EPA-HQ-OPP-2024-0431-0223 Tell the EPA: Protect America’s Children and Ban Brain-Damaging Chlorpyrifos Insecticide
Tell the EPA: Protect America’s Children. Ban Brain-Damaging Chlorpyrifos Insecticide.
Tell the new EPA administration to do what the EPA proposed in 2015. BAN CHLORPYRIFOS NOW. REVOKE ALL tolerances for food and animal feed.
Public comment period ends Monday, March 24, 2025 at 11:59PM ET. The pre-written comment text is editable. Please make it your own or send it as-is.
BRIEF HISTORICAL BACKGROUND ON CHLORPYRIFOS
Major studies from the Mount Sinai School of Medicine, UC-Davis, and Columbia University have found strong evidence that low dose exposure to chlorpyrifos in the womb or after birth inhibits children’s brain development. The effects can be devastating, ranging from lower IQ to higher rates of autism.
In 2015, an EPA review concluded that exposure to chlorpyrifos, an organophosphate insecticide that is similar to sarin, posed an unacceptable risk to human health, both from residues on food and in drinking water. The EPA, led by Obama-appointed Administrator Gina McCarthy, proposed to revoke all food residue tolerances for chlorpyrifos with a final decision to follow a public comment period, by March 31, 2017.
In December 2016, Dow, manufacturer of chlorpyrifos, made a $1 million donation to the incoming administration’s presidential inaugural campaign. Soon after in 2017, Trump-appointed Scott Pruitt, the new EPA Administrator replacing Gina McCarthy, announced EPA’s reversal of the proposed chlorpyrifos ban 20 days after meeting with Dow CEO Andrew Liveris.
In July 2018, Scott Pruitt was forced to resign due to overwhelming charges of corruption and frivolous government spending ($43,000 on a soundproof phone booth, which violated federal spending laws, was only one of Pruitt’s many scandals). The pollution industry lobbyist, Andrew Wheeler, was then appointed to replace Pruitt.
In August 2018, a federal appeals court ruled that the Trump administration endangered public health by keeping this widely used pesticide on the market despite extensive scientific evidence that even tiny levels of exposure can harm babies’ brains. The U.S. Court of Appeals for the Ninth Circuit ordered the EPA to remove chlorpyrifos from sale in the U.S. within 60 days, and instructed the Agency to either revoke or modify the tolerance level for food.
Administrator Wheeler ignored the court order and did nothing, prioritizing corporate profits over children's health.
After EPA’s brazen disregard of the court order and federal inaction, Hawaii, California and New York passed state-level bans on chlorpyrifos. And in January 2020, the European Union banned chlorpyrifos, citing that there is no safe level of exposure.
2021… a new administration…
In August 2021, Biden’s EPA revoked all tolerances for chlorpyrifos on food, establishing the amount of the insecticide allowed at zero, effectively banning it in food and animal feed.
But a GMO growers association sued the EPA and in 2023, the U.S. Court of Appeals for the Eighth Circuit ruled in favor of the lobbying organization. Despite being based on sound science, the Eighth Circuit judge concluded that the EPA's August 2021 revocation of all food tolerances for chlorpyrifos was arbitrary and capricious and remanded the matter back to EPA for further review.
After that lawsuit, Biden’s EPA decided to not fight the pesticide industry, choosing to limit the scope of the ban to appease the pesticide industry and the chemical farmers.
This neurotoxic pesticide is used on alfalfa, almonds, apples, asparagus, broccoli, cauliflower, cherries, citrus fruits, corn, grapes, onions, peaches, pistachios, soybeans, sugar beets, strawberries, tomatoes, walnuts, and wheat, among other crops.
In December 2024, Biden's EPA issued a new proposed rule to revoke all tolerances for residues of chlorpyrifos, except for those associated with the use of chlorpyrifos on the following crops: alfalfa, apple, asparagus, tart cherry, citrus fruits, cotton, peach, soybean, strawberry, sugar beet, and spring and winter wheat.
Yes, you are allowed to laugh out loud. Any proposed ban should and must be protective of babies’ and children’s health. Yet this new proposed rule allows the pesticide to be in all of the foods that babies and children eat.
2025… a new administration… is your head spinning yet? The new EPA administration will be taking public comments on the last administration’s proposal. This is a real opportunity for the EPA to begin fulfilling Trump's promise to Make America Healthy Again.
A pesticide that causes neurological, developmental, and autoimmune disorders, has no place in our food and puts America’s health at risk, especially babies and children. The science is clear. Chlorpyrifos should have been banned years ago. And it should be fully banned now.
Tell the new EPA administration to do what the EPA proposed in 2015. BAN CHLORPYRIFOS NOW. REVOKE ALL tolerances for food and animal feed.
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