Comments to the EPA on deadly paraquat use

TO SUBMIT YOUR OWN COMMENTS: click here and use Docket ID EPA–HQ–OPP–2011–0855.

DEADLINE IS APRIL 1, 2024.

In the far left hand side of the page, click the box that says “only show documents open for comment.” The next thing that pops up is a line that says: “Paraquat Interim Registration Review Decision.” Underneath that is a “comment” box, click on it.

Begin typing or pasting in your comments, or drop any files related to your comments.

Example comment could be:

“As a private citizen, I am concerned about the overall exposure to pesticides that my family and I are subjected to.  I follow closely the recommendations of Utah Physicians for a Healthy Environment (UPHE).  I ask that EPA withdraw approval for the use of paraquat because of the high likelihood of human toxicity, especially its connection to the rise in Parkinson’s disease and other health hazards, as outlined in UPHE’s comments to EPA.”

UPHE’s comments:

The successful strategy of pesticide manufacturers to heavily influence EPA’s decision making has been exposed in numerous books and extensive articles written with the help of whistleblowers, former EPA employees, and internal company documents revealed in court cases. The EPA default philosophy of assuming a chemical is safe unless proof of harm is thoroughly established is existentially at odds with the philosophy governing regulators in Europe, i.e. the precautionary principle, where a product has to be proven safe before it can be placed on the market. This default philosophy is reflected in the EPA’s approval of 94% of pesticides that it reviews for registration. 

Paraquat is recognized worldwide as one of the most toxic herbicides ever produced. Ten times as many countries have banned paraquat as have approved it. Ironically and tellingly, the two countries where it is produced, China and the United Kingdom, are among those that have banned its use. In fact, a state owned Chinese chemical company bought the previous manufacturer, Swiss based Syngenta, in 2017, yet the Chinese government doesn’t allow it to be used in China.  Even Syngenta’s home country, Switzerland, has banned its use.

Some of Syngenta’s own researchers have raised concerns about its safety dating back over 45 years.  Internal company documents prove that Syngenta prioritized profit from the sale of paraquat over health and safety issues, such that when their own company researchers expressed those concerns based on their research, the company committed itself to a strategy to suppress that information while developing studies for the specific purpose of refuting the adverse results of previous studies.  That strategy included engaging lawyers to help edit scientific papers with language that would obscure or minimize findings that exposed product hazards, and commissioning scientists to be part of a “swat team” to instantly refute unfavorable published research. 

In other words, Syngenta manipulated and manufactured “science” to protect their profits. Syngenta’s strategy included successfully arm twisting the EPA to not allow an independent scientist who concluded the evidence for a link between paraquat and Parkinson’s disease was overwhelming, to sit on an EPA advisory panel, and then a strategy to hide that they had been involved in that arm twisting.  Company documents showed Syngenta withheld their own internal research showing that paraquat penetrated and harmed brain tissue in the same way that Parkinson’s disease does.

Parkinson’s is the fastest growing neurological disorder in the world.  Aging of the population can only explain a small part of that trend. A genetic explanation is almost impossible, leaving an environmental toxin the most likely cause. Use of paraquat tripled between 1992 and 2018. Parkinson’s diagnoses increased in the 30 to 64 year old age groups by 50% from 2015 to 2020, a truly alarming trend. Utah Physicians for a Healthy Environment (UPHE) are concerned that paraquat may be used even more in our state, including around the Great Salt Lake, as plant resistance to glyphosate becomes more wide spread.

The EPA’s mission is to protect public health, not the profits of chemical companies. With paraquat and other pesticides, adopting the precautionary principle is the only way to fulfill that mission. Approval of pharmaceuticals by the FDA must follow the precautionary principle, and there is no reason the EPA should approach pesticide approval any differently. EPA has an opportunity to correct some of its past mistakes and should withdraw approval for paraquat.