Safety of Pesticides

also see Industry Shenanigans, children, neonicotinoids, glyphosate , endocrine disruption, lawn/turf and bylaws/general, glyphosate 2 and Safety of Pesticides

PAN International List of Highly Hazardous Pesticides (PAN List of HHPs) March 2021

On June 13, 2023, Safe Food Matters returns to Federal Court in its ongoing battle with Health Canada over glyphosate, Canada’s most widely used herbicide. 'Why? Because something’s not right. In February, 2022, the Federal Court of Appeal ordered the PMRA to review our “Notice of Objection” for a second time – and the Court even provided “Guidance” to PMRA on how to address the issues. But PMRA did not follow the Guidance. Even more, PMRA bent over backward to not address the concerns we raised. PMRA rewrote history. PMRA made up totally new legal tests. PMRA reached for rebuttals without evidence. PMRA defied the rules of procedural fairness. It is clear PMRA does not want a review panel, even though the law allows for it. Watch the Hearing: We would appreciate your support by watching the virtual hearing. It starts at 9:30 am PST, 12:30 EST and is scheduled for the full day. Go to this link for the calendar of hearings for June 13 (link in link), and scroll down to the Ottawa hearing for the case, and select the icon “register for the hearing” which looks like a pen on paper. Our case is Safe Food Matters Inc. v. The Attorney General of Canada and Minister of Health Docket T-2292-22. Our counsel is Jason Gratl. The filings for the Motion will be on our website, under Filings for case T-2292-22.'

Poisoning Regulation, Research, Health, and the Environment: The Glyphosate-Based Herbicides Case in Canada (by Marie-Hélène Bacon et al, Toxics 2023, 11(2), 121; Published: 26 January 2023) Abstract: 'Glyphosate-Based Herbicides (GBHs) are the most widely used pesticides on the planet as well as in Canada, where a total of almost 470 million kilograms of declared “active” ingredient glyphosate was sold between 2007 and 2018. GBHs accounted for 58% of pesticides used in the agriculture sector in Canada in 2017. While the independent scientific literature on the harmful health and environmental impacts of pesticides such as GBHs is overwhelming, Canada has only banned 32 “active” pesticide ingredients out of 531 banned in 168 countries, and reapproved GBHs in 2017 until 2032. This article, based on interdisciplinary and intersectoral research, will analyze how as a result of the scientific and regulatory captures of relevant Canadian agencies by the pesticide industry, the Canadian regulation and scientific assessment of pesticides are deficient and lagging behind other countries, using the GBH case as a basis for analysis.'

BACKGROUNDER: Busting the myths about cosmetic pesticide bans (EcoJustice) worth repeating every year at this time when cosmetic pesticide use starts in earnest.Well-researched 10 point backgrounder. Full of links.

Review Shows that Monsanto/Bayer Claims of Glyphosate Safety Not Supported by Credible Science (Beyond Pesticides, December 21, 2021) 'A research team undertaking a review of industry-conducted glyphosate safety studies submitted to EU (European Union) regulators shows that most of the research fails to meet current international standards for scientific validity. The researchers find that of the 11 reviewed studies, which were submitted to regulators by Bayer AG (now owner of the Monsanto “Roundup” brand of glyphosate herbicide) and several other chemical companies, only two are scientifically “reliable”; six others are deemed “partly reliable,” and the remaining three, “not reliable.” ' The issue is that older studies rely on tests that are only 50% reliable for detecting cancer. 'In response to that July report, the former director of the U.S. National Institute for Environmental Health Sciences (NIEHS), Linda Birnbaum, PhD, indicated that the problem of regulators accepting industry studies “at industry’s word” and simultaneously “ignoring red flags raised in non–industry funded research” is ongoing, according to The Guardian.'

Inspector General Rips EPA for Failure to Test Pesticides for Endocrine Disruption (Beyond Pesticides, August 20, 2021) The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) has issued a damning report on the agency’s progress in protecting the population from potentially damaging endocrine disruption impacts of exposures to synthetic chemical pesticides (and other chemicals of concern). The report’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” SNAP Comment: A google search has not brought me any closer to figuring out if endocrine disruption is considered in pesticide registration or how. I found a 2018 committee report on Advancing consideration of endocrine-disrupting chemicals under the Canadian Environmental Protection Act, 1999 but CEPA is a different Act.

No more excuses: Global network demands phase-out of Highly Hazardous Pesticides by 2030 (PAN, March 19, 2021) Includes links to the PAN International Consolidated List of Banned Pesticides and PAN International List of Highly Hazardous Pesticides (PAN List of HHPs) (March 2021) PAN’s Bans List shows that 162 countries have banned a total of 460 pesticide active ingredients or groups of actives regarded as still ‘currently in use’ in the global market, i.e. not obsolete. In total, there were 94 active ingredients that were newly added to the list of banned pesticides. This includes the world’s most popular weedkiller, glyphosate. The list also shows that for the first time, imidacloprid, clothianidin and thiamethoxam – neonicotinoids linked to bee deaths – have all lost approval in the European Union (EU).

Unsafe at any Dose? Diagnosing Chemical Safety Failures, from DDT to BPA (by Jonathan Latham, PhD, COMMENTARY, Independent Science News, MAY 16, 2016) ' ...instead, the case of BPA strongly implies not a series of bad actors but instead a dysfunctional regulatory system... but the basis of risk assessment is always the estimation of exposure and the estimation of harm. The article then describes with examples:

problems with estimation of exposure and estimation of harm, including historic errors in estimating real world exposures to toxic substances.
'regulatory agencies do 'not recognise that exposures to individual chemicals typically come from multiple sources.'
Most of the assumptions required for such extrapolations, however, have never been scientifically validated,... but in other cases they are actively known to be invalid.
Toxicologists necessarily focus on a limited number of specific “endpoints”.'
The assumption of a linear response is rarely tested, yet for numerous toxins (notably endocrine disrupting chemicals) a linear dose-response relationship has been disproven. Such important limitations and assumptions are generally not noted as caveats to risk assessments.
Researchers conflict of interest
Regulatory agencies structured in a way that favors industry and products by often 'specifically exclud(ing) from regulatory consideration evidence and data not produced by industry.'
safety bar for approval very low and standards for taking any chemical off the market so high that such an event nearly never happen. 'Yet if both standards were based purely on science, as they claim to be, both bars would be the same height.' The article also suggests how environmental groups have 'an opportunity to substantively rethink their strategies and reframe their activities'

EPA Fails to Follow Congressional Mandate to Protect Children from Pesticide Exposure (Beyond Pesticides, February 13, 2020) Congress unanimously passed the Food Quality Protection Act (FQPA) in 1996 to increase protections for children from pesticide exposure. Unfortunately, according to a new study published in Environmental Health, the law is not being employed by the Environmental Protection Agency (EPA) to its full capacity. For most of the 59 pesticides reviewed by the study, EPA did not apply an additional FQPA safety factor and thereby missed an opportunity to protect children’s health. In fact, FQPA solidified EPA’s reliance on risk assessment calculations and mitigation measures that consistently fall short of adequate levels of protection because of serious data gaps, a failure to consider exposure to mixtures and synergistic effects, and a bias against consideration of alternatives (alternatives assessment) that show toxic pesticides to be unnecessary. SNAP Comment: Does anyone know whether Canada is supposed to apply an additional safety factor for children in pesticide registration?

Ethanol Plant Processing Pesticide Coated Seeds Contaminates Nebraska Town US info. (Beyond Pesticides, January 13, 2021) Under FIFRA (the Federal Insecticide Fungicide and Rodenticide Act), a clause known as the “treated article exemption” permits seeds to be coated with highly toxic pesticides without any requirement for the U.S. Environmental Protection Agency (EPA) to assess environmental or public health effects of their use.This allows hazardous pesticides (primarily insecticides and fungicides) to be used indiscriminately with no effective oversight. Research finds that over 150 million acres of farmland are planted with toxic seeds, including nearly four tons of bee-killing neonicotinoids each year. The AltEn plant is unique in that it is accepting unused treated seeds for farmers, advertising the site as a “recycling” facility, according to The Guardian. Apart from biofuel production, ethanol plants usually sell their spent, fermented grains to livestock farmers for feed. Processing toxic seeds has made that product too hazardous for cattle, so AltEn has been selling it to farmers as a soil amendment. The neonicotinoid clothianidin was found in a waste mound at an astounding 427,000 parts per billion (ppb). A wastewater storage pond found high levels of three neonicotinoids – imidacloprid, cloathianidin, and thimethoxam. Thiamethoxam was discovered at 24,000 ppb, over 300 times higher than its acceptable level in drinking water (70ppb), and roughly 1,300 times higher than the level considered safe for aquatic organisms by EPA (17.5ppb). Expectedly, pollinators near the plant are dying off. Judy Wu-Smart, PhD, bee researcher at University of Nebraska documented a sustained collapse of every beehive used by the university for a research project on a farm within a mile of the AltEn plant. SNAP Comment: SK apparently has two ethanol plants with several more in Canada. I hope we donot make the same mistake under the idea of recycling. Why not? Because we did it about treated wood, allowing it to be used or burnt in an unsafe manner under the guise of 'recycling" and 'reusing.' Let's face it,some products are just too toxic for that.

Assumed safety of pesticide use is false, says top government scientist (The Guardian, Damian Carrington, 22 Sep 2017) Damning assessment by one of the UK’s chief scientific advisers says global regulations have ignored the impacts of ‘dosing whole landscapes’ and must change. 'Tyrell, at Pesticide Action Network, said the current pesticide management system was not fit for purpose: “We don’t know how a pesticide will really impact the environment until it is too late. It can take years before enough scientific evidence is collected to persuade regulators to take action, and they will be fought every step of the way by pesticide manufacturers who make millions from these products.”' SNAP Comment: I have an issue with the comparison ofhow well drugs are regulated. Drugs have only recently been tested for in soil and water and have also been widely found. They regularly contaminate fish we eat. I don't think anyone drug co ever tested that. Some drugs have been found to widely kill vultures in 3rd World countries as well. At the scale of the planet and of their use. drugs are equally as impactful as pesticides.

Transcript From Secret Meeting Illustrates EPA Collusion With the Chemical Industry (By Rebekah Wilce, The Center for Media and Democracy | Report. July 28, 2017) Interesting how the IBT scandal comes back to life, even after it was hard to find a mention of it anywhere for decades. Surprisingly, when we had journalists really investigating in Regina, a Leader post journalist, Peter von Stackelberg, broke the IBT story in the Regina Leader Post then published the series of articles in a book of which I have forgotten the title. I looked for this book everywhere and even got hold of Mr von Stakelberg who apparently did not have a copy either. I finally found 2 Canadian libraries, including the Saskatchewan Legislative Library, supposedly with a copy. Neither copy could be found on the shelves, to the librarians' surprise. I did find the book "A Bitter Fog" from van Strum and read it all. I also went to the Regina Public Library and started looking through their microfiches of the Regina Leader Post, which I did not complete. The first article I found was on p. 2 of the 3 July, 1980 paper, titled: "Health Minister to Tell Pesticides' Trade Names." That would be the trade names of the pesticides currently registered in Canada based on faulty safety data. It was followed by 2 p 6 opinion article on 8 July 1980. then others by von Stackleberg on 9 July, 1980, p.3, and July 15, 1980. This is apparently as far as I went looking. von Stakleberg apparently published his IBT articles in the Regina Leader Post for over 6 months. What is important about this scandal is that: “Near the outset of the meeting, the EPA's Fred Arnold, Acting Branch Chief of Regulatory Analysis & Lab Audits, assured the chemical company representatives present that no chemicals would be removed from the market, even though the studies supposedly showing their safety had been proven fraudulent”...” “By 1983, EPA had determined that over 90 percent of IBT's studies submitted to them had serious, invalidating problems.”...”Three IBT officials went to prison, closing a chapter on a massive scientific fraud, but the book was never closed. "As the Howard Johnson transcript reveals, a majority of the IBT studies were never intended to be redone, and still underlie the U.S. chemical regulatory system," said Latham (Director of the Bioscience Resource Project.) "The 1978 Howard Johnson transcript records a crucial meeting of EPA, Canadian, and pesticide industry officials to discuss EPA's response to massive fraud in the safety tests for pesticide registrations. At the meeting, Fred T. Arnold, chief of EPA Regulatory Analysis and Lab Audits, assured industry that EPA's discovery of fraudulent, invalid, or nonexistent safety tests would 'not interfere with the ability to control pests and market pesticides.' This document was the linchpin of my book, A Bitter Fog: Herbicides and Human Rights, documenting the government's acceptance of phony industry studies while dismissing reports of human illness, death, involuntary abortions, birth defects, and other effects of pesticide exposure." SNAP Comment: After the scandal, new international laboratory standards were apparently set up and supposedly followed. The set of studies mandated by the Canadian government (PMRA) for pesticide registration was set up in 1984 and still stands without any additional testing for effects of mixtures or formulations, or new evidence of harm like endocrine disruption or low dose effects. I know all the pesticides with fraudulent tests stayed on the market without appropriate testing at the time. However, I was unclear whether the pesticide companies ever had to redo the fraudulent tests, or whether our registration is still based on them...The safety of any pesticide product already registered at that time should therefore be suspect, as well as the safety of any pesticide conditionally registered (without studies submitted) since then. In the following article, an former EPA scientist reveals that "Most chemicals enter the market without testing," Failure to regulate: Pesticide data fraud comes home to roost (GM Watch, 29 April 2015)

The report of the Environmental Commissioner on Pesticide Safety in Canada, 2015. This report presents the results of a performance audit conducted by the Office of the Auditor General of Canada under the authority of the Auditor General Act.

Findings, Recommendations, and Responses 4
The Agency had not made progress in limiting the duration of some conditional registrations .......................................................................................................... . . . . . . . . . . . 4
In its re-evaluations, the Agency considered the risks and value of pesticides,
but had not assessed their cumulative health effects when required . . . . . . . . . . . . . . .. 9
The Agency made insufficient progress in completing re-evaluations of older pesticides .13
Special reviews of pesticides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
The Agency had begun to consider whether special reviews were warranted for pesticides banned since 2013 in OECD countries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
The Agency did not promptly cancel the registrations of some pesticides whose risks
it had deemed unacceptable . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
The Agency did not provide the public with complete information on conditional registrations, as required by the Pest Control Products Act, or effectively communicate new information on pesticide risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... .. 21