By: Chuck Benbrook, HHRA ED By: Mark Lipson, HHRA Director of Policy and Regulatory Engagement We welcomed the invitation from California’s Department of Pesticide Regulation for members of the public to offer comments and guidance as the State begins to take concrete actions needed to achieve the goals set forth in the new report Sustainable Pest Management: A Roadmap for California. Reviewing the 94-page Roadmap report reminded us how many constituencies, forces, and factors are pushing and pulling farmers, pest managers, and government agencies in multiple directions that are rarely aligned. This Roadmap document describes a very different pest management future that will hopefully become the “de facto” way pests are managed on and off the farm by 2050. If successful by 2050, prevention-based biointensive Integrated Pest Management (bioIPM) will be the norm and there will be minimal if any use of high-risk “Priority Pesticides”. Some thirty-two years ago, DPR hired Chuck Benbrook to carry out a comprehensive evaluation of DPR’s programs and policies to assist in the integration of DPR into the newly-formed Cal-EPA. The resulting report, Challenge and Change: A Progressive Approach to Pesticide Regulation in California, came out in March of 1993. It provides dozens of recommendations intended to do many of the same things that the 2023 Roadmap report hopes to bring within reach. The fact that most pest management systems in California have become more, not less reliant on pesticides over the last 30 years suggests that DPR’s and CDFA’s efforts to achieve Roadmap goals are going to entail heavy lifting, mostly uphill. For this reason in HHRA’s comments, Mark and Chuck describe the nature and substantial scope of changes in laws and policy that will be required to track progress toward Roadmap goals and hopefully, someday, achieve them.

Advocates calling for change in US Ag Inc often struggle to point to successful models through which farming and food chains have evolved toward safer and more sustainable production systems. The surest way to largely eliminate the impacts of prenatal pesticide exposure on birth outcomes and children’s development – HHRA’s foundational goals – is converting US farmland to organic production. We are often asked how such change can come about. Convincing answers to this key and important question are few and far between in the US, but some key lessons are emerging from efforts in Europe to expand organic farming and food supply chains. The Cilento organic food bio-district in Italy was established in 2009 and is thought to be the first-ever in the world. Overcoming challenges faced by organic farmers in marketing their produce was a primary driver. Municipal actions expanded demand for organic food and ingredients via public food-purchasing programs. The lure of scenic rural landscapes and strong support from the agrotourism industry for organic food and farming created new market demand. Today, organic farming is thriving in the Cilento district, profit margins have expanded, and enhanced soil health is supporting higher yields at lower costs on many farms. An action by a city council led to the formation of the Södertälje organic food system in east-central Sweden, some 35 kilometers from Stockholm. The goal was to expand the supply of organic products for public food-procurement programs as a way to advance health and environmental quality. The municipality’s Diet Union developed new food products and recipes in the context of a “Diet for a clean Baltic” to promote health and reduce food waste. Restaurants and cafeterias began using smaller plates to cut down on waste, an intervention that has proven to be surprisingly effective. In south-eastern France the mad cow disease outbreak across Europe was the trigger of action leading to the Mouans-Sartoux organic food system. The initial focus was on supplying organic beef to school canteens, coupled with municipal government support for regional sustainable farm research and food education programs. A multi-faceted effort to provide organic food to children led to greater awareness of the diversity of benefits arising from organic farming. New efforts emerged to reach other vulnerable segments of the population with organic food (e.g. the elderly, pregnant women). These three region-based organic food systems in Europe are case studies in a just-published paper by Lilliana Stefanovic (2020), a scientist in the Department of Organic Food Quality and Food Culture at the University of Kessel in Germany. Imagine that. An academic department focused on organic food quality and culture. How long might it take for such a department to take hold at Iowa State University, in the heart of American farm country? The Stefanovic paper addresses how local organic food systems in Europe can contribute in achieving the Sustainable Development Goals (SDG) set forth by the United Nations, and especially SDG 12, “responsible consumption and production.” Her analysis concludes that local and place-based organic food and farming districts can make important contributions in transforming food and farming systems to promote human and animal health, and soil health and environmental quality. Two drivers played key roles in all three case studies: relatively short distances to population centers, and significant support for organic supply chains from public food-procurement programs, and especially those feeding children. And just a few months ago, the Italian government pledged to invest 3 billion euros (about $3 billion US) to convert at least 25% of the country’s farmland to organic systems by 2027. The funds will come from Common Agricultural Policy payments supported in part by a tax on pesticide sales. There are about 16.6 million acres of arable land in Italy. Reaching the 25% organic goal would entail the transition of around 2 million more acres to organic, given that a little over 15% of Italian farmland is already managed organically. If $3 billion in transition payments were spread over 2 million acres, average payments would be around $1,500 per acre. A multi-pronged effort in Italy is planned to simultaneously grow the supply of organic foods and demand for them. Investments will be made in the infrastructure needed to support profitable regional organic food supply chains, while increasing the supply of value-added, premium foods for sale throughout Italy, Europe, and for a few commodities (especially olive oil), the world. Such bold pledges and audacious goals have come and gone in many countries with little concrete and sustained change to show for the resources invested. But perhaps the time is right in Italy for acceleration in the transition to organic farming in light of the many scientific studies showing that organic farming can both slow global warming and render farms more resilient in the face of drought and flooding. What about here in the USA? The USDA has recently pledged to invest $300 million in a new Organic Transition Initiative. This program will provide new funding via many USDA-program channels to encourage the transition of farms to organic production. While a major increase in USDA funding dedicated to expanding organic production, $300 million over several years is a small share of the approximate $20 billion in annual federal spending on farm commodity and crop insurance programs. It is also instructive to compare the $3 billion investment in Italy to reach their goal of 25% of farmland in organic by 2027 to the $300 million investment just announced by USDA. The Italian program, if it actually happens, would provide about $1,500 per acre transitioned to organic. The USDA’s investment of $300 million translates into about $4.30 per acre across the approximate 70 million newly transitioned acres necessary for 25% of the US cropland base to be managed organically. Current disparity in public support for and investment in the transition to organic farming in the US versus Europe arises from vastly different public awareness of the benefits likely to stem from the transition of more farmland to organic production. Many public and private institutions […]

By Mark Lipson, HHRA’s Director of Policy and Regulatory Engagement September 25th marked the close of public comments on a historic petition to EPA calling for an end to organophosphate (OP) pesticide applications on food crops. Twelve groups led by the United Farm Workers Foundation and Earthjustice petitioned EPA last November with a compelling summation of the case for ending all remaining uses of OP poisons in the food system. From the 1980s through about 2000 both in the US and globally, organophosphate (OP) insecticides were the most heavily applied family of pesticides used to kill insects. For a half-century the OP chlorpyrifos was by far the most heavily used OP, but use ended in 2020 because of adverse impacts on the neural development of children. Several OPs remain in use today including acephate, diazinon, terbufos, dimethoate, and oxydemeton-methyl. HHRA submitted lengthy comments signed by three of its principals, Dr. Phil Landrigan, Dr. Kathleen Merrigan and HHRA Executive Director Dr. Charles Benbrook. Each of the signers has played important roles in the decades-long fight against the manifold harms caused by OP farm chemicals. Dr. Landrigan led the landmark National Academy of Sciences panel that wrote the 1993 NAS report Pesticides in the Diets of Infants and Children. The importance of that NAS study was summarized in a high-profile comment signed by dozens of prominent doctors and scientists in support of the UFW Petition: “In response to the NRC [of the NAS] 1993 pesticide report that documented the overwhelming scientific evidence on early life susceptibility to pesticides, Congress in 1996 unanimously passed the Food Quality Protection Act (FQPA) —the only federal environmental statute containing explicit provisions for the protection of children.” Yet 25 years later the promise of FQPA is not yet fully realized. The scientists’ letter continues: “In the quarter-century since the enactment of the FQPA, while OP uses have continued to increase at the expense of children whose brains were irreparably impaired, the scientific evidence of neurodevelopmental harm in children from real-world OP exposures has strengthened.” The neurotoxic and developmental harms of OPs fall hardest on farmworkers and their families. As the Petition succinctly states: “The farmworkers who grow our food face the highest exposures and risks from OP pesticides. In addition to exposures through food and drinking water, they are exposed when they apply the pesticides or enter fields that have been sprayed, and they and their families are more likely to be harmed by pesticide drift because they live and go to school near where OP pesticides are sprayed…The science, the law, and principles of environmental justice require EPA to ban OP uses that are unsafe and that harm workers and their families.” The Petition calls for four main actions by EPA impacting the human health assessments and regulation of OP insecticides: EPA must end its unreasonable delay and move expeditiously to protect people from the OPs. EPA must revoke tolerances and cancel registrations for food uses of OPs for which the EPA is unable to determine that there is a “reasonable certainty of no harm” stemming from current levels of OP dietary exposures. EPA must update its OP risk assessments to use a regulatory endpoint that will protect children from neurodevelopmental harm, as well as the impacts of coformulants (i.e. “inert ingredients”) on exposure levels and the toxicity of end-use products. EPA must cancel registrations allowing OP uses that pose significant risk of unreasonable adverse effects on applicators, farmworkers and other people exposed near recently treated fields. HHRA’s comments provide the authors’ perspectives on each of these four actions, and the imperative need for EPA to act on them all. In addition to highlighting the well-established neurodevelopmental risks following prenatal exposure to OPs, the HHRA comments synthesize data on the economic costs stemming from OP-driven loss of lifelong IQ. These harms far, far outweigh any remaining pest control benefits from continued use of these insecticides. HHRA’s submission also provides new data and synthesis on dietary risks. While US farmers have reduced OP dietary risks significantly, and many no longer need nor rely on OPs, OP residues and risk levels are rising in several key imported children’s foods, and could continue doing so until EPA revokes OP tolerances as called for in the petition. The HHRA comments demonstrate that there are ample alternatives for the OPs still in use. The comments laud the efforts of the last two decades to streamline registration for new, lower-risk pesticides and recommends even greater investment in biological pest controls. Finally, HHRA’s comments provide data and analysis to unequivocally support immediate and comprehensive cancellation action on the remaining OPs for the health of farmworkers and their families and people living, working, or going to school near OP-treated fields. Now that the public docket has closed, EPA has to decide what the science now shows and the law requires. But the petition’s comprehensive compilation of solid data shows OP risks exceeding the EPA’s “level of concern.” The petition and supporting comments from Landrigan, Merrigan, and Benbrook and many other scientists represents a watershed in the quest for a food system in which public health and worker safety are top-tier goals both in words and action.