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Policy and Regulatory Reform

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Strategic Purpose

Our Public Policy program strives to inform decisions and guide initiatives within the policy arena. We do so by integrating our data and published science in policy-relevant comments, papers, reports, and presentations.

HHRA’s policy work will address ag and food-centric issues that arise in the rule-making process. We will share advice on testing methods and fiscal priorities with the CDC and NIH. When asked, we will contribute ideas as government agencies develop and implement new program initiatives. As opportunities arise, we will share with Congress and State legislatures our sense of where and how food and farming systems need to evolve to routinely promote the health of the land, people, animals, and the planet.

When engaging the policy process, we will incorporate when possible original analytical findings and data generated by HHRA’s Dietary Risk Index system and our Pesticide Use Data System, as well as data gathered in the course of HHRA’s scientific projects.

Comments Submitted by the HHRA Public Policy Team

March 2023. “HHRA Comments on Sustainable Pest Management: Roadmap for California,” submitted to the California Department of Pesticide Regulation in response to a call for public input on implementing the “Roadmap.”

February 2023. “Comments on a Proposed Rule Issued by the Food and Drug Administration: Food Labeling: Nutrient Content Claims; Definition of Term ‘Healthy'”, submitted on behalf of the Heartland Health Research Alliance and the Swette Center for Sustainable Food Systems at Arizona State University. Comments submitted to Docket # FDA-2016-D-23335.

December 2022: “Recommendations to the National Organic Program for the Assessment and Approval of Inert Ingredients in Pesticide Products Approved for Use on Certified Organic Farms”, Heartland Health Research Alliance Comments Submitted to USDA Docket: AMS-NOP-21-0008.

October 2022: “Pesticide Registration Review: Dicamba Revised Human Health and Draft Ecological Risk Assessments”, Heartland Health Research Alliance Comments Submitted to EPA Docket: EPA-HQ-OPP-2016-0223-0026.

September 2022: “Petition to Revoke Tolerances and Cancel Registrations for Certain Organophosphate Uses”, Heartland Health Research Alliance Comments Submitted to EPA Docket: HQ-OPP-2022-0490.

Public Policy Advisory Committee (PPAC)

HHRA’s Public Policy Advisory Committee identifies and pursues opportunities to inform public-policy choices, regulatory decisions, priorities, and initiatives. Its members will be chosen for their knowledge of relevant U.S. federal  and state laws and agencies, as well as for their expertise in forces and factors shaping global trends in food and farming systems.

Chair – Dr. Kathleen Merrigan, Executive Director of the Swette Center for Sustainable Food Systems at Arizona State University (Bio:

PPAC Staff Leader – Mark Lipson, HHRA Director of Policy and Regulatory Engagement

Board Liaison – Audrey Tran Lam, Public Policy Advisory Committee

Committee Member – Dr. Asa Bradman, Public Policy Advisory Committee

Committee Member – Nichelle Harriott, Public Policy Advisory Committee

Policy Drives Possibility

Science is needed to shine a bright light on better paths forward. Policy change creates the guardrails needed to keep progress moving in the right direction. 

Most of today’s public health problems facing farmers, food industry workers, and rural communities stem from how economics, technology, and policy have driven change on farms and along food-value chains.

Many billions of dollars have been invested over the last half-century in creating the systems and infrastructures that govern how most food in America is grown, handled and stored, processed, and sold to consumers. 

Think of all the money invested in how just one form of nitrogen fertilizer — anhydrous ammonia — is manufactured, transported, stored, and applied on farms across the country. 

Compare the billions invested by the government and private companies to produce and supply anhydrous ammonia fertilizers, to the modest investments made over the last one-half century in all other forms of nitrogen, including legume crops, compost, and the conversion of animal manure and organic waste into fertilizer. 

To a significant extent, tax-funded R+D and subsidies have driven public and private investments in the infrastructure that, in turn, determines the relative costs and availability of farming inputs and technology. In this way, they shape how food and farming systems evolve . Put simply, policy drives possibility.

Pesticides must be tested and regulated. Pest management professionals responsible for assuring their safe use have to be trained and empowered with accurate, timely information. Doctors need information on the ways pesticides and animal drugs can trigger disease or impose acute hazards on those occupationally exposed. 

The capacity to carry out pest control and pesticide-risk management tasks too often falls short of need. In fact, across America animal diseases and crop pests are more serious than ever, despite all the new chemistry, drugs, and genetic technology that has been used to keep both in check. The problem is not inadequate investment in pest management systems and technology, it is how this investment has been deployed, coupled with the ways that farming systems have changed. Too many farmers are paying more and more for pest management systems that work less and less well.

Why? The answer arises from how farming systems have changed.  Specialization, housing too many animals in small spaces, and systems that are drug and chemical-dependent by design have opened new ecological niches for pests and animal disease. Farming system specialization and scale have also undermined the biological and ecological cycles and interactions that have traditionally helped farmers raise healthy crops and animals with far less reliance on animal drugs and pesticides.

Today, too many farmers adopt the latest silver bullet technology in their quest to overcome some old or emerging threat to crop yields and animal production, but do so at the expense of soil and animal health, and food safety and nutritional quality. Policy has incrementally pushed and/or enabled farming system changes that have made US Ag Inc less resilient and more vulnerable to a wide array of risks and undercurrents. Systemic policy change will be needed to turn the ship around and will work only if sustained for many years. 

Fundamental Flaw in Pre-Market Assessments

One area of pesticide and animal drug regulation is badly broken and in need of reform — the process by which chemicals and drugs are tested and regulated to assure safe use and avoid unintended environmental, food safety, or economic consequences.

Every new technology, machine, pesticide, and drug is evaluated for safety prior to regulatory approvals and marketing. These pre-market safety studies are designed to identify hazards, estimate exposures, and assess risk levels. The goal is to identify when and where relatively high risks are likely to occur, so steps can be taken to avoid them.

But once new technology is approved and on the market, the diversity of application scenarios typically expands markedly. As the scope of uses expands, the pre-market safety testing supporting them becomes thin, like ice on a pond in the spring.

Most pesticides and animal drugs are evaluated in small studies focused on efficacy and impacts from a specific application — such as a few acres of corn treated with a new herbicide,  or pigs administered a new drug under tightly controlled experimental conditions.

Outcomes are carefully recorded, and as long as no clear problems are identified, the technology is approved for commercial use.

But this way of assessing pesticide and animal drug use is flawed. Why? Because it is based on assumptions proven wrong over and over. It assumes that if one or a few fields of soybeans or corn in Illinois can be sprayed with a new herbicide without problems in one year, then every acre of corn in the country, every year can be sprayed with no problems.

It assumes that an animal drug administered to treat an infection in a few animals on a farm with otherwise healthy animals can be given to thousands of stressed animals in a Concentrated Animal Feeding Operation (CAFO) without any problems arising as a result.

Plus, new silver bullet technology often comes on the market before its impacts are understood, especially in cases where new technology is badly needed and rapidly and widely adopted.

Problems become evident, and eventually hard to ignore. Then, but only sometimes, public health scientists engage and try to understand who is at risk and why, and what the innovators, regulators, and users missed or failed to take into account.

But by the time the scientific community has conducted the research needed to link a now widely used technology to an adverse public health or environmental outcome, there is usually a new set of silver bullets on the market to fill the void and start the cycle anew.

A primary goal of HHRA is developing novel ways to conduct public health science in the food and farming sectors so that health risks are recognized more quickly, and ideally before widespread commercial use of new technology.

The quicker such risks can be identified, the sooner steps can be taken to utilize new technologies in ways, and in those places, where users and the public benefit but no one else pays a price. Paying closer attention to early signs of problems should become business as usual in US testing and regulatory policy, and success in doing so will deliver benefits for all.

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