• Link to SK Organic Resources
  • Learn To Manage Weeds Without Chemical Pesticides
  • LIving Near Fields Increases Pesticide Exposure
  • Learn About Colony Collapse Disorder and How to Protect Bees
  • SNAP Tour of Organic Vegetable Garden
  • SNAP Display at Event
  • Learn to Manage Pests Naturally
  • Learn to Keep Insects Out of your Crops
  • Grow a Lush Garden Organically
  • Learn About Pesticides in Foods

Risk Assessment

also see glyphosate wildlife/birds

Ecological Mystery Unravels, With Toxic Pesticide Use at the Center   (Beyond Pesticides, May 12, 2021) Earlier this year, a team of scientists solved an ecological mystery that had persisted for decades. Throughout the southeastern United States, bald eagles and other top-level avian predators were experiencing mass deaths from a disease known as vacuolar myelinopathy (VM), a neurological ailment that causes lesions in affected animal’s brains. Now, scientists have determined that the chemical bromine, likely introduced by brominated herbicides in attempts to manage the invasive species, is the trigger for the production of the cyanobacteria’s neurotoxin... Most sources of bromine in a freshwater ecosystem are likely to be added by humans.   The use of a bromide-based product, intended to kill a plant that harbors a bacterium that, in the presence of bromine, produces a lethal neurotoxin is far beyond the scope of any risk assessment conducted by pesticide regulatory agencies.'   SNAP Comment: There are 29 diquat pesticides registered in Canada as of 30 May 2021 but apparently no diquat dibromide.or bistribromide.Diquat ion is considered by PAN as highly hazardous pesticide. . 

Herbicide Use in “Regenerative” No-Till Contaminates Waterbodies  US study. (Beyond Pesticides, February 19, 2021)  'Tackling any one problem without precautionary attention to potential consequences of a solution — before it is enacted — is the opposite of the holistic understandings and strategies needed to solve environmental crises. Piecemeal approaches often generate unintended consequences. To wit: Vermont Public Radio (VPR) reports on revelations from a retired state scientist, Nat Shambaugh, who finds that farmers’ efforts to reduce agricultural runoff from fields into waterbodies, by planting cover crops, has resulted in significant increases in the use of herbicides to kill off those crops.'  

In Response to a Lawsuit, EPA Proposes Review Process for Evaluating the Effects of Multiple Pesticide Ingredients on Nontarget Organisms   (Beyond Pesticides, October 11, 2019)   'EPA’s inattention to synergistic impacts on non-target species has long been a deficiency of EPA’s pesticide review and regulation and a focus for Beyond Pesticides’ work to factor in uncertainties, or unknowns, in registering pesticides under a precautionary approach....Of EPA’s call for public comment, the National Law Review notes that, “EPA typically registers pesticide products that are not intended to protect public health without any independent evaluation of efficacy data. ... The OPP document, titled Process for Receiving and Evaluating Data Supporting Assertions of Greater Than Additive (GTA) Effects in Mixtures of Pesticide Active Ingredients and Associated Guidance for Registrants, sets out the process that OPP’s Environmental Fate and Ecological Effects Division is using in its attempts to evaluate synergistic risks. However, that process reviews only those admixtures whose makers assert that their efficacy on the target weed or pest is synergistic. OPP’s narrow focus ignores all the other potential synergistic impacts — effects that may arise when organisms, whether floral or faunal, are exposed to multiple active pesticide ingredients. Such “mixing” may happen during industry formulation of a product, in an applicator’s garage or barn, or at the organismic point of exposure via air, water, soil, and/or food.''  includes link to document. SNAP Comment: Will Canada follow suit?

European Court of Justice Orders EU Regulators to Publicly Release Secret Industry Glyphosate Studies (Organic Consumer Association, March 7, 2019)   'The General Court concludes that the requested studies must be regarded as constituting information which ‘relates to emissions into the environment’ and that an overriding public interest in disclosing the studies is deemed to exist. EFSA could not therefore refuse to disclose them on the ground that that would have an adverse effect on the protection of the commercial interests of the owners of the requested studies.'

Original document at:

EFSA’s decisions refusing access to the toxicity and carcinogenicity studies on the active substance glyphosate are annulled

General Court of the European Union
Luxembourg, 7 March 2019
Judgment in Cases T-716/14
Anthony C. Tweedale v European Food Safety Agency
(EFSA) and T-329/17 Hautala and Others v EFSA

How did the US EPA and IARC reach diametrically opposed conclusions on the genotoxicity of glyphosate-based herbicides? (Charles M. Benbrook, Environmental Sciences Europe, 14 January 2019)

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 could not find the book "Poison Fog" from van strum either, and she did not have a copy to send. So I 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 another 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 Auditsassured 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 am 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 safty 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)

Farmworker Advocates Call For Suspension of Highly Toxic Pesticide (EarthJustice, 21 September 2016) Advocates from across the country ( USA) urge EPA to swiftly ban chlorpyrifos citing unacceptable risks to farmworkers and their families.                Meantime in Canada, 29 chlorpyrifos insecticides are still registered (23 September 2016) including 3 technical products which leaves 26 for commercial use. One product, Lorsban (registration number 29650), can still be used in agriculture for most grain and vegetable crops with time between last application and harvest from 7 (potatoes) to 90 days (beets), PESTS OFORNAMENTALS (COMMERCIAL PRODUCTION ONLY) - GREENHOUSES AND NURSERIES ONLY, and PESTS OF TURF (SOD FARMS ONLY). It can also be used by aerial application with lots of restrictions on wind speed, nozzle type and conditions of application. This particular product is not approved use for mosquito control that I saw. The label identifies it as TOXIC to birds, wild mammals, bees and certain beneficial insects with accompanying use restrictions. This fall 2016, thankfully, neither the City of Regina or Wascana Center Authority have yet reported basal tree spraying of elms for Dutch Elm Disease control (with chlorpyrifos), which they have been doing yearly for over a decade.                                                                                                   With so many rules and restrictions, and so few federal PMRA inspectors to ensure the pesticides are used according to label, who is really checking that the million of annual pesticide applications follow the label description (i.e. the legal document) Chances of getting caught are close to 0Who can honestly say or imply that, because a pesticide is registered, it's safe?

Despite Known Hazards, EPA Waits Decades for Manufacturers to Withdraw Pesticide (Beyond Pesticides, July 8, 2015) Once a pesticide has its foot in the regulatory door in Canada and the USA, it is mind-bogglingly difficult to restrict or ban it,even when it was first registered as conditional without the appropriate testing done. This story is about propoxur (59 products still registered in Canada) including pet flea collars, roach and hornet products and cockroach control as well as garden use and fogger for mosquito and blackflies.' Last week, after decades of review and known toxic hazards, especially to children, the Environmental Protection Agency (EPA) accepted a proposed cancellation for a number of indoor uses (including food establishments) and tolerances of propoxur, a carbamate insecticide known for its toxic effects to children.... It should be noted that EPA engages in lengthy negotiations with pesticide manufacturers, as is the case with propoxur (see recent announcement on chlorpyrifos), rather than pursuing rigorous regulatory standards through its cancellation or imminent hazard authority.' I guess the 'rigorous regulatory standards' are getting harder and harder to enforce because of all the Free Trade agreements which allow companies to sue a country for regulating their product.

Failure to regulate: Pesticide data fraud comes home to roost (GM Watch, 29 April 2015) The EPA originally registered atrazine, Roundup (glyphosate), 2,4-D, and hundreds of other poisons based on fraudulent or nonexistent industry safety studies, their real effects concealed by the EPA and industry for 50 years. Now the fraud and lies are coming home to roost.Referring to the IBT scandal of the late 1970s and early 1980s, The result of the EPA's post-IBT "don't ask, don't tell" policies is that "Most chemicals enter the market without testing," says former EPA scientist Evaggelos VallianatosThus EPA collusion and lies have enabled the pesticide industry to become too big to regulate or even try to control.

Major Pesticides Are More Toxic to Human Cells Than Their Declared Active Principles  (BioMed Research International Vol. 2014, Feb 26, 2014), Three each of herbicide, insecticide and fungicide formulations were individually tested for measured mitochondrial activities, membrane degradations, and caspases 3/7 activities. Fungicides were the most toxic from concentrations 300–600 times lower than agricultural dilutions, followed by herbicides and then insecticides, with very similar profiles in all cell types...Roundup was among the most toxic herbicides and insecticides tested. Most importantly, 8 formulations out of 9 were up to one thousand times more toxic than their active principles. Results challenge the relevance of the acceptable daily intake for pesticides because this norm is calculated from the toxicity of the active principle alone. Chronic tests on pesticides may not reflect relevant environmental exposures if only one ingredient of these mixtures is tested alone.

Three new Environmental Health Criteria (EHC) documents published by the World Health Organization (WHO) identifies major lacks in current risk assessment of chemicals (including pesticides). The lack of information in all three important health areas emphasizes the need for the precautionary principle to dictate decisions, rather than the current inadequate risk assessment procedures not taking into account any of the following evidence.

  • Elemental Speciation in Human Health Risk Assessment (EHC 234)   Different forms (speciation) of each chemical have different biological effects. “Until now, this issue has not been a part of most hazard and risk assessments.” “The effects of individual elements on biological systems are best understood through the effects of elements on biochemical structures and processes, described at the cellular and molecular levels.” The current end-points of risk assessment are much cruder than that and mostly do not reflect such effects. “Biological monitoring is of particular value, because the method integrates the exposure from all sources and by all routes of entry.
  • Principles and Methods for Assessing Autoimmunity Associated with Exposure to Chemicals (EHC 236)   “when all autoimmune diseases are combined, the estimated prevalence is high (3–5% of the general population), which underlines their importance to public health.” “Environmental factors are believed to be a major factor responsible for their increased prevalence.” “Currently, the risk assessment for agents that are suspected of inducing or exacerbating autoimmunity or autoimmune diseases is hampered by the fact that appropriate information is not available….”  “The burden on health and heavy costs of autoimmune diseases highlight their importance with regard to risk assessment.
  • and Principles for Evaluating Health Risks in Children Associated with Exposure to Chemicals (report specifically on environmental chemical exposures) (EHC 237)   One third of the world population are children. “(WHO) estimates that over 30% of the global burden of disease in children can be attributed to environmental factors.” “Traditional risk assessment …have focused mainly on adults and adult exposure patterns… There is a need to expand risk assessment paradigms to evaluate exposures relevant to children from preconception to adolescence.”  Most chemicals have not been assessed for potential toxicity to children, nor have the most vulnerable subpopulations of children been identified.” The reports identifies several areas in which research is needed. “Protection of children is at the core of the sustainability of the human species. It should be a priority of all countries and international and national organizations to provide safe environments for all children and reduce exposure to environmental hazards through promotion of healthy behaviours, education, and awareness raising at all levels, including the community, family, and child.

Designing Safer Chemicals.Linda S. Birnbaum. Environ Health Perspect 121:a9–a9 (2013). Online 1 January 2013
.Scientists of many disciplines introduce a Tiered Protocol for Endocrine Disruption (TiPED). TiPED, which focuses explicitly on detecting the endocrine-disrupting potential of a new chemical early in the design process, will be useful for companies wishing to respond to this consumer interest. However, it is a voluntary approach, not a regulatory program. This means it is not yet part of the testing required for pesticides.