Ron Whitehurst, PCA and co-owner Rincon-Vitova Insectaries, Inc.
MYTH: “Chemical farming is based on sound science.”
TRUTH: The science that backs chemical fertilizer and pesticide use is largely “tobacco science”. It took 50 years from the time that tobacco was shown to cause cancer to get a label on a pack of cigarettes that said that smoking was linked to cancer. The tobacco industry paid scientists to do studies that “showed” that using tobacco did not cause health problems. Pesticide companies pay scientists to do studies that “show” that pesticides work and are needed.
Beware of the public-private partnership! Our tax dollars build public universities; but since we, as a society, support little pure research inquiring about biological control entomology, professors are forced to secure private money from pesticide companies to do research and trials on pesticides. Furthermore, peer review is not the sole measure of sound science. Unsound and biased study designs are often hard to detect. Peer reviewers can be, knowingly and unknowingly, compromised by not wanting to act against vested interests that could damage their careers.
A common distortion resulting from study designs is the choice of the type of farming system used for trial plots. Chemical pesticides are trialed on farms where the plants attract pests that have been or are out of control. If the pesticide was trialed on farms with healthy plants where pests and beneficials were in balance, reduction in the pest density would not be statistically significant, and there would be no benefit over the untreated check, and no point in doing that study. It is easy to design a study to prove that a pesticide treatment killed significant numbers of pests compared to plots which received no treatment. This is beyond unsound–it is manipulated science. And yet there are peers who do not question this type of study design.
| Peer reviewers can be, knowingly and unknowingly, compromised by not wanting to act against vested interests that could damage their careers. |
MYTH: “There is no evidence that healthy plants do not attract pests and disease.”
TRUTH: There is an abundance of repeated observations that healthy plants are not subject to pests and diseases. Repeated observations are at least as valid scientifically as controlled variable peer-reviewed comparison studies. Those who make such repeated observations discuss them widely on webinars, but their observations will not be found in peer-reviewed journals and they are rarely invited to present at academic conferences.
Scientists who want to study biological input-based agriculture, biological control and agroecology are excluded from funding and staff and can’t get their work published due to difficulty finding peers willing to review their papers. Everything they have done or want to do is effectively censored. They try to find funding from NGOs and unlikely sources. They may collaborate with a nearby hospital for the privilege of using their lab equipment. They may establish their own labs and sell services and possibly field trial contracts with pesticide companies and/or the EPA to support their own research. The funding pipeline from pesticide companies can even distort office relationships to the extent that those who refuse chemical pesticide and fertilizer funding are marginalized socially. Manipulated science is suspected in much chemical farming research while truth-seeking science regarding biological-input and biodiversity-based alternatives is suppressed. Sadly, the careers of those interested in honest research are negatively affected, or they are driven out of research institutions to be free to pursue such study and tell the truth. [Verhaaq, 2009]
MYTH: “Better living through chemistry; we can improve on how nature works.”
TRUTH: We live in a world of relationships. We are not disinterested, un-affected bystanders observing technology and marketing. Science tries to be objective as a means to a socially-accepted basis of truth. Adding toxins to our environment harms those beings with which we are in relationship: microbes that provide fertility in our soil, essential microbes in our gut, insects that pollinate our fruit, birds that eat pest caterpillars, lizards that eat ants, our children that fill us with joy, grandparents that share their wisdom.
“Technology” supporting nature is essential, but what most people understand as proprietary technology is not what it is cracked up to be. There are other ways of knowing and being in relationships. We must listen when those other ways contradict what “chemistry and technology” are saying. New federal policy requires that Indigenous Traditional Ecological Knowledge (ITEK) and internal methods of validating knowledge must be respected and plan programs that work with, not against, nature.
| Adding toxins to our environment harms those beings with which we are in relationship… |
MYTH: “A small amount of toxin in a large volume or area is diluted to have negligible negative effects, aka dilution is the solution to pollution.”
TRUTH: Fat soluble pesticides are biomagnified so that small amounts of toxin in an area can bio-accumulate. Insects feed on the toxin, and then it builds to toxic levels in the bodies of birds, bats and amphibians. Through the phenomenon of biomagnification, whale blubber and human breasts and prostate glands all become destinations for fat-soluble organochlorine pesticides in the food web.
MYTH: “Ingenuity and innovation will yield new technological solutions to overcome problems of pesticide resistance, risks and residues.”
TRUTH: The only way to perpetuate funding for research is to manifest this myth that more study will yield a better patented product input solution. Because natural enemies and agroecological knowledge are not patentable, no vested interest has any incentive to spend money to fund such research.
MYTH: “Farm Advisors help farmers consider alternatives to toxic inputs.”
TRUTH: The studies and trials paid for by pesticide companies become the basis for the recommendations included in the Guidelines by the UCIPM program and by the University of California Cooperative Extension. If a Farm Advisor wants to help a farmer consider alternatives, he or she must reach outside of what is found in University publications. There have been individual Farm Advisors over the decades who have made and disseminated their own useful observations about non-toxic alternatives, but that has not been the rule and some actively push toxic methods and marginalize biological methods at farmer meetings. For example, at a presentation about using Trichogramma to help control navel orangeworm, a UC Farm Advisor closed the meeting telling over 200 farmers that the pest would develop resistance to the Trichogramma wasps.
The University of California and UC Cooperative Extension have long largely functioned as marketing arms of the pesticide and fertilizer industry with some wonderful exceptions. Test this yourself. Ask an Extension agent how to control a particular pest and observe. Chances are quite high that he/she will go to the UC-IPM Guideline and relay to you the chemical pesticides effective for that pest. Most agents need to be prompted to list the other IPM approaches for controlling the pest.
| Ask an Extension agent how to control a particular pest and observe. Chances are quite high that he/she will go to the UC-IPM Guideline and relay to you the chemical pesticides effective for that pest. |
MYTH: “Pesticides approved for use in California go through the most thorough, scientifically-based analysis and review in the world.”
TRUTH: Europe has much more strict hazard-based vs risk-based evaluation. Europe employs the precautionary principle. Evidence suggests and some Public Records Requests have revealed clearly that the US-EPA registration process is capable of and has perpetrated well-practiced blind acceptance of manipulated study designs and data (i.e. cutting off an animal toxicity study before tumors develop, selective inclusion of data, and/or excluding data showing harm by questioning the health of the control animals, etc.) to enable/legitimize pesticide manufacturers to pollute our shared public commons.
Additionally, because of their smaller size and accelerated metabolism, children are about 10 times more sensitive to pesticides than adults. But the intent of the registration process prioritizes getting toxic products on the market rather than protecting public health. Claiming that pesticides currently on the market are extensively tested is a false statement.
MYTH: “Pesticide products are thoroughly tested for safety.”
TRUTH: Manufacturers submit required safety test data on the active ingredient in the product, but not on the adjuvants or on the formulated product as it is sold. The toxicity of the product on the shelf was not tested for the regulatory process. However, formulated pesticides are 10 to 100 times more toxic depending on the particular target organism. To accommodate this fact, toxic levels should be 1/100th of the published level.
The current “safety” regime is not working. IF the intent is to prevent harm from proper use of pesticides, neighbors of farmers using toxic pesticides (according to label instructions) shouldn’t get sick, have a degraded experience of life, get cancer, and/or die. But the experience is that farmers that use toxic pesticides and their neighbors get sick. Globally, an estimated 44 percent of farmers, farmworkers, and pesticide applicators experience at least one incident of acute pesticide poisoning on the job every year, and 11,000 die annually from accidental pesticide poisoning. [Boedeker, 2020]
If the intent is to allow a certain percentage of citizens to get sick to enable pesticide companies to make a profit, that is neither acceptable nor ethical. Again, evidence shows that the registration process is merely a tangle of mental gymnastics designed to enable/legitimize pesticide manufacturers to pollute our shared public commons with impunity.
| The toxicity of the product on the shelf was not tested for the regulatory process. However, formulated pesticides are 10 to 100 times more toxic depending on the particular target organism. |
MYTH: “These ingredients that are evaluated and registered by US-EPA go through over three hundred required human health and environmental safety studies.”
TRUTH: Let’s look at the case of Industrial Bio-Test Laboratories (IBT Labs) faking data for the toxicity of Roundup. The studies were never replicated, so Roundup has remained on the market for 45 years without valid toxicity studies [GMO Myths and Truths, 2014]. The much touted “science” is done by or for the pesticide registrant, muddied by a conflict of interest. This is science in service of the profit motive. If the study design is biased or lacking and stringent data handling procedures are not ensured, no amount of peer review of a fraudulent study can transform the results into sound science.
Instead, the risk analysis amounts to an “acceptable” number of cancers or birth defects per 100,000 from using the product in a certain way. The individuals that put their bodies on the line with exposure to the pesticide, most often unknowingly because they trust that the government regulations protect them, do not have significant input into that decision. What is an “acceptable” number of cancers? In contrast to what? And to whom?
| All the crops in CA can be grown organically without synthetic toxic pesticides, using natural pesticides which have zero risk of causing cancer. That is one of a number of reasons why the organic label must be utilized as the metric for setting transition goals away from toxic pesticides. |
MYTH: “In a standard risk vs benefit analysis, any hazard from using a pesticide is mitigated (made OK) by restrictions on the label.”
TRUTH: A risk/benefit analysis assumes that there is a valued benefit to some entities from using the pesticide. Who benefits? The prevailing narrative is that the farmer benefits from using the pesticide to protect the crop; however, there are non-toxic alternatives for that pesticide. Additionally, using strong chemical pesticides disrupts biological control on organic and regenerative farms where pests are managed using cultural or mechanical methods and (soft) bio-pesticides where necessary. Introducing a toxin therefore provides no benefit to the people involved, whether they be farmers, farm workers, or the neighbors living and working nearby. There are likewise negative impacts from introducing a toxin into their surrounding environment.
There are financial benefits for the pesticide manufacturer, distributor, and salesperson from selling the pesticide, which are often justified as beneficial to the economy. So the farm worker is required to risk cancer for the benefit of the “economy”, meaning the pesticide industry sector. Is this a trade off that you would accept?
MYTH: “Despite the US-EPA registration process, products entering California undergo an independent second comprehensive evaluation by DPR scientists before being registered for use. DPR also requires additional “California only” studies before registration reviews are complete. This process is very painstaking and slow (taking 5-7 years) because DPR wants to be sure the new product has some level of efficacy and can be safely brought to market in California.”
TRUTH: Based on what has been reported by retired EPA scientists and discovered in Public Record requests, most of the studies submitted to the US-EPA for review could be flawed. There is enough evidence to conclude that none can be trusted without a fresh review looking for flaws, biases, and/or high-level US-EPA administrative intercession on behalf of pesticide manufacturers overruling the recommendations of rank and file scientists. The same studies are sent from the US EPA to the CA EPA. The conflict of interest resulting in flaws and biases in required toxicity studies moves unchanged from the federal to the state regulators.
The slowness of CA EPA to review such new products is apparently not because of the extra care taken in the review. There is at least an appearance that the review process is being overseen by individuals who are influenced by powerful pesticide companies. In a typical “good ol’ boy ” culture, decisions are based on the belief that pesticides are necessary “tools” to grow our food. Meanwhile DPR accepts the risks associated with registering new pesticides, and farms continue to be sacrifice zones, and farmworkers disposable pawns in the registration game.
CA EPA could streamline the process for review of new and biorational pesticides, but assessments need to be based on hazard and not risk.
| The conflict of interest resulting in flaws and biases in required toxicity studies moves unchanged from the federal to the state regulators. |
MYTH: “Additional label restrictions on products protect public safety, like Restricted Use Pesticides (RUP), and Agricultural Commissioners have discretion to require even more restrictions when conditions in their counties may require them. In addition, Agricultural Commissions must be given a Notice of Intent (NOI) prior to an application of a RUP based on risk parameters established through the product’s registered label and DPR’s registration requirements.”
TRUTH: No amount of pseudo religious legal ceremony or certified papers will change the fact that using toxic pesticides is an aggressive act. The non-aggression principle is a good approach to interacting with others. Putting a toxin into the commons (my space) that has the potential to make one sick, poison livestock, poison wildlife (food for some), and pollute resources is an aggressive act. This is done without the consent of those affected.
MYTH: “Pesticides are safe when used according to label directions.”
TRUTH: We hear continuing reports from farmworkers who are sickened by exposure to pesticides in the fields where they work. Farmworkers who are sickened by exposure to pesticides in the fields have many reasons for hesitating to ask questions or express a grievance. Scientific reports show low sperm counts, birth defects, fertility problems, from neonics (endocrine disruptors) which are considered low risk pesticides. There are also reports that safety training is superficial and does not adequately explain the risks if someone does not follow the label instructions. There is no information on the label about cumulative risks and synergistic effects and whether the formulation is more risky than the active ingredient.
Public health professionals around the world talk about One Health, the combination of ecological, human, social health, and others talk a bit more broadly about Planetary Health.[Garnier, et. al. 2020]
| “Farmworkers who are sickened by exposure to pesticides in the fields have many reasons for hesitating to ask questions or express a grievance.” |
MYTH: “American farmers need to feed the world.”
TRUTH: It is true that the climate crisis, supply line disruption, and political unrest point to food shortages and famine. Someone in the world is dying of hunger every four seconds. As a parent I empathize with parents watching a child die for lack of food. But the solution is not shiploads of devitalized GMO corn and dairy milk powders from cows living on GMO feed. Solution: pay for the loss and damage to countries suffering climate impacts who did nothing to cause it, ensuring that it goes into capacity-building for small-holder agroecosystem restoration.
Industrial agriculture to feed 30% of the world’s population is using 80% of the world’s land, water, and fertilizer. Smallholder farmers with less than five hectares of land feed 70% of the world with resources that they regenerate.
There are effective ways to help these small farmers be successful, such as appropriate trade agreements and political alignments so that farmers in poor nations can compete with internal and external corporate agriculture interests, make land-grabbing and water-grabbing by US-based entities illegal, and invest in restoration of land and small water cycles for resilience to climate impacts. America needs to overhaul every US AID program from food aid that destroys markets for local farmers to Farmer to Farmer that arrogantly exports myths about industrial agriculture efficiency. The world would benefit if American farmers focused on their own soil conservation and crop diversification, including increased perennial cropping and cover cropping for climate and economic resilience. They could even consider welcoming immigrants seeking asylum as neighbors and co-learners in rural resilience strategies.
“U.S. farm exports do not go to the nations that suffer the most from hunger but to nations whose consumers can afford to pay global market prices. An analysis of U.S. farm exports for 2015 found that 86% of U.S. farm exports went to 20 nations classified by the United Nations as medium-to- highly developed, and only half of one percent went to 19 of the least developed nations, including Haiti, Yemen, and Ethiopia.” (Environmental Working Group, 2016).
MYTH: “It will take a long time to turn around a chemical input-based farm.”
Truth: Soil Food Web trained consultants and regenerative agriculture consultants have successfully reversed degraded fields in one season with experienced help. The knowledge and experience in soil and sap analysis works to dramatically reduce fertilizer and pesticide use and tillage. The duration depends on soil type, compaction, weather or climate, and the level of soil degradation.
John Kempf of Advancing Eco Agriculture uses primarily sap analysis to plan foliar nutrient sprays and soil inoculants to ensure healthy plants and a healthy plant microbiome to produce a good crop. Soil Food Web technicians ensure high quality compost is used for side dressing, teas and extracts, determine what functional groups of bacteria, fungi, protozoa and nematodes are missing, and suggest appropriate practices and inputs to build life in the soil.
It often used to take three to five years to repair degraded soil and it still can in some soils, but with skilled, experienced help it now takes less time. It is an existential imperative to start now. We need to sequester carbon in soil and we can reduce pesticide use when plants are healthy and don’t have pests.
When we get it right we can transform a desolate, degraded landscape into a lush, productive, veritable paradise in a couple years. What do you want for your legacy?
| “It is an existential imperative to start now because of the potential for biological carbon sequestration.” |
MYTH: PCAs are well trained and licensed to protect the public health.
TRUTH: The words of Robert van den Bosch in 1978 could have been written today:
“The examination and licensing law has been a severe setback to the development of a rational pest-control system in California, because it drapes the pesticide salesman with a mantle of professional respectability and thereby enhances the myth that he offers competent and objective advice on pest-control problems. Now when the salesman flashes his business card to a prospective customer, it bears the impressive title licensed pest control adviser, and this title is backed by a document bearing the seal of the great state of California. The salesmen are so proud of their newly achieved respectability that they have formed an organization, the Council of California Agricultural Pest Control Advisers, to advertise their transition from peddlers to “professionals.” But despite their instant professionalization, they remain salesmen, and rational pest control suffers because of their legally sanctioned camouflage. California’s Agricultural Pest Control Advisory Committee, with its inclusion of chemical company employees and a pest-control operator (spray applicator), fortifies the misconception that pest control and chemical control are essentially synonymous….Thanks to the politics of pest control, the pest-management advisory profession seems destined to decades of mediocrity, and the environment to a continuing biocidal blight.” Van den Bosch (p.96-7)
“Integrated control is simply rational pest control: the fitting together of information, decision-making criteria, methods, and materials with naturally occurring pest mortality into effective and redeeming pest-management systems.” Van den Bosch (p.151)
| Thanks to the politics of pest control, the pest-management advisory profession seems destined to decades of mediocrity, and the environment to a continuing biocidal blight.” Van den Bosch (p.96-7) |
MYTH: Access to a suite of effective and feasible ‘alternatives’ to high-risk pesticides” is what is most needed to reduce economic risk.
TRUTH: This is the “efficiency/substitution” attempt to stay within a chemical input-based farming system. In chemical farming systems “alternatives” generally refer to chemical pesticides. However, every crop can be grown in a biodiversity-based farming system that best mitigates every risk. For resiliency we need to move to biodiversity-based or regenerative farming systems. The reduction of risk is primarily in whether the farmer is open to increasing biodiversification. Reliance on cheap pesticides is a major economic risk growers bring on themselves. Greater profitability is achieved when healthy soils yield healthy plants that need few inputs.
MYTH: PCA certification is working, we don’t need to fix it.
TRUTH: Martin Guerena, Sustainable AGriculture Program Specialist, with private non-profit National Center for Appropriate Technology–ATTRA, made these observations about the challenges for Pest Control Advisors:
Especially with annual vegetable and strawberry growers, Martin Guerena observes that a lot of them would spray regardless of a need.”It was like insurance. And a lot of times it was not needed, yet they sleep better knowing the product has been sprayed, especially about two weeks before harvest, maybe even a week before harvest, just so when they get to harvest there won’t be an issue. It’s twisted. But that’s how it is. And I’m sure just those two factors alone would reduce useless use of pesticides tremendously.”
“The structural issue of PCA sales incentives must be fixed. Incentives to sell chemicals trump good sense. Scouting needs to become a serious trained occupation, paid for unbiased, high quality information. Chemical sales consultants should stop masquerading as knowledgeable agronomists. Making this happen seems both essential and very difficult….The fact that PCAs working for chemical companies work on commission, so the more they sell, they are stimulated or incentivized to sell more chemicals than are actually needed. That is a big political issue.”
No matter how much training and additional certifications are added, unless the conflict of interest occurring when people receive commissions on pesticide sales is addressed, this critical role in pest management advising for farmers will bias farming toward synthetic pesticide use. Pay PCAs a good flat rate with no commission, and then have them recommend whatever they need to recommend. But with a commission on how many pesticides they sell, of course, the more they sell the more money they are going to make.
California Code for Pest Control Advisor Regulations must be amended to require (a) Each licensed agricultural pest control adviser and grower, when determining if and when to use a pesticide that requires a permit, shall write up a biological and/or organic treatment methodology for consideration, which would substantially lessen any significant adverse impact on the environment.
Amend Code 6556 to read: Each recommendation shall include: (e) Certification that written methodology of biological and/or organic treatment measures that would substantially lessen any significant adverse impact on the environment have been shared with the grower (or written by the grower who is also a PCA). The code must delete “if feasible” because every crop in California can be grown organically.
A standing advisory committee is needed to guide the development and continual improvement of SPM educational curricula, composed primarily of entomology and agroecology instructors at state and community colleges.
| Pay PCAs a good flat rate with no commission, and then have them recommend whatever they need to recommend. |
MYTH: Transforming agriculture to regenerative will not reverse climate change. The models forecast uncertain capacity to sequester carbon.
TRUTH: This negative prognosis is the result of reductionist framing, that the whole is the sum of the parts. It is ignorant of the emergent properties of complex systems that are more than the sum of their parts.
We are looking at horribly degraded landscapes. When people colonized California they killed the beavers, cut the trees, overgrazed with cattle, plowed, fertilized and poisoned with pesticides that reduce the capacity of living soil to sequester carbon. Glyphosate herbicides are ubiquitous even in government programs for soil conservation. Never mind that they chelate minerals so they are unavailable to the plants, compromising plant health, reducing their defenses against pests. The landscape we now see will not pull carbon dioxide from the air in any great quantities. We can realize a better future, by transforming our agriculture to intensive horticulture, creating food forests, providing meaningful work, food, clothing, supply medicine, restore small water cycles, buffer weather extremes, and move our economy of scarcity to one of abundance. With directed work we can recreate a paradise on Earth.[Kravcik, 2012]
Cautious estimates of carbon sequestration look at increasing organic matter in the top six inches of soil, the plow share. With perennial agriculture, we can look at increasing organic matter in the top 2 meters of soil, with no practical limit on how much carbon it can hold. Of course we are not looking at a static situation, we are talking about increasing the cycling of carbon, through a living system.
Our landscape has been de-watered. We are causing warming and drought by the way we manage the land. If we increase the latent heat of evaporation by covering the soil and moving to perennial crops, rain will sink into the ground and be available to grow trees which cool the earth, recreating small water cycles.This is the same process as when you get out of the pool and the wind blows and you feel cold as the water evaporates from your skin. When we plant a 100 km2 area (about 40 square miles) with trees, we change the weather.
The California Air Resources Board unfortunately appears to believe that the available models are all they have on which to base incentivizes for carbon farming. We suggest that time is wasting given that there are people who have the necessary knowledge and experience to speed up the transition to biodiversity-based farming systems characterized by deep roots, high microbial and carbon levels, and reduced pests and pesticides. We need to charge in with ambitious goals within a plan of adaptive management and on-going evaluation.
REFERENCES:
Boedeker, W., Watts, M., Clausing, P. et al. The global distribution of acute unintentional pesticide poisoning: estimations based on a systematic review. BMC Public Health 20, 1875 (2020). https://doi.org/10.1186/s12889-020-09939-0
California Code of Regulations (Title 3. Food and Agriculture) Division 6. Pesticides and Pest Control Operations, Chapter 2. Pesticides, Subchapter 4. Restricted Materials, Article 3. Permit System
Fagan, J., Antoniou, M., Robinson, C. GMO Myths and Truths–An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops and foods. 2014, EarthOpenSource, 2nd Ed.
Garnier, J., Savic, S., Boriani, E. et al. Helping to heal nature and ourselves through human-rights-based and gender-responsive One Health. One Health Outlook 2, 22 (2020). https://doi.org/10.1186/s42522-020-00029-0
Kravcik, M. Water for the Recovery of the Climate – A New Water Paradigm, 2012.
Van den Bosch, R. The Pesticide Conspiracy, 1978. Reprint University of California Press.
Verhaag, Bertram and Verena Schonauer (Directors), Arpad Pusztai, Ignacio Chapela, Scientists Under Attack: Genetic Engineering in the Magnetic Field of Money, 2009 Documentary film 88 min.
The Bug Farm 