with at least 60% alcohol—is as effective as stronger chemicals. For cleaning hard surfaces, 70% alcohol (common rubbing alcohol) is sufficient.

>> Tell EPA to support least-toxic disease prevention.

Beyond Pesticides will submit this petition to EPA's Office of Pesticide Programs (OPP)

 
 

03/09/2020 — Plant Organic Seeds and Plants; Tell Your State to Act to Protect Pollinators This Spring

It’s time to think about gardening! Whether you’re growing vegetables to eat or flowers for pollinators, you’ll want to be sure that your seeds and plants are free from harmful pesticides. Seeds and plants in many garden centers across the country are grown from seeds coated with toxic fungicides and bee-harming neonicotinoid pesticides, or drenched with them.

Plant organic seeds and plants!

As bees suffer serious declines in their populations, we urge people and communities to plant habitat that supports pollinator populations, and have provided information to facilitate this in our BEE Protective Habitat Guide. However, plants are too often grown with hazardous pesticides that either harm pollinators in their cultivation or threaten bees as they pollinate or forage on treated plants. For more information on the dangers of neonicotinoid coated seeds, see Beyond Pesticides’ short video Seeds That Poison.

Beyond Pesticides has compiled a directory of companies and organizations that sell organic seeds and plants to the general public. Included in this directory are seeds for vegetables, flowers, and herbs, as well as living plants and seedlings. Specific questions on each seller’s seeds can be directed to their customer service line. You can also download a handy bi-fold brochure version of this directory that you can print and take with you. If you know of a company that is not on this list, please let us know by sending an email to [email protected].

Although many seed companies indicate that they sell untreated seeds, Beyond Pesticides encourages you to look for organic seeds. While untreated seeds surely are a step in the right direction, they do not ensure that the seed production practices are protective of bees or that residual chemicals do not contaminate the plant.

Send a message to your Governor to encourage your state to plant organic seeds and plants in public places.

Letter to Governor:

 With honey bee and wild pollinator populations in decline, planting for pollinators has become a popular way to enhance pollinator habitat and the appearance of parks and roadsides. However, plants are too often grown with hazardous pesticides that either harm pollinators in their cultivation or threaten bees as they pollinate or forage on treated plants.

Beyond Pesticides has compiled a directory of companies and organizations (bp-dc.org/organicseeds) that sell organic seeds and plants to the general public. Included in this directory are seeds for vegetables, flowers, and herbs, as well as living plants and seedlings. Specific questions on each seller’s seeds can be directed to their customer service line.

A recent paper titled “Declines in insect abundance and diversity: We know enough to act now,” provides a run-down of additional actions to take, including these actions at the local and state level:

*Strengthen pesticide regulations and ban cosmetic use.

*Retail companies should have clear labels to warn about the impact on nontarget insects.

*Sub-national policy to protect insects should be pushed before national or international agreements are achieved.

*Strong incentives to protect, enhance, and restore habitat.

*Proper funding for conservation and management of land.

*Begin conservation efforts before species are on the brink of extinction.

*Mitigate and sequester carbon emissions; promote clean energy.

*Increase habitat connectivity.

I urge you to ensure that our state is implementing a pollinator protection plan that uses organic seeds and addresses these additional essential steps.

Thank you.

03/02/2020 — Tell EPA to Ban Atrazine

Protect Children and Frogs from this Endocrine Disrupting Pesticide

Atrazine, the second most-used herbicide in the U.S., is an insidious poison. Atrazine is known for producing frogs with extra limbs. It also affects the endocrine system and reproductive biology of humans. In addition to its agricultural uses on corn, sorghum, and sugar cane, atrazine is also used on home lawns, school grounds, and parks, where exposure to children is common. Nontoxic alternatives are available for all of these uses.

>>Sign the petition demanding that EPA ban atrazine and its cousins simazine and propazine.

Beyond Pesticides will submit comments: Docket: EPA-HQ-OPP-2017-0750 (FRL-10002-92) Due today, March 2.

Notice: Pesticide Registration Review; Proposed Interim Decisions for Several Triazines

 

Petition to Office of Pesticide Programs (OPP):

We have serious concerns with the proposed interim decisions on reregistration of three triazine pesticides: atrazine, simazine, and propazine. These triazines are highly mobile and persistent in the environment and have been linked to numerous adverse health and environmental effects which have motivated numerous public interest campaigns to ban their use in the U.S. as well as in Europe. The Draft Ecological Risk Assessments for the Registration Review of Atrazine, Simazine, and Propazine dated October 5, 2016  found high risks that were supported by EPA's assessments.

EPA's Proposed Interim Decisions present data demonstrating unreasonable adverse effects. These hazards are unacceptable, especially in light of the availability of nontoxic alternatives. The hazards include:
 

*The technical mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH) which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset.

*Despite these endocrine disrupting effects, EPA reduces the margin of safety and underestimates exposure to children.

*EPA states, “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates in these same locations.”

*In spite of these findings, EPA will increase the level of atrazine allowed in waterways.

Please adhere to the statutory mandate of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and suspend the registration of these pesticides that pose unreasonable adverse health and environmental effects.

02/26/2020 — Tell Your Congressional Representative to Support the Agriculture Resilience Act

 

Agriculture both suffers from the impacts of the climate crisis and contributes significantly to global warming. Representative Chellie Pingree of Maine has introduced H.R. 5861 aimed at achieving a 50% reduction in agricultural emissions by 2030 and net zero emissions by 2040, relative to 2010 levels.

Tell Your Congressional Representative to Cosponsor H.R. 5861.

July of 2019 was the hottest month ever recorded on Earth. The last time atmospheric carbon dioxide levels were this high (over 415 ppm) was during the Pliocene period – between 5.3 and 2.6 million years ago. We have seen changing precipitation and temperature patterns, resulting in flooding of some agricultural regions and droughts in others, crops and livestock varieties no longer suited to the geographical area where they have been produced, and new problems with insects, weeds, and disease.

The Intergovernmental Panel on Climate Change (IPCC) finds that Agriculture, Forestry, and Other Land Use contributes about 23% of total net anthropogenic emissions of greenhouse gases. At the same time, organic production can help reduce greenhouse gas emissions and sequester carbon in the soil.

Regenerative organic agriculture reduces emissions of carbon dioxide and nitrous oxide. In nonorganic, chemical-intensive agriculture, greenhouse gas emissions result from the use of nitrogen fertilizer, synthetic herbicides and insecticides, fossil fuel consumption associated with farm equipment, and the transportation of materials and products to and from the farm. The manufacture of synthetic fertilizers and pesticides is a major source of energy use in chemical-intensive agriculture–the manufacture and use of synthetic nitrogen fertilizers alone are responsible for as much as 10 percent of direct global agricultural emissions. This is important because pound-for-pound, nitrous oxide is 300 times as potent as carbon dioxide in warming the planet.

Besides reducing energy use, organic agriculture helps combat climate change by sequestering carbon in the soil. Organic agriculture also produces farms resilient to climate change because high soil organic matter content and mulching help to prevent nutrient and water loss. In addition, organic agriculture increases biodiversity, which is needed to meet the challenges of new insects, diseases, and weeds.

 The best time to have addressed global warming was 20 years ago, but the second-best time is now. Organic, regenerative agricultural practices help mend the earth from the ground up. Rep. Pingree’s Agriculture Resilience Act establishes specific goals and responsibilities in order to “accelerate the ability of agriculture and the food system to first achieve net zero carbon emissions and then go further to be carbon positive by removing additional carbon dioxide from the atmosphere.”

Tell Your Congressional Representative to Cosponsor H.R. 5861.

Letter to Congress

Agriculture both suffers from the impacts of the climate crisis and contributes significantly to global warming.  I am writing to ask you to cosponsor H.R. 5831, which is aimed at achieving a 50% reduction in agricultural emissions by 2030 and net zero emissions by 2040, relative to 2010 levels.

July of 2019 was the hottest month ever recorded on Earth. The last time atmospheric carbon dioxide levels were this high (over 415 ppm) was during the Pliocene period – between 5.3 and 2.6 million years ago. We have seen changing precipitation and temperature patterns, resulting in flooding of some agricultural regions and droughts in others, crops and livestock varieties no longer suited to the geographical area where they have been produced, and new problems with insects, weeds, and disease.

The Intergovernmental Panel on Climate Change (IPCC) finds that Agriculture, Forestry, and Other Land Use contributes about 23% of total net anthropogenic emissions of greenhouse gases. At the same time, organic production can help reduce greenhouse gas emissions and sequester carbon in the soil.

Regenerative organic agriculture reduces emissions of carbon dioxide and nitrous oxide. In nonorganic, chemical-intensive agriculture, greenhouse gas emissions result from the use of nitrogen fertilizer, synthetic herbicides and insecticides, fossil fuel consumption associated with farm equipment, and the transportation of materials and products to and from the farm. The manufacture of synthetic fertilizers and pesticides is a major source of energy use in chemical-intensive agriculture–the manufacture and use of synthetic nitrogen fertilizers alone are responsible for as much as 10 percent of direct global agricultural emissions. This is important because pound-for-pound, nitrous oxide is 300 times as potent as carbon dioxide in warming the planet.

Besides reducing energy use, organic agriculture helps combat climate change by sequestering carbon in the soil. Organic agriculture also produces farms resilient to climate change because high soil organic matter content and mulching help to prevent nutrient and water loss. In addition, organic agriculture increases biodiversity, which is needed to meet the challenges of new insects, diseases, and weeds.

The best time to have addressed global warming was 20 years ago, but the second-best time is now. Organic, regenerative agricultural practices help mend the earth from the ground up. Rep. Pingree’s Agriculture Resilience Act establishes specific goals and responsibilities in order to “accelerate the ability of agriculture and the food system to first achieve net zero carbon emissions and then go further to be carbon positive by removing additional carbon dioxide from the atmosphere.”

Please cosponsor H.R. 5831.

Thank you.

02/18/2020 — Take Action: Trump Administration’s Cuts to Science and the Environment

As in the in the past, President Trump once more proposes a budget that slashes funding for essential scientific research and environmental protection. His budget proposal includes cuts of nearly 10 percent to Health and Human Services (HHS) and 26 percent to the Environmental Protection Agency (EPA). And in the Department of Agriculture (USDA), he would again attempt to cut back on the Supplemental Nutrition Assistance Program (food stamps). Climate change appears to be absent.

Tell your Congressional delegation to hold the line on EPA’s budget to protect health, resources, and the economy!

Although agency heads, like Secretary of Agriculture Sonny Perdue, support the President’s budget, nonprofit advocates for scientific research and environmental protection are more negative. “The administration’s proposed budget cuts to research risk slowing our nation’s science just when it is reaping benefits for all Americans in the forms of better health, a stronger economy, a more sustainable environment, a safer world, and awe-inspiring understanding,” said Sudip Parikh, chief executive of the American Association for the Advancement of Science.

Even as the new coronavirus spreads, the Center for Disease Control and Prevention (CDC), is targeted for a 16 percent reduction. CDC has responsibilities that go well beyond infectious diseases and drug abuse. The Agency for Toxic Substances and Disease Registry, established as part of the Superfund program, is part of CDC that creates toxicological profiles—comprehensive evaluations of toxic chemicals found at toxic waste sites.

The proposed 26 percent reduction in EPA’s budget would eliminate nearly 50 programs, including large cuts to research and development and elimination of funding for the Energy Star program. “Congress should toss this Trump budget into the dustbin of history like they’ve done with the other ones,” said former EPA Administrator Gina McCarthy, who served during the Obama administration and is now head of the Natural Resources Defense Council.  

The U.S. House of Representatives, which is constitutionally invested with the “power of the purse,” will be looking closely at cuts in the proposed budget. “Like the three budgets before this, the Trump budget request will likely face bipartisan opposition, but we can’t take anything for granted. As a member of the House Appropriations Committee, I will fight for funding to support the long-term health and wellbeing of all Americans and reject this reckless budget from President Trump,” said U.S. Representative Chellie Pingree of Maine.

Tell your Congressional delegation to hold the line on EPA’s budget to protect health, resources, and the economy!

Letter to Congress

Please support a budget that fully funds scientific research and environmental protection programs.

Although his appointed agency heads support the President’s budget, nonprofit advocates for scientific research and environmental protection are more negative. “The administration’s proposed budget cuts to research risk slowing our nation’s science just when it is reaping benefits for all Americans in the forms of better health, a stronger economy, a more sustainable environment, a safer world, and awe-inspiring understanding,” said Sudip Parikh, chief executive of the American Association for the Advancement of Science.

Even as the new coronavirus spreads, the Center for Disease Control and Prevention (CDC), is targeted for a 16 percent reduction. CDC has responsibilities that go well beyond infectious diseases and drug abuse. The Agency for Toxic Substances and Disease Registry, established as part of the Superfund program, is part of CDC that creates toxicological profiles—comprehensive evaluations of toxic chemicals found at toxic waste sites.

President Trump’s proposed 26 percent reduction in EPA’s budget would eliminate nearly 50 programs, including large cuts to research and development and elimination of funding for the Energy Star program. “Congress should toss this Trump budget into the dustbin of history like they’ve done with the other ones,” said former EPA Administrator Gina McCarthy, who is now head of the Natural Resources Defense Council.

This is false economy. It endangers the American public and its air, land, water, and biodiversity. EPA is responsible for enforcing the Safe Drinking Water Act, with a goal of making the nation’s waters fishable and swimmable. EPA enforces the Clean Air Act, which has cleaned up American cities, reducing illness and property damage from smog. And EPA is responsible for overseeing the clean-up of contaminated sites, thus preventing further pollution and illness. The agency also regulates pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

All of EPA’s programs require the application of science to public policy.

EPA has been plagued with budget constraints for many years, but now, with such drastic cuts, programs spearheaded by EPA to protect air, water, people, and wildlife from toxic pollution will suffer–a goal made clear by the Trump Administration. Eliminating resources needed to prevent problems means that more money will need to be spent repairing damage and treating disease.

EPA plays a critical role in reviewing science and implementing laws protecting human health and the environment. Science itself has been under attack by the Trump Administration, as evidenced by its issuance of scientific grant and hiring freezes at EPA and other agencies nationwide, along with a ban on science communications through social media platforms.

Please support a budget that fully funds scientific research and environmental protection programs.

Sincerely,

02/10/2020 — Save the National Environmental Policy Act (NEPA)

Through the publication of Rachel Carson’s Silent Spring, pesticide dangers became a major driver for the environmental movement. Perhaps the most effective piece of environmental legislation is the National Environmental Policy Act (NEPA). Because NEPA requires a wide-ranging evaluation of the potential environmental impacts of federal actions, as well as alternatives, it serves as a model for environmental decision making. Now key elements of NEPA are under attack by the Trump Administration.

Ask your Congressional Representatives to pressure the White House to retract the proposed changes. At the same time, add your signature to the Beyond Pesticides public comment to Council on Environmental Quality (CEQ).

NEPA established the Council on Environmental Quality (CEQ) as the agency within the White House that is responsible for carrying out the purposes of the act. The regulations established by the CEQ have persisted through changes in administrations for more than 30 years without major modification. Changes proposed by the Trump Administration’s CEQ threaten this model decision-making process.

NEPA is a procedural law. It sets no environmental standards, but sets a standard for evaluating environmental impacts of proposed federal actions. It requires that federal agencies consider the short-term, long-term, and cumulative impacts of actions and disclose them to the public. Courts have ruled, for example, that registration of a pesticide by EPA is not sufficient to address environmental concerns under NEPA.

The Trump CEQ proposal will weaken NEPA regulations in a number of ways:

  • It will limit the scope of required review to exclude from NEPA review non-federal projects with minimal federal funding or minimal federal involvement.
  • It will remove the requirement for cumulative impact analysis, an important component of NEPA review. This removes the examination of greenhouse gas emissions.
  • It advises agencies to evaluate the applicability of NEPA in a way that conflicts with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act.”
  • It defines the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant.”
  • It establishes tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments. While this may eliminate some wasted time, it also limits the depth of analysis.

Ask your Congressional Representatives to pressure the White House to retract the proposed changes. At the same time, add your signature to the Beyond Pesticides public comment to Council on Environmental Quality (CEQ).

Petition to CEQ

(Comment to CEQ that must be submitted to Regs.gov by March 10. https://www.regulations.gov docket number CEQ-2019-0003)

NEPA requires that federal agencies perform a comprehensive, cumulative, in-depth analysis of the environmental impacts of proposed federal actions and alternatives to them. NEPA establishes a standard of decision-making for all federal agencies. CEQ’s proposed changes to NEPA regulations are unacceptable and should be scrapped. They would:

*Unreasonably limit the scope of required review;

*Remove the requirement for cumulative impact analysis and the examination of greenhouse gas emissions;

*Conflict with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act;”

*Define the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant;” and

*Establish tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments, limiting the depth of analysis.

Thank you for your consideration.

Letter to Congress

I am writing to ask that you intervene with the Council on Environmental Quality to prevent the issuance of regulations that would weaken environmental decision making.

Through the publication of Rachel Carson’s Silent Spring, pesticide dangers became a major driver for the environmental movement. Perhaps the most effective piece of environmental legislation is the National Environmental Policy Act (NEPA). Because NEPA requires a wide-ranging evaluation of the potential environmental impacts of federal actions, as well as alternatives, it serves as a model for environmental decision making. Now key elements of NEPA are under attack by the Trump Administration.

NEPA established the Council on Environmental Quality (CEQ) as the agency within the White House that is responsible for carrying out the purposes of the act. The regulations established by the CEQ have persisted through changes in administrations for more than 30 years without major modification. Changes proposed by the Trump Administration’s CEQ threaten this model decision-making process.

NEPA is a procedural law. It sets no environmental standards, but sets a standard for evaluating environmental impacts of proposed federal actions. It requires that federal agencies consider the short-term, long-term, and cumulative impacts of actions and disclose them to the public. Courts have ruled, for example, that registration of a pesticide by EPA is not sufficient to address environmental concerns under NEPA.

The Trump CEQ proposal will weaken NEPA regulations in a number of ways:

*It will limit the scope of required review to exclude from NEPA review non-federal projects with minimal federal funding or minimal federal involvement.

*It will remove the requirement for cumulative impact analysis, an important component of NEPA review. This removes the examination of greenhouse gas emissions.

*It advises agencies to evaluate the applicability of NEPA in a way that conflicts with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act.”

*It defines the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant.”

*It establishes tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments. While this may eliminate some wasted time, it also limits the depth of analysis.

Please tell the CEQ to revoke these proposed regulations.

Thank you.

02/03/2020 — Save Mayflies and the Ecosystems that Depend on Them

In more bad news from the insect world, recent research published in the Proceedings of the National Academy of Sciences reveals a precipitous decline in numbers of mayflies where they have been historically abundant. The research finds that in the Northern Mississippi River Basin, seasonal emergence of burrowing mayfly (genus Hexagenia) adults declined by 52% from 2012 to 2019; in the Western Lake Erie Basin, from 2015 to 2019, the reduction was a shocking 84%. Neonicotinoid insecticides are a significant factor in this decline because mayflies are extremely vulnerable to their impacts, even at very low exposure levels.

Ask Congress to tell EPA, USDA, and the Department of Interior to develop a joint effort to ensure that its decisions and compliance with its authorizing statutes address the crisis of the threat to mayflies.

Ephemeroptera to entomologists—“mayflies” to the rest of us—is an insect order comprising keystone species, on which other species in an ecosystem are very dependent, and without which, the ecosystem would undergo drastic change. The plummeting mayfly “count” is especially alarming because mayflies are a critical, primary food source in aquatic and terrestrial ecosystems, and provide an important ecological service. As the research study notes, “Seasonal animal movement among disparate habitats is a fundamental mechanism by which energy, nutrients, and biomass are transported across ecotones. A dramatic example of such exchange is the annual emergence of mayfly swarms from freshwater benthic [lake or river bottom] habitats. . . . Annual . . . emergences represent the exchange of hundreds of tons of elemental nutrients, thousands of tons of biomass, billions of organisms, and trillions of calories worth of energy to the surrounding terrestrial habitat. . . . A single emergence event can produce 87.9 billion mayflies, releasing 3,078.6 tons of biomass into the airspace over several hours.” According to Purdue University ecologist Jason Hoverman, PhD, “Mayflies serve critical functions in both aquatic and terrestrial ecosystems. Because of their important role as prey, reductions in their abundance can have cascading effects on consumers throughout the food web.” Without this critical keystone species, an important food source and nutrient recycler would be lost.

Thus, although neonics are directly toxic to many insects, the role of pesticides in destabilization of ecosystems is not necessarily direct. Beyond direct toxicity, pesticides can significantly reduce, change the behavior of, or destroy populations of plants and animals. These effects can ripple up and down food chains, causing what is known as a trophic cascade. The loss or reduction of populations at any trophic level—including amphibians, insects, or plants—can result in changes that are difficult to perceive, but nonetheless equally damaging to the stability and long-term health of an ecosystem.

Three phenomena account for most of the decrease in mayfly populations: (1) dramatically increased use of neonicotinoid pesticides, to which mayflies are highly sensitive; (2) algal blooms, especially in Lake Erie, caused primarily by runoff of agricultural fertilizers and other nutrient-dense pollutants; and (3) the warming impacts of the climate crisis, which include higher water temperatures that can wreak havoc with the development of these tiny creatures.

Because the threats to mayflies cut across regulatory boundaries, it is important for federal agencies to cooperate in protecting them. Action must be taken to protect vulnerable waterways from neonicotinoid contamination. The frequency of detections in U.S. waterways cannot be overlooked. Such routine detections, even at low levels, indicate that our waterways are being overloaded with mobile and persistent chemicals at highly elevated concentrations.  Thus far, little action has been taken to restrict the use of these chemicals in response to the independent scientific literature and EPA risk data that identify direct threats to aquatic invertebrates, as well as indirect threats to higher trophic organisms. Federal benchmarks based on testing on insensitive species are not protective of more sensitive species. Similarly, action is needed to prevent runoff from agricultural fields and feedlots and adopt climate-friendly policies.

Ask Congress to tell EPA, USDA, and the Department of Interior to develop a joint effort to ensure that its decisions and compliance with its authorizing statutes address the crisis of the threat to mayflies.

Letter to Congress

I am writing to call your attention to a serious ecological problem that requires a coordinated effort across government agencies.

Recent research published in the Proceedings of the National Academy of Sciences reveals a precipitous decline in numbers of mayflies where they have been historically abundant. In the Northern Mississippi River Basin, seasonal emergence of burrowing mayfly adults declined by 52% from 2012 to 2019; in the Western Lake Erie Basin, from 2015 to 2019, the reduction was a shocking 84%.

The plummeting mayfly “count” is alarming because mayflies are a critical, primary food source in aquatic and terrestrial ecosystems, and provide an important ecological service. As the research study notes, “Seasonal animal movement among disparate habitats is a fundamental mechanism by which energy, nutrients, and biomass are transported across ecotones…A single emergence event can produce 87.9 billion mayflies, releasing 3,078.6 tons of biomass into the airspace over several hours.”

According to Purdue University ecologist Jason Hoverman, PhD, “Mayflies serve critical functions in both aquatic and terrestrial ecosystems. Because of their important role as prey, reductions in their abundance can have cascading effects on consumers throughout the food web.” Without these critical keystone species, important food sources and nutrient recyclers would be lost.

Three phenomena account for most of the decrease in mayfly populations: (1) dramatically increased use of neonicotinoid pesticides, to which mayflies are highly sensitive; (2) algal blooms, especially in Lake Erie, caused primarily by runoff of agricultural fertilizers and other nutrient-dense pollutants; and (3) the warming impacts of the climate crisis, which include higher water temperatures that can wreak havoc with the development of these tiny creatures.

Because threats cut across regulatory boundaries, it is important for federal agencies to cooperate in protecting mayflies. U.S. waterways are being overloaded with mobile and persistent chemicals at highly elevated concentrations.  Little action has been taken to restrict the use of toxic chemicals despite independent scientific literature and EPA risk data that identify direct threats to aquatic invertebrates, as well as indirect threats to higher trophic organisms. Similarly, action is needed to prevent runoff from agricultural fields and feedlots and adopt climate-friendly policies.

Thank you,

01/27/2020 — Insist that the Veterans Administration Cover Conditions Caused by Agent Orange

United States military veterans suffering from bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms after their exposure to Agent Orange will remain unprotected and uncompensated until at least late 2020, according to a letter sent by Veterans Affairs (VA) Secretary Robert Wilkie to U.S. Senator Jon Tester (D-MT).

Send a letter to Veterans Affairs (VA) Secretary Robert Wilkie insisting that bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms be added to the VA’s list of eligible conditions.

Congress included a provision in the must-pass December federal spending bill requiring VA to provide legislators “a detailed explanation” for the now multi-year delay in determining whether to list the diseases. The provision is intended to cut through the ongoing delays, but there is no indication VA is going to meet the 30-day deadline. “The longer VA continues to drag its feet on expanding the list of conditions associated with Agent Orange, the longer our veterans continue to suffer—and die—as a result of their exposure,” Senator Tester said in a statement to the news site Connecting Vets. He continued, “It’s time for VA to stop ignoring the overwhelming evidence put forth by scientists, medical experts and veterans and do right by those who served. Any prolonging of their suffering is unacceptable.” 

The delay is seen by advocates for veterans as a serious lack of support and compensation at a time when the current administration is mobilizing the military. In October 2019, U.S. Senator Sherrod Brown’s (D-OH) attempt to introduce a resolution requiring the Trump Administration’s VA to list the diseases was shot down by U.S. Senate Veterans Affairs Committee Chairman Johnny Isakson (R-GA), citing costs. Rick Weidman, legislative director of Vietnam Veterans for America, summed up his response to ProPublica, “If you can afford the goddamn war, you can afford to take care of the warriors.”

“Some might accuse this body that we are waiting for them to die, as hard as it is to say that,” Sen. Brown said on the Senate floor. He continued, “Veterans shouldn’t have to fight this one at a time … we did this to them. The American government decided to spray Agent Orange. We knew it was harmful.”

According to Military Times, 83,000 veterans suffer from bladder cancer, Parkinson’s-like symptoms or hypothyroidism, and an untold number have high blood pressure. It is imperative that soldiers who fight for their country know they will be compensated when they fall ill as a result of their service.

Agent Orange, given its name because it was stored in orange striped drums, contained the active ingredients 2,4-D and 2,4,5-T. This formulation was contaminated with the highly toxic 2,3,7,8-tetrachlorodibenzo-p-dioxin (also called TCDD or simply dioxin) and is now banned. Not only were soldiers exposed on the battlefield, but many veterans who flew in post-Vietnam UC-123 Agent Orange spray aircraft had their health devastated by residual contamination.  

The Vietnam government is part of an ongoing lawsuit against Bayer’s Monsanto as the manufacturer of the deadly herbicide during the war. Recent reports find that dioxin continues to contaminate Vietnam’s soils, water, sediment, fish, aquatic species, and food supply.

While Agent Orange is banned, 2,4-D, which comprised one half of its make-up, is still one of the most widely used herbicides on lawns, school grounds, and parks today. It is considered a possible human carcinogen, and has been linked to liver damage and endocrine disruption in humans, in addition to being toxic to wildlife, pets and beneficial insects. Previous research from the U.S. Environmental Protection Agency has detected dioxin contamination in a number of 2,4-D herbicide products produced for consumer sale.

Send a letter to Veterans Affairs (VA) Secretary Robert Wilkie insisting that bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms be added to the VA’s list of eligible conditions.

Letter to Secretary Robert Wilkie

Dear Secretary Wilkie:

I am writing in support of United States military veterans suffering from bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms after their exposure to Agent Orange—who remain unprotected and uncompensated.

The VA continues to drag its feet on expanding the list of conditions associated with Agent Orange, and our veterans continue to suffer—and die—as a result of their exposure. As Senator Tester said, “It’s time for VA to stop ignoring the overwhelming evidence put forth by scientists, medical experts and veterans and do right by those who served. Any prolonging of their suffering is unacceptable.”

Your delay is evidence of a serious lack of support and compensation for veterans at a time when the current administration is mobilizing the military. Opponents of compensation cite costs, while others, like Rick Weidman, legislative director of Vietnam Veterans for America, say, “If you can afford the goddamn war, you can afford to take care of the warriors.”

“Some might accuse this body that we are waiting for them to die, as hard as it is to say that,” U.S. Senator Sherrod Brown said on the Senate floor. He continued, “Veterans shouldn’t have to fight this one at a time … we did this to them. The American government decided to spray Agent Orange. We knew it was harmful.” According to Military Times, 83,000 veterans suffer from bladder cancer, Parkinson’s-like symptoms or hypothyroidism, and an untold number have high blood pressure.

It is imperative that soldiers who fight for their country know they will be compensated when they fall ill as a result of their service. Please add bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms to the VA’s list of eligible conditions.

Thank you.

01/17/2020 — Send a Message to EPA: Do Your Job to Protect Health and the Environment

As news reports come in demonstrating the threats to major groups of organisms, such as insects and birds, and the stability of Earth's ecosystems, and scientists appeal for major policy changes, recent actions by the Environmental Protection Agency's Science Advisory Board highlight the need for public insistence that EPA do its job.

>>Tell EPA Administrator Andrew Wheeler to follow the advice of scientists and do his job. Tell your Congressional representatives to support scientific integrity at EPA and other agencies.

Although the influence of regulated corporations has historically silenced science that threatens profits–as shown by industry reaction to Rachel Carson's Silent Spring—attacks on science in federal agencies have increased in the Trump administration. EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. Now EPA's war on its own scientists has reached the point that its Science Advisory Board, which oversees the scientific integrity of the agency's regulation, posted letters on-line criticizing EPA's rollback of environmental protections. As reported in a front page story on January 1, 2020 by The New York Times, “A top panel of government-appointed scientists, many of them hand-selected by the Trump administration, said on Tuesday that three of President Trump's most far-reaching and scrutinized proposals to weaken major environmental regulations are at odds with established science.”

These most recent rollbacks involve protection of waterways, limitations on vehicle emissions, and use of scientific data to support health regulations. Without reliance on science, agency policies cannot fail to be arbitrary and capricious – the standard of irresponsibility in government. The Times quoted Patrick Parenteau, a professor of law with the Vermont Law School“The courts basically say if you're going to ignore the advice of your own experts you have to have really good reasons for that. And not just policy reasons but reasons that go to the merits of what the critiques are saying.”

>>Send a message to EPA Administrator Andrew Wheeler that he must do his job, as supported by the best available science.

Letter to EPA Administrator Wheeler:

As news reports come in demonstrating the threats to major groups of organisms, and the stability of Earth’s ecosystems, and as international scientists appeal for major policy changes, action by the Environmental Protection Agency (EPA) to protect biodiversity and ecosystem integrity has never been more critical. Recent actions by the EPA’s Science Advisory Board highlight the need for public insistence that the agency do its job.

Under your leadership, EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. Now EPA’s own Science Advisory Board, which oversees the scientific integrity of the agency’s regulation, has posted letters on-line criticizing EPA’s rollback of environmental protections. As reported by The New York Times, “A top panel of government-appointed scientists, many of them hand-selected by the Trump administration, said on Tuesday that three of President Trump’s most far-reaching and scrutinized proposals to weaken major environmental regulations are at odds with established science.”

These most recent rollbacks involve protection of waterways, limitations on vehicle emissions, and use of scientific data to support health regulations. Without reliance on science, agency policies cannot fail to be arbitrary and capricious–the standard of irresponsibility in government. The Times quoted Patrick Parenteau, a professor of law with the Vermont Law School, “The courts basically say if you’re going to ignore the advice of your own experts you have to have really good reasons for that. And not just policy reasons but reasons that go to the merits of what the critiques are saying.”

It is time for you, as the Administrator of EPA, to listen to your own advisors and the best available science and act to preserve life on Earth.

Thank you.

Letter to Congressional Representatives and Senators:

I am writing to ask you to request EPA Administrator to follow the advice of agency scientists and do his job to protect human health and the living environment.

As news reports come in demonstrating the threats to major groups of organisms, and the stability of Earth’s ecosystems, and as international scientists appeal for major policy changes, action by the Environmental Protection Agency to protect biodiversity and ecosystem integrity has never been more critical. Recent actions by the Environmental Protection Agency’s Science Advisory Board highlight the need for public insistence that EPA do its job.

Under the current administration, EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. Now EPA’s own Science Advisory Board, which oversees the scientific integrity of the agency’s regulation, has posted letters on-line criticizing EPA’s rollback of environmental protections. As reported in a front page story by The New York Times, “A top panel of government-appointed scientists, many of them hand-selected by the Trump administration, said on Tuesday that three of President Trump’s most far-reaching and scrutinized proposals to weaken major environmental regulations are at odds with established science.”

These most recent rollbacks involve protection of waterways, limitations on vehicle emissions, and use of scientific data to support health regulations. Without reliance on science, agency policies cannot fail to be arbitrary and capricious–the standard of irresponsibility in government. The Times quoted Patrick Parenteau, a professor of law with the Vermont Law School, “The courts basically say if you’re going to ignore the advice of your own experts you have to have really good reasons for that. And not just policy reasons but reasons that go to the merits of what the critiques are saying.”

It is time for the Administrator of EPA to listen to his own advisors and the best available science and act to preserve life on Earth.

Thank you.

 

01/13/2020 — Take Action: Help Restore Protections for Migratory Birds

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

Ask your U.S. Representative to support and cosponsor the Migratory Bird Protection Act. Thank those who are already cosponsors.

Songbirds Threatened. The poisonous farm fields that migratory birds forage reduce their weight, delay their travel, and ultimately jeopardize their survival, according to “A neonicotinoid insecticide reduces fueling and delays migration in songbirds,“ published in the journal Science. Like their effects on insect pollinator populations, neonicotinoid insecticides generally do not cause acute poisoning and immediate death, but instead precipitate a cascade of sublethal impacts reducing their fitness in the wild. As the authors told Environmental Health News, the study is a call not simply to ban neonics or one class of chemical, but to change the entire farming system toward more sustainable bird and bee-friendly practices.

Bird Habitat Threatened in Arkansas. A citizen science monitoring project of Audubon Arkansas found evidence of contamination from the weed killer dicamba far from the genetically engineered soybean and cotton fields, documenting nearly 250 observations of dicamba symptomology across 17 Arkansas counties. Community scientists were trained by Audubon to detect dicamba symptoms. Dan Scheiman, PhD, bird conservation director for the organization, after launching the project this spring, said, “Spraying dicamba on millions of acres of soybean and cotton is an uncontrolled experiment that puts sensitive habitats at unacceptable risk. In a landscape full of genetically engineered crops, the atmospheric build-up of volatized dicamba may result in significant damage to our state natural areas, wildlife management areas, national wildlife refuges, family farms, and the wildlife they harbor.”

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit. The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials use the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines, and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.

Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

On January 8, U.S. Representative Alan Lowenthal and 18 bipartisan cosponsors introduced the Migratory Bird Protection Act (H.R. 5552) to restore the critical protections removed by the Trump Administration.

Ask your U.S. Representative to support and cosponsor the Migratory Bird Protection Act. Thank those who are already cosponsors.

Letter to request cosponsorship

I am writing to ask you to restore important protections for migratory birds by cosponsoring H.R. 5552, the Migratory Bird Protection Act.

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

Songbirds Threatened: The poisonous farm fields that migratory birds forage reduce their weight, delay their travel, and ultimately jeopardize their survival, according to “A neonicotinoid insecticide reduces fueling and delays migration in songbirds,“ published in the journal Science. Like their effects on insect pollinator populations, neonicotinoid insecticides generally do not cause acute poisoning and immediate death, but instead precipitate a cascade of sublethal impacts reducing their fitness in the wild. As the authors told Environmental Health News, the study is a call not simply to ban neonics or one class of chemical, but to change the entire farming system toward more sustainable bird and bee-friendly practices.

Bird Habitat Threatened in Arkansas: A citizen science monitoring project of Audubon Arkansas found evidence of contamination from the weed killer dicamba far from the genetically engineered soybean and cotton fields, documenting nearly 250 observations of dicamba symptomology across 17 Arkansas counties. Community scientists were trained by Audubon to detect dicamba symptoms. Dan Scheiman, PhD, bird conservation director for the organization, after launching the project this spring, said, “Spraying dicamba on millions of acres of soybean and cotton is an uncontrolled experiment that puts sensitive habitats at unacceptable risk. In a landscape full of genetically engineered crops, the atmospheric build-up of volatized dicamba may result in significant damage to our state natural areas, wildlife management areas, national wildlife refuges, family farms, and the wildlife they harbor.”

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit. The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials used the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.
Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

Please cosponsor the Migratory Bird Protection Act (H.R. 5552) introduced by Representative Alan Lowenthal and 18 bipartisan cosponsors to restore the critical protections removed by the Trump Administration.

Letter to current cosponsors

I am writing to thank you for cosponsoring H.R. 5552, the Migratory Bird Protection Act.

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit.  The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials used the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.

Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

Thank you for cosponsoring H.R. 5552, the Migratory Bird Protection Act.

01/06/2020 — End Factory Farms: Support the Farm System Reform Act

In the midst of recalls of romaine lettuce contaminated with a pathogenic strain of E. coli, states and counties across the country are calling for a moratorium on large confined animal feeding operations (CAFOs). Now Senator Cory Booker is seeking to pass similar legislation at the national level. These industrial-scale operations are commonly referred to as “factory farms.”

>>Tell your U.S. Senator to cosponsor the Farm System Reform Act.

In the last week of November 2019, the Centers for Disease Control and Prevention (CDC) issued a food safety alert concerning a multistate outbreak of E. coli linked to romaine lettuce harvested from Salinas, California. As of November 25, 67 cases had been reported across 19 states, 39 of which required hospitalization, including six who developed kidney failure. The E. coli strain causing the outbreak — O157:H7, also known as STEC — is genetically identical to that responsible for lettuce-related outbreaks in 2017 and 2018. STEC is a dangerous, Shiga toxin-producing type of E. coli. Other outbreaks occurred earlier in 2019 as well.

Dangerous strains of E. coli, including O157:H7, are typically associated with cattle in feedlot conditions. The first of the two outbreaks in 2018 was traced back to manure runoff from a CAFO in the vicinity of the lettuce farm, which polluted water that was used to irrigate the lettuce fields. CAFOs are a major source of water contamination throughout the U.S. As noted by the Arizona Department of Environmental Quality"Nationwide and in Arizona, the potential for surface and ground water pollution exists through livestock facility discharge of manure-contaminated run off to natural waterways and through wastewater leaching to aquifers. Water and air pollution lead the list of concerns that have led to a number of state and local initiatives to institute moratoria on new and expanded CAFOs. Iowa, which has experienced an explosion of CAFOs, is the example these people want to avoid. In South Dakota, Lyle Reimnitz, who lives a half-mile from a Davison County hog farm with a permit for 8,000 sows, says, “I don't want to see South Dakota become another Iowa,” he said. “We don't need all our rivers and streams polluted. I know everybody wants cheap meat, but that comes at a terrible price for people who live here.”

In Wisconsin, supporters of a statewide moratorium on CAFOs are urging concerned citizens to ask County Supervisors, Town Board Members, and City Councilors to pass resolutions supporting a state-wide CAFO moratorium. In California, a report on dairy CAFOs found that “major production externalities are still imposed upon the communities in which Concentrated Animal Feeding Operations (CAFOs) are located, due in large part to lack of resources, information, enforcement capability and political will on the part of local and regional regulatory agencies.” And, in Indiana, a report by the Indiana Business Research Center found, “For town residential properties, having the closest RLO [regulated livestock operation, or CAFO] upwind of the residence reduced the sale price by $4,980.00 and if the closest RLO contained dairy cattle, the sale price was further reduced by $32,340.00 for every 100 mature head.” In addition to these concerned citizens, the American Public Health Association has also called for a moratorium on CAFOs.

A majority of Americans say they want more stringent oversight of large-scale livestock operations, according to a national poll by Johns Hopkins University's Center for a Livable Future released December 10, 2019.

Traditional family farmers, and groups like the National Farmers Union, favor judicious regulatory controls due to the overall deleterious impacts these industrial agricultural sites have on rural communities. Other impacts include odors and fugitive dust that might contain antibiotic-resistant organisms.

Senator Booker's bill, the Farm System Reform Act, would require that "corporate integrators" are "responsible for pollution and other harm caused by CAFOs,” which would be phased out by 2040.  

>>Tell your U.S. Senator to cosponsor the Farm System Reform Act.

Letter to Congress

I am writing to ask you to cosponsor the Farm System Reform Act, unveiled by Senator Cory Booker in December.

In the midst of recalls of romaine lettuce contaminated with a pathogenic strain of E. coli, states and counties across the country are calling for a moratorium on large confined animal feeding operations (CAFOs). Sen. Booker’s bill seeks a moratorium at the national level.

In the last week of November 2019, the Centers for Disease Control and Prevention (CDC) issued a food safety alert concerning a multistate outbreak of E. coli linked to romaine lettuce harvested from Salinas, California. As of November 25, 67 cases had been reported across 19 states, 39 of which required hospitalization, including six who developed kidney failure. The E. coli strain causing the outbreak — O157:H7, also known as STEC — is genetically identical to that responsible for lettuce-related outbreaks in 2017 and 2018. STEC is a dangerous, Shiga toxin-producing type of E. coli. Other outbreaks occurred earlier in 2019 as well.

E. coli O157:H7 is typically associated with cattle. The first of the two outbreaks in 2018 was traced back to manure runoff from a CAFO in the vicinity of the lettuce farm, which polluted water that was used to irrigate the lettuce fields. CAFOs are a major source of water contamination throughout the U.S. As noted by the Arizona Department of Environmental Quality, “Nationwide and in Arizona, the potential for surface and ground water pollution exists through livestock facility discharge of manure-contaminated run off to natural waterways and through wastewater leaching to aquifers.”

Water and air pollution lead the list of concerns that have led to a number of state and local initiatives to institute moratoria on new and expanded CAFOs. Iowa, which has experienced an explosion of CAFOs, is the example these people want to avoid. In South Dakota, Lyle Reimnitz, who lives a half-mile from a Davison County hog farm with a permit for 8,000 sows, says, “I don’t want to see South Dakota become another Iowa,” he said. “We don’t need all our rivers and streams polluted. I know everybody wants cheap meat, but that comes at a terrible price for people who live here.”

In Wisconsin, supporters of a statewide moratorium on CAFOs are urging concerned citizens to ask County Supervisors, Town Board Members, and City Councillors to pass resolutions supporting a state-wide CAFO moratorium. In California, a report on dairy CAFOs found that “major production externalities are still imposed upon the communities in which Concentrated Animal Feeding Operations (CAFOs) are located, due in large part to lack of resources, information, enforcement capability and political will on the part of local and regional regulatory agencies.” In Indiana, a report by the Indiana Business Research Center found, “For town residential properties, having the closest RLO [regulated livestock operation, or CAFO] upwind of the residence reduced the sale price by $4,980.00 and if the closest RLO contained dairy cattle, the sale price was further reduced by $32,340.00 for every 100 mature head.” In addition to these concerned citizens, the American Public Health Association has also called for a moratorium on CAFOs.

A majority of Americans say they want more stringent oversight of large-scale livestock operations, according to a national poll by Johns Hopkins University’s Center for a Livable Future released December 10, 2019.

Please cosponsor Senator Booker’s bill, the Farm System Reform Act, which would require that “corporate integrators” are “responsible for pollution and other harm caused by CAFOs” and phase them out by 2040.

Thank you.

 

01/02/2020 — The National Organic Program Must Defend Biodiversity

Beyond Pesticides

An unintended consequence of the National Organic Standards, the rules that govern certified organic agricultural production, actually provides an incentive for the conversion of critical ecosystems to organic cropland, fueling deforestation and biodiversity loss.

>> Tell the National Organic Program to issue regulations that will prevent the conversion of native ecosystems to organic cropland.

One National Organic Program (NOP) requirement for organic certification—a three-year waiting period during which land must be free of disallowed substances—encourages the conversion of critical ecosystems, which do not require the three-year waiting period.

Conversions of native landscapes to working organic land to date include losses of: a California forest, Colorado prairies, a New Mexico wetland, and native sagebrush lands in Washington and Oregon. The Wild Farm Alliance, which provides critical leadership on the issue, points out, “These areas, that were once delivering critical ecosystem services and providing essential habitat for wildlife, are no longer performing the same functions and [it] would take hundreds of years to reverse the damage.”

The National Organic Standards Board (NOSB), which is responsible for advising the U.S. Department of Agriculture (USDA) on implementation of the Organic Foods Production Act (OFPA), has been studying this problem since 2009, ultimately resulting in a 2018 recommendation. Beyond Pesticides commented on the proposal, “Despite efforts of organic farmers to build and protect biodiversity, it is unlikely that the organic farm will achieve the same level of biodiversity and ecological resilience as the original ecosystem. On the other hand, the conversion of conventional, chemical-intensive agriculture to organic agriculture provides huge benefits to biodiversity through both the absence of toxic inputs and positive measures to increase biodiversity in soil-based systems that are required by OFPA or its regulations. Therefore, Beyond Pesticides supports efforts by the NOSB to eliminate incentives to convert high-value native land to organic production, as well as to increase incentives to convert chemical-intensive farmland to organic production.”

In May 2018, the NOSB approved (nearly unanimously) the revised, formal Eliminating the Incentive to Convert Native Ecosystems to Organic Production recommendation. Typically, once the NOSB has made a recommendation, NOP puts it on the rulemaking agenda, develops a rule proposal on the basis of the recommendation, solicits public comment, and then develops a final rule. Yet, NOP has taken no action to bring the recommendation into its rulemaking process. Public pressure on USDA is needed to persuade NOP to “do its duty” and bring the NOSB recommendation forward to the rulemaking agenda.

>> Tell the National Organic Program to issue regulations that will prevent the conversion of native ecosystems to organic cropland.

Letter to USDA

I am very concerned about the failure of the National Organic Program to protect native ecosystems by implementing the NOSB recommendation “Eliminating the Incentive to Convert Native Ecosystems to Organic Production.”

Conversions of native landscapes to working organic land to date include losses of: a California forest, Colorado prairies, a New Mexico wetland, and native sagebrush lands in Washington and Oregon. The Wild Farm Alliance points out, “These areas, that were once delivering critical ecosystem services and providing essential habitat for wildlife, are no longer performing the same functions and [it] would take hundreds of years to reverse the damage.”

Despite efforts of organic farmers to build and protect biodiversity, it is unlikely that the organic farm will achieve the same level of biodiversity and ecological resilience as the original ecosystem. On the other hand, the conversion of conventional, chemical-intensive agriculture to organic agriculture provides huge benefits to biodiversity through both the absence of toxic inputs and positive measures to increase biodiversity in soil-based systems that are required by the Organic Foods Production Act and its regulations.

The NOSB recommended nearly unanimously that NOP should adopt regulations to define “native ecosystems” more specifically and require a 10-year waiting period before such land can be converted into organic cropland. With the crisis in loss of biodiversity that we are experiencing, it is important that organic producers lead the way in protecting the diversity of life.

Please initiate regulations eliminating incentives to convert native ecosystems to organic production as soon as possible.

Thank you.