Search Climate Insights Directory

A coalition of 42 organizations, including Earthjustice and the NRDC, submitted comments on the EPA's Draft Sewage Sludge Risk Assessment for PFOA and PFOS. The coalition argues that the EPA's assessment confirms that these 'forever chemicals' in sewage sludge pose unacceptable risks to human health and the environment, particularly through land application on farms. They claim the EPA's risk calculations are underestimates because they use low-end concentration models and ignore combined exposure effects. The document calls for the prompt finalization of the assessment, the establishment of numerical limitations and management practices under the Clean Water Act, and the expansion of future risk assessments to include other PFAS, synthetic organic fluorine compounds, and microplastics. Additionally, they advocate for stricter pretreatment standards for industrial dischargers to prevent PFAS from entering publicly-owned treatment works.

The document argues for a total ban on chlorpyrifos in Canada, asserting that the PMRA's proposed re-evaluation decision does not go far enough. The authors claim that risks to pollinators, birds, mammals, and aquatic life are unacceptable and that current risk assessments underestimate exposure due to a lack of surface water monitoring data. They specifically challenge the safety of continued use in mosquito control and greenhouses, citing evidence of biodiversity in temporary pools and the inefficiency of label restrictions to prevent runoff.

The document argues that the PMRA's proposed phase-out of imidacloprid is too slow and narrow in scope, failing to account for the risks to wild pollinators beyond honey bees and bumblebees. It criticizes the reliance on label statements for risk mitigation, citing inadequate enforcement capacity in Canada. The authors highlight risks from environmental contamination, such as residues in non-target wildflowers and dust from treated seeds, and argue that the economic value of neonicotinoid seed treatments is overrated. They recommend a full ban on all outdoor uses, aligned with European Union regulations, and a shift toward Integrated Pest Management (IPM).

The document outlines opposition to a Draft Screening Assessment regarding hydrogen sulfide (H2S), sodium bisulfide (Na(SH)), and sodium sulfide (Na2S). The authors argue that H2S poses significant risks to human health, particularly for communities near oil and gas operations, and that the government's assessment fails to apply a precautionary approach or account for olfactory nuisance as an adverse effect.

The document critiques the PMRA's special review of atrazine, claiming it ignores synergistic effects of pesticide mixtures, fails to assess surface water contamination, and uses less protective drinking water standards than necessary. It cites evidence of atrazine's presence in Canadian groundwater and surface water, as well as its links to endocrine disruption in wildlife and various cancers and developmental issues in humans.

The report analyzes the EPA's 2007 risk assessment, finding that unlined coal ash ponds and landfills pose severe cancer and non-cancer risks to humans and aquatic ecosystems. It specifically highlights that residents near unlined ponds mixing ash and coal refuse face a 1 in 50 cancer risk from arsenic, 2,000 times the EPA's regulatory goal. The document also notes that boron levels in surface waters can reach 2,000 times safe thresholds for aquatic life. It argues that the EPA underestimated these risks by ignoring direct surface water releases and inhalation pathways, and calls for the phase-out of ash ponds within five years and the mandatory use of composite liners for landfills.