We are hearing a lot these days about per- and polyfluoroalkyl (PFAS) chemicals, better known as “forever” chemicals. They are called forever chemicals because some have been found to bioaccumulate in the environment and in animals, including humans. The latest allegations claim a link between PFAS and pesticides and health risks, which anti-pesticide activist groups are using to demand the removal of any pesticide containing a single PFAS molecule.

Currently, approximately 25 bills have been introduced across the country regarding PFAS, so it’s not a “California-only” issue. Activists, of course, are prioritizing California to build credibility in other states. This has led to the introduction of AB 1603, which would ban all pesticides containing a PFAS molecule. We will discuss this bill in more depth later, but first let’s talk about PFAS so readers understand and have better context for the issues surrounding PFAS and pesticides.

Do Pesticides Contain PFAs and Why?
Some pesticides, including many of the newer, softer alternative pesticides, contain a single PFAS molecule. However, it is important to remember that this molecule was included in the formulation as part of the overall active ingredient, not as a single or separate ingredient.

The PFAS molecule is included in a formulation because it improves how products adhere to plant surfaces and penetrate target pests. It also reduces wash-off from plants, which increases protection for non-target organisms and the environment. This can reduce the overall number of applications, which reduces the tractor’s carbon footprint and the volume of product applied.

They also contribute to the development of alternative chemistries and new modes of action, which is critical to ensuring farmers have an adequate toolbox of products for product-use rotation and to preventing pest resistance to products.

Activist Allegations About Pesticides and PFAS
Unfortunately, activist groups are attempting the old standby strategy of throwing the same health and safety allegations against pesticides against the barn wall, only this time linking them to PFAS and seeing what sticks!

The allegations being circulated are that any pesticide containing a single carbon-fluorine molecule constitutes a PFAS and therefore poses the same risks as a multi-chain carbon-fluorine PFAS chemical, and that it should be treated the same.

The activists allege that any single-carbon PFAS molecule poses an unacceptable risk to human health and the environment, and that PFAS used in pesticide formulations bioaccumulate in people through residues found on crops.

Of course, no science or proof has been produced to verify these allegations, but that doesn’t stop them from being made, nor does it seem to stop their supporters, including legislators, from acting on them.

What Are the Public Health Risks of a PFAS Molecule in a Pesticide?
The risks from PFAS came to public and government attention when monitoring studies in states with large manufacturing industries, such as cookware and textiles, found multi-carbon PFAS bioaccumulating in the environment and, due to runoff from those factories, in farm animals and humans.

These were primarily industries that used chemical products such as Teflon or stain-resistant carpet treatments in their products. However, those chemistries contained long-chain fluorinated molecules with six or more fluorinated carbons in the products. Those multi-molecule carbon chains pose a problem that the U.S. EPA is addressing.

As a result of concerns about PFAS chemistries, the U.S. EPA has been studying all PFAS molecules, including single PFAS molecules.

The U.S. EPA has released its findings on PFAS molecules and has reached the following conclusions:
• Single-fluorinated carbon molecules are more susceptible to chemical transformation. As a result, they are less likely to persist or bioaccumulate in the environment.

• FIFRA, the U.S. EPA and the Federal Food, Drug, and Cosmetic Act have found reasonable certainty of  “no harm” from residue exposure. These safeguards include tolerances for all food-use pesticides, including single fluorinated carbons.

• U.S. EPA’s safety assessment is not based solely on U.S. studies. The studies are supported by registration standards approved in the European Union, Canada, Australia, the United Kingdom and other countries.

• The risk from single-PFAS molecules is so small that the U.S. EPA intentionally excluded single fluorinated carbon molecules from being designated as PFAS.

How Is Pesticide Product Safety Being Assured in California?
In addition to the studies the U.S. EPA has conducted and continues to conduct, DPR in California has been evaluating PFAS, specifically regarding pesticides, for almost a decade.

Let’s remember, DPR has perhaps the most scientifically advanced evaluation process for pesticides in the country, perhaps the world. They evaluate every chemistry for safety, including those containing fluorinated carbon molecules, to determine whether there is a risk of bioaccumulation. If there is, the product will not be registered.

Other agencies responsible for product safety do not have DPR’s scientific capabilities to ensure product safety, but DPR ensures that the products it oversees meet some of the strictest science-based safety standards in the world.

And let’s also remember that the DPR product registration process is backed by extensive surface and groundwater monitoring, the most extensive air-monitoring system in the country and, when needed, soil analysis to ensure pesticides are not accumulating.

What About Our Food Itself?
This leads us to activist allegations of bioaccumulation via residues on California-produced commodities. Their claims regarding PFAS from pesticides lack important scientific context. Ignoring context results in misleading conclusions and poor policymaking.

Along with perhaps the most conservative registration process in the country and extensive ongoing human health and environmental monitoring, DPR and CDFA conduct the most comprehensive market basket residue evaluations of fresh produce in the world.

I have shared findings from this program in the past, but as a reminder to readers, let me review the most recent year’s findings.

The most recent produce monitoring report is from 2023. The report showed that 97% of fruits and vegetables sold in California had no detectable pesticides. California-grown produce showed that more than 99% had no detectable residues.

If there is no detectable residue, whether or not a single PFAS molecule is present in the formulation, there is no bioaccumulation.

Let’s also remember that the market basket monitoring program targets produce most frequently eaten by infants and children, products listed under Proposition 65 and produce consumed by a cross-section of ethnic and socioeconomic populations.

California Assembly Bill 1603
Assembly Bill 1603 (AB 1603) was introduced this year by Assemblymember Nick Schultz, who represents Burbank.

His bill would require that all pesticides containing a PFAS molecule, even a single molecule, be designated by DPR as a Restricted Use Pesticide (RUP) by 2028.

Current estimates indicate this would add approximately 1,100 pesticides to the RUP list, based on allegations rather than facts. That would trigger the addition of those 1,100 products to DPR’s SprayDays notification program. How could agricultural commissioners possibly handle all the additional paperwork?

AB 1603 would also prohibit, commencing Jan. 1, 2030, the use or sale of any pesticide that contains one of 23 specified PFAS chemicals intentionally added as active, adjuvant or inert ingredients in a formulation.

The actual products are not identified in the bill, so the Legislature would, in effect, be banning products blindfolded.

It would also, by Jan. 1, 2035, ban any pesticide containing a PFAS molecule, thereby banning the 1,100 pesticides noted earlier altogether.

This would leave DPR insolvent, leaving California with the self-inflicted wound of either deferring to the U.S. EPA for pesticide regulatory policy or having the general fund, taxpayers, finance DPR’s more than $100 million budget.

Some states have passed PFAS-style bills and are already introducing follow-up or cleanup-type bills when they compare the actual risk with the hyperbole advanced by activists they bought into.

Is There Real Risk Here?
What is particularly interesting are the allegations of risk posed by pesticide residues and the author’s efforts to manage the bill’s cost.

Asm. Schultz amended the bill to exempt consumer-use products. The obvious immediate goal was would be to lessen the financial impact on DPR by reducing the number of products banned.

However, early analysis indicates that exempting consumer-use products would have little impact on the cost of the bill.

The other reason to exempt these products is that if they are banned, homeowners will lose ready access to them, increasing their inconvenience and costs in protecting their homes, pets and family members.

This leads to a fundamental policy question. If this molecule is so dangerous that it needs to be banned in agricultural pesticides to prevent accumulation on farms, why isn’t it a risk when it comes into direct contact with your constituents in Burbank or other urban centers?

Wouldn’t there be a greater risk of bioaccumulation from contact with your home or lawn, or from contact with your pets?

It would appear the author’s safety concerns only go as far as avoiding pushback from increased costs for large groups like constituents who vote.

So, when asking yourself whether PFAS pose a risk in pesticides, I recommend that we consider those questions not in hyperbolic generalizations but in facts.

• Broad-stroke bans are a tool of poor policy, not good policy. They ignore nuance for easy generalizations.

• Multi-carbon PFAS with six or more molecules can be of concern for bioaccumulation. However, those chain molecules are not used in pesticides. Again, applying general statements may provide an easy headline, but it doesn’t provide sound policy.

• The elimination of all pesticides containing a single-carbon fluorinated molecule will eliminate many new alternative pesticides, making California’s goal of implementing a Sustainable Pest Management system virtually impossible.

• There is no scientific evidence that single-carbon fluorinated molecules included in a pesticide formulation bioaccumulate.

• Every hazard associated with PFAS, including immunotoxicity, developmental effects, endocrine disruption, persistence and neurotoxicity, is already required to be evaluated under FIFRA before pesticide can be marketed.

• DPR also aggressively conducts post-registration environmental monitoring and scientific research on food residues, which can detect chemicals down to parts per trillion.

• Based on gold-standard research, the U.S. EPA has established a definition of PFAS that deliberately excludes single-carbon molecules.

• If a single-carbon PFAS is so dangerous that it must be banned for food production, why is it not dangerous enough to be banned when it comes into direct contact with urban homeowners?

When you consider the facts, there is no valid reason to pursue a ban on these pesticides other than chasing a headline, of course!

Publisher’s Take

The Big Picture: What to do Next

1. Not all PFAS are treated the same scientifically

Regulatory concern is focused primarily on long-chain PFAS, while single-carbon fluorinated molecules used in some pesticides are treated differently by the U.S. EPA.

2. Many newer “softer” pesticides could be affected by future regulation

A broad ban on PFAS could remove numerous alternative chemistries currently used for resistance management and selective pest control.

3. California’s pesticide review system is already highly restrictive

DPR evaluates pesticide chemistries for environmental persistence, residue and bioaccumulation risks before products are registered.

4. Residue monitoring remains a major part of food safety oversight

California conducts extensive produce residue testing, including commodities commonly consumed by infants and children.

5. Regulatory changes could significantly affect pest management options and costs

Proposed legislation such as AB 1603 could impact pesticide availability, application requirements and long-term integrated pest management strategies for growers.