The Biden EPA Must Change Pesticide Regulation

The Trump Environmental Protection Agency (EPA) reversed in four years much of the progress made by EPA in decades, and that push continues. The Biden EPA needs to advance a new vision.

>>Tell President-elect Biden to adopt a new direction for pesticide regulation.

Challenge so-called “benefits” of pesticides.
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. Claimed “benefits” for toxic pesticides need to be judged in comparison to organic production, which is able to produce all types of food and feed. The Organic Trade Association reports that organic sales now exceed $55 billion per year, and the U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $9.9 billion worth of organic food on 5.5 million acres in 2019. EPA assumes benefits of pesticides, rather than measuring them, and does not take into account the development of resistance. The cost-competitive success of organic food production and nonagricultural land management practices make the case that toxic pesticides lack benefits.

Protect pollinators.
Agriculture relies on insect pollinators to facilitate fertilization and maintain annual crop yield. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet many agricultural pesticides are killing pollinators outright, making them more susceptible to parasites and disease, and destroying their habitat. Pollinator protection should be a priority of EPA.

Protect workers.
Farmworkers are at greatest risk from pesticide exposure. A blatant example of systemic racism is imbedded in risk assessments in environmental regulation. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. For example, EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—and such exposures routinely occur to fenceline communities, farmworkers, and factory workers.

Protect biodiversity.
Roughly a quarter of the global insect population has been wiped out since 1990, according to research published in the journal Science. Monarchs are near extinction and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies, the foundation of so many food chains, and fireflies, the foundation of so many childhood summer memories, for reasons that can be easily prevented with leadership in regulating pesticides. It is likely that the declines we are seeing in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, has been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. Amphibians are also particularly at risk. A new biological evaluation by EPA finds that the widely used weed killer glyphosate/Roundup threatens nearly every animal and plant species on the U.S. list of threatened and endangered species — 93% of them, in fact. This, on top of its cancer-causing properties, supports urgent action to ban the herbicide along with others that destroy habitat and replace them with organic practices and organic compatible products.

Get rid of endocrine-disrupting pesticides.
Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson's, Alzheimer's, and childhood and adult cancers. In 1998, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 21 years, the Endocrine Disruptor Screening Program (EDSP) has made little progress in reviewing and regulating endocrine-disrupting pesticides. Now the program has stalled entirely.

To ensure appropriate follow-through, Congress gave EPA a timeline to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. It started a screening program (Tier 1) and reported results in 2009. According to EPA, Tier 1 Screening (which looks at high exposure chemicals) is not sufficient to implicate a chemical as an endocrine disrupting chemical. It is instead a step to define which chemicals must undergo Tier 2 testing – the only stage that can influence regulatory decision-making. It is unclear when or how EPA will move forward with Tier 2 testing, and how, if at all, any Tier 2 findings will be used to inform actual regulation.

Get rid of neurotoxic pesticides that harm children.
The target of action by which many pesticides kill is the nervous system. It is not surprising, then, that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides (relative to their body weight) than adults, and whose developing organ systems are typically more sensitive to toxic exposures.

The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child's neurological, respiratory, immune, and endocrine system, even at low exposure levels. Several pesticide families, such as synthetic pyrethroids, organophosphates, and carbamates, are also known to cause or exacerbate respiratory symptoms like asthma. The American Academy of Pediatrics wrote, “Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.”

And yet the Trump EPA has refused to ban the extremely neurotoxic insecticide chlorpyrifos—an action that was begun during the waning days of the Obama administration. Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA's action to allow its continued use a failure of both its protective mission and ethics. Further, it is an environmental justice failure, given that risks of exposure fall disproportionately on low-income African American and Latino families, including farmworker families, who are at the greatest risk of harm. The ban on chlorpyrifos will be an important first step in eliminating neurotoxic pesticides.

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Dear [Elected Official],

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I am writing to offer suggestions for priority policies and actions for your incoming EPA, in the area of pesticide regulation. Pesticide regulation needs a change of direction.

1. Challenge so-called “benefits” of pesticides. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. The standard for claimed “benefits” for toxic pesticides organic production. USDA finds that organic producers in the U.S. produced $9.9 billion worth of organic food in 2019. EPA assumes benefits, rather than measuring them, and does not take into account the development of resistance.

2. Protect pollinators. Agriculture relies on insect pollinators for fertilization and annual crop yields. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet many agricultural pesticides kill pollinators outright, make them more susceptible to parasites and disease, and destroy their habitat.

3. Protect workers. Farmworkers are at greatest risk from pesticide exposure. Systemic racism is imbedded in environmental risk assessments. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers,  people of color, and those with preexisting health conditions or comorbidities. EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA excludes worker exposure. Risk assessments do not include exposures to multiple chemicals—that routinely occur to fenceline communities, farmworkers, and factory workers.

4. Protect biodiversity. Roughly a quarter of the global insect population has been wiped out since 1990. It is likely that declines in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance,  have been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. EPA finds that the widely used weed killer glyphosate/Roundup threatens 93% of animal and plant species on the U.S. list of threatened and endangered species. This, on top of its cancer-causing properties, supports a ban on the herbicide along with others that destroy habitat.

5. Get rid of endocrine-disrupting pesticides. Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. EPA is stalled and ignoring its responsibility.

6. Get rid of neurotoxic pesticides that harm children. The target of action by which many pesticides kill is the nervous system. It is not surprising, then that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides (relative to their body weight) than adults, and whose developing organ systems are typically more sensitive to toxic exposures.

And yet, the Trump EPA has refused to complete the ban of the extremely neurotoxic insecticide chlorpyrifos that was begun during the Obama administration. Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA’s action to allow its continued use a failure of its mission and an environmental justice, since risks of fall disproportionately on low-income African American and Latino families. The ban on chlorpyrifos will be an important first step in eliminating neurotoxic pesticides.

Under your leadership, a revitalized EPA will take our nation in a new direction—one that requires the agency to think holistically, shift away from petroleum-based pesticides, and fertilizers, and embrace solutions that protect ecosystems that sustain all life.

Thank you.

Sincerely, [Your information here]