Posts Tagged ‘EPA’

Pesticide Fear Mongering continues on social media

Two headlines are traveling the social media circuit recently that continue to use non-scientific evaluations of pesticide use to try to shape the cultural myth that pesticides are inherently bad for everyone. The first one is the continued publication by the Environmental Working Group (EWG) of their so called Dirty Dozen list, a list that supposedly warns consumers of the produce with the highest pesticide residues. This list has been debunked by peer reviewed analysis to show that the methodology they use to rank the selected produce has no scientific backing. Even the very report the EWG says it uses to generate the data for their list, the USDA Pesticide Data Program (PDP,) states that the “… summary shows that, overall, pesticide residues found on foods tested are at levels below the tolerances set by the U.S. Environmental Protection Agency (EPA) and do not pose risk to consumers’ health. The U.S. Food and Drug Administration (FDA) has concluded that pesticide resi220px-Warning2Pesticidesdues pose no risk of concern for infants and children.” Nutritional experts continue to say that increasing the consumption of fruits and vegetable decreases the risk of heart disease, cancer, diabetes and obesity. This includes a recent study titled UCL study finds new evidence linking fruit and vegetable consumption with lower mortality. Studies have shown that conventional and organic produce have the same healthy outcomes for consumers. Why does the EWG continue to scare consumers away from healthy food choices? Because it fits the narrative they want to promote. They do not seem to care that studies are finding that their scare tactic are doing more harm than good, especially for low income shoppers who have far few food choices than other income groups.

The second is an article titled “UN experts denounce ‘myth’- pesticides are necessary to feed the world” published by The Guardian and picked up by a number of anti-pesticide activist sites. This report is yet another “white paper” put out as a UN source that is nothing more than an opinion piece. It doesn’t even quote or review any of the official UN FAO or scientific literature from any UN committees. It continues in the same way as the EWG piece, to come to a conclusion first and work backwards, using cherry picked peer reviewed studies, to find information to justify the headline. In his evaluation of the article, David Zaruk, an EU science communication specialists writes “The “Pesticides are a myth” report has no authors and was submitted in the name of a rapporteur who has no experience in agriculture. And the Guardian published an article without any interest in analyzing its foundations or sources – just quotes the “UN report”. It doesn’t look at the FAO or basic science.” Lumping all pesticides and all farming types into a story trying to say that the benefits of pesticides are a “myth” just doesn’t explore in depth the vast literature available that is contrary to the thesis of the article. The article even draws conclusions that are contrary to the sources it cites. “It is a myth,” said Hilal Elver, the UN’s special rapporteur on the right to food. “Using more pesticides is nothing to do with getting rid of hunger. According to the UN Food and Agriculture Organization (FAO), we are able to feed 9 billion people today. Production is definitely increasing, but the problem is poverty, inequality and distribution.”
In a Facebook discussion digging into the articles references one commenter says, “Production is increasing because pesticides have enabled it. Their references don’t back their claims.” He then goes on to detail the conflicts in many of the cited reference and what the article is saying.

Fear of pesticides has been around a long time. Even before Racheal Carson’s “Silent Spring” people were questioning their wide spread use in farming. But questioning their use and using science to find out what the problems were and how to fix them has only strengthened the crop protection industry. Now trained professionals with expertise in Integrated Pest Management have the tools to carefully evaluate and choose the right crop protection product needed and have the information to evaluate and mediate health and environmental concerns. That knowledge is growing all the time. ‘Of course, there are always risks associated with using such chemicals, but the answer is to heavily regulate the industry and increase transparency, not to ban their use. The scientific evidence time and again demonstrates the benefits for using pesticides far outweighs the risks.’ – Professor Kathleen Lewis, Professor of Agricultural Chemistry at University of Hertfordshire’s Department of Human and Environmental Sciences (HES) and Research Leader for the Agriculture and Environment Research Unit (AERU). Crop protection tools are getting better all the time. They are becoming more environmentally friendly and safer for workers. New technologies are developing products that are more selective, targeting the pest and leaving other flora and fauna in our fields intact.

It is important for those in the agricultural industry to speak up and tell the truth about pesticides and their use so that the continued mantra of the “evil pesticide” is not the narrative that sticks in the minds of our consumers. People are susceptible to fear on topics they know very little about. Those of us that have the expertise on these matters should keep ourselves informed and be willing to engage people in conversations that will help educate and ease people’s fears. Acknowledge the reality of their fears and do not use scorn to put them down as that only further entrenches them in their position. Once you understand why they have the fears they do you can then empathize and tailor your response in a why they will be more accepting to the information.

Further reading:

Is Conventional Produce Dirty? No, But the Marketing Tactics Of Big Organic Are

Anti-Ag U.N. Report Written by Attorneys Argues for Big Ag

3 Reasons The EWG’s “Dirty Dozen” Is Still a Dirty Lie

The Perils of Anti-Pesticide Hysteria

For the Benefit of Consumers, It’s Time to Promote Positive, Reassuring Information

No, The UN Did Not Dismiss Pesticides as Unnecessary

Why Keep the E.P.A?

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On February 3, 2017 Rep. Matt Gaetz [R-FL-1] introduced a bill titled H.R.861 – To terminate the Environmental Protection Agency. There are certainly plenty of people, mainly business owners and some farmers, who are pretty fed up with the layers and layers of regulations and associated paperwork that keeps them from doing the work they want to be doing. Many farmers see some of the EPA’s regulation as vastly overreaching to the point of threatening to put them out of business. Rep. Gaetz wrote in a letter to colleagues about his bill stating that “Our small businesses cannot afford to cover the costs associated with compliance, too often leading to closed doors and unemployed Americans,” and that “It is time to take back our legislative power from the EPA and abolish it permanently.” I certainly do not deny that there are problems regarding how regulations affect people and businesses. The language Gaetz’s bill states that the EPA will terminate at the end of 2018. There seems to be no plan on what happens to all the laws the EPA is currently administrating. There is certainly a lot of uncertainty about the future of the EPA under the current administration. There are many reasons why we should keep the EPA. For a reminder, read Why We Need the EPA. My concern is what will happen to our crop protection industry if the EPA suddenly disappears?

The federal law that directly affects pesticide use is called the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). After World War II there was a sharp increase in chemical use in many industries, including farming. This act was passed back in 1947 and was enacted “to address the growing issue of potential environmental damage and biological health risks associated with such widespread use of insecticides”1. FIFRA’s basic function is to “govern the registration, distribution, sale, and use of pesticides in the United States2. The original act required anyone selling pesticides in interstate commerce to register them with the USDA and there was very little required to get a product registered.

In the early 1960’s after the break through publication of Rachael Carson’s book Silent Spring, many people became more aware of the problems pesticides were causing to the environment and potential hazard to human health as well. Many issues started to get noticed, not just environmental and threats to public health but also safety issues for agricultural workers. When the EPA was formed in 1970 the administration of FIFRA was moved to that agency.

Making sure that our crop protection products are safe and effective is an essential role that the EPA has for farmers. We need products that are proven to work, that they can be used safely by our workers and, also,  around our homes, since many of us live on our farms. dreamstime_xxl_83065129We need to make sure our products are safe for our consumers and that our land and water are safe for the future generation that we will be passing our farms down to, not to mention just being good stewards of the land in general. These are all goals that farmers and the EPA have in common. The data the EPA collects and reviews from registrants and the data that the agency produces through their own scientific reviews are essential in order to defend the use of products, easing fears made by those that make false claims of health and environmental harm, and justifying the need to stop using products that no longer fit the safety goals stated above. Without the science done at the EPA, crop protection products are at risk from lawsuits by groups trying to ban any pesticide use and new products that we need will not be able to get registration.

FIFRA does not mandate that the EPA should be the agency in charge of administering the act but it is uniquely qualified to do so. The program could be moved to the FDA or back to the USDA but those agencies are not set up to do the environmental science needed to evaluate crop protection products.  Since science being done on air, water and other areas the EPA regulates ties in closely to all aspects of farming, keeping the regulation of pesticides at the EPA would keep the science needed all under the same agency and allow for better communication and shared resources. If anything the EPA needs more funding, upgraded technology to do better toxicology screening faster, more scientists with the needed expertise and, hopefully, more with a background in crop protection and agriculture.

Another idea of getting the federal government out of what the EPA does and let the states run their own programs is also highly problematic. Now the EPA does the bulk of the work sifting through the data and approving product registration, safety and use regulations. Many states do look at the EPA registration packages and make changes for their local conditions but if each state had to do the entire task of registering a product the costs would be astronomical and the potential for conflicting regulations across state lines could make interstate commerce of crop protecrtion products unmanageable.

Science is the backbone of every aspect of agriculture. We rely on it for almost everything we do.  We should be working on making the EPA better at what they do, not getting rid of it entirely. The EPA has plenty of experience in place to continue to do the work we need in the area of crop protection products. Regulations should be based on sound science but not just when the regulations fall in our favor. We can’t defend sound science on one hand when we are trying to save a product under registration and throw it out when a regulation restricts us. A hearing held February 7th by the House Committee on Science, Space & Technology promised to focus on “Making the Environmental Protection Agency great again” got off on the wrong foot, in my opinion, when the committee chair Lamar Smith suggested that the agency had “relied on questionable science based on nonpublic information that could not be reproduced, a basic requirement of the scientific method” 3. Trying to label science you may not agree with as “questionable” in order to shape policy is what is being done and threatens to be the “nail in the coffin” for the EPA.

Limiting the type of science the EPA can use by suggesting they are using “questionable science” and not following the basics of the scientific method because it can’t be “reproduced” will limit the science needed by the EPA. Only using public information would greatly limit what science can be used or evaluated. Only using science that can be “reproduced” also limits science as it does not allow for scientists to look at changes in methodology or allow for other scientific designs to be used to study the same issue. Not all lab studies can be reproduced, especially if you are trying to transfer what you see in the lab to field conditions.

Weakening the EPA is not in our industry’s best interest. Changes in how regulations are made should be focused on using the science with local stakeholders to craft programs and best use practices to make sure all of the goals of safe farming for agriculture and the environment are met. We should be looking to strengthen EPA regional offices so that they have the staff and funds needed to work with local stakeholders. Legislation like the Wasteful EPA Programs Elimination Act4, introduced by Rep. Sam Johnson (R-Texas), calling for the closure all of the EPA’s regional offices is not the way forward. Focused, targeted, well thought out programs with input from all sides should be the way forward. People have lost trust that science is being used to make regulations that will benefit them. Only by working together and actually listening to each other can regulators and stakeholders rebuild trust in the system.

Footnotes

  1. History of the EPA.” Wikipedia. Accessed February 09, 2017. .
  2. Summary of the Federal Insecticide, Fungicide, and Rodenticide Act.” EPA. January 10, 2017. Accessed February 09, 2017. .
  3. Harvey, Chelsea. “The hearing was titled, ‘Making EPA great again.’ Scientists are afraid the opposite will happen.” The Washington Post. Accessed February 09, 2017.
  4. H.R.2111 – 114th Congress (2015-2016): Wasteful EPA Programs Elimination Act of 2015.” H.R.2111 – 114th Congress (2015-2016): Wasteful EPA Programs Elimination Act of 2015 | Congress.gov | Library of Congress. April 29, 2915. Accessed February 11, 2017.

The use of some toxic pesticides may be warranted.

Not all pesticides are created equal and some, as we all know, are more toxic than others. The EPA has been reviewing the data on many of the older pesticide categories for some time now and using new guidelines to determine if their uses are still safe.

One active ingredient that is going through this process is Chlorpyrifos. Because of its high mammalian toxicity it is getting a good review. The EPA has made some changes to how this product is being used with its first ruling back in 2000 eliminating all residential uses except for roach bait in protective bait stations. Then back in 2002 it banned the use of the product on tomatoes and made some further restrictions on its use on citrus, tree nuts and other crops. In 2012 the EPA limited the use of chlorpyrifos by lowering application rates and creating no-spray buffer zone requirements.

“Chlorpyrifos can cause cholinesterase inhibition in humans at high enough doses; that is, it can overstimulate the nervous system causing nausea, dizziness, confusion, and at very high exposures (e.g., accidents or major spills), respiratory paralysis and death.”1 Most of the issues with this product has been occupational exposures that applicators would experience and most of those concerns have been addressed through training and strict personal protective equipment requirements.

Why does keeping the use of this product matter for agriculture? Chlorpyrifos is used in corn and soybeans and, because of the large number of acres of these crops, these uses are the largest for this product. Many of these applications are seed treatments, but it is also used on fruits and nut trees, and a limited number of vegetable and row crops as well. Uses have already been restricted as a result of the EPA’s re-registration process. For example, on fruit trees and grapes, it can only be used during the dormant season and on citrus and vegetable crops the harvest intervals have been greatly increased. Most of the foliar application on crops are done because there are pests that are very difficult to control and this product happens to be one of a few that will work. Aphids on asparagus, broccoli, cabbage, and soybeans, as well as leaffooted plant bugs on almonds, are the most common needs for a foliar application I come across. Even though there are other products that can work to control these pests, the lack of products to rotate with means the loss of chlopyrifos runs the risk of developing resistance to those few products faster. “Matthew E. O’Neal, Iowa State University entomologist said when it comes to soybeans there should be some concern about what a chlopyrifos ban could mean in years to come. ‘My concern is if we get into a situation where we have a resistance to the other classes of insecticides used for aphids we’re going to need an alternative,’ he said. ‘Chlorpyrifos is commonly used by farmers for aphids and other pests in soybeans. If one class of insecticide replaces its uses in soybeans, this could increase the likelihood of resistance occurring. In four or five years that’s when you’d start to notice there are is no chlopyrifos and you’re looking for something that works.'”2 This warning holds true for the other critical uses as well. Without the use of chlopyrifos in asparagus for aphids those growers will have a hard time getting a crop to market as many other aphid control products are no longer effective on asparagus aphids.

Knowing that the EPA was reviewing the uses of chlopyrifos and that some concerns (which I will address later) had been brought up, University of California, California Department of Pesticide Regulation and industry stakeholders made a thorough assessment of the critical uses of chlopyrifos in some key crops grown in California and have made some recommendations on how to successfully manage the use of this product. The 198 page document reviews the key uses of chlorpyrifos in four key crops in the state. “The four crops represent $10 billion in annual revenue and cover 2.4 million acres of cropland. During the period of 2002-2012, 61% of the total chlorpyrifos use was recorded on these four crops.”3 The study pointed to an overall decrease in the use of chlorpyrifos with some years showing a slight increase, no doubt due to spikes in pest pressure. These spikes in the amount of product used has caused concern in some areas due to the human and environmental risks associated with chlorpyrifos. Note: since the CDPR report came out a new product to control aphids in alfalfa has been registered and the situation for that crop and chlorpyrifos use has improved.

The major cause for concern now is the previously identified drinking water issues and dealing with a petition from the Natural Resources Defense Council (NRDC) and Pesticide Action Network North America (PANNA). This is the petition the court has addressed in determining that the EPA timeline for evaluating the drinking water issue was not adequate. The EPA’s 2014 revised human health risk assessment confirmed a potential risk to drinking water in small watersheds near areas where chlorpyrifos is widely used. These small watersheds are generally less than 40 square miles and in small regions of the country. The examples are outlined in the revised risk assessment. 4 “The 2014 assessment included a refined drinking water assessment for the Pacific Northwest and the Southeast, but not the entire country. The EPA has determined that safe levels of chlorpyrifos may be exceeded for people whose drinking water is derived from certain vulnerable watersheds in parts of the United States.  the EPA is continuing to work on its refined regional drinking water assessment in order to identify those vulnerable watersheds.”5

Can the drinking water issues be addressed without banning all the uses for chlorpyrifos? Since the problem seems to be isolated to small watersheds near well-defined areas of high chlopyrifos use, it seems that other ways to mitigate the problems should be examined. The work published in the CDPR “Chlorpyrifos Critical Use” report shows that a well thought out approach to this problem is achievable. The report outlines uses to focus on and best use practices to hopefully reduce levels of chlopyrifos in surface water that are exceeding tolerances. Research and education are key components of the process. Farmers and those making pest control decisions need to be aware of the potential problems surrounding the use of chlorpyrifos and need to be willing to make decisions that will help keep the product out of local waterways. But in order for such an approach to work, all stakeholders involved must be on board and willing to follow best use practices.

California’s State Water Resources Control Board has surface water monitoring programs in place and have been monitoring water for a number of contaminants including, but not limited to, certain pesticides, such as chlorpyrifos. Their Irrigated Lands Regulatory Program has many years of data showing where contaminants have been found and at what levels. Data since 2006 has shown some improvements in surface water chlorpyrifos contamination but some areas are still showing exceedances, and some of those areas were not involved in the crops mentions in the DPR critical use program. More investigation and outreach seems to be needed.

So what does all this mean for the fate of chlorpyrifos? Unfortunately the regulatory process does not have a good track record for making policy based solely on scientific evidence, and there are many public groups that have very little patience with any attempt to develop programs that will keep pesticides they are not happy with in use. Research, data collection, programs, and outreach all take time and money. Budgets are tight ,and the number of people with expertise in these areas are declining, making resources available to work on these issues very tight. Public distrust of government regulators is on the rise at the same time government continues to cut budgets for the science needed to address these issues. EPA is forced to rely more and more on industry supplied data which increases the public distrust of the current system. The current public comment period for the proposal to revoke the tolerances for chlopyrifos will be over by the end of the year. Stakeholder groups on both sides of the issue are currently sending in their views on the matter. It would be nice to see a measured and thought out approach to making sure this product can still be used where it is needed come out of this process.

Footnotes
1. http://www2.epa.gov/ingredients-used-pesticide-products/chlorpyrifos
2. You’ll Still Have Pesticide Options If Lorsban’s AI is Banned – DTN
3. CDPR Critical Use Report
4. EPA’s revised human health risk assement for chlopyrifos
5. Proposal to Revoke Chlorpyrifos Food Residue Tolerances