ventura, August 24, 2020

Sign and share the Climate Coalition Petition

Join us in asking the Ventura County Board  of Supervisors to include programs to educate people about how pesticides pollute the environment and harm people.  To make comment on this for the VC2040 General Plan, email to Susan Curtis <[email protected]> no later than Monday, August 31, 3:30 p.m.. 

Petition:  To support all 40 of the recommendations from the 350 Climate Coalition including these about pesticides, sign the  Petition to the Supervisors:  CLICK HERE

Instructions:  To comment to the Supervisors during the September 1 hearing or ahead of time by email: CLICK HERE.

Sales of pesticides should be discouraged. No more jugs of Roundup piled up at the checkout line. The active ingredient, glyphosate easily enters through skin of all organisms and disrupts the biochemistry.  Fish are especially vulnerable.  Roundup being an antibiotic and systemic poison used on seeds prevents functions of carbon sequestration, water retention and water-holding capacity to withstand prolonged drought and flooding. It kills protective microbes that protect plants against disease.

Neonicotinoid pesticides that harm bees are banned in the EU and Canada. Why would we want them sold and used here? They kill pollinators and beneficial organisms and the birds and bats that eat them. Acute and long-terxposure to farmworkers needs to be monitored

Anti-coagulant rodenticides  also need to be put at the back of the store with displays about the harm from each product. Rat poison kills owls, eagles, mountain lions. 

Let’s protect ecosystems as a climate action. Toxins inhibit the ecosystem functioning that normally draws down and keeps carbon dioxide out of the atmosphere. The land can hold much of the carbon dioxide that is causing climate change, but it must be managed regeneratively, without poisons. Let people know how pesticides harm the environment and contribute to climate change and may harm them.

We gave the Supervisors lots of explanation and references below.  Read our five recommended policies and programs and reasoning.  The science indicates these should be banned. At least we need an educational program so that people don’t think buying and spreading poison around is normal.

When you write your comment, put in a good word for Integrated Pest Management (IPM) that starts with pest prevention and biological and cultural practices and selective low-risk pesticides as a last resort. These alternatives start with system design and plant health care inherent in regenerative agriculture that minimizes pests and diseases in the first place. The County should adopt policy to promote regenerative agriculture and IPM!

Don’t forget to sign and share the Climate Coalition Petition

The science is clear on banning these pesticides. At least let the risks be widely known to discourage their use. Here is what we provided to the County Supervisors to back up these five new recommendations for the General Plan:

4 NEW Policy COS-1.16 Discourage sale and use of anticoagulant rodenticides and toxic herbicides on private property. The County shall discourage businesses from using or selling anticoagulant rodenticides, toxic herbicides, and neonicotinoid insecticides and discourage property owners from purchasing or using these chemicals on their properties.  CAP, EJ, HC

SHORT RATIONALE:  Added to ensure dissemination of scientific information about synergistic and cumulative effects on biodiversity, ecosystem function, and climate change beyond what is covered on pesticide labels.

18  NEW Program COS-II Environmental risk communications and availability of alternatives to pesticides labeled Hazard and Caution. The County shall develop a risk communication program about the potential harmful impacts from DANGER and WARNING label pesticides on ecosystems including impacts from synergistic and cumulative effects. CAP, EJ, HC

SHORT RATIONALE: Added to provide scoping for environmental risk communication to the public about effects on biodiversity, ecosystem function, and climate change beyond what is covered on pesticide labels.

 RATIONALE FOR NEW PROGRAM TO DISCOURAGE SALE AND USE OF AND TO COMMUNICATE ENVIRONMENTAL RISKS FROM DANGER AND WARNING LABEL PESTICIDES 

Risk communication to the public with shifting societal perceptions are moving people to a greater awareness and desire to not use toxic chemicals. Consumers want to protect themselves, may be concerned about farmworkers and other pesticide handlers (discussed in the Rationale for a proposed related New Policy and Program in the Hazard and Safety Element), but also for concerns about ecosystem restoration and climate mitigation discussed below. 

Risks from to the environment from anticoagulant rodenticides (ARs): (Adapted from comment June 2020 by Center for Biological Diversity) The County’s utilization of Integrated Pest Management for long term sustainable strategies to address rodent infestations provides the model for municipal and public use.¹ Effective, affordable alternatives to rat poison include rodent-proofing homes and farms by sealing cracks and crevices and eliminating food sources; providing owl boxes in rural areas to encourage natural predation; and using traps that don’t involve these highly toxic chemicals.² Municipalities in Ventura County, such as Thousand Oaks, have developed resources to provide individuals in their communities with resources for sustainable rodent control.³  The County has proven IPM alternatives and, for the same important reasons, the use of these materials must be phased out throughout the county.  

The feed through effect of anticoagulant rodenticides on higher predators not only harms the raptors, mountain lions, bobcats and other predators, it destroys the ecosystem functioning that draws down and stores carbon dioxide from the atmosphere. For example, rodents are a source of food for raptors and larger predators that eat and poop surplus biological material–part of a protective carbon cycle in the landscape. 

Risks to the environment from  neonicotinoid pesticides including Clothianidin (Bayer’s successor product to imidacloprid) are a family of systemic pesticides, which are taken up by a plant’s vascular system and expressed through pollen, nectar and gutation droplets from which bees then forage and drink. Neonicotinoids kill sucking and chewing insects by disrupting their nervous systems. 

These insecticides have taken over the seed treatment market, are toxic to insect pollinators and are lead suspects as causal factors in Colony Collapse Disorder that threatens honeybees. A recent study shows negative effects on grassland and insectivorous bird biodiversity probably due to direct consumption of coated crop seeds and indirectly from disruptions of the food supply for birds that cannot find the insects that they have evolved to reproduce on. This research provides compelling support for the re-evaluation of policies of the US EPA to allow use of neonicotinoids, particularly around bird habitats. We should not wait for the US EPA and then CAL EPA to conduct more studies before banning these pesticides; the least we can do is educate the community about their risks and alternatives.

Risks to the environment from organochlorine pesticides. These compounds bioaccumulate in the environment and remain stable in fat tissue of all species resulting in increasing exposure in longer-lived, higher trophic level predators. 

Risks to the environment from Roundup and glyphosate. Contrary to myth, glyphosate is persistent in the environment (persistence depends on soil type), blows in the wind and bioaccumulates in larger mammals, and it is widely present in surface water, rainfall, or groundwater. 

“Chemical cocktail” effect – or synergistic and cumulative pesticide exposures of multiple interacting chemicals combine to have greater or synergistic effects than would be predicted by traditional toxicological models. Pesticides can have a cumulative “toxic loading” effect both in the immediate and long term. Neonicotinoids are known to persist in the soil for years and to have a cumulative effect on neurotransmitters over time. 

Stormwater carries mixtures of bioactive contaminants (pesticides and pharmaceuticals) and other organic chemicals with known or suspected risk. Studies show dozens of chemicals per testing site with individual concentrations exceeding 10,000 ng/L, and cumulative concentrations up to 263,000 ng/L raising concerns about potential environmental effects during runoff events.  Studies of negative impacts from cumulative effects of pesticide runoff on coho salmon raise particular concern about restoration of steelhead trout in Ventura County rivers. U.S. environmental regulation remains behind current toxicological science in accounting for synergistic and cumulative chemical effects in food chains.

 Climate change impacts from pesticide and herbicide use  Climate mitigation and resilience depend on healthy above and below-ground ecosystems. We must communicate about how pest control choices affect climate change as well as the environment. 

 Carbon farming or sequestration (made possible by healthy soils) is entirely the work of soil microbes interacting with soil, roots and water. Soil microbes and plant roots are harmed by pesticides. A healthy, biodiverse above ground foodweb with an abundance and diversity of insects has a role in carbon sequestration, because both soil-dwelling and above-ground Insects are the food for birds, bats, fish and even large mammals all depositing carbon at the soil interface in their frass and body parts. All forms of dead and alive microbial, plant, invertebrate and vertebrate biomass contribute to a functioning ecosystem that maximizes carbon sequestration.

 Ecosystem restoration that values high native plant biodiversity can support a many-fold increase in abundance of the above-ground invertebrate and vertebrate food web at high degrees of biological function. Vegetation contributes even more when there are at least eight species in a plant community. Non-noxious ‘weeds’ may contribute cost-effectively to farm, garden or landscape biodiversity and ecosystem function. In fact, so-called ‘weeds’ better referred to as ‘volunteer plants’, are powerful actors for restoring degraded, polluted soil. Weeds indicate what the soil needs to become more healthy. 

 When there are herbicides killing cultivated and volunteer plants above ground and no toxic pesticides harming microbes below ground, sufficient diversity supports the phenomenon of a community tipping point of microbes that increases functionality by “quorum sensing”. At the  tipping point there is a significant increase in the performance of that soil for holding carbon, soil aggregation, infiltrating water, nitrogen fixation, and nutrient cycling. With enough biodiversity in the plant community, there is no need for added natural or artificial fertilizer.  

 Roundup is the biggest selling pesticide in the U.S. and is seriously implicated in habitat and whole ecosystem destruction. Roundup being an antibiotic and systemic poison used on seeds prevents functions of carbon sequestration, water retention and water-holding capacity to withstand prolonged drought and flooding. It kills protective microbes that protect plants against disease. By using non-toxic and more selective weed management, we support healthy plants that contribute significantly to pesticide use reduction and climate resilience for economic survival for benefits such as mitigating flooding and heat island effect 

Finally, the production and transport of pesticides also have a high fossil fuel carbon footprint. Continuing to reduce GHG emissions will become increasingly costly and difficult during the transition away from fossil fuels. Communicating about risks from pesticides will have a multiplier effect through education on reducing the demand for toxic pesticides and a steady increase of capacity for biological carbon sequestration.

Counties have a legal option to restrict or ban pesticides (including rodenticides) as established in case law. Ventura County has long deferred all regulatory decision-making to the California Department of Pesticide Regulation, but this is a decision based not on legal precedent, but on a lack of political will to ensure protection for the people of the county. At least, the County should tell people the truth about pesticide risks.

One of a number of examples of political courage is by the City of Malibu that passed amendments to its Local Coastal Program (LCP) to prohibit the use of pesticides, including ARs, throughout the city, and to require that new development permits have a condition of approval that includes “a prohibition on the use of pesticides, including insecticides, herbicides, rodenticides or any toxic chemical substance which has the potential to significantly degrade biological resources.” City of Malibu, Resolution 19-54.

Case law to restrict pesticide and rodenticide use can be found in the adoption of a LCP by the Coastal Commission which has been supported by the California Attorney General’s office and upheld in court. The Attorney General’s office explains that the Food and Agriculture code explicitly allows for the Coastal Commission to exercise its authority “under the Coastal Act to regulate land use in the coastal zone” as it does when it affirms LCPs to restrict pesticide use. The legality of regulating pesticides via the Coastal Act’s adoption of an LCP was also upheld by the Los Angeles Superior Court. 

 the [Coastal] Commission is requiring a pesticide ban for the County’s LCP, to be administered by the County, because the Commission has the authority to do so as part of its administration of the Coastal Act. F&A Code section 11501.1(c) permits the commission to require [Los Angeles County] to conform to this ban in administering the LCP. 

 Mountainlands Conservancy LLC v. California Coastal Commission, Case No. BS 149063, decision on petition for writ of mandate: denied (Sept. 5, 2017) at 20. Ventura County should take strong steps to limit unintended impacts to biological resources from ARs by prohibiting their use within the Coastal Zone by amending the LCP. 

Footnotes and citations about environmental risks from pesticides and herbicides

• Zeng, G., Chen, M. & Zeng, Z. Risks of neonicotinoid pesticides. Science 340, 1403 (2013).
• Li, Y., Miao, R. & Khanna, M. Neonicotinoids and decline in bird biodiversity in the United States. Nat Sustain (2020); https://doi.org/10.1038/s41893-020-0582-x
• Heller, M. Bill aims to ban pesticides harmful to bees. E&E News (21 February 2019); https://www.eenews.net/eenewspm/2019/02/21/ stories/1060121799\ 
• Masoner, Jason, R. et al Urban stormwater: An overlooked pathway of extensive mixed contaminants to surface and groundwaters in the United States Environ. Sci. Technol. 2019, 53, 17, 10070–10081 https://doi.org/10.1021/acs.est.9b02867
• Laetz, Cathy A., et al The Synergistic Toxicity of Pesticide Mixtures: Implications for Risk Assessment and the Conservation of Endangered Pacific Salmon Environmental Health Perspectives 2009 117, 3, 348-353. https://doi.org/10.1289/ehp.0800096
• Ventura County 2017, Raptor Pilot Study for Levee Protection: Integrated Pest Management Program, Ventura County Public Works Agency – Watershed Protection District, https://vcportal.ventura.org/BOS/District2/RaptorPilotStudy.pdf; Ventura County, Utilizing Raptors to Control Rodents on a Levee – VCWPD’s Pilot Program, Ventura County Public Works Agency – Watershed Protection District Operations and Maintenance Division, https://vcportal.ventura.org/BOS/District2/Utilizing_Raptors_to_Control_Rodents_on_a_Levee.pdf 
• Safe Rodent Control Resource Center, Rodent Control Strategies, http://saferodentcontrol.org/site/rodent-control/ 
• https://www.toaks.org/departments/public-works/sustainability/landscaping/rodent-control 
• Agenda Item 4.A. https://www.malibucity.org/AgendaCenter/ViewFile/Minutes/_12092019-1432
• Glyphosate Monograph” by Pesticide Action Network http://pan-international.org/wp-content/uploads/Glyphosate-monograph.pdf

21 NEW Policy HAZ-5.9 Discourage sale and use of registered materials with signal words DANGER and WARNING. The County shall discourage businesses from using or selling toxic herbicides, organochlorine, carbamate, and neonicotinoid insecticides and discourage property owners from purchasing or using these chemicals on their properties. CAP, EJ, HC

SHORT RATIONALE: Added to ensure dissemination of scientific information about synergistic and cumulative effects on human health and worker safety beyond what is covered on pesticide labels.

24 NEW Program HAZ-Y Public health risk communications and availability of alternatives to pesticides labeled Danger and Warning. The County shall develop a risk communication program about worker safety and consumer risks from exposure to DANGER and WARNING label pesticides. CAP, EJ, HC

SHORT RATIONALE: Added to describe the needed scope for risk communication and pest control alternatives for worker safety and public health concerning pesticide exposure beyond what is covered on pesticide labels.

RATIONALE:  There is increasing awareness and concern among scientists and the public that chemical pollutants can suppress immune processes and thus cause increased development of neoplastic and infectious diseases in the food chain. Studies are likely to show that compromised human responses, such as to Covid-19, are correlated with the amount of pesticides in someone’s body and/or urine. 

There is  proven causality of Roundup and Non-Hodgkin’s lymphoma. Legal cases related to glyphosate will continue to increase. The label is far from adequate to ensure that people are trained to protect themselves. The public has no idea when they may be exposed to a carcinogen when they lie down to relax on the grass, pick up a ball or play frisbee with their dog. Any entity that buys and oversees the use of pesticides has potential liability and should be proactive educating pesticide handlers and unsuspecting members of the public by communicating risks.

• Winans, B., at. al. Environmental toxicants and the developing immune system: a missing link in the global battle against infectious disease? Reprod Toxicol. 2011 Apr; 31(3): 327–336. https://www.ncbi.nlm.nih.gov/entrez/eutils/elink.fcgi?dbfrom=pubmed&retmode=ref&cmd=prlinks&id=20851760

Risks to humans from glyphosate intake via skin or in food: Glyphosate affects basic biochemical pathways of cells of all vertebrate organisms that can include hepatorenal damage, effects on nutrient balance through chelating action, and endocrine disruption. It harms functioning in gut linings of all organisms by affecting the “tight junctions” that open and close in the single cell layer separating the gut from the bloodstream. When exposed to glyphosate, the tight junctions become abnormally large and open. Oversized gut openings allow foreign molecules, e.g. partially digested food, to enter the body setting off immune system alarms.  

People react differently to immune system alarms. Some lose defenses against emerging tumors. In some people, based in part on genetics, immune systems may go into permanent overdrive as evidenced by the alarming increase in autoimmune diseases including autism and pre-diabetes. Nervous and reproductive systems are affected. Some medical doctors suspect glyphosate in the epidemic of poly cystic ovarian syndrome. Glyphosate has exceeded the allowed levels for drinking water in 3 of 10 samples of mother’s milk.  

Despite evidence since the 1980’s that glyphosate causes damage to human physiology, iit was approved, and manufacturers have successfully pressured the EPA to periodically raise the allowable concentration  in drinking water.  Glyphosate was reclassified as a probable carcinogen by the World Health Organization in 2015. Glyphosate has never been tested during foetal development at environmental levels of exposure and its commercial formulations have never been tested for more than one month in rats. 

Many scientific reports about Roundup, taken as a whole, raise doubt about the validity of the current ADI “acceptable daily intake” and suggest that the levels we are exposed to may not be safe over the long term. 

o    Meyers, et al. “Concerns over use of glyphosate-based herbicides and risks associated with exposures: a consensus statement,”, Environ Health. 2016; 15: 19. 

Risks to humans from pesticides: Exposure science is clear about the negative impacts from pesticides to public health and the environment, such that local governments should at minimum educate the community about the risks that are currently not being addressed by responsible science-based federal and state government regulation.

Risks to humans from organophosphates and carbamates are commonly used synthetic insecticides with the same mechanism of action for toxicity. These groups of pesticides are “potent inhibitors of acetylcholinesterase, which can result in parasympathetic and sympathetic overstimulation, skeletal muscle paralysis, and sometimes respiratory failure”. Three studies indicate that exposure causes lower IQ in human offspring. 

• Gupta, R. C., Mukherjee, I. R. M., Doss, R. B., Malik, J. K., & Milatovic, D. (2017). Organophosphates and carbamates. In Reproductive and Developmental Toxicology (pp. 609-631). Academic Press.

Organochlorines  Reduction and elimination of this class of pesticides would prevent the disastrous long term effects we saw after the proliferation of PCBs and DDT. 

• Borgå, K., Fisk, A. T., Hoekstra, P. F., & Muir, D. C. (2004). Biological and chemical factors of importance in the bioaccumulation and trophic transfer of persistent organochlorine contaminants in arctic marine food webs. Environmental Toxicology and Chemistry: An International Journal, 23(10), 2367-2385.

25 NEW Program HAZ-Z Farmworker Protection Standards. The County shall employ a Certified Industrial Hygienist to communicate work hazards to farmworkers according to OSHA worker protection standards, and seek funding and research for opt-in biomonitoring when farmworkers are exposed to hazard and caution label pesticides, and to characterize lifetime exposure to conditions in the field, ranging from dust particulates to inhalation of pesticides. EJ, HC

SHORT RATIONALE: Added to focus OSHA-level worker protection standards for farmworkers including data gathering to ensure protections.

RATIONALE:  Farmworker protection standards are set by the US EPA Worker Protection Standard (WPS) requiring:

• A designated representative to be made available to communicate risks and hazards inherent to one’s job. This representative should be well versed in OSHA worker protection standards to elevate the quality of the WPS. 
• An OSHA-level Ergonomic expertise is also needed to mitigate the risk for work-related musculoskeletal disorders. 
• Funding and research for opt-in biomonitoring of workers should be offered when hazard and caution label pesticides are used. 
• Gathering quantitative data will enhance our understanding of pesticides for public health goals. 

• • https://www.epa.gov/sites/production/files/2019-03/documents/nejac_letter_on_worker_protection_standards.pdf

• Concerns about harmful pesticide exposure are growing as evidenced by a bicameral pesticide regulation bill to be introduced in Congress that would ban certain pesticides based on an extensive body of science. Senator Udall and Congressman Negusi seek to update laws in response to warnings about critical links in our food chain and the need to protect children and farmworkers from brain damage and other health risks of dangerous pesticides. The following public health protections are covered in this bill and should should immediately be incorporated in risk communications by the County as part of a program to discourage their sale and use on public and private property and accompany an OSHA-level Worker Safety Protection program for farmworkers: 

• Certain pesticides will be banned.
  • Organophosphate insecticide.
  • Neonicotinoid insecticide.
  • Paraquat herbicide.
• Regulatory process will be changed.
  • Citizens will be able to petition EPA to identify dangerous pesticides so they will not be indefinitely permitted to remain on the market.
  • It will stop EPA from issuing emergency exemptions and conditional registrations to use pesticides before they have gone through full health and safety reviews.
  • Communities will be able to enact protective legislation and other policies without fear of veto of preemption by state law.
  • It will suspend the use of pesticides the European Union or Canada says are unsafe until reviewed by EPA.
• Protections will be provided for pesticide users.
  • Farmworker employees will be required to report all pesticide-related injuries to EPA; penalties for failure to report or retaliation.
  • EPA will have to review pesticide injury reports and work with pesticide manufacturers to develop ‘better’ labeling to prevent