Big Changes Called for to Sever the Roots of Injustice in the Distribution of Pesticide Risks and Benefits

Eaters Deserve More Complete Information About Nutrition and Health Impacts on Food Labels
Multiple lines of evidence point to consumer food choices as major contributors to diet-related disease, and poor health and fitness. In a peer-reviewed journal article published today, authors Chuck Benbrook and Robin Mesnage cite studies indicating that “Some 90% of the estimated USD 4.3 trillion in annual health care costs in the US is triggered or made worse by poor food quality and diet-related disease.” Benbrook is the founder and former executive director of the Heartland Health Research Alliance (HHRA). The authors recommend novel metrics on both the nutrient density of food, and how to more accurately and usefully characterize the degree of food processing and its impacts on public health. The article is open access in the journal Foods and entitled “Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets.” The core nutrient density metric is a ratio: the percent of daily nutrient needs satisfied by a serving of food relative to the percent of a 2000 calorie daily diet taken up by the serving of food. This single metric is unmatched in comprehensively reflecting the nutritional quality of food. A graphic option to convey the metric on packaging is presented in Figure 3 in the new paper: A novel graphic is presented in Figure 5 to which integrates both the nutrient density and food processing metrics and graphics in a single graphic, shown below. The impacts of ultra-processed food (UPF) on public health outcomes is among the hottest topics in nutrition, medical, and public health journals, and media coverage on food quality and health outcomes. At the request of the journal, the authors developed a video abstract that explains the paper’s goals, methods, and key findings and recommendations. The authors conclude their paper with these observations: Transparent and accurate food product-specific ingredient and nutrient composition data should determine the content of nutrition health labeling. Efforts to soften the message should be resisted in light of the overwhelming need for new food labels that help bring about substantial improvements in food nutritional quality and dietary choices. Benbrook and Mesnage’s paper builds on public comments HHRA submitted in response to the US Food and Drug Administration (FDA) proposed rule in 2023 to update the definition of the term “healthy” on food labels. The proposed role would require foods labeled “healthy” to contain minimum amounts of foods recommended by USDA’s Dietary Guidelines, and to limit saturated fat, sodium, added sugar and other less healthy nutrients. Entitled “Food Labeling: Nutrient Content Claims; Definition of Term `Healthy’”, the comments recommended new nutrition/health messaging on the front of food packaging. Co-authors of comments included the chair of HHRA’s Policy Advisory committee Dr. Kathleen Merrigan, HHRA science advisors, and other experts working on how changes in farming systems and technology can increase the nutritional quality of food: Dr. Hannah Flower, Dr. Donald R. Davis, Dr. David Montgomery and Anne Biklé. In the comments, the authors introduced “NuCal” as a name for their new system. Resources HHRA February 2023 comments to the FDA. Benbrook and Mesnage (2024). Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets, Foods. https://doi.org/10.3390/foods13213377 Video Abstract: “Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets”
HHRA Weighs in on Key Pesticide Issues Under Review by the National Organic Standards Board
HHRA and ORG-Tracker, represented by Dr. Chuck Benbrook and Dr. Brian Baker, submitted comments to the Agricultural Marketing Service at the USDA in advance of the National Organic Standards Board (NOSB) meeting in Portland, Oregon, from October 22nd to 24th, 2024. Drs. Benbrook and Baker will both attend the conference and deliver public comments. ORG-Tracker is a project carried out by HHRA. It aggregates pesticide residue data from inspections of organic farms carried out by certifiers. The tables generated by ORG-Tracker utilize the results of certifier testing to compare residue frequency and risk levels to food produced on conventional farms. The team is working to more effectively highlight gaps and challenges faced by certification agencies to answer questions like What crops should we be testing, and where? Is a pesticide residue found in an organic sample likely caused by accident, pesticide drift, or an intentional and illegal application? How can we modify organic programs to better mitigate risk? The comments delivered to the USDA discuss risk-based certification, pesticide residue testing, and policies impacting the incorporation of so-called inert ingredients in the biopesticides approved for use on organic farms. They argue for a more rigorous, comprehensive, and health-focused approach to risk oversight. Regarding residue testing, they advocate for more expansive and effective data aggregation to inform consumers and the organics community. Finally, for inert ingredients, they recommend further review of current policy, including increased transparency of ingredients in pesticide products. Thank you to Drs. Benbrook and Baker for your advocacy and hard work! The three sets of comments are posted on HHRA’s website as part of our policy program: Comments to the NOSB on the Risk-Based Certification Discussion Document Under Consideration During the October 2024 Meeting in Portland, Oregon Written Comments on the NOSB Discussion Document “Residue Testing for the Global Supply Chain” Comments on the Inert Ingredients in Organic Pesticide Products Proposal dated August 13, 2024 Drs. Benbrook and Baker also submitted and presented comments at the Spring 2024 meeting of the NOSB, which are available on HHRA’s Policy and Regulatory Reform page.
Dr. Kimberly Yolton joins HHRA board
Dr. Yolton is a developmental psychologist and epidemiologist serving as Professor of Pediatrics at Cincinnati Children’s Hospital Medical Center. Her interests include exposures and experiences that may alter a child’s developmental trajectory from infancy through adolescence. She collaborates on research projects on typical child development as well as those focused on the impact of exposures to environmental toxicants, opiates and stress during early development.
Paul Hartnett, HHRA’s Executive Director
Paul Hartnett has served as HHRA’s CFO since our founding . With the departure of Russell King, Paul has now joined the board and Executive Director. We thank Russell for his service and wish him the best in his future endeavors.
Heartland Study Enrolls 1,000th Mother-Infant Pair
July 19, 2024 – In June of this year, the Heartland Study achieved a major milestone, enrolling its 1,000th mother-infant pair. Enrollment is now at 50% of goal. The objective of the Study is to help fill major gaps in our understanding of the impacts of herbicides on maternal and infant health. Currently in Phase 1, the Study is focused on evaluating associations between herbicide concentrations in body fluids and tissue samples from pregnant women and infants, and pregnancy/childbirth outcomes. Phase 2 is designed to evaluate potential associations between herbicide biomarkers and early childhood neurological development. Much appreciation for the mothers enrolled, and the entire Heartland Study Team including scientists, support staff and clinicians for this tremendous achievement, and for our funders to making this work possible. Read more about the study including peer-reviewed studies published in Chemosphere and Agrichemicals at our publications page. The investment required to conduct this study exceeds $1 million each year. You can support this important work by making a donation here.

Have you heard: A new study has reported that one-half of the residents in high-density, low-income public housing in New York State apply pesticides inside their apartments at least once per week?

No wonder then that 85% of pregnant African American and Dominican women in NYC had at least one pesticide in their umbilical cord blood samples at delivery, or that 8 or more pesticides were found in the air in 30% of the apartments in which young children lived.

Or that farmworkers in Monterey County in California had median levels of some types of pesticides in their urine 385-times higher than the rest of the US population. The most highly exposed group of people in general is farmworkers, but for the 83% of farmworkers that identify as Hispanic and Latinx the risks are often even higher.

These are among the statistics and study results reported in a provocative, challenging paper just published in BMC Public Health entitled “Pesticides and environmental justice in the USA: root causes, current regulatory reinforcement and a path forward” (Donley et al., 2022).

Provocative because the paper backs up hard-edged statements with solid evidence like the facts cited above. Challenging because it makes a strong case for the big changes needed to reduce pesticide exposures and risks that disproportionally impact Black, Indigenous and People of Color (BIPOC). The authors also inject some realism into their analysis by acknowledging the many reasons why needed changes are likely out of reach.

The paper calls for many changes in pesticide regulatory law and policy to begin to dismantle the legal and institutional factors and forces that perpetuate today’s inequitable distribution of human-health “costs” stemming from reliance on pesticides. The authors conclude:

“The root causes of these disparities involve hundreds of years of systemic oppression kept in place through structural racism and classism in the USA.”

One recommended set of policy actions highlighted in the paper would aspire to remove what the authors label a “pesticide safety double standard.” This double standard arises from the fact that Congress has directed the EPA to apply a stricter standard in efforts to cap pesticide dietary exposures/ risks facing the general public, compared to the standard applicable to exposures/risks facing farmworkers and others who use pesticides at work, The authors write:

“The second thing EPA should do under its current authority is to finally, and formally, define ‘no unreasonable adverse effects’ in a way that appropriately recognizes and reduces harm to agricultural workers.”

But unfortunately, Congress has already set forth a definition of “unreasonable adverse effects” in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) that leaves essentially no room for EPA to address farmworker and applicator risks via the tolerance setting process:

“(bb) UNREASONABLE ADVERSE EFFECTS ON THE ENVIRONMENT.—The term ‘unreasonable adverse effects on the environment’ means…(2) a human dietary risk from residues that result from a use of a pesticide in or on any food inconsistent with the standard under section 408 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a).”

Via this definition, FIFRA directs the EPA to focus on average risks to the general public from pesticide residues in food. This is one of many reasons why the EPA will need help from Congress in removing the double standard embedded in how EPA assesses pesticide risks facing the general public versus more heavily exposed people, the majority of which are members of BIPOC communities.

In a published paper released in August 2021, HHRA has offered its own set of recommendations to enhance the scientific rigor and independence of pesticide risk assessments.

Like many of the changes identified in the Donley et al. paper, the changes HHRA has called for will also require fundamental changes in the FIFRA statute. In other words, just one more complex, contentious task on the long list awaiting the attention of the US Congress.