A petition demanding that the EPA evaluate the toxicity of all ingredients
in pesticides, not just the "active ingredient" turned into a suit.
http://www.centerforfoodsafety.org/files/2023-05-31-complaint_85005.pdf
https://tinyurl.com/yc4bm7v3
The issue is clear - the definition of "pesticide" is "any substance or
mixture of substances intended for preventing, destroying, repelling, or
mitigating any pest", so the toxicity of adjuvants, emulsifiers, wetting
agents, and so on clearly is part of a "pesticide", and per the plain
language of its own regulations the EPA should evaluate the entire mixture
of every pesticide product, not just the claimed "active ingredient".
Beekeepers have been burned by this many times. Here's just one very recent
paper of many:
https://doi.org/10.1093/jee/toad161
But what cropped up in this suit is verrrrrry interesting - although suing
the EPA with the simple demand "do your job", the pesticide makers and users
who the EPA regulates can presume to "defend" the EPA under a legal concept
called "intervention".
https://storage.courtlistener.com/recap/gov.uscourts.cand.413520/gov.uscourt
s.cand.413520.45.0.pdf
https://tinyurl.com/ykskbz27
The "intervenors" in this case include Croplife America, the American Seed
Trade Association, the Agricultural Retailers Association, the American
Soybean Association, the National Cotton Council of America, the National
Corn Growers Association, and the National Association of Wheat Growers.
So, this seems to be a list of the groups that have an interest in keeping
these "additives" secret, unexamined, and unregulated. It also exposes the
industry entities that have engaged in "regulatory capture" to the point
that they feel so certain that they "own" the EPA, that they need to defend
the pet regulators, and their "investment" in keeping the EPA as toothless
and passive as possible. So, at long last, we have a group of trade groups
openly declaring that THEY actually own and run the EPA for the benefit of
the member companies.
Years ago, a petition that demanded that the EPA evaluate the toxicity of
all ingredients in pesticides went nowhere, as Scott Pruitt was EPA
Administrator, and he was too busy lining his pockets with graft, resulting
in 14 ethics investigations for every possible form of expense account
fraud, and his eventual resignation.
https://archive.ph/20180419143537/https://www.nytimes.com/2018/04/18/climate
/scott-pruitt-epa-investigations-guide.html
<https://archive.ph/20180419143537/https:/www.nytimes.com/2018/04/18/climate
/scott-pruitt-epa-investigations-guide.html>
https://tinyurl.com/3bws9k7n
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