Pesticide use in the United States is regulated via a complex system of registration and review under the auspices of the Environmental Protection Agency (EPA). We are working to make the regulatory process safer for birds, people, and our planet.
Weaknesses and loopholes in the current regulatory process undermine the implementation and enforcement of safeguards protecting people and wildlife. As a result, many pesticides and other toxics green-lighted by the EPA have ultimately been shown to be more harmful to non-target species than first believed.
To provide a coordinated response to the EPA’s registration and re-registration processes for pesticides, we work closely with our partners in the National Pesticide Reform Coalition.
This group was formed in 2002 by ABC and other nonprofits and now comprises more than 40 organizations, including bird and invertebrate specialists, human health groups, and conservation and environmental NGOs.
One of our highest priorities is to upgrade the incident reporting system for dead birds, bats, bees, and other wildlife. Incident reporting involves collecting data on sick or dead animals to assess pesticide impacts in the field.
These reports provide an important backstop to EPA registration-review decisions. Incident reporting is especially critical as EPA moves toward greater use of “21st century computational toxicology,” relying more on mathematical modeling and less on animal-testing in the laboratory to determine if a pesticide is safe.
Dead animals in the “wild” – be it agricultural fields or city streets – can be the canaries in the coalmine that provide us with valuable real-world data on how the pesticides are affecting birds and other wildlife.
Under federal pesticide regulations, the reporting thresholds for wildlife are too high to be useful. For example, the registrant is only required to report a bird kill if the incident affected 200 or more individuals of a so-called flocking species, 50 or more individuals of a songbird species, or five or more individuals of a predatory bird species.
For other wildlife the reporting thresholds are absurdly high as well. There’s no requirement to report deaths of a herding species of mammal, for example, if the kill involves fewer than 50 dead animals, and there’s no need to tell EPA about a fish-kill involving fewer than 1,000 schooling fish. For bees and other invertebrates there are hardly any reporting requirements.
The data-gathering deficit means that Registration Review decisions are rarely informed by kill-data from the field. Upgrading the EPA incident reporting system would be a relatively simple and low-cost measure with enormous benefits in our understanding of pesticide impacts on birds, bees, bats and other wildlife.
