HomeMy WebLinkAboutCOM 0489.168 2018-2020 BEYOND PESTICIDES
701 E Street, 3E 1w Washington DC 20003
202-543-5450 phone 202-543-4791 fox
Info@beyondpesflcides.org w wwwbeyond esticides.org
Hawai'i County Council
Committee of Agricultural,Water, Energy and Environmental Management
In STRONG SUPPORT of Bill 101
October 14,2019
Thank you for the opportunity to address the Committee. Beyond Pesticides is a national
nonprofit membership organization that aims to educate the public on the hazards of
pesticides and promote alternatives to their use. On behalf of our members and supporters in
Hawai'i and across the United States, we strongly support the passage of Bill 101, and offer
technical support and services to assist Hawaii County personnel in the transition away from
herbicide use in public spaces.
Bill 101 is a huge step toward protection of children, elderly, and vulnerable population groups
that suffer from compromised immune and neurological systems, cancer, reproductive
problems, respiratory illness and asthma, Parkinson's, Alzheimer's, diabetes, and learning
disabilities. Of the 30 most commonly used lawn care pesticides, 16 are linked to cancer, 17
are endocrine (hormone) disruptors, 21 are reproductive toxicants, 12 are linked to birth
defects, 14 are neurotoxic, 25 cause kidney liver effects, and 26 are skin or eye irritants.'
In addition to concerns over human health, we are at a time of cascading environmental crises.
Managed honeybee populations across the country have been declining at an unsustainable
rate, approximately 301 each year.2 Wild pollinators are also in trouble; eastern monarch
butterflies lost 80%of their population since 1990.3 And new research published late last
month finds that 30%, over 3 billion birds have been lost since 1970,4 risking the Silent Spring
first warned by Rachel Carson. Studies finds that pesticides are contributing each of these
concerning statistics.
Now is the right time for Hawai'i County to act on toxic pesticides.The science on the dangers
of pesticides is clear. The Hawaii State Board of Education, and local communities across the
state are choosing to stop using these toxic chemicals on our public spaces.
Health Effects of 30 Commonly Used Pesticides.2015.Beyond Pesticides.http://www.beyondpesticides,org/lawn/factsheets/30health.pdf
(See Appendix C for a fully cited copy of the fact sheet)
z Bee Informed Partnership.National Management Survey.Total Annual Losses.https:Hbip2.beeinformed.org/survey/
a Center for Biological Diversity.2017.Iconic Butterfly Has Declined by More Than 80 Percent in Recent Decades,
https://www.biologicaldiversity.org/news/press_releases/2017/monarch-butterfly-02-09-2017.ph p
I Greenfield boyce,Nell.2019.North America has lost 3 billion birds,scientists say.NPR.https://www.nor.org/2019/09/19/762090471/north-
america-has-lost-3-billion-birds-scientists-say
Comm.
Ref. To:
P�°f• "�,�� 'OCT 15 2019
BEYOND PESTICIDES
701 E Street,SE im Washington DC 20003
202-543-5.450 phone a 202--543-4791 fax
info@beyondpesticides.org■www;beyondpestioides,orc
Hawai'i County Council
Committee of Agricultural,Water, Energy and Environmental Management
In STRONG SUPPORT of Bill 101
October 14,2019
Thank you for the opportunity to address the Committee. Beyond Pesticides is a national
nonprofit membership organization that aims to educate the public on the hazards of
pesticides and promote alternatives to their use. On behalf of our members and supporters in
Hawai'i and across the United States, we strongly support the passage of Bill 101, and offer
technical support and services to assist Hawai'i County personnel in the transition away from
herbicide use in public spaces.
Bill 101 is a huge step toward protection of children, elderly, and vulnerable population groups
that suffer from compromised immune and neurological systems, cancer, reproductive
problems, respiratory illness and asthma, Parkinson's,Alzheimer's, diabetes, and learning
disabilities. Of the 30 most commonly used lawn care pesticides, 16 are linked to cancer, 17
are endocrine (hormone) disruptors, 21 are reproductive toxicants, 12 are linked to birth
defects, 14 are neurotoxic, 25 cause kidney liver effects, and 26 are skin or eye irritants.'
In addition to concerns over human health, we are at a time of cascading environmental crises.
Managed honeybee populations across the country have been declining at an unsustainable
rate, approximately 30%each year.2 Wild pollinators are also in trouble; eastern monarch
butterflies lost 80%of their population since 1990,3 And new research published late last
month finds that 30%, over 3 billion birds have been lost since 1970,4 risking the Silent Spring
first warned by Rachel Carson. Studies finds that pesticides are contributing each of these
concerning statistics.
Now is the right time for Hawai'i County to act on toxic pesticides.The science on the dangers
of pesticides is clear. The Hawaii State Board of Education, and local communities across the
state are choosing to stop using these toxic chemicals on our public spaces.
Health Effects of 30 Commonly Used Pesticides.2015.Beyond Pesticides.http://www.beVondpesticides.org/lawn/factsheets/30health.pdf
(See Appendix C for a fully cited copy of the fact sheet)
2 Bee Informed Partnership.National Management Survey,Total Annual Losses.https:Hbip2.beeinformed.org/survey/
3 Center for Biological Diversity.2017.Iconic Butterfly Has Declined by More Than 80 Percent in Recent Decades.
https://www.biologicald iversity.org/news/press_releases/2017/monarch-butterfly-02-09-2017.php
4 Greenfieldboyce,Nell.2019.North America has lost 3 billion birds,scientists say.NPR.https://www.npr.org/2019/09/19/762090471/north-
america-has-lost-3-billion-birds-scientists-say 04.16A
i •16AComm. No
Ref. To:
OCT 1.7.209_
Adverse Effects ofChemical Pesticides
The passage ofBill 101bcritical asour country's appetite for pesticides raises grave concerns
about the effects ofuhemica Wntensivepractices, our relationship Lonature, chemical effects at
the cellular level, and weed resistance to chemical controls.The U.S. Geological Survey has
linked pesticide use in urban areas to runoff and pesticide contamination of local waterways.5
Of the 30 most commonly used lawn pesticides,20 have ahigh potential to Mach into
waterways,. 19 have been detected seeping into groundwater,22are toxic tobirds, 14are
toxic to mammals,29are toxic tobees, and all 3Qufthese chemicals present toxicity concerns
forfish or other aquatic organisms. I [See Appendix C and D for a chart and references for this
information.]
Rachel Carson wrote inSilent Spring, "By their very nature, chemical controls are sdf-defeating,
for they have been devised and applied without taking into account the complex biological
systems against which they have been blindly hurled.The chemicals may have been pretested
against afew individual species, but not against living cnnnnnunities." She warned ustuprotect
the diverse organisms that make up a healthy ecosystem, including bees, birds, butterflies and
other pollinators.
Pesticide-induced Diseases
Scientific literature documents elevated rates of chronic diseases among people exposed to
pesticides, with increasing numbers of studies associated with both specific illnesses and a
range ofillnesses. Beyond P*stkidea^Pest/cide-/nduced Diseases Database'documents over
75Dstudies linked tmhuman health effects. 0fwhich, there are 359 studies oncancer;107
studies Vnsexual and reproductive dysfunction;102 studies mmParkinson-s disease;07studies
onlearning and developmental disorders;33 studies oobirth defects;32studies mnasthma;
1Bstudies mndiabetes;and 12 studies mnAlzheimer's disease.
The studies in the database show that our current approach to restricting pesticide use through
risk assessment-based mitigation measures is not working. EPA's risk assessment fails to look at
chemical mixtures, synergistic effects, certain health endpoints (such asendocrine disruption\,
disproportionate effects to vulnerable population groups, and regular noncompliance with
product label directions.These deficiencies contribute to its severe limitations in defining real
world poisoning, as captured by epidemiologic studies in the database. [See Appendix Afor
additional health effect information, and Appendix B for failures of the EPA regulatory system.]
I United States Geological Survey.2007.Pesticides in US Streams and Groundwater.Environmental Science and Technology.
I Environmental Effects of 30 Commonly Used Lawn Pesticides.2015.Beyond Pesticides.
'Beyond Pesticides.2v1,.Pesticide Induced Diseases Database.
databass/overview
2
An Organic Systems Approach that Eliminates the Need for Toxic Pesticides
By limiting the use of pesticides, Bill 101 encourages County Personnel to implement organic
practices that have been shown to maintain turf expectations with minimal financial
implications. While conventional, chemical-intensive turf and landscape management programs
are generally centered on a synthetic product approach that continually treats the symptoms of
turf problems with toxic chemicals, organic approaches focus on the root causes of pest
problems, which lie in the soil.These land management techniques reveal that toxic pesticides
are not needed for successful turf management. Rather,this approach incorporates preventive
steps based on supporting soil biology to improve soil fertility and turf grass health, natural or
organic products based on a soil analysis that determines need, and specific cultural practices,
including mowing height, aeration, dethatching, and over-seeding.
For example, in the case of mowing high,the natural system supported by this practice is an
increase in the root depth of grass. Deeper roots provide greater capacity for the grass to draw
water and nutrients from the soil, and stronger grass plants are better able to crowd out weeds
or slough off pest pressure.Thus, the practices incorporated as part of a systems approach
build resiliency, a term used to describe the ability for an environment to bounce back to its
previous state after a disturbance. By fostering healthy soil biology,this approach leads to less
need for outside inputs, such as synthetic pesticides and fertilizers.And when properly
maintained, lawns and playing fields cared for in this way meet the same expectations of
conventional, chemically managed turf.
These practices and the ever-expanding product line of natural alternatives has enabled a cost
parity between the conventional and natural approach. A report produced by nationally
renowned turf grass expert Chip Osborne in coordination with Grassroots Environmental
Education, which looks specifically at the cost of conventional and organic turf management on
school athletic fields, concludes that once established, a natural turf management program
can resulvin savings of greater than 25%compared to a conventional turf management
program.8 There is also research from Harvard University which determined that, ultimately,
total operating costs of its organic maintenance program are expected to be the same as the
conventionally based program. In a 2009 New York Times article,9 the school determined that
irrigation was reduced by 30% saving 2 million gallons of water a year as a result of reduced
irrigation needs. The school was also spending $35,000/year trucking yard waste off site.The
university can now use those materials for composting and has saved an additional $10k/year
due to the decreased cost and need to purchase fertilizer from off-campus sources.10 And while
a decade ago the natural systems approach required slightly increased up-front costs and saw
savings in the long run,technology and practices have now progressed to the point where
parity can be achieved from the outset.
s Osborne,Charles and Doug Wood.2010.A cost Comparison of Conventional(Chemical)Turf Management and Natural(Organic)Turf
Management on School Athletic Fields.Grassroots Environmental Education.http://www.grassrootsinfo.org/pdf/turfcomparisonreport.pdf
e Raver,Anne.2009.The Grass is Greener at Harvard.http://www,nytimes.com/2009/09/24/garden/24garden.html?_r=2
°Harvard University.2009.Harvard Yard Soils Restoration Project Summary Report.http://www.slideshare.net/harvard uos/harvard-yard-
soils-restoration-project-summary-report-22509-4936446
3
Herbicide-Free Management ofRights ofWay and Open Spaces
Herbicide-free management of county rights of way and other open spaces is also based on a
holistic systems approach. We are working with public works departments across the State of
Hawai'i to identify areas of roadway that can be maintained with barrier solutions like weed
mats urcover seeding. VVewill beworking with road crews over the next few years toidentify
stretches of road/highway that can be replanted with native trees such as aali'i and crown
flower bushes to create pollinator corridors that also choke out invasive weeds. _
The Maui Division of the Department of Transportation invested in specialized machinery that
can mow hard-to-reach stretches of highway, eliminating the use of herbicides, and allowing
them to improve sight distance instead of leaving stretches of dead brown weeds at tight
corners and along scenic stretches of highway. During their work io eliminate herbicide use on
the highways, they have identified areas where the presence of weeds and their living biology
and root systems are actually beneficial, as they prevent runoff and dangerous rock falls during
rain storms.
/nmany areas, mtargeted inquiry mtwhere and why herbicides ore being used reveal that
their use is actually unwarranted, and other methods of weed control are actually much more
Appendix A' Key Areas mfConcern
Children's Vulnerability
Children face unique dangers from pesticide exposure.The National Academy of Sciences
reports that children are more susceptible to chemicals than adults and estimates that 50%of
lifetime pesticide exposures occur during the first five years of|ife.xx |nfact, studies show
children-'s developing organs create "'early windows of great vulnerability"during which
exposure inpesticides can cause great domoga"Additionally, according toresearchers atthe
University of California-Berkeley School of Public Health, exposure to pesticides while in the
womb may increase the odds that a child will have attention deficit hyperactivity disorder
13
(ADHD).
11 Nationa I Research Council,Nation a I Academy of Sciences.1993.Pesticides in the Diets of Infants and Children,National Academy Press,
Washington,DC:z84-zos.
11 Lanungan,p.J,LClaudio,saMarkowitz,et al.1999.'Pesticides and inner-city children:exposures,risks,and prevention."Environmental
Health Perspectives 10v(Supp|s):'az-ar.
11Marks AR,Harley K,Bradman A,xvmmK,Barr DB,Johnson C,etal.znm.Organophosphate Pesticide Exposure and Attention mYoung
Mexican-American Children:The CHAMACCIS Study.Environ Health Perspect 118:1768-1774.
4
I
i
x
i
As EPA points out in its document, Pesticides and Their Impact on Children:Keep Facts and
Talking Points:`
• "Due to key differences in physiology and behavior, children are more susceptible to
environmental hazards than adults."
• "Children spend more time outdoors on grass, playing fields, and play equipment where
pesticides may be present."
• "Children's hand-to-mouth contact is more frequent, exposing them to toxins through
ingestion."
In 2012, the American Academy of Pediatrics (AAP) released a landmark policy statement,
Pesticide Exposure in Children, on the effects of pesticide exposure in children, acknowledging
the risks to children from both acute and chronic effects.15 AAP's statement notes that,
"Children encounter pesticides daily and have unique susceptibilities to their potential toxicity."
The report discusses how kids are exposed to pesticides every day in air,food, dust, and soil.
Children also frequently come into contact with pesticide residue on pets and treated lawns,
gardens, and indoor spaces.
Pesticides, such as glyphosate and its formulated products (Roundup) and 2,4-D, both widely
used on turf and lawns, can be tracked indoors resulting in long-term exposures. Scientific
studies show that pesticides, like 2,4-D, that are applied to lawns drift and are tracked indoors
where they settle in dust, air and on surfaces and may remain in carpets."," Pesticides in these
environments may increase the risk of developing asthma, exacerbate a previous asthmatic
condition, or even trigger asthma attacks by increasing bronchial hyper-responsiveness.18 This is
especially important as infants crawling behavior and proximity to the floor account for a
greater potential than adults for dermal and inhalation exposure to contaminants on carpets,
floors, lawns, and soil.19
A study published in the Journal of the National Cancer Institute finds that household and
garden pesticide use can increase the risk of childhood leukemia as much as seven-fold.ZO
Similarly, a 2010 meta-analysis on residential pesticide use and childhood leukemia finds an
association with exposure during pregnancy, as well as to insecticides and herbicides. An
association is also found for exposure to insecticides during childhood.21
Prenatal exposures to pesticides can also have long-lasting impacts on infants and children.
Herbicides, like glyphosate, can adversely affect embryonic, placental and umbilical cord cells,
and can impact fetal development. Preconception exposures to glyphosate were found to
moderately increase the risk for spontaneous abortions in mothers exposed to glyphosate
14 See:https://www.epa.gov/sites/production/files/2015-12Jdocuments/pest-impact-hsstaff.pdf
15 Roberts JR,Karr CJ;Council On Environmental Health.2012.Pesticide exposure in children.Pediatrics.2012 Dec;130(6):e1765-88.
16 Nishioka,M.,et al.1996.Measuring lawn transport of lawn-applied herbicide acids from turf.Env Science Technology,30:3313-3320.
11 Nishioka,M.,et al.2001."Distribution of 2,4-D in Air and on Surfaces Inside Residences.Environmental Health Perspectives 109(11).
16 Hernandez,AF.,Parron,T.and Alarcon,R.2011.Pesticides and asthma.Curr Opin Allergy Clin Immunol.11(2):90-6.
16 Bearer,CF.2000.The special and unique vulnerability of children to environmental hazards.Neurotoxicology 21:925-934;and Fenske,R.,et
al.1990.Potential Exposure and Health Risks of Infants following Indoor Residential Pesticide Applications.Am J.Public Health.80:689-693.
20 Lowengart,R.et al.1987.Childhood Leukemia and Parent's Occupational and Home Exposures.Journal of the National Cancer Institute.
79:39.
21 Turner,M.C.,et al.2010.Residential pesticides and childhood leukemia:a systematic review and meta-analysis.Environ Health Perspect
118(1):33-41.
5
products.oOna2O10analyssobservedthatvvonnenvvhousooesdddesintheirhorneSuryards
were two times more likely to have offspring with neural tube defects than women who did not
use pesticide S.23 Studies also find that pesticides, like 2,4-D, can also pass from mother to child
through umbilical cord blood and breast milk.z4,zs
Biomonitoring testing has also documented pesticide residues in children. Residues of lawn
pesticides, like 2,4-D and rnecoprup, were found in 15 pe/cent of children tested, ages three to
seven, whose parents had recently applied the lawn chemicals. Breakdown products of
�
organophosphateinsectiddesxverepresentin98.7percentofohi|drentested. |none study,
children in areas where glyphosate is routinely applied were found to have detectable
concentrations in their urine.z/While glyphosate is excreted quickly from the body, it was
concluded, "apart may beretained urconjugated vvithotherconnpoundsthatcanshnou|ate
biochemical and physiological responses."A 2002 study finds children born to parents exposed
to glyphosate show a higher incidence of attention deficit disorder and hyperacLivity.zx
Pesticides and Pets
'
Studies find that dogs exposed to herbicide-treated lawns and gardens can double their chance
of developing canine lymphoma (1) and may increase the risk of bladder cancer in certain
breeds bvfour toseven times /2\.
/1\ Scottish Terriers exposed to pesti ci cle-treated lawns and gardens are more likely to
develop transitional cell carcinoma ofthe bladder, atype ofcancer.zy
/2\ "Statistically significant" increase in the risk of canine malignant lymphoma in dogs
vvhenexposedtohe/biddes, particu|or|yJ,4-D, connrnon|yusedon |avvnsandin "vveed
and feed" products."
Adverse,Effects to Wildlife
While the data is pouring in on intersex species in waterways that surround urban and
suburban areas and there are certainly a mix a factors,the contribution of runoff from
suburban landscapes are seen as an important contributor. In Suburbanization, estrogen
contonn/nobhc\ ondsexratio/n wild amphibian populations, the authors from Yale University's
School of Forestry and Environmental Studies and the U.S. Geological Survey (USGS)find the
following: "While there is evidence that such endocrine disruption can result from the
application of agricultural pesticides and through exposure to wastewater effluent,we have
identified a diversity of endocrine disrupting chemicals within suburban neighborhoods.
12Arbuckle,r.s,un'z,mMemL.s.(mu1).xnsxp|u,amryx^nlysis of tneEffect ofpestmoesxpomeonthe m,ku,spontaneuusAuumonm
anOntario Farm Population.Environ Health peone*my.osz-us/.
21a,enuer,Jo,etal.zo1u.Maternal Pesticide Exposure and Neural Tube Defects in Mexican Americans.Ann Epidemiol.20(l):16-22.
24 Pohl,HR.,et al.2000.Breast-feeding exposure of infants to selected pesticides.Toxicol Ind Health.16:6s'77.
21 Sturtz,N.,et al.2000.Detection of 2,4-dichlorophenoxyacetic acid(2,4-D)residues in neonates breast-fed by 2,4-oexposed dams.
Neurotoxicology 21(1-2):14/-5*
=va/cke,Mathieu,et al.2004.Characterization of exposure to pesticides used in average residential homes with children ages 3 to 7 in
Quebec.National Institute mpum/cxealtx'uuems,
27 Acquavella,J.F.,et al.(2004).Glyphosate Biomonitoring for Farmers and Their Families:Results from the Farm Family Exposure Study.
Environ Health peonmct.112(3),321-326.
11Cox c.2004.Journal of Pesticide Reform.Vol.24(4)citing:Garry,V.F.et al.2002."Birth defects,season of conception,and sex of children
born to pesticide applicators living in the Red River Valley of Minnesota."Environ.Health Persp.110(Suppl.3):441-449.
° aves, .
Journal of the National Cancer Institute,83(17):1226.
10 Glickman,Lawrence,et al.2004."Herbicide exposure and the risk of transitional cell carcinoma of the urinary bladder in Scottish Terriers,"
Journal of the American Veterinary Medical Association 224(8):1290-1297.
6
Sampling populations of a local frog species, we found a strong association between the degree
of landscape development and frog offspring sex ratio. Our study points to rarely studied
contamination sources, like vegetation landscaping and impervious surface runoff,that may be
associated with endocrine disruption environments around suburban homes."31
Pesticides and the Decline of Pollinators
Since 2006, honey bees and other pollinators in the U.S. and throughout the world have
experienced ongoing and rapid population declines.The continuation of this crisis threatens the
stability of ecosystems,the economy, and our food supply, as one in three bites of food are
dependent on pollinator services. Pollination services are valued at over$125 billion globally.
According to a 2014 Presidential Memorandum, pollinators provide $24 billion annually to the
US economy.32
Appendix B.The Failure of EPA Regulatory System
Pesticides are, by their very nature, poisons.The Federal Insecticide Fungicide and Rodenticide
Act (FIFRA),the law governing pesticide registration and use in the U.S., relies on a risk-benefit
assessment, which allows the use of pesticides with known hazards based on the judgment that
certain levels of risk are acceptable. However, EPA,which performs risk assessments, assumes
that a pesticide would not be marketed if there were no benefits to using it and therefore no
risk/benefit analysis is conducted or evaluated by the agency "up front." Registration of a
pesticide by EPA does not guarantee that the chemical is "safe," particularly for vulnerable
populations such as pregnant mothers, children, pets, and those with chemical sensitivities.
Below are examples of concern within the pesticide registration process.These factors should
give pause to lawmakers tasked with protecting public and environmental health, and supports
action, such as Bill 52-14, to prohibit toxic pesticides and, in so doing, encourage alternatives.
Conditional Registration. EPA will often approve the use of a pesticide without all of the
necessary data required to fully register the chemical, and will assign it a "conditional"
registration.The agency assumes that while it waits for additional data the product would not
cause adverse impacts that would prevent an eventual full registration.A recent report (2013)
from the Government Accountability Office, entitled EPA Should Take Steps to improve Its
Oversight of Conditional Registrations,33 strongly criticizes this process, citing poor internal
management of data requirements, constituting an "internal control weakness."The report
states, "The extent to which EPA ensures that companies submit additional required data and
EPA reviews these data is unknown. Specifically, EPA does not have a reliable system, such as
an automated data system, to track key information related to conditional registrations,
including whether companies have submitted additional data within required time frames."
However, these recommendations do not go far enough. Pesticides without all the data
31 Lambert,M.R.,Giller,G.S.J.,Barber,L.B.,Fitzgerald,K.C.,Skelly,D.K.,2015.Suburbanization,estrogen contamination,and sex ratio in wild
amphibian populations.Proc.Natl.Acad.Sci.112,11881e11886.
32 White House Blog:New Steps to Protect Pollinators,Critical Contributors to Our Nation's Economy
http://www.wh itehouse.gov/blog/2014/06/20/new-steps-protect-pollinators-critical-contributors-our-nation-s-economy.
se Government Accountability Office.August 2013.EPA Should Take Steps to Improve Its Oversight of Conditional Registrations.GAO-13-145.
http://www.gao.gov/products/GAO-13-145.
7
required for afull understanding ofhuman and environmental toxicity should not beallowed
on the market. Several historic examples exist of pesticides that have been restricted or
canceled due to health or environmental risks decades after first registration. Chlorpyrifos, an
organophosphate insecticide, which is associated with numerous adverse health effects,
including reproductive and neurotoxic effects, had its residential uses canceled in 2001. Others,
like propoxur, diazinon, carbaryl, aldicarb, carbofuran, and most recently enclosulfan, have seen
their uses restricted or canceled after years on the market due to unreasonable human and
environmental effects. Recently, a product manufactured by DuPont, Imprelis, with the active
ingredient aminocyclopyrachlor, was removed from the market only two years after EPA
approval under conditional registration.14 Marketed as 8 broadleaf weed killer, |rnpre|is was
found to damage and kill trees. However, in EPA's registration of the chemical, the agency
noted, "In accordance with FIFRA Section 3(c)(7)(C),the Agency believes that the conditional
registration of aminocyclopyrachlor will not cause any unreasonable adverse effects to human
health or to the environment and that the use of the pesticide is in the public's interest; and is
"ys
therefore granting the conditional registration.
Failure to test or disclose inert ingredients. Despite their innocuous name, inert ingredients in
pesticide formulations are neither chemically, biologically, or toxicologically inert; in fact they
can be just astoxic asthe active ingredient Quite often, inert ingredients constitute over 95%
of the pesticide product. In general, inert ingredients are minimally evaluated, even though
many are known to state, federal, and international agencies to be hazardous to human health.
For example, until October 23, 2014'36 creosols, chemicals listed as hazardous waste under
Superfund regulations and considered possible human carcinogens by EPA,37 were allowed in
pesticide formulations without any disclosure requirement. EPA recently took action to remove
cresols and 71 other inert ingredients from inclusion in pesticide formulations as a result of
petitions from health and consumer groups. However, numerous hazardous inerts remain. For
example, a 2009 study, entitled Glyphosate Formulations Induce Apoptosis and Necrosis in
Human Umbilical, Embryonic, and Placental[e8s,uo found that an inert ingredient in
formulations of the weed killer Roundup (glyphosate), polyethoxIated tallowarnine (POEA), is
more toxic to human cells than the active ingredient glyphosate, and, in fact, amplifies the '
toxicity of the product—an effect not tested or accounted for by the pesticide registration
process. A 2014 study, Major pesticides are more toxic to human cells than their declared active
principle,found inert ingredients had the potential to magnify the effects of active ingredients
by1,000fold.
Pesticide manufacturers argue against the disclosure of inert ingredients on pesticide product
labels, maintaining that this information is proprietary. Limited review ofinert ingredients in
pesticide products highlights a significant flaw with the regulatory process. Rather than adopt
precautionary approach when itcomes to chemicals with unknown toxicity, EPA allows
uncertainties and relies on flawed risk assessments that do not adequately address exposure
11 Environmental Protection Agency.June 2012.Imprelis and Investigation of Damage to Trees.
xttn://www.epa.uuv/pestmues/regu|ouow/impreos.mm|.
11Environmental Protection Agency.August zu1n.Registration mthe New Active Ingredient Ammono/om/racxm,for Use vnNon-Crop Areas,
Sod Farms,Turf,and Residential Lawns.
nu»://www.emu/ation,.um/cntenuaeamewobject/u~os00uo6xnu4Osumamspmu/nn~atmu`memucomenuyne~pdf.
11 Environmental Protection Agency.October 2014.EPA Proposes to Remove 72 Chemicals from Approved Pesticide Inert Ingredient List.
ntt»://yosem/te.ena.moxmna/aumn,e,so,Vunm7me2ceceeocxszsraseuu4moczr$oyrsswaassnuuuas2s/u,annozasoumpe^oummeot.
"`Environmental protecunAgency.October zo1s,Cresol/Cresylic Acid. nttn://www.epa.mov/ttnatmml/ouxeVoem/s.mm|.
11nenacxou,and seraun/.2009.Glyposate Formulations Induce Apoptosis and Necrosis in Human Umbilical,Embryonic,and Placental Cells.
Chemical Research and Toxicology.mtp://Poos.^u.^rgldoyobsIlu1m4tx8wml8n.
8
and hazard.Then, when data becomes available on hazards, these pesticides, both active
ingredients and inerts, have already left a toxic trail on the environment and people's well-
being.
Label Restrictions Inadequate. From a public health perspective, an inadequate regulatory
system results in a pesticide product label that is also inadequate, failing to restrict use or
convey hazard information. While a resident may be able to glean some acute toxicity data,
chronic or long-term effects will not be found on products' labels. Despite certain pesticides
being linked to health endpoints, such as exacerbation of asthma'39 learning disabilities,40 or
behavioral disorders'41 this information is not disclosed on the label. Furthermore, data gaps for
certain health endpoints are also not disclosed.
Mixtures and Synergism. In addition to gaps in testing inert ingredients and their mixture with
active ingredients in pesticide products, there is an absence of review of the health and
environmental impacts of pesticides used in combination. A study by Warren Porter, PhD.,
professor of zoology and environmental toxicology at the University of Wisconsin, Madison,
examined the effect of fetal exposures to a mixture of 2,4-D, mecoprop, and dicamba exposure
—frequently used together in lawn products like Weed B Gone Max and Trillion— on the
mother's ability to successfully bring young to birth and weaning.42 A 2011 study, entitled
Additivity of pyrethroid actions on sodium influx in cerebrocotorial neurons in primary culture,43
finds that the combined mixture's effect is equal to the sum of the effects of individual
pyrethoids.This equates to a cumulative toxic loading for exposed individuals. Similarly,
researchers looked at the cumulative impact the numerous pesticides that may be found in
honey bee hives in the 2014 paper Four Common Pesticides, Their Mixtures and a Formulation
Solvent in the Hive Environment Have High Oral Toxicity to Honey Bee Larvae.44 The findings of
the study send no mixed messages —pesticides, whether looked at individually, in different
combinations, or even broken down into their allegedly inert component parts have serious
consequences on the bee larvae survival rates.The synergistic effects in most combinations of
the pesticides amplify these mortality rates around the four-day mark.
Research by Tyrone Hayes, PhD, professor of integrative biology at UC Berkeley has compared
the impact of exposure to realistic combinations of small concentrations of pesticides on frogs,
finding that frog tadpoles exposed to mixtures of pesticides took longer to metamorphose to
adults and were smaller at metamorphosis than those exposed to single pesticides, with
consequences for frog survival.The study revealed that "estimating ecological risk and the
impact of pesticides on amphibians using studies that examine only single pesticides at high
concentrations may lead to gross underestimations of the role of pesticides in amphibian
declines.1141
"Hernandez et al.2011.Pesticides and Asthma.Current opinion in allergy and clinical immunology.
http://www.ncbi.nlm.nih.gov/pubmed/21368619.
411 Horton et al.2011.Impact of Prenatal Exposure to Piperony)Butoxide and Permethrin on 36-Month Neurodevelopment.Pediatrics.
http://www.ncbi.nlm.nih.gov/pubmed/21300677
41 Furlong et al.2014.Prenatal exposure to organophosphate pesticides and reciprocal social behavior in childhood.
42 Cavieres MF,Jaeger J,Porter W.Developmental toxicity of a commercial herbicide mixture in mice:I.Effects on embryo implantation and
litter size.Environmental Health Perspectives.2002;110(11):1081-1085.
43 Cao et al.2011.Additivity of Pyrethroid Actions on Sodium Influx in Cerebrocortical Neurons in Primary Culture.Environmental Health
Perspectives.http:JJehp.niehs.nih.govj1003394j.
44 Zhu et al.2014.Four Common Pesticides,Their Mixtures and a Formulation Solvent in the Hive Environment Have High Oral Toxicity to Honey
Bee Larvae.PLOS One.http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0077547.
41 Hayes TB,Case P,Chu!S,et al.Pesticide Mixtures,Endocrine Disruption,and Amphibian Declines:Are We Underestimating the Impact?
Environmental Health Perspectives.2006;114(Suppl 1):40-50.doi:10.1289/ehp.8051.
9
Appendix C. Health Effects of Commonly Used Pesticides
Health Effects of
AM Aft JOIL
.5u it..;ommonlyr Used Pesticides
EnilorArw Repmduefive Iddney/Liver Sensitizer/
Cancer Disruption Effects Neurotoxidty Damage liTitant Birth DefecU
OEM
X
XI Xi
X-
clowakd xz Xz X,
Diquat Gibromide XMI XT,
Fluazipap-p-butyi X1 X1 XL
XP
Imazapyr X7 X2
MCFA V5 X2 XZ )(11 XI
(Mcppjj
Peargork Add- V
X
Triclopyr
Acephate X, Xil, xi� X,-
Bifien th&kIf
'C' Xa
X,
Carbaryi X5 x1c xs X�L W I X",
X X,
Imidad'oprid X7 X-1 XT
X21:
xl
Malathiow M44=-
Rerniethrin- X3 XIL7 X=,I X, X!
rn
Tti
Permethrin-
r
d
t
'e h
t0
h
fP
C,
Amyst in V X'
rob
propiconazote XS X1 X1 X1
X
1,4 letw X� X X1 -X2
Mhkopbanale n -'ed,
X
XZ
Towtv, 16 17 21 14 25 26 12
EPA S� rf. Y
10
Description
Mosttmddty determinations based on interpretations and conclusions.of stutiess by universft gmemmerrt,or otmarsiaadon daTabasEmM
cells may referto - insuffiderit data or tfcherrrcaf is considered relatively rumn-tc do based can:currently available rata"
The last of 30 commonly used lawn chemkafs is based on irfcrrr.r on provided by the C,enerat Accounting Cfffoe 19%Repon,'-awn Care
Sticfdes:Risks Remain Uncertain While Prohibited Safety Claims Conthuef U.S.Environmental Pmte<:t on Agency(EPA)Naborrai Pe5-,kxL-
Stinrey
'
(:155),Farm Chemicals KwKftmk(1989),The National Home and Garden Pesticide Use Sammy by Research Tdangle lnslit ,NC;
(1992),rmuftiple state rem,current EPA EmIronmer%il kmpaa Statements,and ftp Asssessments,EPA natural sales aril usage data,best-
selling
estself products at f. :s and Horne f3epM and Beyrcand Pe iddes`information request,_
more lrforrnatran m hazards associated with pesticides please see Beyond Pestrcf s`Gateau can Vii&-Ftawn&and WePest amon-
rageraaentat svww.be+ rdpestictde5.cTgjgat -For questions and other:inq€a ,please contact our office at.102-543-5450,e€nail infer@
pesticides€arga rvisrt us on the webat wwwbeyondpestddesxrg
Citations
1. U.S.EPA_Cff:'ice of Pesticide Program Reregistratfon Eligibility Lied5ions(RED5j Interim RELY GRED),and RED factsheets..
hrtp,kl ter-epa-g-pest tides/rer--,.-t rat onJ_
2- National Libra.yof Medidne,TOXNET;.Hazardous,Srstbstzr€rees Database,lhap:fjtoxnetrim-nih.govf"
3. U.S_EPA 2012.OfMce of Pesticide Programs Chemicvfs Eveafuntedfar Carcinogenic Patenorrd
ht .l'/npicorst,edu/daefniical_e tuated" f
+f- California Environmental Protection Agency-Piapasitiori 65-C'heinkarls Known to theStrrte ter Cause Cancer e r
Rppnadurtcve Fiaareiry.Office of Ernnronmer l Health Hazard Assessment.
http:f/'—r hha_ Tiprtrpb5jprop55_tistjfilesjP[ ingleG52rr13.pdt
5_ The Pesticide Management Education Program at Cornell University_Pestcid,-Fictive Ingredientltrforsrxav'w-
http:/,/Pmep.cce.comell.edu/profriesfind-aw-htmt-
f. The Endocrine litsraptioan Exchange.2011-last of Potential Erten rine LTisrrrprears_
http,./[,&wwen c€inedisrupftn.cam/endoaine-TEf1X,lisLoveR,Iew.php-
7. Northwest Coalition for Afteraratives to Pesticides(NCAP},.Pesti dde Factsheets.
:jfw+evv.peicde.orajgettite facjs€rde factshets-
zi:_ Beyond Pesticides C'h €l4?oteh Factsheets,http:{j deyondr €icides_org{(ne-tic di#!s/ctsheets/indexht m.
9 U-S.EPA-Chronic( aaercer)ToxicityvarndorChemkarfEListedUnderEPCFASectjan313TadcReleasetraventory
Program-httpijjwww-epa.gov/tri[trichemiLals/hazardinib/hazaT)O ronic non-cancer95.pdf
Ia. European onion Com missacnr on the Environment List of 145 substances,with endocrine disruption classi`kations,.
Annex 13 http:Jjeceuropa.eulenvirDnrnent/end rir�efstrategy/5ub�ance5 en.htart#report2.
11- Extension Toxicology Network(EXT NM Pesticide Information P:ofles.http;{jextoanet_cr eduTtghinde�htrril_
12. Internatioflaf Agency for Research on Cancer veld Health Grganization tiA—RC}category 2A,the agent Imixtu e)is probably
cardnogenic to humns,based on sufficient evidence of carcinngenkity in laboratory anirnai studies_
http:jf monographs.iarcfr/ENG/Classifieationfindex:php.
Cost Updated May 2015
11
Appendix D. Environmental Effects of 30 Commonly Used Lawn Pesticides
WIE�o=g'o"*ni"yiJs'e'rt-IIILoa'wn Pesticides
11 -X111 I
potential Toxic to Fish/ Tsrxicto
Leachef Toxic to Birds Aqua* Toxic to Sees Mammals
Organisms
Z*b::
XL,
Beftfluralin X7 X— VIII
X2,11
5M,
Mamba XZ71 XIJU XMIi XSWJi
:XI,
X, . .......
XS
Dithiowr )V"IL
Glyph sate' Xg X, XI-2,11 Xil'il xll X4
hn-pyr,
15o ben X11 x. xsa A*
WPA
Mecoprop(MCPP)l X4 XI;"-B-,! xs�,11 XZ X I'- X'-
X041 W�u X3
XI�7-' )ft�Z3Al -TL
TrMuralin- Xk- X;!I
NEW
Acf-ph
Y3,%I XA,3
Bifenthdn't X14c;M Xmou xlaou
X
5pranil X, Xsl xzlkVul xmiul
P 7,
X X
Xt--,- X3
TftlorFon rias XL3,11 XL Ma )(Ill
Azoxystrobin Xg VAIA xu XI-a Kn
Myclob�tanil i )V
propicorrazole 7f2 X, )(k-11 XS=
X,
'Sulfur', XL Nil
Thiophanate!metttyl X, X`1
xu',11
X
Totals: 19 20 22 30 2.3 14
e.PA
12
Description
E;=tmddty deterniinatlons based on interpTetat r-,indconclusions efstudes by university,government or+arganization databases-Empty
ceps may refer to e€the'insufficient data or if the chermcaf is considered relat`vely non-wyk based on currently available data.The col-umn la-
beled'Ratent€raltoLeach'referstoachernicarspotential tome into deeper soil lamesand eventuallyinto grour,dusctter.The colurnnlabeled
to Mammals'refer to conclusiorys,based on evidence from studies done on non-human mammals_
The list of 30 eommanly used lawn chemicals is based an iriforinstion provided by the General Accowrfing Office,1990 Report,"Lamm Care
Peticdes,Risks Remain Uncertain White Proffibtted SafM Claims Continue,`tt1 Envirtnunertal Protection Agency(EPA(National Pesti
Survey(19%),Farm Chemicals Handbook t1989),The National Horne and Garden:Pesticide Use Stay by l search Tfiangle hstitiate,NC
11490,multiple state nom,current EPA Environmental Impatt Statements,and#tisk A,:,essmeras,EPA national saie and mage data,best-
sElling produm at Lowes and Home Depot,and':Beyond Pias def inibmiation rNueZ,
For more information on hazards associated with pesticides,please see Beyond Pestfdda5'G atovvny o,pertidde Hazards and SafePest:rs Man-
agement at wwV&eyundpesnddes-mVgateway.For€uestions and other Inquiries,please contact our office at 202-543-545G,emaif info@
beVondpestiddes.org or v&us an the web at beyc-ndpesdd:ivdes o€g.
Citations
1_ Ekten sionToxicokagy k(ETOXNETlPestiddeImbrrai atimPaofiles.Available at-hap:j/e c uj*, g7hindex l rr;l.
2- Northwest Coalition for Aite€rsatives to Pesticides(P A ,Pesticide Factsheets.Avalfable at htip;flstidide-orgfget the€acts/
pestide-,facisheets_
3- tf.S_EPA Office of Preveivtiorl,Pesticide and Tok Substariie,Reregistiation Eligibility Decisions( ),interim REL (iREDs)and RED
Fa rests Available at http Elam -efts gm,/pesticides/rer strat ogs=&htm_
4. National UbraryofMedicine.T IET Hazardous Substances Database.Nalfabfeatthttp:�/t nitnrah }cgibans
ht€rrlgen?i PSDB.
5. Pesticide Action Network Fesocide'Database Available at http:/ ernfo:oeg_
& Fluoride Action Alert Pesticide€mjectFactsheets_Available at:hnp.,/ :flucrrideaiertog pesoidesj=..:
3. U.S.GeolcgicadSurverQualityinPrirrjpe]Aquifer5cftteUrdtedS ,1991--)Glo-2Dl5-,Availabtearhttp://pubs-USgs-gov/
crrc/13ED/..
B. Batmgl A_,KT Meyer,KAA,KLavda,and LE Dietc.Glyphosateand]rsDegiadationPmdwAMPAOccu€FrequentlyandWidelyin
1.l_S SrziIs,Surfac e Water Gmu €,and Pmdpitati lourrial;of the Aar eruan!1 terRe;ources A;ssrraat cn(fAWA)50(2)_375-29
2014.Available at http:/fankr ib a€yr. leyLettm/doir ljD-Mltjaw-12159/bzzm
9. U-S.Geological Survey:Occurrence of Furioddes and Other Perbdides in Surface Water Groundwater,and Sediment from Three
Targeted-Use lse Areas in the tinted S e.2413_Available m.http-,Ifv, mknoEdreLtc=Mencelaitde/piV-tZO456535=219.
M National Pesticide Intormation Cerder(F9CP1 _'ivailableat .,j/nplera--eduf hdnL
11 University cfHerdiurdlshire_PPDB_Pesticide Properties Database-
eabfe Bttpf{' ltertsa��/aerie/ jenf.
12_ Ll forestServiceHuman Heat 'Ec g RskAssessmentAvaflahleat, http*//wrm�_fs.fed.rasftd -theaah/ tx&Li k mL
zcz r 3.z rY ... 2 art tr.
Lost L!pdatedMay 2015
13