Time for an Intervention with Pesticide Regulators: 60 Years After “Silent Spring,” We Need Systemic Change

by Heather Spalding, MOFGA Deputy Director

The past legislative session in Augusta generated some important victories in Maine’s pesticide regulation arena. We banned chlorpyrifos, restricted landscape use of neonicotinoids (neonics), prohibited the use of glyphosate and dicamba on school grounds, and reformed the composition of the Board of Pesticides Control (BPC), establishing that there will be no conflict of interest for those serving in the two public member seats (out of seven total). The next session will hold hearings on the threats of glyphosate-containing chemicals to forest ecosystems, including the soil microbiome, and capturing statewide pesticide sales and use data. All of this encourages us, and we are grateful to the Legislature and Gov. Mills for embracing these advances. However, in the broader scheme of pesticide policy, these wins represent tentative baby steps toward the systemic change needed to protect human and environmental health. Almost 60 years after Rachel Carson’s breathtaking and heartbreaking expose, “Silent Spring,” the pesticide industry continues to enjoy its revolving-door relationship with regulators at the peril of countless species and our basic human needs — clean air, water and soil. Life on Earth is at stake, and it’s time to add pesticide policy to the list of urgent needs for systemic change.

More than 18,000 pesticide products are registered for use by the Environmental Protection Agency (EPA). Pesticide applicators spray these chemicals over more than 150 million acres of farmland, forests and municipalities, and inside and outside millions of dwellings, workplaces and institutions. (Relative data for the state of Maine is difficult to estimate because the BPC hasn’t yet established a comprehensive-sales and use registry. Stay tuned.) Loose regulations, lax registration requirements and callous disregard for peer-reviewed science has led to death and disease in humans and animals, destruction of habitat for endangered species and dramatic declines in bird and invertebrate populations. Maine, the United States and the world are long overdue for a paradigm shift that places human and ecological health over pesticide industry profits.

Celebrating MOFGA’s 50-year milestone, we’ve honored the vision and commitment of founders like Cliff and Helen Parsons, Abbie McMillen (then Abbie Page), Ken and Roberta Horn, Jim Luthy, Mort Mather, Charlie Gould, Frank Eggert, Chaitanya York, Tim Nason and so many others who knew that Maine could grow food, manage landscapes and improve the quality of life without the use of synthetic pesticides. They drew inspiration from Carson’s work, and laid the groundwork for decades of public policy initiatives promoting organic management practices.

MOFGA has provided a steady drumbeat for the march toward a more local and more organic agriculture. Whether lobbying for bills in the Legislature, advocating for regulatory reform at the EPA or BPC, organizing for reforms in the marketplace, reporting peer-reviewed pesticides research, collaborating with municipalities on local ordinances, or presenting speakers and performances like Kaiulani Lee’s brilliant one-woman play, “A Sense of Wonder,” about the life of Rachel Carson, MOFGA has maintained vigilance and provided viable solutions for minimizing reliance on pesticides. If you’d like to gauge your knowledge of pesticide regulation, take MOFGA’s Pesticide Quiz, compiled by former MOFGA board president and public policy committee member Sharon Tisher.

With five decades of progress, we know that organic production no longer occupies a quaint little niche in the food system, but represents the future of agriculture. Organic farmers and processors still represent a small percentage of the country’s overall agricultural production (currently almost 6% of the U.S. food market), however demand for organic goods and services is growing steadily. According to research conducted by the Organic Trade Association and released in May, organic sales increased by 12.4% to $61.9 billion last year. The demographic trend among organic consumers is becoming more mainstream, as awareness spreads about the health, environment and animal welfare benefits of organic farming. We recognize that market forces are not enough and have joined in a clarion call for systemic reform in pesticide policy.

In a recent letter to EPA, organizations from across the country demand a complete overhaul of pesticide regulations, along with the leadership and human resources allocated to manage the agency’s Office of Pesticide Policy (OPP). The letter makes a case for healing the abysmal mindset of relative risk management toward a precautionary one that poses two logical questions: “Is there a clear and present pest problem?”; and, if so, “Can we address the problem with non-chemical and organic management practices?” They seem like basic and reasonable questions, right? Unfortunately, they rarely figure into the pesticide registration process. The OPP has the power to take a precautionary approach by embracing the “reasonable adverse effects” standard under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). The OPP could, legally should, and must do so much more to assess the very need for synthetic pesticides and address the harmful effects of pesticide formulations including secret inert ingredients, contaminants and metabolites.

Without OPP leadership in creating markets for non- and least-toxic alternatives, the pesticide industry will continue to block progress toward an organic future. We see this repeatedly here in Maine when the BPC finds itself unable, or unwilling, to take bold action because it relies on and defers to EPA’s lead. OPP now has a window of opportunity to embrace systemic change and rise to President Biden’s call for Modernizing Regulatory Review, which directs the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity and the interests of future generations. With this mandate, the OPP could reinvent itself and take the following substantive actions:


  • Embrace a precautionary approach to pesticide use establishing that human and environmental health take precedence over pesticide-industry profits.
  • Elevate the urgency of the environmental justice, biodiversity and climate crises, acknowledging how pesticides have exacerbated these problems.
  • Create incentives for natural solutions to pest management that minimize reliance on pesticides.

Leadership and Allocation of Human Resources

  • Enforce EPA’s Scientific Integrity Policy, which requires all employees to conduct, utilize and communicate science with honesty, integrity and transparency, both within and outside the agency.
  • Adopt limitations on revolving door hires between the OPP and the pesticide industry.
  • Require interagency coordination with the U.S. Fish and Wildlife Service to ensure protection of endangered species.
  • Recruit a leader for OPP who is highly motivated to embrace systemic change in pesticide policy.
  • Replace OPP staff members who have been complicit in allowing registration based on false or insufficient data, or have knowingly blocked regulations on bad-actor pesticides such as chlorpyrifos, dicamba, glyphosate, triazine herbicides, paraquat and all organophosphates and neonics.
  • Create an independent ombudsperson position in OPP that would represent the interests of the public, not the manufacturers or applicators.
  • Hire additional staff to address the massive backlog in periodic registration reviews, ensure compliance with Section 7 of the Endangered Species Action, assess benchmarks for water contamination and create a new set of enforceable standards.
  • Convene advisory committees to assess pesticides that have been banned in other countries and consider similar prohibitions if justified, assess impacts of pesticides on pollinators, and revoke registrations for pesticides most harmful to pollinators.

Registration Process Reform

  • Reform the common practice of accepting non-peer-reviewed studies while rejecting peer-reviewed journal-published studies.
    • Cancel pesticide registrations that were based on false data and prohibit companies that falsified their data from registering new products until OPP can verify legitimacy of the data.
    • Weigh the dangers of pesticides against the availability of less dangerous alternatives — e.g., organic agriculture and landscape management.
    • Require endocrine disruption in assessment of effects. Endocrine disruptors have been linked to ADHD, Parkinson’s, Alzheimer’s, diabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorders, cancer and other metabolic disorders.
    • Assess the cradle-to-grave impacts of pesticides, not just the impacts associated with application.
    • Require proof of efficacy, using organic agriculture as a standard of production.
    • Prohibit prophylactic use of products such as neonic-coated seeds. The practice flies in the face of the much-heralded though loosely interpreted practice of Integrated Pest Management.
    • Assess the effects on soil health.
    • Prohibit the use of per- and polyfluoroalkyl substances (PFAS) in pesticides as inert or active ingredients as well as PFAS in pesticide containers.
    • Evaluate the list of ingredients labeled as “inert” and assess their synergistic effects when combined with other chemicals in the pesticide formulation.
    • Curtail the abuse of emergency exemptions.
    • Eliminate the “treated article” exemption for regulating seeds and consumer goods that are treated with pesticides.
    • Protect vulnerable populations by improving label language so that it’s clear and understandable in appropriate languages as needed by applicator communities; and by establishing meaningful buffer zones — especially for children at schools and daycare centers.
    • Eliminate pesticidal dog or cat products that cause mortalities.
    • Require assessments of pesticides sales and use data with goals of minimizing reliance on chemicals and improving human and environmental health.

There are organic, mechanical and biologic alternatives to most of the practices offered by industrial agribusiness. We have the knowledge, the natural resources and consumer interest to achieve global organic management, but to achieve that goal we have to root out the industrial forces at play. Please join us as we advocate for these practical and reasonable solutions that will lead to a vibrant, local and organic agriculture that is accessible and fair for all.

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