California’s Department of Pesticide Regulation (DPR) has published a draft of a policy that would replace its Integrated Pest Management policy with a Sustainable Pest Management (SPM) policy that is different in name only. SPM makes a commitment to continue using pesticides in California until 2050, and by implication, beyond. It makes NO commitment to reduce pesticide use or reconsider the current targets of pesticide applications. It claims that the health hazards and damage to the environment will be reduced by identifying “Priority Pesticides” for possible substitution or “eventual elimination.” It doesn’t commit to identifying any specific number of dangerous pesticides nor does it provide specific criteria for selecting these dangerous products. It claims that increased testing and development of new products will result in safer products and puts these judgments into the hands of “stakeholders” with “experiential and observational knowledge” rather than scientists with expertise in soil science, endocrinology, toxicology, epidemiology, biology, botany, horticulture, etc. The “stakeholder” committee that wrote the SPM proposal for urban areas included the manufacturer of pesticides and other users and promoters of pesticides.
That’s not an exhaustive list of the many faults of SPM and the dangers that lurk in it. I hope you will read it yourself and consider writing your own public comment by the deadline on Monday, March 13, 2023, at 5 pm. The document is available HERE. It’s less than 100 pages long and it is a quick read because it is basically a collection of bullet-points.
This is how to comment: “DPR is accepting public comments to inform the prioritization and implementation of the Roadmap’s recommendations through March 13, 2023 at 5 p.m. Comments can be shared in writing to firstname.lastname@example.org or by mail to the department at 1001 I Street, P.O. Box 4015, Sacramento, CA 95812-4015.” Please note that Department of Pesticide Regulations is not offering revisions, only “prioritization and implementation.”
My public comment on California’s “Sustainable Pest Management Roadmap”
A summary of my public comment is below. A link to the entire comment is provided at the end of the summary:
Public Comment on
“Sustainable Pest Management Roadmap”
(AKA “Pathway to poisoning the environment for another 25 years”)
My public comment is focused on pesticide use in urban areas because of my personal experience and knowledge of pesticide use where I live. These are the broad topics I will cover in detail with specific examples later in my comment:
- Since glyphosate was classified as a probable carcinogen by the World Health Organization in 2015 and the manufacturer of glyphosate settled 100,000 product liability lawsuits by awarding $11 billion to those who were harmed by glyphosate, public land managers have been engaged in the process of substituting other, usually equally or more dangerous herbicides for glyphosate to deflect the public’s concerns. The Sustainable Pest Management Roadmap (SPM) formalizes this process of substitution without addressing the fundamental problems caused by pesticides.
- SPM endorses the status quo that exists now. Affixing the word “Accelerating” to SPM is an extreme case of double-speak that deliberately obscures, disguises, distorts, or reverses the meaning of words. SPM ensures that toxic pesticides will be used in California for more than 25 years, to 2050, and likely beyond. SPM therefore accelerates the damage to the environment that is occurring now. Given that climate change will enable the movement of more pests into areas where they are now suppressed by weather, greater use of pesticides should be anticipated so long as the underlying issue is not addressed.
- The underlying issue is that pests have been identified for eradication that in some cases cannot be eradicated and in other cases should not have been identified as pests either because they are innocuous or because of the valuable ecological functions they perform. The key question that SPM does not address is whether pesticide use is truly necessary in the first place. Unless we focus on whether a pesticide is actually necessary, all other issues are merely window dressing for perpetual pesticide use.
- SPM proposes to identify “Priority Pesticides” for possible substitution without any clear definition of “Priority Pesticides,” a process that is ripe for manipulation. Given the substitutions that are occurring now, we cannot assume that further substitutions would be less toxic. SPM puts the classification of “Priority Pesticides” into the hands of “stakeholders” without clearly identifying who stakeholders are. SPM says “stakeholders” were involved in the development of the proposed policy. Those stakeholders included only users and promoters of pesticide use. There was no representation on the Urban Sub-Group of organizations such as Californians for Pesticide Reform, California Environmental Health Initiative, Beyond Pesticides, Center for Environmental Health, Environmental Working Group, etc. Nor was there any visible expertise in the fields of science that are capable of analyzing and evaluating the impact of pesticides, such as soil science, endocrinology, toxicology, entomology, botany, biology, or horticulture. SPM ensures that this exclusion will continue during the implementation phase by suggesting that “experiential and observational” knowledge should be represented on an equal footing with undefined “science.” The word “science” is being used and abused by advocates for pesticide use who dangle it as a magic talisman, conferring fraudulent credibility.
My entire public comment is available here: