

(Beyond Pesticides, March 17, 2019) Forget about single-pesticide issues: this affects every single one of them. EPA is allowing massive data gaps to persist for each and every pesticide product it registers by conducting the bulk of its health and environmental risk assessments using active ingredients alone. With its current practices, EPA is failing its federal mandate to protect public health and the environment and misleading the public about what is “safe.”

Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients.

When pesticides are sprayed on our crops, lawns, and roadsides, and enter into our waterways, groundwater and drinking water, we are exposed to whole formulations, whole tank mixtures, and whole pesticide combinations, not just active ingredients (those that the manufacturer claims are the only ingredients that attack the target pest). It is the whole formulation that makes the poison, and that whole formulation must be regulated.

Active ingredients are far from the whole story of pesticide poisoning. Despite their name, “inert” ingredients are very often not chemically, biologically, nor toxicologically inert or innocuous. According to a peer-reviewed study, as of 2006, more than 500 ingredients that were listed as “inert” in some products serve as the active ingredient in other products. Many “inert” ingredients are known to state, federal, and international agencies to be hazardous to human health. One of the most hazardous ingredients in common formulations of the popular herbicide Roundup is a surfactant, which is classified as an “inert,” and therefore not listed on the label. A 2013 study found that some Roundup adjuvants are 9,661 times more toxic to human cells than the active ingredient glyphosate. The real threats of herbicides, fungicides, and insecticides are masked when EPA only tests active ingredients.

Synergy between ingredients adds yet another layer to the stack of untested threats. Ingredients added to formulations are specifically selected for their ability to make the active ingredient more potent, yet these effects are ignored in the vast majority of EPA-required testing. A 2016 Center for Biological Diversity (CBD) Investigative report found that 69% of recently approved pesticide patent applications claimed or demonstrated synergy between ingredients in the product.

Based on EPA’s current policies, the agency does not require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor does it require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.

To put it another way: EPA has no idea whether the pesticide products it registers and claims pose an “acceptable risk” could cause cancer, chronic disease, developmental delays, or infertility. EPA has no idea whether the pesticide products it registers could harm or kill birds, fish, aquatic invertebrates, or honey bees. These data gaps are alarming and unacceptable, and a misinterpretation of the law.

Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients.

If you have a moment, please take a few minutes to navigate to EPA’s public comment page and tell EPA directly that it must require whole mixture testing. By clicking on ‘Comment Now!’ you can become part of the official decision-making process in this critical, far-reaching issue. See below for suggested comments (which you can cut-and-paste into the EPA docket), or personalize your own.

(Suggested Comment):

I am writing in support of the policy amendments detailed in the petition, “Seeking Revised Testing Requirements of Pesticides Prior to Registration,” Docket # EPA-HQ-OPP-2018-0262-0001.

Whole pesticides must be tested across all areas of toxicity in the same form in which they are commonly applied, in order to comply with FIFRA and adequately protect the environment and public health.

Based on published policies (40 C.F.R § 158.500-660), EPA does not currently require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor does it require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.

By requiring only the active ingredient for the majority of pesticide risk assessment tests, EPA is failing to adequately protect against known widespread hazards of “inert” ingredients and their synergistic effects on whole pesticide toxicity.

EPA must fulfill its federal mandate and test whole pesticide formulations and mixtures, as they are commonly applied. Anything less falls short of adequate protection under the law.

Sincerely,