In their ongoing, and seemingly relentless, war against agriculture, environmental justice and farmworker advocate organizations have taken aim at agriculture once again. On November 18, 2021 the United Farm Workers, United Farm Workers Foundation, Earthjustice, California Rural Legal Assistance Foundation, Farmworker Association of Florida, Farmworker Justice, GreenLatinos, Labor Council for Latin American Advancement, League of United Latin American Citizens, Learning Disabilities Association of America, Pesticide Action Network North America, and Pineros y Campesinos Unidos del Noroeste (the Earthjustice Petition) filed a petition with the U.S. Environmental Protection Agency (EPA), requesting the Agency revoke all tolerances and cancel all associated registrations for food uses of the following organophosphate pesticides (OPs): Acephate, Densulide, Chlorethoxyfos, Chlorpyrifos-methyl, Diazinon, Dichlorvos, Dicrotophos, Dimethoate, Ethoprop, Malathion, Naled, Phorate, Phosmet, Terbufos, and Tribufos. In addition, the petitioners request that the Agency take actions to protect workers from potential risks of exposure to OPs, update its risk assessments to include a protective regulatory endpoint for children, and complete registration review on the OP class of chemicals by October 1, 2022.

Why are activists doing this? Here is their stated position. In their petition, the activists claimed “organophosphates are a class of neurotoxic pesticides originally developed by the Nazis as nerve agents in World War II. OPs cause acute pesticide poisonings by suppressing acetylcholinesterase (AChE or cholinesterase), an enzyme that regulates nerve impulses throughout the body. In addition, a growing body of scientific literature establishes that Ops cause neurodevelopmental harm to children at exposures far below those that cause 10% cholinesterase inhibition, EPA’s current regulatory endpoint. Published, peer reviewed studies correlate OP exposure with impaired motor and mental development, reduced IQ, attention disorders and autism at low exposures. Some OPs are also linked to cancer and reproductive harm.”

The activists further commented that “People are exposed to OP pesticides through residues on the food they eat, contamination of the water they drink and when the pesticides drift from where they are applied to where people work, go to school or play. Children often have greater exposure than adults to OPs due to their increased hand-to-mouth activity, and relative to adults, they eat more fruits and vegetables, drink more water and breathe more air for their body weight. The farmworkers who grow our food face the highest exposures and risks from OP pesticides. In addition to exposures through food and drinking water, they are exposed when they apply the pesticides or enter fields that have been sprayed, and they and their families are more likely to be harmed by pesticide drift because they live and go to school near where OP pesticides are sprayed. Farmworkers and their families are majority people of color and low income.”

So why dichlorvos? It is even used on the farm, so why is the UFW going after it? Why is anyone going after it? While making all these claims and statements, nowhere in their petition did they provide validated scientific information that actual exposures are occurring. They even claim that while personal protective equipment can protect against exposure, it is often insufficient, yet there was no actual proven scientific data supplied to support the claims. Not one single shred of evidence.

For the tree nut hulling and processing industry, dichlorvos is of utmost importance. Dichlorvos is the active ingredient in Card-O-Vap 8 and/or VAP-X. These products are widely used with tree nut hullers and processors for very effective control of red flour beetles, confused flour beetles, Indian meal moths and warehouse beetles. It is the only way to eliminate an infestation. These products have replaced the use of methyl bromide for the control of these insects. Furthermore, they have been used without incident and are critical to the control of these pests in our food facilities. Food safety is a very high priority for our tree nut hulling and processing facilities, and these products are an absolute necessity for maintaining a food-safe environment. If we don’t control these insects, we can’t sell tree nuts. And if we can’t sell tree nuts, what happens to the jobs at those facilities?

The tree nut industry strongly feels the request to revoke the tolerances and cancel the registrations is without scientific basis and not warranted. These products are safely used and have even tighter use restrictions going into effect later this year. These requirements will ensure these critical tools are used safely and appropriately. We have been unable to identify an equally effective alternative and would be severely impacted by the elimination of these products. Accordingly, the Western Agricultural Processors Association strongly urged U.S. EPA to not move forward with the revocation of tolerances or the cancellation of any pesticide registrations related to dichlorvos. This is just another baseless attack against those who feed and clothe the world, and who provide jobs to the very people the activists claim they represent.