Local and State Action in Response to Response to Changing TimesTenth  Annual  Conference  of  the  Pesticides  &  The  Chesapeake  Bay  Watershed  Project  Reisterstown, Maryland

Jay FeldmanBeyond PesticidesOctober 24, 2017

Rachel Carson’s landmark book, Silent Spring, published in 1962 –55 years ago, has provided us with guiding principles, an affirmation of core values, routed in scientific understanding of biological systems that are central to the sustainability of our environment and our very existence.

The Federal Pesticide Policy ContextRachel Carson55th Anniversary of Silent Spring

Complex Biological Systems

n “By their very nature, chemical controls are self-defeating, for they have been devised and applied without taking into account the complex biological systems against which they have been blindly hurled. The chemicals may have been pretested against a few individual species, but not against living communities.”

n “To assume that we must resign ourselves to turning our waterways into rivers of death is to follow the counsel of despair and defeatism. We must make wider use of alternative methods that are now known, and we must devote our ingenuity and resources to developing others.” –Rachel Carson, Silent Spring

Total studies 763 linking pesticide exposure to health outcomes:

359 studies on cancer107 studies on sexual and reproductive dysfunction102 studies on Parkinson’s disease87 studies on learning and developmental disorders33 studies on birth defects32 studies on asthma18 studies on diabetes12 studies on Alzheimer’s disease

Pesticide-Induced DiseasesDatabase

Increased risk for Non-Hodgkin’s lymphoma (NHL) for people exposed to common herbicides and fungicides, particularly the weedkiller mecoprop (MCPP). People exposed to glyphosate (found in Roundup®) are 2.7 times more likely to develop NHL.

Hardell, L., et al. 1999, J of the Am Cancer Societ

A population-based, case control study of Long Island, New York breast cancer cases finds an increased risk associated with: (a) lifetime residential pesticide use (b) application of lawn insecticides themselves.

Teitelbaum, S.L., et al. 2007. American Journal of Epidemiology

Key Studies

Cancer

Parkinson disease (PD) is a chronic, progressive neurological disease that is associated with a loss of dopaminergic neurons in the brain. The molecular mechanisms underlying the loss of these neurons still remain elusive. Oxidative stress is thought to play an important role in dopaminergic neurotoxicity. Environmental factors, such as neurotoxins, pesticides, insecticides, dopamine (DA) itself, and genetic mutations in PD-associated proteins contribute to mitochondrial dysfunction which precedes reactive oxygen species formation.

Blesa J, et al., 2015. Front Neuroanat

While oxidative stress is implicated in Parkinson's disease (PD), prolonged exposure to moderate dose of cypermethrin induces Parkinsonism

Tripathi P, et al. 2014. J Physiol Biochem.

Key Studies

Parkinson’s Disease

Exposures to pesticides at environmentally or occupationally relevant levels show significant associations between pesticide exposure and sperm parameters. A decrease in sperm concentration was the most commonly reported finding.

Martenies, et al., 2013, Toxicology

Evidence exist that atrazine exposure, even at levels below the U.S. EPA water quality standards, is associated with increased menstrual cycle irregularity, longer follicular phases, and decreased levels of menstrual cycle endocrine biomarkers of infertile ovulatory cycles.

Cragin et al., 2011, Environmental Research

Key Studies

Sexual and Reproductive Dysfunction

A cancer causing agent in humans, based on laboratory animal studies. (IARC Monographs Volume 112, 2015)

A review of the scientific literature links glyphosate to a wide range of diseases through a mechanism that modifies DNA functioning. (Samsel and Senoff,1 Journal of Biological Physics and Chemistry, 2016)

Study links chronic, ultra-low dose exposure to glyphosate in drinking water to adverse impacts on the health of liver and kidneys. (Mesnage et al., Environmental Health, 2015)

Key Studies

Glyphosate (Roundup)

Two commonly used neonicotinoid insecticides, thiamethoxam and clothianidin, adversely effect the reproductive ability of male honey bees and queen bees in managed and wild colonies.

Straub  et  al.,  2016,  Royal  Society  Publishing

Widespread neonicotinoid contamination, persistence, and impacts on wildlife.

Goulson, D. 2013. J Applied Ecology

Once in soil, neonicotinoids have a high propensity to leach into groundwater, streams, and ponds. For instance, one California study (2012) reports 89% of water samples taken from rivers, creeks, and drains in the state contain imidacloprid.

Starner, K et al. 2012. Bulletin of Environmental Contamination and Toxicology

Key Studies

Neonicotinoids

In the regulatory arena at the U.S. Environmental Protection Agency (EPA), alarms began to go off when the agency found in its 2017 risk assessment for the most widely used neonicotinoid, imidacloprid, that,

“[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates.”

USEPA.  2017.  Preliminary  Aquatic  Risk  Assessment  to  Support  the  Registration  Review  of  Imidacloprid.  Office  of  Chemical  Safety  and  Pollution  Prevention.  Washington  DC.

Regulatory Findings

Neonicotinoids

The agency evaluated an expanded universe of adverse effects data and finds that acute (short-term) and chronic (long-term) toxicity endpoints are lower (adverse effects beginning at 0.65 µg/L (micrograms per liter)-acute and 0.01 µg/L-chronic effects) than previously established aquatic life benchmarks (adverse effects from 34.5 µg/L-acute and 1.05µg/L-chronic effects). EPA finds risks from imidacloprid exposure to ecologically important organisms not previously evaluated as part of its regulatory review.

Yet, EPA describes its review process as requiring studies of the most sensitive organisms and a range of publicly available environmental laboratory and field studies.

(USEPA.  2017)  

Regulatory Findings

Neonicotinoids

According to EPA, foliar spray and a combination of application methods have “the greatest potential risks for aquatic invertebrates. . .” Freshwater invertebrate species that are listed under the Endangered Species Act (ESA) are also at elevated risk from foliar applications of imidacloprid.

Soil applications also result in chronic concerns for both freshwater and saltwater invertebrates. EPA did not find direct risks to fish or amphibians, however, the agency acknowledges that “the potential exists for indirect risks to fish and aquatic-phase amphibians through reduction in their invertebrate prey-base.”

USEPA.  2017.  

Regulatory Findings

Neonicotinoids

EPA, in its 2016 “refined risk assessment” concludes that aquatic plant communities are affected in many areas where atrazine use is heaviest, and there is potential chronic risks to fish, amphibians, and aquatic invertebrate in these same locations. In the terrestrial environment, there are risk concerns for mammals, birds, reptiles, plants and plant communities across the country for many of the atrazine uses.

Levels of concerns were exceeded by as much as 200-fold for some organisms!

Source: Refined Ecological Risk Assessment for Atrazine, EPA, April, 2016.

Key Studies

Atrazine: Ecological Risk

“Children encounter pesticides daily and have unique susceptibilities to their potential toxicity. Acute poisoning risks are clear, and understanding of chronic health implications from both acute and chronic exposure are emerging. Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.”

Key Studies

Children’s VulnerabilityAmerican Academy of Pediatrics2012

Researchers from Yale University’s School of Forestry and Environmental Studies and the U.S. Geological Survey (USGS) found that there are a diversity of endocrine disrupting chemicals within suburban neighborhoods.

By sampling populations of a local frog species, the researchers found a strong association between the degree of landscape development and frog offspring sex ratio.

Vegetation landscaping and impervious surface runoff may be associated with endocrine disruption environments around suburban homes.

Lambert et al., 2015, Proceedings of the National Academy of Sciences

Key Studies

Wildlife

Key Law

Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)Maryland Pesticide Registration and Labeling Law

Lack of Regulatory Attention to Pesticide Efficacy. While efficacy data must be developed by registrants, only efficacy data for public health uses are reviewed. Marketplace determines benefits.

Labels and Use Designations Become the Default Safety Standards. Cautionary label information on timing of application does little to prevent long-term, sublethal and residual effects. Compliance enforcement lacking.

Key Law

Complexities Not Addressedn Mixturesn Synergistic effectsn Inerts, metabolites and contaminantsn Endocrine disruptionn Assumes 100% compliancen Arbitrary exposure assumptions n No monitoring of adverse effectsn Additional margin of safety

sometimes arbitraryn Uncertainties/limitation of risk

assessment not disclosed on products

Key Law

Mixtures and SynergismAdverse effect of fetal exposures to a mixture of 2,4-D, mecoprop, and dicambaexposure —frequently used together in lawn products like Weed B Gone Max and Trillion— on the mother’s ability to bring young to birth and weaning.

Cavieres et al., 2002, Environmental Health Perspectives

Frog tadpoles exposed to mixtures of pesticides at real world doses took longer to metamorphose to adults and were smaller at metamorphosis than those exposed to single pesticides, with consequences for frog survival.

Hayes et al., 2006, Environmental Health Perspectives

Key Law

Mixtures and SynergismEPA must collect and assess information on chemical mixtures and potential synergistic effects in order to improve oversight over pesticide registrations and management of developing herbicide resistance. (OIG, 2017)

EPA’s Office of Chemical Safety and Pollution Prevention, responded, “Synergy considerations present a source of uncertainty that might be germane to risk assessments and regulatory decisions in certain instances,” It will consider howbest to use synergistic effects data for pesticide registration decisions by 2019. OIG. EPA. EPA Can

Strengthen Its Oversight of Herbicide Resistance With Better Management Controls, June 21, 2017.

n`“No discernible advantage in yields – food per acre” for the United States and Canada over Western Europe during the time of GE crop adoption.

n A comparison between rapeseed yields in Canada and Western Europe shows increases in both regions, with Europe’s yields consistently higher, independent of the use of GE crops. For corn, gains in food per acre were found to be roughly equal between the U.S. and Western Europe.

n As crop yields in Europe increased, pesticide use (fungicides, herbicides, and insecticides) decreased dramatically. As yields in the U.S. remained flat, insecticide use has remained the same, while the spread of herbicide-tolerant weeds has caused use of these chemicals to skyrocket.

Failure to increase Yields and Reduce Pesticide Use

Genetically Engineered Crops

Con

vent

iona

l ch

emic

al-­

inte

nsiv

evs

.O

rgan

icOrganic Practices & Policy

n Systems Approachn National List of Allowed and

Prohibited Substances

n Certification and Inspection

n National Organic Standards Board

Con

vent

iona

l ch

emic

al-­

inte

nsiv

evs

.O

rgan

icContact Information

Jay FeldmanExecutive DirectorBeyond Pesticides

701 E Street SEWashington DC 20003

202-543-5450jfeldman@beyondpesticides.org

www.beyondpesticides.org