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United States Environmental Protection Agency (EPA) 

 Deceptive Approval Process:

Pesticides Approved Without Thorough Safety Testing 

Perception: The EPA verifies pesticides are safe before approving them to be used on food crops.

Reality: The EPA evaluates data supplied by the PESTICIDE PRODUCERS to grant approval for use on crops. 

Key Points:

*"Tolerances are the maximum amount of the pesticide residue that is allowed to occur on a food, and that is an amount that the EPA expects with reasonable certainty to cause no harm."

*"Of course, those tolerance levels are only as good as the data on which they are based. Much of the scientific evidence and data that EPA reviews and relies upon in making its decision during the risk assessment are provided by the companies seeking pesticide registration."

*"And it is that initial submission of evidence and data that will continue to form the basis for re-evaluations and reviews in the future, despite the potential for the data to become outdated as scientific techniques and our understanding of pesticide toxicity evolves.56"

*"Another limitation is that for some effects, animal models may not be adequate for evaluating the effects on humans, such as the development of neurological diseases and the disruption of the human hormone system (endocrine disruption)."

*"In addition, while our ability to understand the true toxicity of individual pesticides is limited, mixtures of pesticides present an even greater challenge to toxicologists.62"

*" Unfortunately, finding mixtures of multiple pesticide residues on one type of produce is the rule and not the exception."

*" In addition, consumers probably consume multiple produce items with multiple different residues on them."

*"Traditional safety testing also assumes that higher doses are more harmful than lower doses.60 Yet in 2000, an independent panel of experts convened by the National Institute of Environmental Health Sciences and the National Toxicology Program found that some endocrine disrupting chemicals defy that convention and can have effects at very low levels, even below the “no effect” levels determined by traditional toxicology testing methods.61"

*Numerous studies have reported that exposure to a combination of pesticides will have unique effects and that
mixtures of pesticides could have “greater than additive” effects.63
Those combined effects are often termed “synergistic” effects. In addition, pesticides are formulated products, which means they are mixtures with an active ingredient and many “inert” ingredients.64"

*"Yet the effects of chemical mixtures are largely untested and unknown,65 and “mixture assessment” is an evolving discipline within toxicology.66 Testing is generally done on individual pesticides rather than on mixtures, and on the active ingredient alone, rather than on the final product with inert ingredients.67"

*"The active ingredients may be tested alone for toxicology studies, but the inert ingredients may also be toxic themselves.68 And unlike the active ingredients, inert ingredient disclosure on pesticides labels is not required (because of confidential business information protections), making it almost impossible for the public or independent scientists to assess exposure and adverse impacts."

*"And finally, the EPA continues to make decisions based on incomplete safety information."

*"The Environmental Protection Agency (EPA) has developed chronic reference doses (RfDs) for pesticides. RfD values are used by regulatory agencies to set limits for human exposure to chemicals via the diet and drinking water."

*"However, RfDs do not take the risk of cancer into consideration, nor has the agency developed test methods to take into account epigenetic or endocrine-system-driven impacts. RfDs are expressed as milligrams of a pesticide’s active ingredient per kilogram of body weight per day."

Read Full Article:

Source:

From Crop to Table Pesticide Report. (2015 March). Retrieved from https://article.images.consumerreports.org/prod/content/dam/cro/news_articles/health/CR_FSASC_FromCroptoTablePesticides_Mar2015.pdf

Key Points:

*"Even the EPA concedes that its pesticide registration process is no guarantee of safety. EPA regulations specifically prohibit manufacturers of pesticides from making claims such as "safe," "harmless" or "nontoxic to humans and pets" with or without accompanying phrases such as "when used as directed." (40 CFR sec. 156.10(a)(5)(ix))"

*"Even if there are substantial health risks, the EPA may decide the economic benefits outweigh the risks."

*"Toxicity tests are performed neither by the EPA nor by independent laboratories contracting with the EPA."

*"Pesticide manufacturers provide the data on which the EPA bases its judgments."

*"Thus, the total number of registered pesticide products containing known or suspected carcinogens is far greater than 40, but few have been severely restricted in the United States … Pesticides … approved for use by the U.S. Environmental Protection Agency (EPA) contain nearly 900 active ingredients, many of which are toxic."

*"Many of the solvents, fillers, and other chemicals listed as inert ingredients on pesticide labels also are toxic, but are not required to be tested for their potential to cause chronic diseases such as cancer.” (President’s Cancer Panel Report, Page 45, http://deainfo.nci.nih.gov/advisory/pcp/annualReports/pcp08-09rpt/PCP_Report_08-09_508.pdf)

Read Full Article:

Source:

Sharon S. Tisher, J.D. (2018 Edition). Main Organic Farmers Gardeners Association. Retrieved from http://www.mofga.org/Programs/Public-Policy/Pesticides-Action/Pesticides-Quiz

Key Point:

*"Potential registrants must generate scientific data necessary to address concerns pertaining to the identity, composition, potential adverse effects, and environmental fate of each pesticide."

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Source:

EPA Data Requirements for Pesticide Registration. (no date listed). Retrieved from https://www.epa.gov/pesticide-registration/data-requirements-pesticide-registration

Key Point:

*"On the basis of information furnished by the registrant, the above named pesticide is hereby registered under the Federal Insecticide, Fungicide and Rodenticide Act."

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Source:

U.S. Environmental Protection Agency Notice of Pesticide Registration Office of Pesticide Programs Registration Division Name of Pesticide Glyphosate 41%. (2016 June 21). Retrieved from https://www3.epa.gov/pesticides/chem_search/ppls/091543-00001-20160621.pdf

Key Point:

*"On the basis of information furnished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal Insecticide, Fungicide and Rodenticide Act."

*"Based on your response to the Reregistration Eligibility Decision, EPA has reregistered the product listed above."

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Source:

U.S. Environmental Protection Agency notice of Pesticide Reregistration Office of Pesticide Programs Registration Division Name of Product Drexel Diazinon Insecticide. (2006 December 7). Retrieved from https://www3.epa.gov/pesticides/chem_search/ppls/019713-00091-20061207.pdf

Key Point:

*"On the basis of information furnished by the registrant, the above named pesticide is hereby registered under the Federal Insecticide, Fungicide and Rodenticide Act."

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Source:

U.S. Environmental Agency Office of Pesticide Programs Registration Division Notice of Pesticide Registration Name of Pesticide Product MPower Dicamba DMA. (2015 April 13). Retrieved from https://www3.epa.gov/pesticides/chem_search/ppls/091097-00007-20150413.pdf

 

March 29, 2017

Key Points:

*"In one of his first major decisions as Environmental Protection Agency administrator, Scott Pruitt sided with the pesticide lobby over scientists in an eleventh-hour decision to abort the agency's proposal to ban chlorpyrifos – an insecticide that at small doses can harm children's brains and nervous systems – from use on food crops."

*"Pruitt and the Trump administration’s decision ignored overwhelming evidence that even small amounts of chlorpyrifos can damage parts of the brain that control language, memory, behavior and emotion." 

Read Full Article:

Source:

Formuzis, Alex. (2017, March 29). EPA Chief Scraps Scheduled Ban of Pesticide That Harms Kids’ Brains. Retrieved from https://www.ewg.org/release/epa-chief-scraps-scheduled-ban-pesticide-harms-kids-brains

Filed August 12, 2016
Key Point:

*"The panel held that the requested six-month delay was not justified in light of the EPA’s history in the matter, as well of the court’s previous extensions. The panel directed the EPA to take final action by March 31, 2017.  The panel retained jurisdiction over any further related proceedings."
Read Full Article:

Source:

United States Court of Appeals for the Ninth Circuit. (2016, August 12). Retrieved from https://cdn.ca9.uscourts.gov/datastore/opinions/2016/08/12/14-72794.pdf

January 5th, 2016

Key Points:

*"Chlorpyrifos is a powerful developmental neurotoxicant. Exposures to even very low doses of chlorpyrifos during critical windows of exquisite vulnerability during the nine months of pregnancy and in early postnatal life can cause brain damage to children that is characterized by diminished cognitive ability (lowered IQ), problems with working memory, delays in motor development and disruptions of primitive reflexes.  It should be noted that working memory skills in the early elementary school years are a strong predictor of learning outcomes and academic achievement in later years (Alloway et al. 2010). These disruptions in children’s brain development appear to be permanent, irreversible and lifelong."

*"In November, 2015 EPA acknowledged that it is unable to make a safety finding regarding chlorpyrifos use as required under the Federal Food, Drug, and Cosmetic Act (FFDCA).5"

*"EPA determined 15 years ago that residential uses of chlorpyrifos resulted in exposures to children that exceeded safe levels by orders of magnitude."

*"During these last 15 years, consumers in the U.S. have also continued to be exposed to chlorpyrifos and other organophosphate pesticides through residues on produce (Bradman et al 2015; Lu et al 2006, Vogt et al 2012).9 10 Children experience greater exposure to organophosphate pesticides due to their increased hand-tomouth action, and relative to adults they eat more fruits and vegetables, drink more, and breathe more.11"

*"Thus, with each year of delay in cancelling food tolerances and agricultural and other uses of chlorpyrifos, more children are unnecessarily at elevated risk for problems in learning, social skills, motor function, respiratory health, and other developmental domains."

Read Full Article:

 

 

Source:
Comments to EPA from Environmental Health Scientists and Healthcare Professionals In Support of EPA’s Proposal to Revoke Chlorpyrifos Food Residue Tolerances. (2016, January 5). Retrieved from https://www.nrdc.org/sites/default/files/hea_16010401a.pdf

Key Points:

*"In March 2017, the U.S. Environmental Protection Agency (EPA) decided not to ban Chlorpyrifos, a widely used pesticide."

*"Most of Dow Chemical’s studies relied on standard toxicity testing recommended in the“OECD Guidelines for the Testing of Chemicals.” However, these methods cannot detect the more subtle effects caused by low doses and long-term exposures. Effects of chlorpyrifos on brain development are the focus of many academic research articles but not included in OECD guidelines. Therefore, these academic studies were not originally considered in regulatory decision making."

*"In March 2017, despite mounting evidence for its toxicity, Scott Pruitt, head of the current EPA, denied the petition from the two NGOs and decided not to ban chlorpyrifos."

*"This decision would leave chlorpyrifos on the market until its next registration review, a program that re-evaluates all pesticides on a 15-year cycle. For chlorpyrifos, the deadline is Oct 1st, 2022."

*"In their press release, the EPA acknowledged that current use of chlorpyrifos leads to its incorporation in food and drinking water above safe levels, but they emphasized that chlorpyrifos was a highly effective and widely used pest-management tool."

*"More than 34,000 pesticides that are derived from about 600 basic chemicals are registered by the EPA for use in this country."

Read Full Article:

Source:

Hi, Xindi (Cindy). (2018, April 17). The Most Widely Used Pesticide, One Year Later. Retrieved from http://sitn.hms.harvard.edu/flash/2018/widely-used-pesticide-one-year-later/

Key points:

*”In evaluating a pesticide registration application, we assess a wide variety of potential human health and environmental effects associated with use of the product. Potential registrants must generate scientific data necessary to address concerns pertaining to the identity, composition, potential adverse effects, and environmental fate of each pesticide.”

Read Full Article:

Source:

United States Environmental Protection Agency Pesticide Registration Data Requirements for Pesticide Registration. (no date listed). Retrieved from https://www.epa.gov/pesticide-registration/data-requirements-pesticide-registration

Bayer Crop Science-Movento

Key Points:

*”On the basis of information furnished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal Insecticide, Fungicide and Rodenticide Act.”

*”CAUTION”

*”Harmful if swallowed or absorbed through skin.”

*”MOVENTO is a suspension concentrate formulation and is active primarily by ingestion against immature insect life stages.”

*”Sufficient leaf tissue must be present for uptake and translocation of this product; due to this requirement, do not apply prior to petal-fall on pome fruits, stone fruits, and tree nut crops. Following application to plant foliage, MOVENTO is fully systemic, moving through phloem and xylem to all plant tissues including new shoot, leaf and root growth; systemicity and efficacy may be hindered during periods of cold temperatures, under drought conditions, or when plants are not actively growing.”

*”Crops of Crop Group 10 including: Calamondin, Citrus citron, Citrus hybrids (Citrus spp., includes chironja, tangelo and tangor), Grapefruit, Kumguat, Lemon, Lime, Mandarinltanoerinel, Oranoe (sweet and sour), Pummelo, and Satsuma mandarin.”

Read Full Article:

Source:

U.S. Environmental Protection Agency, Office of Pesticide Programs, Registration Division, Notice of Pesticide Registration, name of Pesticide Product Movento. (2008, June 30). Retrieved from https://www3.epa.gov/pesticides/chem_search/ppls/000264-01050-20080630.pdf

Key Points:

*"The toxicity testing is provided by the producer and is reviewed by regulatory authorities, such as the U.S. Environmental Protection Agency (EPA) and the European Food Safety Authority (EFSA); the latter relies on a detailed evaluation carried out by a Rapporteur Member State (RMS)."

*"Independent academic studies and industry-sponsored toxicity studies may lead to fundamentally different conclusions [1], as is the case for chlorpyrifos. Thus, based on independent epidemiological, in vivo and in vitro studies, the evidence points to adverse health effects of chlorpyrifos exposure on the developing nervous system, associated with lowered IQ at school age, at current levels of exposure [2]. These outcomes have been observed at exposure levels far below those recognized to cause effects on brain development in an industry-funded developmental neurotoxicity (DNT) study commissioned for regulatory purposes [3, 4]."

*"In our review of raw data on a prominent pesticide, chlorpyrifos, and a related compound, discrepancies were discovered between the actual observations and the conclusions drawn by the test laboratory in the report submitted for authorization of the pesticide."

*"Although our findings may not be generalized, they suggest the existence of bias in the reporting of industry-sponsored toxicity studies."

Read Full Article:

Source:

Mie, Axel; Ruden, Christina; Grandjean, Philippe. (2018, November 16).Safety of Safety Evaluation of Pesticides: developmental neurotoxicity of chlorpyrifos and chlorpyrifos-methyl. Retrieved from https://ehjournal.biomedcentral.com/articles/10.1186/s12940-018-0421-y

Key Points:

*"The term pesticide includes many kinds of ingredients used in products, such as insecticides, fungicides, rodenticides, insect repellants, weed killers, antimicrobials, and swimming pool chemicals, that are designed to prevent, destroy, repel, or reduce pests of any sort."

*"Pesticide companies, or registrants, must submit a wide variety of scientific studies for review before EPA will set a tolerance."

Read Full Article:

Source:

United States Environmental Protection Agency, Setting Tolerances for Pesticide Residues in Foods. Retrieved from https://www.epa.gov/pesticide-tolerances/setting-tolerances-pesticide-residues-foods

Key Points:

*”There is indeed an epidemic of disorders, striking one out of three American children, triggered by the unimaginable load of toxics in their everyday lives.”

*”Why do some children get sick from toxic exposures while others do not?  The decoding of the human genome has recently revealed that, in addition to inherited variations that are genetic mutations, there are inherited variations that are slight differences in the sequence of DNA in the genes.  These variations are the reason a child is born with green eyes rather than brown, or blood type A rather than O. (National Institute of Environmental Health Sciences, n.d.).  These variations also predispose a person from the womb through life to be more or less vulnerable to environmental insults.

*”Yet it’s crucial to remember that a child might have a predisposition to an illness but the illness would never surface without the toxic assault (Koger, Schettler, & Weiss, 2005).  The genes may load the gun, but the environment pulls the trigger!”

*”Government regulatory agencies whose role is to protect us from environmental harm have collaborated in the toxic assault by sharply pulling back on their regulating.  Further, a powerful new network of scientists-for-hire, public relations firms, and lawyers has grown up to serve polluting companies.  Their role on behalf of their corporate clients is to cast doubt about the dangers of toxic products and processes.  The goal is to arm companies with research and expert testimony to delay or derail regulation, to overwhelm families who bring lawsuits against them, and to mollify the fears of communities faced with pollution and of consumers faced with toxic products.”

Read Full Article:

Source:

Philip and Alice Shabecoff. The Toxic Assault on Our Children. (2008). Retrieved from http://thenadd.org/modal/bulletins/v12n2a3~.htm

Key Points:

*"Modern biotechnology relies on newer techniques, such as genetic engineering, to incorporate genetic material from one living organism into another."

*"Plant-Incorporated Protectants (PIPs)" "For example, by transferring specific genetic material from a bacterium to a plant, scientists can create plants that produce pesticidal proteins or other chemicals that the plant could not previously produce."

*"Using this technology, scientists have modified corn, cotton, and potatoes to produce a pesticidal protein that is toxic when ingested by specific insect pests. In this case, the plant-incorporated protectants are chemicals produced by plants whose DNA has been modified, as well as the DNA that produces the chemicals."

*"The plant's modified DNA now expresses pesticidal properties by producing a bacterial protein that will protect the plant from specific insects. Since March 1995, EPA has registered 12 PIPs."

*"Genetically Modified Microbial Pesticides" "Genetically modified microbial pesticides are either bacteria, fungi, viruses, protozoa, or algae, whose DNA has been modified to express pesticidal properties.""To date, EPA has registered eight such products, which contain a modified microorganism and inert ingredients."

*"Herbicide-Tolerant Crops""Herbicide tolerant crops contain new genes that allow the plant to tolerate these herbicides. The most common herbicide-tolerant crops (cotton, corn, soybeans, and canola) are those that are resistant to glyphosate, an effective herbicide used on many species of grasses, broadleaf weeds, and sedges."

*"EPA has established tolerance exemptions for registered genetically modified microbial pesticides and plant-incorporated protectants because, based on a thorough scientific evaluation, EPA has found that the tolerance exemptions are safe."

*"In these rules, the Agency has determined that, in regulating plant-incorporated protectants, the new protein and its genetic material are regulated by EPA; the plant itself is not regulated."

Read Full Article:

Source:

United States Environmental Protection Agency: "EPA's Regulation of Biotechnology for Use in Pest Management. Retrieved from https://www.epa.gov/regulation-biotechnology-under-tsca-and-fifra/epas-regulation-biotechnology-use-pest-management

Key Points:

*”In what could easily be classified as one of the US Environmental Protection Agency's (EPA) worst decisions yet, a final rule released by the EPA earlier this month creates an exemption for residue tolerance levels of genetically modified (GM) Bt toxin in GM soy foods and feed.1

*”There is a major problem with the EPA's assertion that Bt crops are safe, and that is their decision to regard Bt toxin sprayed on plants as the same as plants genetically modified to produce Bt toxin from within. The two are not the same, nor are they equally safe, as the EPA would have you believe.”

*”In other words, when Bt is applied to plants topically, it degrades quickly in the sunlight – typically after one week it is broken down (and sometimes as soon as 24 hours). GM Bt crops, however, have the Bt-toxin gene built-in, so the toxin is not broken down and cannot be washed off. You simply cannot avoid consuming it.”

*”This is concerning, because even when natural Bt toxin was fed to mice, they had tissue damage, immune responses as powerful as those to cholera toxin and even started reacting to other foods that were formerly harmless.

*”Furthermore, the plant-produced version of the poison is thousands of times more concentrated than the spray. So if Bt genes are indeed capable of transferring horizontally to the bacteria colonizing the human digestive tract, scientists believe it could reasonably result in: Gastrointestinal problems, Autoimmune diseases, Food allergies, Childhood learning disorders"

Read Full Article:

Source:

Dr. Mercola. (2014, February 26). EPA Approves Exemption for Bt Residues in Soy Foods from GM Crops. Retrieved from https://articles.mercola.com/sites/articles/archive/2014/02/26/bt-toxin-residues.aspx