Action of the Week

Action of the week is intended to provide you, our supporters and network, with one concrete action that you can take each week to have your voice heard on governmental actions that are harmful to the environment and public and worker health, increase overall pesticide use, or undermine the advancement of organic, sustainable, and regenerative practices and policies. As an example, topics may include toxic chemical use, pollinator protection, organic agriculture and land use, global climate change, and regulatory or enforcement violations.

Please fight for farmers in our state and support these provisions by co-sponsoring the Local and Regional Farmer and Market Support Act.

*Provides emergency response grants for farmers markets and local food enterprises to allow those operations to adapt to new market conditions, implement public health and safety protections, and further support communities experiencing food insecurity.

*Prioritizes funding for Black, Indigenous, and people of color and low-income communities of color and include robust outreach, technical assistance, and data collection, to ensure that aid is distributed equitably.

I am writing to ask you to co-sponsor the Local and Regional Farmer and Market Act (H.R. 8096), introduced by Rep. Alma Adams of North Carolina. It is critical for pandemic response and recovery for agriculture.

This bill will help farmers stay in business and keep feeding their communities, ensure equitable access to aid, and support our responsive, resilient local food supply chains. Ultimately, it will create a more resilient farm and food system for the long haul toward recovery.

While farmers struggle to feed their communities during the ongoing coronavirus pandemic, many have not received support for critical safety and technology needs. Billions in federal aid through the Coronavirus Food Assistance Program (CFAP) has gone out, but failed to reach all farmers—particularly direct marketing farmers and ranchers, diversified farmers, and folks who are Black, Indigenous, and people of color. Local and regional food enterprises have worked to supply food through farmers markets, food hubs, CSAs, and more, but have not received the support given to larger enterprises.

The Local and Regional Farmer and Market Support Act (H.R. 8096), introduced by Rep. Alma Adams of North Carolina, will help meet the needs of farmers who have been left out. Please urge your Congressional Representative co-sponsor this bill.

As Congress returns to Washington this week, it is overdue to pass critical pandemic aid for families and communities, including helping small and mid-scale farms and ranches, farmers markets, and local food businesses address the impacts of the Covid-19 pandemic.

This bill will help farmers stay in business and keep feeding their communities, ensure equitable access to aid, and support our responsive, resilient local food supply chains. Ultimately, it will create a more resilient farm and food system for the long haul toward recovery.

While farmers struggle to feed their communities during the ongoing coronavirus pandemic, many have not received support for critical safety and technology needs. Billions in federal aid through the Coronavirus Food Assistance Program (CFAP) has gone out, but failed to reach all farmers—particularly direct marketing farmers and ranchers, diversified farmers, and folks who are Black, Indigenous, and people of color. Local and regional food enterprises have worked to supply food through farmers markets, food hubs, CSAs, and more, but have not received the support given to larger enterprises.

The Local and Regional Farmer and Market Support Act (H.R. 8096), introduced by Rep. Alma Adams of North Carolina, will help meet the needs of farmers who have been left out. Please urge your Congressional Representative co-sponsor this bill.

As Congress returns to Washington this week, it is overdue to pass critical pandemic aid for families and communities, including helping small and mid-scale farms and ranches, farmers markets, and local food businesses address the impacts of the Covid-19 pandemic.

09/08/2020 — Tell Canada to Ban Horrifically Hazardous Wood Preservative Pentachlorophenol

Tell Canada to Ban Pentachlorophenol TAKE ACTION BY SEPTEMBER 13 to Send Comments and Sign the Petition! Canada is considering the elimination of one of the worst persistent pollutants—pentachlorophenol (penta)—that dot our landscape in utility poles and railroad ties. This wood preservative—a cancer-causing chemical with dioxin, furans, and hexachlorobenzene that causes health and environmental degradation—has no place in society as we struggle with shared global challenges of public and worker health threats, the climate crisis, and biodiversity decline. We have a chance to urge Canada to move ahead with a pentachlorophenol ban, joining with Mexico to show leadership in the protection of health and the environment—something the U.S. has not done. >> Tell Canada to ban pentachlorophenol. Canada's Pest Management Regulatory Agency (PMRA) is accepting comments on a proposal to ban the all uses of penta in Canada. Comments are due September 13. Canada is a signatory to the Stockholm Convention on Persistent Organic Pollutants, which voted 90-2 to ban penta in 2015. The United States is not a signatory to the Stockholm Convention and still allows the use of penta on utility poles and other “wood that is subject to decay or insect infestation, including supporting structures in contact with the soil in barns, stables, and similar sites.” Despite the ban in force in 186 countries, the United States has continued to import and use this hazardous wood preservative on telephone poles and railroad ties throughout the country. With Mexico set to close one of the last production plants in the world, Gulbrandsen Chemicals Inc. tried to make Orangeburg, a majority black community in South Carolina, the new epicenter for penta manufacturing. Following protests by lawmakers and coverage in The State newspaper, the company dropped its plans. Penta is used to pressure treat wood, with the aim of prolonging its use in utility poles and railroad ties. Beyond Pesticides has sounded the alarm on penta and other wood preservatives for over 20 years, starting with the reports Pole Pollution and Poison Poles, which outlined the science on the hazards and alternatives to preservative-coated utility poles. Penta is a particularly concerning wood preservative, as it is well known to be contaminated with hexachlorobenzene, polychlorinated dibenzo-p-dioxins, and furans. Acute contact exposure through contact or inhalation with penta-treated products can result in severe irritation. Chronic risks include damage to organ systems like the liver and kidney, as well as impacts on immune, nervous, and endocrine system functioning. EPA reviews previously classified penta as a probable carcinogen, however its Integrated Risk Information System recently classified it as “likely to be carcinogenic.” The U.S. Environmental Protection Agency (EPA) estimates that at least 1 in 1,000 workers are likely to develop cancer during their career at a penta production plant. While EPA continues to drag its feet, an international treaty, called the Stockholm Convention on Persistent Organic Pollutants, was brought into force. Parties to the Stockholm Convention are bound to eliminate the use and production of hazardous chemicals voted on by member countries. The U.S. is glaringly absent from this treaty, signing it in 2001, yet never ratifying it through the Senate. Despite opposition from the U.S. and India, which is a minor producer of the chemical, the Stockholm Convention voted to impose the strictest ban possible on penta, beginning in 2016. This set a clock ticking on the last North American penta plant, located in Matamoros, Mexico. Mexico was granted a five-year exemption from the treaty in order to provide time to shift production. With 2021 fast approaching, the plant's owner, Cabot Microelectronics, announced it would stop manufacturing the chemical in order to comply with the Stockholm Convention. Around the same time, Gulbrandsen Chemicals Inc., a company that lists its headquarters in South Carolina, but appears to have ties to India, announced it would bring a production plant to Orangeburg. The U.S. has long been the largest consumer of penta, and as a result has an intimate history with the chemical's manufacturing process. Hundreds of Superfund sites throughout the country are designated as such because they were the location of previous penta production plants. According to research Beyond Pesticides conducted in Pole Pollution in the late 1990s, roughly 250 sites on the Superfund National Priorities list were contaminated with penta. A ban by Canada will put added pressure on the U.S. EPA to finally ban penta. The Canadian PMRA proposal summarizes the environmental and health hazards of penta. In the environment, concerns are persistence, mobility, and bioaccumulation (presence in all environmental compartments); potential risk to aquatic organisms; potential risk to terrestrial vertebrates; and release to the environment of polychlorodibenzodioxins, polychlorodibenzofurans, and hexachlorobenzene. Human health concerns include occupational exposure in wood treatment facilities and exposure to the general public from treated wood that could produce serious health effects. The long-term non-cancer risk was not shown to be acceptable. Based on the arithmetic mean exposure for all sites, all job groups and assuming 35 years of work per 78 year lifetime, cancer risk for workers in the treatment facilities is estimated as 1 × 10-3, compared to Health Canada's generally acceptable level of 1.0 × 10-5 for occupational scenarios. PMRA concludes, “Evaluation of the available scientific information related to the human health aspects of concern indicated that under the current conditions of use of pentachlorophenol, potential risk to human health is not shown to be acceptable.” >> Send this letter and sign the petition telling Canada to ban pentachlorophenol. Please note: By sending this letter, you will also be adding your name to the petition that Beyond Pesticides will submit to Canada's Pest Management Regulatory Agency. I am writing to support the proposal of the PMRA to ban all uses of pentachlorophenol. We share one global environmental that cannot tolerate continual contamination with persistent pollutions that travel the earth and contribute to public and worker health threats, the climate crisis, and biodiversity decline. Canada is a signatory to the Stockholm Convention on Persistent Organic Pollutants, which voted 90-2 to ban penta in 2015. Penta is a particularly dangerous wood preservative, as it is well known to be contaminated with hexachlorobenzene, polychlorinated dibenzo-p-dioxins, and furans. Acute contact exposure through contact or inhalation with penta-treated products can result in severe irritation. Chronic risks include damage to organ systems like the liver and kidney, as well as impacts on immune, nervous, and endocrine system functioning. The U.S. Environmental Protection Agency (EPA) recently classified it as “likely to be carcinogenic.” The Canadian PMRA proposal recognizes the environmental and health hazards of penta. In the environment, concerns are persistence, mobility, and bioaccumulation (presence in all environmental compartments); potential risk to aquatic organisms; potential risk to terrestrial vertebrates; and release to the environment of polychlorodibenzodioxins, polychlorodibenzofurans, and hexachlorobenzene. Human health concerns include occupational exposure in wood treatment facilities and exposure to the general public from treated wood that could produce serious health effects. The long-term non-cancer risk was not shown to be acceptable. Based on the arithmetic mean exposure for all sites, all job groups and assuming 35 years of work per 78 year lifetime, cancer risk for workers in the treatment facilities is estimated as 1 × 10-3, compared to Health Canada’s generally acceptable level of 1.0 × 10-5 for occupational scenarios. PMRA concludes, “Evaluation of the available scientific information related to the human health aspects of concern indicated that under the current conditions of use of pentachlorophenol, potential risk to human health is not shown to be acceptable.” Please ban all uses of pentachlorophenol in Canada, bringing the world closer to eliminating this highly toxic persistent organic pollutant. Thank you for your consideration of my comments. Sincerely,

08/31/2020 — Help Keep Toxic Herbicides Out of Lake Tahoe, Protect this Treasured and Sacred Ecosystem; Advance Alternatives

We don’t need to use toxic weed killers to manage unwanted vegetation in Lake Tahoe, given the havoc they will wreak on a treasured and sacred ecosystem. The Tahoe Regional Planning Agency and Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) are accepting comments on a draft environmental impact report/ environmental impact statement (EIR/EIS) analyzing environmental impacts of a proposed Tahoe Keys Lagoons Aquatic Weed Control Methods Test (“Project”). Unless we all speak up, the Project could involve the application of herbicides to Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and should be selected for the proposed weed control test program. Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm. Located on the border of California and Nevada, Lake Tahoe is treasured for its scenic and ecological values not just by residents of those states, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an “Outstanding National Resource Water” under the Clean Water Act, and is recognized nationally and globally as a natural resource of special significance. The herbicides chosen for consideration in this program—florpyrauxifen-benzyl, triclopyr, and endothall—pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally superior choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program. Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts. See Beyond Pesticides’ detailed comments. Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm. Letter to Tahoe Regional Planning Agency/Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) I am writing to agree with the draft EIR/EIS authors that the Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and ask that the Tahoe Regional Planning Agency/Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) choose this alternative for the proposed weed control test program. Lake Tahoe is treasured for its scenic and ecological values not just by residents of California and Nevada, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an “Outstanding National Resource Water” under the Clean Water Act and is recognized nationally and globally as a natural resource of special significance. The herbicides chosen for consideration in this program pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally best choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program. Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts. Please see comments submitted by Beyond Pesticides, which I support. Thank you for your consideration of these comments.

08/27/2020 — Keep Toxic Herbicides Out of Lake Tahoe, Protect Treasured Ecosystem

We don't need to use toxic weed killers to manage unwanted vegetation in Lake Tahoe, given the havoc they will wreak on a treasured and sacred ecosystem. The Tahoe Regional Planning Agency and Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) are accepting comments on a draft environmental impact report/ environmental impact statement (EIR/EIS) analyzing environmental impacts of a proposed Tahoe Keys Lagoons Aquatic Weed Control Methods Test (“Project”). Unless we all speak up, the Project could involve the application of herbicides to Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and should be selected for the proposed weed control test program. >> Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm. Located on the border of California and Nevada, Lake Tahoe is treasured for its scenic and ecological values not just by residents of those states, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an "Outstanding National Resource Water" under the Clean Water Act, and is recognized nationally and globally as a natural resource of special significance. The herbicides chosen for consideration in this program—florpyrauxifen-benzyl, triclopyr, and endothall—pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally superior choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program.

Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts. See Beyond Pesticides' detailed comments. >> Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm. Letter to TRPA/LRWQCB: I am writing to agree with the draft EIR/EIS authors that the Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and ask that the Tahoe Regional Planning Agency/Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) choose this alternative for the proposed weed control test program. Lake Tahoe is treasured for its scenic and ecological values not just by residents of California and Nevada, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an "Outstanding National Resource Water" under the Clean Water Act and is recognized nationally and globally as a natural resource of special significance. The herbicides chosen for consideration in this program pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally best choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program. Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts. Please see comments submitted by Beyond Pesticides, which I support. Thank you for your consideration of these comments. Sincerely,

08/24/2020 — Tell Congress to Restore Organic Funding Taken Away by USDA

USDA’s Farm Service Agency (FSA) announced on August 10 that it will be reducing reimbursement rates for the organic certification cost share program, which provides reimbursements to organic farms and handling operations. The August 10 Federal Register notice stated that FSA is “revising the reimbursement amount to 50 percent of the certified organic operation’s eligible expenses, up to a maximum of $500 per scope.” The 2018 Farm Bill clearly set reimbursement rates at 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per regulated activity. This change hurts the transition to organic production at a time when it is crucial that the organic sector grows—eliminating petroleum-based pesticides and synthetic fertilizers that are contributing to devastating pollution, the climate crisis, and biodiversity decline. This action by USDA is unwarranted and completely unacceptable. The 2018 Farm Bill provided new funding for the program and also directed USDA to use the program’s carryover balances from previous years to fund the program for fiscal years 2019 through 2023. Given these sources of funding, there should be plenty of funds available for the program’s operation in fiscal year 2020. Either USDA’s accounting for this program is flawed or the agency has decided to disregard the Congressional funding directives in the 2018 Farm Bill. In addition, the FSA has done a huge disservice to the organic community in this time of crisis by delaying the release of funds by many months while organic operations struggle to stay in business as they weather a pandemic and loss of markets. Organic, direct market, and diversified operations have largely been excluded from existing USDA pandemic relief programs, including the Coronavirus Food Assistance Program, while the top 1% of recipients got more than 20% of the money, totaling $1.2 billion. Organic operations should apply for certification cost-share assistance as soon as they are able to do so with their state agency or local FSA office. Operations have until October 31, 2020 to apply for funding. FSA has stated that “if additional funding is authorized at a later time, FSA may provide additional assistance to certified operations that have applied” for the organic certification cost share program. TAKE ACTION: Tell Congress to restore organic funding taken away by USDA. Letter to Congress: I am writing to express my outrage that USDA’s Farm Service Agency has chosen to reduce support for the organic certification cost share program in the midst of a pandemic. The organic certification cost share program provides organic farmers and handling operations with modest reimbursement of up to $750 to cover a portion of their annual certification fees. This decision was announced via an August 10 Federal Register notice that stated FSA is “revising the reimbursement amount to 50 percent of the certified organic operation’s eligible expenses, up to a maximum of $500 per scope.” This unilateral action by USDA is unwarranted and completely unacceptable and disregards the Congressional funding directives in the 2018 Farm Bill. The 2018 Farm Bill clearly set reimbursement rates at 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per scope. In addition, the FSA has done a huge disservice to the organic community in this time of crisis by delaying the release of funds by many months while organic operations struggle to stay in business as they weather a pandemic and loss of markets. Organic, direct market, and diversified operations have largely been excluded from existing USDA pandemic relief programs, including the Coronavirus Food Assistance Program, while the top 1% of recipients got more than 20% of the money, totaling $1.2 billion. If the USDA wants organic farms and our regional economies to survive and thrive, it should be helping organic operations during the pandemic. Producers and other organic operations need this support now more than ever because they are faced with loss of markets due to COVID-19 and increasing costs as they modify their operations to keep workers and customers safe and implement new sanitation and staffing procedures. I urge you to communicate with FSA to ensure that the full organic certification cost share reimbursement is reinstated. In addition, given USDA’s delay in announcing the funding availability, I urge you to extend the deadlines for state agencies to apply to administer the program, and for organic operations to apply for the assistance. Please sign onto the letter from Representatives Plaskett, Davis, Brindisi, and Newhouse urging USDA to reinstate the maximum reimbursement rate for the organic certification cost share program, as well as extend all applicable program deadlines to ensure that farmers who are still dealing with COVID-19 impacts have ample time to access these funds. To sign onto the letter, you can contact Tiana Thomas in Rep. Plaskett’s office ([email protected]), Robert Dougherty in Rep. Brindisi’s office ([email protected]), Janie Costa in Rep. Rodney Davis’ office ([email protected]), or Travis Martinez in Rep. Newhouse’s office ([email protected]). The letter will close at COB on Monday, August 24. Thank you.

08/17/2020 — Tell Lowe’s and Home Depot to Promote Organic Instead of Poisons

08/10/2020 — Coronavirus Safety Measures Required for School Reopening; Toxic Disinfectants Are Not a Shortcut to Safety

08/03/2020 — Tell Congress to Require EPA to Stop Ignoring People of Color in Setting Safety Standards—Agency Ignores People at Elevated Risk to Deadly Combination of Pesticides and Covid-19 Exposure

The effects of pesticide use are important, yet ignored, factors affecting people of color (POC) who face elevated risk from Covid-19 as essential workers, as family members of those workers, and because of the additional or cumulative risk that pesticides pose. As a part of this deadly combination, exposure to pesticides occurs at work, in community parks, schools and playing fields, and through food residues. EPA is ignoring the real hazards resulting from a combination of exposures that is reflected in the statistics that have emerged—with farmworkers suffering a rate of coronavirus five times higher and landscapers three times higher than community rates. Why is this the case? Because pesticide exposure weakens the respiratory, immune, and nervous system and makes those exposed more susceptible to the coronavirus. EPA has the power to immediately, on an emergency basis, adjust allowable pesticide use and exposure, recognizing that we have alternative practices and products to meet food production and landscaping needs. Tell Congress to require EPA to examine the contribution of pesticide exposure to Covid-19 and protect those at greatest risk, people of color. Farmworkers and landscapers have been deemed essential employees during the coronavirus outbreak, but without mandated safety protocols or government assistance, have experienced an explosion in Covid-19 cases. Workers in these industries are primarily Latinx people of color, many of whom are undocumented. According to a report published by the University of California Los Angeles, Latinx Californians aged 50 to 64 have died from the virus at rate five times higher than white people of the same age. Most people in the U.S. suffer from one or more chronic conditions identified as putting people at increased risk of dying from Covid-19. The diseases, which involve disruption of the immune system, include metabolic diseases of obesity, diabetes, liver, kidney, and cardiovascular disease, respiratory diseases including asthma, allergy, emphysema, and chronic obstructive pulmonary disease (COPD), in addition to autoimmune diseases, such as rheumatoid arthritis, multiple sclerosis, Crohn’s disease, and lupus. The chronic inflammation induced by these diseases makes a dangerous heightened response to coronavirus more likely. While metabolic, respiratory, and autoimmune disease is widespread, the poor working conditions to which farmworkers and landscapers are subject put them at disproportionate risk of pesticide-induced diseases. Occupational exposure to pesticides is, in fact, a form of institutionalized racism, putting people of color at disproportionate risk of death from Covid-19. It is essential that when EPA weighs risks and benefits of pesticide use, it does not allow risks to workers and people of color to be ignored or undervalued. An appraisal of the contribution of pesticide use and exposure to health outcomes of Covid-19 is urgently needed. Tell Congress to require EPA to examine the contribution of pesticide exposure to Covid-19 and protect those at greatest risk, people of color. Letter to Congress I am writing out of concern for disproportionate risks to people of color arising from pesticide exposure during this pandemic. Please take emergency steps to require EPA to examine the contribution of pesticide exposure to the severity of Covid-19. The effects of pesticide use are important, yet ignored, factors affecting people of color who face elevated risk from Covid-19 as essential workers, as family members of those workers, and because of the additional or cumulative risk that pesticides pose. As a part of this deadly combination, exposure to pesticides occurs at work, in community parks, schools and playing fields, and through food residues. EPA is ignoring the real hazards resulting from a combination of exposures—reflected in the statistics showing that farmworkers suffer a rate of coronavirus five times higher and landscapers three times higher than community rates. Why? Because pesticide exposure weakens the respiratory, immune, and nervous system and makes those exposed more susceptible to the coronavirus. Farmworkers and landscapers have been deemed essential employees during the coronavirus outbreak, but without mandated safety protocols or government assistance, have experienced an explosion in Covid-19 cases. Workers in these industries are primarily Latinx people of color, often undocumented. According to a report published by the University of California Los Angeles, Latinx Californians aged 50 to 64 have died from the virus at rate five times higher than white people of the same age. Most people in the U.S. suffer from one or more chronic conditions identified as putting people at increased risk of dying from Covid-19. The diseases, which involve disruption of the immune system, include metabolic diseases of obesity, diabetes, liver, kidney, and cardiovascular disease, respiratory diseases including asthma, allergy, emphysema, and chronic obstructive pulmonary disease (COPD), in addition to autoimmune diseases, such as rheumatoid arthritis, multiple sclerosis, Crohn’s disease, and lupus. The chronic inflammation induced by these diseases makes more likely a dangerous heightened response to coronavirus. While metabolic, respiratory, and autoimmune disease is widespread, the poor working conditions to which farmworkers and landscapers are subject put them at disproportionate risk of pesticide-induced diseases. Occupational exposure to pesticides may be seen as institutionalized racism, putting black and brown people at disproportionate risk of death from Covid-19.



Farmworkers and landscapers have been deemed essential employees during the coronavirus outbreak, but without mandated safety protocols, adequate regulatory review, or government assistance, have experienced an explosion in Covid-19 cases. Workers in these industries are primarily Latinx people of color, many of whom are undocumented. According to a report published by the University of California Los Angeles, Latinx Californians aged 50 to 64 have died from the virus at rate five times higher than white people of the same age. It is essential that when EPA weighs risks and benefits of pesticide use, it does not allow risks to workers and people of color to be ignored or undervalued. An appraisal of the contribution of pesticide use and exposure to health outcomes of Covid-19 is urgently needed. Please mandate EPA to perform an emergency assessment of the contribution of pesticide exposure to Covid-19 vulnerability. To highlight the urgency of this assessment, EPA should be given three months to put in place temporary measures based on scientific literature and advice of medical personnel, with permanent measures to be codified within a year. Thank you for your attention to this urgent issue.

07/27/2020 — Tell Evian to Protect the Integrity of Its Purity Claim by Supporting a Worldwide Shift to Organic

Evian bottled water, produced by the French company Danone, is supposed to be so pure that scientists will calibrate their measuring devices with it. But new data from Swiss researchers finds it to be contaminated with a toxic fungicide. “The fact that even the Evian springs in the French Alps, which are hardly affected by humans, contain pesticide residues is alarming and shows the far too careless handling of these substances,” Roman Wiget, president of the international drinking water association AWBR told the German-language Swiss weekly. The answer is not to simply ban another toxic pesticide, only to be followed by another toxic pesticide, but foundational changes to agriculture and land management with a shift to organic practices. Tell Evian to protect water quality and the integrity of its purity claim by prominently supporting a worldwide shift to organic agriculture and land management. Danone claims that the purity of Evian bottled water comes from its source in Cachat Spring at the base of the French Alps in the town of Évian-les-Bains, France, where it is “[p]rotected under a fortress of geological layers built by glaciers 30,000 years ago, it slowly travels through natural snowy, glacial rocks naturally filtering it.” Evian publishes results of water quality testing, supporting its claims of water high in natural minerals and lacking detections of synthetic chemicals. Findings of the transformation products of the fungicide chlorothalonil, which is unlikely to have been used near the source of Evian water, demonstrate the fact that pesticides cannot be controlled. Evian, as a purveyor of “pure” water for people who are concerned about the contamination of their own local water supplies, should take actions to protect its water. Chlorothalonil is a dangerous, highly toxic pesticide. As a probable human carcinogen, there is no safe dose. The transformation products found in Evian bottled water can be removed by carbon filtration, but such treatment results in contaminated carbon and places the burden of removal on Evian, rather than the chemical companies. Although other pesticides have not been found so far in Evian’s water, there is no reason to believe that the Cachat Spring is safe from contamination from other chemicals as long as chemical-intensive agriculture and land management is the norm. As of 2020, chlorothalonil use is banned in the EU. However, long-distance transport is evidently responsible for the contamination of Cachat Spring water, and the presence of currently used pesticides in the Arctic is evidence of cause for concern. It is particularly worrisome that groundwater, as a principal source of drinking water, is increasingly found to be contaminated with pesticides, even those used far from the site where the groundwater is withdrawn. Action is required worldwide, and we are urging Danone to become a leader in protecting the environment and its brand. Evian should protect the purity of its water by supporting Beyond Pesticides’ international campaign to transition to organic agriculture. This effort not only protects groundwater, but it confronts the apocalyptic challenges we face as a global community with the climate crisis and the devastation of biodiversity. In the short-term, Danone should protect its consumers and its integrity by using filtration to remove chemical contaminants and labeling when they cannot be removed. However, using filtration is only a limited short-term fix that does not address underlying chemical dependency on hazardous and persistent pesticides that are not needed for land management. Tell Evian to protect water quality and the integrity of its purity claim by prominently supporting a worldwide shift to organic agriculture and land management. Thank YOU for all you do,

— The Beyond Pesticides Team Letter to Antoine Portmann, President and General Manager, Danone Waters of America: I am writing in reaction to findings that chlorothalonil transformation products have been found in Evian’s bottled water. Chlorothalonil is a dangerous, highly toxic pesticide. As a probable human carcinogen, there is no safe dose. The transformation products found in Evian bottled water can be removed by carbon filtration, but such treatment results in contaminated carbon and places the burden of removal on Evian, rather than the chemical companies. Although other pesticides have not been found so far in Evian’s water, there is no reason to believe that the Cachat Spring is safe from contamination from other chemicals. The answer is not to simply ban another toxic pesticide, only to be followed by another toxic pesticide, but make foundational changes to agriculture and land management with a shift to organic practices. I am writing to implore Evian and the Danone company to prominently support a worldwide shift to organic agriculture and land management. The Evian company is a victim of outdated, antiquated farming and land management practices, supported by the chemical industry that is poisoning the water supply worldwide. Evian bottled water is supposed to be so pure that scientists will calibrate their measuring devices with it. The fact that even the Evian springs in the French Alps, which are protected from most human impacts, contain pesticide residues is alarming and demonstrates that pesticides cannot be controlled. Evian, as a purveyor of “pure” water for people who are concerned about the contamination of their own local water supplies, should take actions to protect its water supply not through a chemical-by-chemical response, but with holistic and systemic change. As of 2020, chlorothalonil use is banned in the EU. However, long-distance transport is evidently responsible for the contamination of Cachat Spring water, and the presence of currently used pesticides in the Arctic is evidence of cause for concern. It is particularly worrisome that groundwater, as a principal source of drinking water, is increasingly found to be contaminated with pesticides, even those used far from the site where the groundwater is withdrawn. Action is required worldwide. I request that Evian protect the purity of its water by supporting Beyond Pesticides’ international campaign to transition to organic agriculture and land management. This effort not only protects groundwater, but it confronts the apocalyptic challenges we face as a global community with the climate crisis and the devastation of biodiversity. In the short-term, Danone should protect its consumers and its integrity by using filtration to remove chemical contaminants and labeling when they cannot be removed. However, using filtration is only a limited short-term fix that does not address underlying chemical dependency on hazardous and persistent pesticides that are not needed for land management. The company should protect its consumers and its integrity by using filtration to remove chemical contaminants and labeling when they cannot be removed. The contamination caused by toxic pesticide use, no longer needed to grow food or manage land safely and economically, has cascading effects and requires an urgent holistic response. I am asking you— will Danone become a leader in advancing organic agriculture and land management? Thank you, in advance, for your response.

07/20/2020 — Tell Public Officials to Stop Mosquito Spraying and Adopt a Safe, Effective Mosquito Management Plan

07/13/2020 — Demand to Keep the Soil in Organic, Reject the Labeling of Hydroponic Crops as Organic!

Soil is central to organic production. Therefore, hydroponic operations should not be considered eligible for organic certification, and the National Organic Program (NOP) must take a clear position in opposition to hydroponics and other non-soil-based methods in organic production, including containers. Organic farmers and consumers strongly agree that organic production must be soil-based. Tell NOP hydroponics is not organic! Educate your congressional representatives and senators. NOP authorizes the certification of hydroponic operations as organic. This undermines the authenticity of organic farming and creates unequal competition, market instability, and consumer distrust in organic certification. Organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on environmentally beneficial methods such as green manure, crop rotation, and biological pest management. On March 3, 2020, the Center for Food Safety (CFS) filed a lawsuit challenging the USDA’s decision to allow hydroponics operations to be certified organic. Organic farmers and consumers believe that the organic label means two things: grown in the soil and farmed in a manner that builds soil biology and the natural cycling of nutrients. Hydroponics meet neither of these requirements and involves methods of growing crops that is dependent on soluble synthetic nutrients. Soil Ecology Supports Healthy Crops

Historically, perhaps the most important principle of organic production is the “Law of Return,” which, together with the rule “Feed the soil, not the plant” and the promotion of biodiversity, provide the ecological basis for organic production and land management. Together these three principles describe a production system that works with natural systems. The Law of Return says that we must return to the soil what we take from the soil. Non-crop organic matter (residue) is returned directly or through composting plant materials or manures. To the extent that the cash crop removes nutrients, they must be replaced by cover crops, crop rotation, or additions of off-site materials, when necessary. Although some hydroponic producers may compost residues, they do not return the residues to the hydroponic system and close the loop. Inputs of organic matter reported by hydroponic practitioners are produced off-site, with no return to their production system. While most organic growers depend on some off-site inputs, most of the fertility in a soil-based system comes from practices that recycle organic matter produced on-site. The cycling of organic matter and on-site production of nutrients—as from nitrogen-fixing bacteria and microorganisms that make nutrients in native mineral soil fractions available to plants—is essential to organic production. The Law of Return is not about feeding plants, but about conserving the biodiversity of the soil-plant-animal ecological community. “Feed the soil, not the plant” reminds us that the soil is a living superorganism that supports plant life as part of an ecological community. We do not feed soil organisms in isolation, to have them process nutrients for crop plants; we feed the soil to support a healthy soil ecology, which is the basis of terrestrial life. Feeding the soil is intended to support the soil ecosystem is intrinsically counter to a hydroponic system. Hydroponics, in bypassing the soil ecology, rely on added plant nutrients that feed the plants. Additionally, creating a structure to house hydroponic goes against the legal requirement in federal organic law: “The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.” Biodiversity Conservation

Finally, biological diversity is important to the health of natural ecosystems and agroecosystems. The definition of “organic production” in the federal organic regulations requires the conservation of biodiversity. As stated in the NOP Guidance on Natural Resources and Biodiversity Conservation (NOP 5020), The preamble to the final rule establishing the NOP explains: “The use of ‘conserve’ [in the definition of organic production] establishes that the producer must initiate practices to support biodiversity and avoid, to the extent practicable, any activities that would diminish it. Compliance with the requirement to conserve biodiversity requires that a producer incorporate practices in his or her organic system plan that are beneficial to biodiversity on his or her operation.” (76 FR 80563) Biodiversity promotes ecological balance, which protects farms from outbreaks of damaging insects and disease. It supports the health of the soil through the progression of the seasons and stresses associated with weather and farming. It supports our health by offering a diversity of foods. On a soil-based organic farm, many practices support biodiversity—from crop rotations to interplanting to devoting space to hedgerows and other non-productive uses. Many of these practices can and should be used by farmers producing food in greenhouses. However, hydroponics is considered a monocultural environment that does not support biodiversity. Thus, it is not enough for a hydroponics producer to say it is not diminishing soil and plant biodiversity—the operation must take active steps to support biodiversity. Organic production allows exceptions to soil-grown produce like mushrooms, which grow on ecologically appropriate substrate such as manure or wood and sprouts. Sprouts are not required to be grown in soil because sprout production is a way of processing seeds. However, these exceptions imply that organic production is soil-based. The ecological system of a hydroponic nutrient system is more like a fermentation chamber—a means of processing plant nutrients—than the soil ecosystem of an organic farm. Integral to the Organic Foods Production Act (OFPA) is the understanding that soil is alive, not merely a medium for supporting plants, as is the case, to a large extent, in “conventional” chemical-intensive agriculture. “Conventional” farmers pour poisonous synthetic fertilizers into soil without the protecting the ecological community. Interestingly, in defining organic in OFPA, organic producers compared conventional agriculture to hydroponics because it bypasses the soil. Practitioners of hydroponics have learned the value of biology in their nutrient solutions. However, the biology of fermentation tanks is not “soil ecology,” although it is merely an artificial mimic of soil ecology and a reductionist approach to manipulating nature. Threatening the Value of the Organic Label

Organic farmers and consumers view the current interpretation of organic as a threat to the integrity of the organic seal, impacting every organic farmer and consumer in every state. The consideration of hydroponic production in organic is an issue that impacts every aspect of the organic industry. Members of the organic industry consistently rank this issue, maintaining consumer’s confidence in the organic seal, as a top priority and mandatory to their success. However, it is critical that we address any compliance limitations of organic certification systems when it occurs and ensure corrective action in a timely fashion with full transparency. Without this kind of response, public trust in the organic food label will suffer dramatically. Additionally, to the extent that the enforcement system is known to be highly rigorous, it will decrease the likelihood of aberrant behavior. One factor leading consumers to purchase organic produce is its perceived greater nutrient value. Research supports that perception—showing that nitrate concentrations in leafy vegetables are significantly different for hydroponic, conventional, and in-ground organic systems, with desired nutrients generally more concentrated in organic vegetables. Prior to the coronavirus outbreak, the organic industry was meeting with congressional staff to explain its position. We need your help to continue that effort as your outreach to NOP and your elected official is critical to our success. Because of the high turnover of congressional staff, groups opposing this policy need to continuously educate our elected officials on this issue. We urge you to take action by sending a letter to NOP and your congressional representative. Tell NOP hydroponics is not organic! Educate your congressional representatives and senators. Thank you!

The Beyond Pesticides Team

07/06/2020 — Tell EPA to Ban the Persistent Toxic Herbicide Clopyralid that Contaminates Compost

EPA’s proposed interim decision (PID) on the weed killer clopyralid is inadequate to protect human health, property, nontarget plants, and pollinators from damage. Clopyralid poses unreasonable adverse effects that cannot be remedied by EPA’s proposed fixes. It should be banned. Sign the petition by noon Monday, July 6! Tell EPA to ban the persistent toxic herbicide clopyralid. Clopyralid is a toxic persistent herbicide used to control broadleaf weeds on lawns and turf, range, pastures, right-of ways, and on several crops. Approximately 1.6 million pounds of clopyralid is used on 20 million acres per year in the U.S. on agricultural land, but it is also commonly used to kill dandelions, clover, and thistles. Lawn care operators applied over a million pounds of clopyralid in 2013. Clopyralid is notorious for causing damage to nontarget plants. The registration was modified in 2002 to delete residential turf uses from the clopyralid product label. Additionally, under the amended label professional applicators are required to notify property managers not to compost clippings from treated grass. EPA proposes to expand the prohibition to include school turf, but clopyralid products will continue to be used on golf courses and certain other forms of nonresidential turf, as well as farm, ranch, and forestry uses. Clopyralid causes environmental and property damage through drift, runoff, use of treated plant material (such as straw or grass clippings) for mulch or compost, contaminated irrigation water, and urine or manure from animals consuming treated vegetation. Clopyralid is “considered volatile,” according to EPA, meaning that it can evaporate from foliage and soil after application, move away from the application site, and “adversely affect nontarget broadleaf plants.” EPA calculated that volatilization of only one percent of applied clopyralid would be enough to damage nontarget plants. Clopyralid can cause damage to sensitive plants at levels of 10 parts per billion. It is not broken down in composting facilities, and composters are very concerned about carry-over of clopyralid and other persistent herbicides, such as aminopyralid, aminocyclopyrachlor, and picloram into compostable materials. Clopyralid can enter the composting facility through lawn clippings, hay, straw, crop residues, and manure. Compost facilities now test for residues of persistent herbicides, but such tests are time-intensive and expensive. In November 2002, the registration of clopyralid for use on residential lawns was voluntarily cancelled by the registrant, Dow AgroSciences. However, compost feedstocks are contaminated by other uses that are still allowed. Residues from any of these uses may find their way to composting facilities. Grass clippings, hay, and straw may also be used as mulch, allowing direct transfer of the herbicide to susceptible plants. The contaminated mulch and compost may be used by homeowners, landscapers, or organic farmers. In the case of homeowners, it can mean the loss of expensive plantings. Landscapers may be liable for damages. In the case of organic farmers, it can mean the loss of a crop and possibly the loss of organic certification. Clopyralid is not metabolized by animals but passes through in urine and feces. Thus, farmers and composters are advised to avoid manure from animals that may have eaten hay or feed that may be contaminated with it or other persistent herbicides. EPA proposes label amendments to mitigate these problems. If these label restrictions are followed, they may minimize the spread of clopyralid residues into sensitive areas. Doing so, however, reduces the availability of organic nutrients for crops and compost makers, thus burdening organic farmers and composters. This places undue burdens on those who do not benefit from the use of the herbicide and makes agriculture less sustainable. Instead, registrations of clopyralid and other persistent herbicides should be cancelled. All herbicides, especially those targeting broadleaved plants, pose the risk of removing plants that provide food and habitat for pollinators. Some of those pollinators may be threatened or endangered species. As EPA admits, it has not evaluated risks to threatened and endangered species. Nor has it completed endocrine disruption evaluation. Since both of these are very sensitive consequences—that may result from much lower exposures than those evaluated thus far—reregistration must not proceed until those evaluations—including consultation with U.S. Fish and Wildlife Service and National Marine Fisheries Service—are complete. Although EPA downplays them, clopyralid does present human health risks. Clopyralid is classified by EPA in acute toxicity class III as slightly toxic. Laboratory studies have shown that clopyralid is a severe eye irritant and dermal irritation has also been noted, which can lead to skin sensitization for prolonged skin exposures. Some developmental and reproductive effects have been observed in laboratory animals. The livers and kidneys of rats as well as the livers of dogs were affected by changes in weight and decreased red blood cell counts. Another study found that weights of rabbit fetuses decreased at both low and high doses of clopyralid. Skeletal abnormalities were also observed in these fetuses at all doses. Clopyralid products also contain toxic contaminants and “inert” or “other” ingredients. Resistance to herbicides is an expected consequence of their use, so any perceived benefit of using an herbicide must be discounted by its reduced lifespan as an effective weed control. There are currently 514 unique cases (combinations of species and sites of action) of herbicide resistant weeds globally, with 262 species (152 dicots and 110 monocots). Weeds have evolved resistance to 23 of the 26 known herbicide sites of action and to 167 different herbicides. Herbicide resistant weeds have been reported in 93 crops in 70 countries. Resistance to clopyralid is known in four species, and resistance to other synthetic auxins has been documented in other species. The growth of organic agriculture demonstrates the viability of nontoxic alternatives in agriculture. Nonorganic producers are looking to organic practices for help in dealing with the problem of herbicide resistance. In turf systems, managers are increasingly successful using organic systems, often mandated by local ordinances. The use of clopyralid poses risks to human health, property, and the environment that are borne mostly by those who do not receive any benefit from the use of the herbicide. The risks are not outweighed by benefits, so the registration of clopyralid should be cancelled. See Beyond Pesticides comments for more details and references. Sign the petition by noon Monday, July 6! Tell EPA to ban the persistent toxic herbicide clopyralid.

06/29/2020 — Tell USDA to Reject Bayer-Monsanto’s Multi-Herbicide Tolerant Corn—Please sign the petition by Monday, July 6, 4pm EDT

Bayer’s Monsanto is requesting non-regulated status for corn that will increase the use of drift-prone and toxic herbicides. This means that the planting of a new genetically engineered (GE) variety of corn, which requires substantial weed killer use, will not be restricted in any way. The syndrome of ‘more-corn, more-pesticides, more-poisoning, more-contamination’ must stop—as we effect an urgent systemic transformation to productive and profitable organic production practices. Because USDA is proposing to allow a new herbicide-dependent crop under the Plant Protection Act, the agency must, but does not, consider the adverse impacts associated with the production practices on other plants and the effects on the soil in which they are grown. Business as usual is not an option for a livable future. Sign the petition. Tell USDA we don’t need more use of 2,4-D, Dicamba, and other toxic herbicides associated with the planting of new GE corn. Bayer-Monsanto has developed multi-herbicide tolerant MON 87429 maize, which is tolerant to the herbicides 2,4-D, dicamba, glyphosate, glufosinate, and aryloxyphenoxypropionate (AOPP) acetyl coenzyme A carboxylase (ACCase) inhibitors (so-called “FOP” herbicides, such as quizalofop). Now the company wants this corn to be deregulated—allowing it to be planted and the herbicides use without any restrictions. The petition below, and our formal comments explain the dangers in greater detail. 2,4-D is a phenoxy herbicide that is as well known for its propensity to drift as it is for its damaging health and environmental effects. Approval of Bayer-Monsanto’s application would result in adverse impacts and contamination, along with the demonstrated plant-damaging effects. Over the decades of its use, 2,4-D has been linked to an increased risk of birth defects, reduced sperm counts, increased risk of non Hodgkin lymphoma, Parkinson’s disease, and hormone disruption, as well as other health problems. 2,4-D drift has long been a known problem to off-site locations, endangered species, and non-target crops. Many forms of 2,4-D volatilize above 85oF and 2,4-D drift has been known to damage tomatoes, grapes, and other plants. Herbicide concentrations 100 times below the recommended label rate have been reported to cause injury to grapes. Dicamba is a selective benzoic acid herbicide similar in structure and mode of action to phenoxy herbicides like 2,4-D. We have concerns that increased use of dicamba will lead to elevated human and environmental exposures, and especially via contamination of waterways. Concerns about dicamba drift have already proved to be valid. First registered in the late 1960s, dicamba has been linked to cancer, reproductive effects, neurotoxicity, birth defects, and kidney and liver damage. It is also toxic to birds, fish and other aquatic organisms, and known to leach into waterways after an application. It is a notoriously drift-prone herbicide. Studies and court filings show dicamba able to drift well over a mile off-site after an application. Glyphosate is a broad spectrum, post-emergent, non-selective systemic herbicide used on non-cropland, as well as a variety of crops. It has seen the largest use in crops that are genetically engineered to be tolerant to it, where it can kill most grassy and broadleaved plants. Glyphosate products, such as Monsanto’s Roundup, are formulated with surfactants and other ingredients to increase its effectiveness as a weed killer. Reviews of glyphosate and glyphosate-based herbicides demonstrate a growing scientific consensus and concern about their health, environmental, and social impacts. A group of well-known and respected scientists collaborated on a consensus “Statement of Concern” stating that glyphosate is more persistent in the environment than previously believed and that evidence has accumulated over the past two decades, showing that glyphosate-based herbicides have serious impacts on human health and the environment, the extent of which has yet to be fully determined. Epidemiological studies—in which exposure is to formulated products rather than the technical grade active ingredient glyphosate—have found a positive association between exposure to glyphosate-based herbicides and cancer. On March 20, 2015, the International Agency for Research on Cancer (IARC) announced that it had classified glyphosate as a class 2A carcinogen, as “probably carcinogenic to humans.” This category is the most definitive of any based on standard laboratory animal testing. An April 2019 report by the Agency for Toxic Substances and Disease Registry (ATSDR) — an agency of U.S. Department of Health and Human Services — documented evidence of findings that support glyphosate’s carcinogenicity. Glyphosate is also an antibiotic and, as such, has negative impacts on the human gut biota. The imbalance (dysbiosis) of bacteria in the gut has been associated with many modern diseases. Use of antibiotics, like glyphosate, in agriculture allows residues of antibiotics and antibiotic-resistant bacteria to emerge on agricultural lands, move through the environment, contaminate waterways, and ultimately reach consumers in food. Both the human gut and contaminated waterways provide incubators for antibiotic resistance. The Northwest Center for Alternatives to Pesticides summarizes the effects of glufosinate: Glufosinate is a broad-spectrum herbicide that kills plants by inhibiting the enzyme glutamine synthetase, an enzyme also found in animals, including humans. Glufosinate chemically resembles glutamine, a molecule used to transmit nerve impulses in the brain. Neurotoxic symptoms observed in laboratory animals following ingestion, dermal exposure, or inhalation of glufosinate include convulsions, diarrhea, aggressiveness, and disequilibrium. Dogs appear to be the laboratory animal most sensitive to glufosinate. Ingestion of glufosinate for two weeks caused heart and circulatory failure resulting in death. Exposure of pregnant laboratory animals to glufosinate caused an increase in premature delivery, miscarriages, the number of dead fetuses, and arrested development of fetal kidneys. Concentrations of a glufosinate-containing herbicide of less than one part per million cause mortality of oyster and clam larvae. Several species of disease-causing fungi are resistant to glufosinate, while a beneficial fungus that parasitizes disease-causing fungi is very susceptible to glufosinate. This means that use of glufosinate can have “important microbiological consequences. Quizalofop is a developmental and reproductive toxin and recognized as an endocrine disruptor by the EU. It carries the signal word “Danger” and requires full protective equipment. The label carries the signal word “Danger,” warning of health and environmental hazards. Dicamba and 2,4-D vapor drift and subsequent crop injury to sensitive broadleaf crops have been frequent problems. Abnormal leaf growth, floral development, reduced yield, and reduced quality have all been observed from dicamba drift. These impacts have severe economic consequences for non-GE and organic farmers. The burden should not be placed on these farmers to protect themselves from drift with best management practices. The Animal and Plant Health Inspection Services (APHIS) cannot assume that the environmental impacts associated with herbicide drift will be mitigated by the registration requirements established by EPA on pesticide labels. Unfortunately, label directions have been shown to have no effect on decreasing spray drift. In fact, EPA has acknowledged this and has attempted to review and revise pesticide labeling guidance. EPA’s efforts to mitigate against potential risks from drift by requiring buffer zones and application restrictions have proven ineffective. USDA Must Deny Monsanto’s Petition. APHIS has a responsibility under the law, the Plant Protection Act, to prohibit and/or restrict any plant or plant product that poses a risk to the environment. APHIS must fully review the salient impacts of multi-herbicide-tolerant MON 87429 corn, and the expected increase in use of drift-prone and toxic herbicides and reject the petition for deregulation. GE crops are not the solution for glyphosate resistant weeds created by glyphosate-resistant GE crops. Had a proper environmental assessment been conducted by APHIS on previous GE decisions, the economic and environmental threat of resistant, invasive weeds may have been avoided. It is time for the agency to focus on other sustainable, integrated methods for long-term weed management, which allow our nation’s farmers to get off the toxic treadmill. USDA/APHIS must not escalate the American agricultural economy’s broad reliance on herbicides because of the failure of glyphosate GE technologies. Now is the time to concede that GE technologies have not lived up to their promises and encourage our nation’s farmers to return to more sustainable methods of farming. Sign the petition. Tell USDA we don’t need more use of 2,4-D, Dicamba, and other toxic herbicides associated with the planting of new GE corn. Thank you!

The Beyond Pesticides Team

06/22/2020 — Pollinator Week: We Protect People at Greatest Risk When We Protect Pollinators and the Environment from Toxic Pesticides

06/15/2020 — Take Action: Tell Congress to Save Our Oceans from Trump’s Executive Order

06/09/2020 — EPA Must Deny Routine “Emergency” Exemptions for This Bee-Toxic Pesticide

EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. These three states (and others) have received emergency exemptions for this use for the nine previous years and it must not be allowed for a tenth year. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses. Sign the Petition to EPA and Send a Letter to Your Congressional Representative and Senators: EPA Must Deny Routine “Emergency” Exemptions As a neocotinoid insecticide, dinotefuran presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack. Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems. With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. In fact, an organic systems plan must not allow the use of synthetic pesticides unless the use of management techniques—including crop rotation, crop nutrient management, sanitation, “selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases,” management of predators and parasites, and use of lures, traps, and repellents—are shown to be insufficient. In addition, the synthetic chemicals they use must meet stringent requirements prohibiting harm to human health and the environment. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption. In 2006, EPA promulgated regulations making it easier to issue repeat emergency exemptions, despite the fact that the definition of an emergency condition requires an “urgent, non-routine situation.” In the case of dinotefuran, EPA has approved 125 emergency exemptions in eight states from 2011 through 2019 to kill brown marmolated stinkbugs in pome and stone fruits. The emergency exemptions were approved for all nine years in five states, eight years in two states, and four years in one state. EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration. If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working. Sign the Petition to EPA and Send a Letter to Your Congressional Representative and Senators: EPA Must Deny Routine “Emergency” Exemptions Please sign the petition by June 10. It will be delivered to EPA before the end of the comment period on June 11. A copy will be delivered to your congressional Representative and Senators. Please also consider adding to your impact by submitting your own comments to Regulations.gov. Thank you,

The Beyond Pesticides Team PETITION TO EPA: To EPA Docket EPA-HQ-OPP-2020-0264: Beyond Pesticides and the undersigned oppose granting emergency exemptions for dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. EPA’s allowance of an emergency pesticide application of a pesticide every year for nine years is not justifiable and it must not be allowed for a tenth year. EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. The three states (along with others) have received emergency exemptions for this use for the nine previous years. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses. Dinotefuran, as a neonicotinoid insecticide, presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack. Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems. With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. In fact, an organic system plan must not allow the use of synthetic pesticides unless the use of management techniques—including crop rotation, crop nutrient management, sanitation, “selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases,” management of predators and parasites, and use of lures, traps, and repellents—are shown to be insufficient. In addition, the synthetic chemicals they use must meet stringent requirements prohibiting harm to human health and the environment. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption. In 2006, EPA promulgated regulations making it easier to issue repeat emergency exemptions, despite the fact that the definition of an emergency condition requires an “urgent, non-routine situation.” In the case of dinotefuran, EPA has approved 125 emergency exemptions in eight states from 2011 through 2019 to kill brown marmolated stinkbugs in pome and stone fruits. The emergency exemptions were approved for all nine years in five states, eight years in two states, and four years in one state. EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration. If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working. Thank you. Letter to Congress Please tell EPA not to grant emergency exemptions for the bee-toxic insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. EPA’s allowance of an emergency pesticide application of a pesticide every year for nine years is not justifiable and it must not be allowed for a tenth year. EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. The three states (along with others) have received emergency exemptions for this use for the nine previous years. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses. Dinotefuran, as a neonicotinoid insecticide, presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack. Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems. With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption. EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials.. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration. If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working. Thank you.

06/01/2020 — Tell the National Organic Program that Inaction on “Inert” Ingredients Is Unacceptable

During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of the National Organic Program at USDA to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. The NOSB has only one alternative left to force USDA action—denying relisting at the Fall meeting. >>Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now. Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.” In fact, the ingredients not listed on a label of a pesticide product—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to disclose and test all ingredients in pesticide products, as well as the full formulation. The research tested the toxicity of the herbicide glyphosate, so-called “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, they studied a number of other pesticides. Although GBH products are not permitted in organic production, the results of the Defarge et al study are relevant to decisions concerning materials used in organic crops and livestock. The scientists found that for GBH products, glyphosate was not the major toxic component–to either plants or human cells–and that formulations, as well as glyphosate alone, are endocrine disruptors at low concentrations. Glyphosate alone did not show herbicidal effects on tomato plants for five days following application. Formulations that included POEA (polyethoxylated tallowamine) are the most toxic to plants and human cells, and POEA itself is highly toxic to plants and animals. GBH formulations are no more toxic to plants than the formulants (“inert” ingredients). The researchers concluded, “Hence G [glyphosate] did not appear to be the main active substance of the herbicide, but rather the formulants.” The researchers also identified a number of other toxic substances in the products, including arsenic, chromium, cobalt, nickel, and lead. Arsenic was present in almost all samples. This research challenges the apparent assumption by NOP that “inert” ingredients are less important to review than “active” ingredients. The “active” ingredients in pesticide products used in organic production receive intense scrutiny before the NOSB allows their use. However, “inert” ingredients –which, as the Defarge et al study demonstrates, may actually be the active ingredients— have not received any scrutiny by the NOSB for compliance with OFPA criteria. In the Beyond Pesticides report “Inert” Ingredients Used in Organic Production, we summarize what is known about the toxicity of the 127 “inerts” then known to be used in organic production, compared to the 39 synthetic active ingredients on the National List. More “inerts” than active ingredients used in organic production have been shown to be acutely toxic, neurotoxic, carcinogenic, nephrotoxic or hepatotoxic, sensitizers, endocrine disruptors, and toxic to aquatic organisms. NOP must respond to the NOSB recommendations that “inert” ingredients used in organic production be reviewed by the NOSB according to OFPA criteria by initiating actions to carry out NOSB recommendations. >>Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now. Letter to Secretary Perdue, Administrator Tucker, NOP Deputy Administrator Tucker: I am concerned that the National Organic Program (NOP) has not followed through with recommendations from its advisory board, the National Organic Standards Board (NOSB), to fully review “inert” ingredients in pesticide products used in organic production according to the standards of the Organic Foods Production Act. During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of NOP to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. NOP inaction leaves NOSB with only one alternative—denying relisting at the Fall meeting. Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.” In fact, ingredients not listed on a pesticide product label—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, reported in “Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides” (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini, tested the toxicity of the herbicide glyphosate, so-called “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, they studied a number of other pesticides. Although GBH products are not permitted in organic production, the results of the Defarge et al study are relevant to decisions concerning materials used in organic crops and livestock. The scientists found that for GBH products, glyphosate was not the major toxic component–to either plants or human cells–and that formulations, as well as glyphosate alone, are endocrine disruptors at low concentrations. The researchers concluded, “Hence G [glyphosate] did not appear to be the main active substance of the herbicide, but rather the formulants.” The researchers also identified a number of other toxic substances in the products, including arsenic, chromium, cobalt, nickel, and lead. This research challenges the apparent assumption by NOP that “inert” ingredients are less important to review than “active” ingredients. The “active” ingredients in pesticide products used in organic production receive intense scrutiny before the NOSB allows their use. However, “inert” ingredients–which, as the Defarge et al study demonstrates, may actually be the active ingredients—have not received any scrutiny by the NOSB for compliance with OFPA criteria. In the report “Inert” Ingredients Used in Organic Production, Beyond Pesticides summarizes what is known about the toxicity of the 127 “inerts” then known to be used in organic production, compared to the 39 synthetic active ingredients on the National List. More “inerts” than active ingredients used in organic production have been shown to be acutely toxic, neurotoxic, carcinogenic, nephrotoxic or hepatotoxic, sensitizers, endocrine disruptors, and toxic to aquatic organisms. NOP must respond to the NOSB recommendations that “inert” ingredients used in organic production be reviewed by the NOSB according to OFPA criteria by initiating actions to carry out NOSB recommendations. Thank you.

05/22/2020 — Take Action: Tell USDA to Crack Down on “Organic” Livestock Factories

For years, USDA has been looking the other way as giant corporate agribusinesses, primarily producing conventional eggs and poultry, have squeezed family-scale farmers out of the market and misled and defrauded consumers. Due to a lawsuit challenging the Trump administration on the scuttling of new rules that would make it harder for factory farms to qualify for organic status, USDA is seeking input on what was previously an error-filled and biased economic assessment of the rulemaking. Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings. If you would prefer to write your own custom comment you can submit it on Regulations.gov. Letter to National Organic Program (Jenny Tucker, Ph.D. To the National Organic Program: Please include my comment below in evaluating the economic analysis report pursuant to the Organic Livestock and Poultry Practices rulemaking. Docket number: AMS-NOP-20-0037 Both the current and previous OLPP analyses include the following misstatements and omissions: It is a misconception to refer to, and judge, the economic impacts of the OLPP as if the requirement for outdoor access was a new and onerous regulation. In fact, from the beginning of the USDA organic program, “all” organic livestock have been required to have access to the outdoors. The new proposed rule does nothing more than create some enforceable benchmarks to facilitate oversight by USDA and its accredited third-party certifiers.



Analyzing the economic impact, as if this were a new regulatory obligation, is misdirected. All organic livestock producers should have been providing meaningful outdoor access from day one.



Factoring in impacts on retail pricing is not germane to this decision-making. The size of the market is irrelevant. When consumers pay a premium for organic eggs and poultry, they expect that the birds are being managed in accordance with the law, which requires outdoor access and promotion of the natural instinctive behaviors of the animals.



True organic management of meat birds and laying hens is not currently possible in the massive industrial-sized buildings that USDA has allowed to be certified. Investments were made in these structures while it was known that elements in the organic industry were challenging the legality of the operations and, thus, their investments have always been at risk.



In England and the European Union, organic birds have always had access to the outdoors in smaller flocks. Subsequently, the price differential between conventional and organic eggs has been greater. However, the market share for organic in many of those countries surpasses that of the United States. Organic consumers already assume that they are buying eggs and poultry produced with a higher level of animal welfare. They are currently being defrauded. The question of their willingness to pay a premium is irrelevant.



If some of the larger operators are forced to exit, entrepreneurs will quickly scale-up to meet new market demand. The shift to producers who comply with both the spirit and letter of the law should not be a factor in implementing the new rulemaking.



Regardless of how much outdoor space is provided, it is not possible to offer legitimate access when birds are housed in giant, multitiered aviary systems. Buildings housing as many as 100,000-200,000 birds prevent the expression of instinctual behavior, a regulatory requirement, as it would be necessary to walk over thousands of other birds in order to access a door. Believing otherwise is a myth perpetuated by corporate interests in egg production.



Because USDA’s analysis starts from the wrong baseline—one that is not consistent with the law–the analysis omits the economic injury to family-scale farmers who are currently complying with the regulations by allowing birds meaningful access to the outdoors that continues when the OLPP is not implemented. Furthermore, there are many family farmers who have been prevented from entering the organic market for poultry meat and eggs because, as it has grown, market share has been dominated by giant conventional ag companies that have gamed the system to achieve lower operating costs and higher profitability. In conclusion, any economic analysis of the impact of new rulemaking should be viewed through the prism of the Organic Foods Production Act and its current regulations. To do otherwise places family farmers at a competitive disadvantage and perpetuates a fraudulent myth that the majority of organic poultry, managed by corporate agribusiness, is truly “organic.” Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings.

05/18/2020 — Tell USDA and Congress: #DoBetterUSDA and Support Small Organic Farmers

In response to the coronavirus pandemic, the United States Department of Agriculture (USDA) is putting forth a Coronavirus Food Assistance Program (CFAP) that funnels money from the Coronavirus Aid, Relief, and Economic Security (CARES) Act and other sources directly to farmers. However, agricultural justice advocates are questioning just who is going to benefit from the aid packages. Due to corporate and governmental interplay, we know that the agrichemical industry and big commodity crop farmers are at the top of the list. It remains unclear how small, diversified farms can apply for financial assistance. There is little to no mention of equity in USDA aid distribution that considers farmers of color, farmworkers, or assistance for organic farms. As it stands, large, chemical-intensive commodity farmers may benefit while many of our neighbors get left behind >> Turn up public pressure to help small, organic farmers: Tell USDA to #DoBetterUSDA CARES specifies that USDA must support “producers of specialty crops, producers that supply local food systems, including farmers markets, restaurants, and schools, and livestock producers, including dairy producers.” Despite this, USDA's action plan to implement the CARES Act does very little to address the needs of local, diversified, and organic agriculture. There are two parts to the CFAP funding: $16 billion in direct payments to commodity growers, specialty crop farmers, and livestock and dairy producers. Payments will be based on actual losses. Farmers can collect no more than $125,000 per commodity, and there is an overall limit of $250,000. The commodity must have experienced at least a 5% decline in price since January. $3 billion in direct purchases of meat, dairy, and specialty crops. USDA is paying for food from farmers to fill food boxes for families in need. Fresh food is being prioritized, but there is no mention of organic agriculture. The further distribution of funds and coordination for this program is unclear, as the rule is still pending approval by the White House Office of Management and Budget (OMB). However, the following preliminary breakdown of direct payments has been reported: $9.6 billion – livestock and dairy producers

$3.9 billion – row crop producers (i.e. corn, soybeans, cotton)

$2.1 billion – specialty crops (i.e. fruits, vegetables, nuts)

$500 million – other crops (i.e. hemp, horticulture, goats, sheep) USDA offered a short webinar on May 14th, mainly describing paperwork requirements for farmers to document their income and recent, pandemic-induced losses. Farmers are to contact their local Farm Service Agency (FSA) to apply for funding. Proving loss is much more difficult for diversified, small, and organic farmers than commodity crops. Additionally, some small farms are actually seeing an increase in revenue, and therefore will not qualify for funding, though they may need help scaling up to meet new demand. Bobby Pahia, a Maui farmer (Hoaloha Farms) says, “I'd appreciate an aid package that helps small farms grow through this crisis, instead of just calculating loss—aid that funds solutions instead of paying for failures. We could improve distribution streams during this crisis, and beyond. Let's put systems in place that better connect farms to schools and communities. Let's find the failures in the current system, and then use aid packages to fund solutions. If we use these historic aid packages to build a strong foundation of support for small farmers, we can improve the long term health of communities and our environment, all while responding to Covid-19 shutdowns.” According to the National Sustainable Agriculture Coalition, “Right now, the program [CFAP] isn't set up to account for farmers who sell into local/regional markets, diversified farmers, or organic farmers. It doesn't have a thorough outreach plan or reserved funding for underserved producers (including farmers of color). It doesn't reflect realistic timelines for farmers' losses or their increased expenses in addition to their losses. And it does not focus aid on independent, family-scale livestock producers who need help (instead of large corporate operations). In short, we have many questions, and we need answers to ensure this program reaches all farmers impacted by the current crisis.” John Dobovan, a Maui farmer (Kulahaven Farms), says, “If we are going to have a truly sustainable a