Forget about single-pesticide issues: this affects every single one of them. EPA is allowing massive data gaps to persist for each and every pesticide product it registers by conducting the bulk of its health and environmental risk assessments using active ingredients alone. With its current practices, EPA is failing its federal mandate to protect public health and the environment and misleading the public about what is “safe.”
When pesticides are sprayed on our crops, lawns, and roadsides, and enter into our waterways, groundwater and drinking water, we are exposed to whole formulations, whole tank mixtures, and whole pesticide combinations, not just active ingredients (those that the manufacturer claims are the only ingredients that attack the target pest). It is the whole formulation that makes the poison, and that whole formulation must be regulated.
Active ingredients are far from the whole story of pesticide poisoning. Despite their name, “inert” ingredients are very often not chemically, biologically, nor toxicologically inert or innocuous. According to a peer-reviewed study, as of 2006, more than 500 ingredients that were listed as “inert” in some products serve as the active ingredient in other products. Many “inert” ingredients are known to state, federal, and international agencies to be hazardous to human health. One of the most hazardous ingredients in common formulations of the popular herbicide Roundup is a surfactant, which is classified as an “inert,” and therefore not listed on the label. A 2013 study found that some Roundup adjuvants are 9,661 times more toxic to human cells than the active ingredient glyphosate. The real threats of herbicides, fungicides, and insecticides are masked when EPA only tests active ingredients.
Synergy between ingredients adds yet another layer to the stack of untested threats. Ingredients added to formulations are specifically selected for their ability to make the active ingredient more potent, yet these effects are ignored in the vast majority of EPA-required testing. A 2016 Center for Biological Diversity (CBD) Investigative report found that 69% of recently approved pesticide patent applications claimed or demonstrated synergy between ingredients in the product.
Based on EPA's current policies, the agency does not require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor do they require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.
To put it another way: EPA has no idea whether the pesticide products it registers and claims pose an “acceptable risk” could cause cancer, chronic disease, developmental delays, or infertility. EPA has no idea whether the pesticide products it registers could harm or kill birds, fish, aquatic invertebrates, or honey bees. These data gaps are alarming and unacceptable, and a misinterpretation of the law.
>> Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients.