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Will Allen: We Need Food and Farming Regulation NOW!

Will Allen grew up on a small farm in southern California and served in the Marine Corps between the Korean and Vietnam wars. He received a PhD in Anthropology (focused on Peruvian tropical forest agriculture) and taught at the University of Illinois at Urbana-Champaign, and the University of California, Santa Barbara, before being fired and sentenced to a year in jail for civil rights and antiwar activism. He returned to farming and farm labor full time in 1972 and has been farming organically ever since in Oregon, California, and Vermont, where he now co-manages Cedar Circle Farm. He is also the author of The War on Bugs.

Salmonella contaminated pistachios, peanuts, tomatoes, melons, and jalapenos and the slaughtering of downer beef are glaring examples of sloppy farming and processing combined with regulatory failure. All of these regulatory failures and bad farming practices didn’t cause only bankruptcies or huge cuts in 401-Ks, they sickened hundreds of millions and killed hundreds of thousands of people over the last thirty years!9

The following is by Will Allen, author of The War on Bugs:

Taxpayers are demanding that government enforce existing regulations and create more stringent rules to limit the excess and greed in banking, insurance, housing, and on Wall Street. But, in the rush to regulate, we can’t forget to oversee industrial agriculture. It is one of our most polluting and dangerous industries. Like the financial sectors, its practices have not been well regulated for the last thirty years. Let me run down a few of the major problems that have developed because of our poorly regulated U.S. agriculture.

Carbon Foot Print: The U.S. EPA estimated in 2007 that agriculture in the U.S. was responsible for about 18% of our carbon footprint, which is huge because the U.S. is the largest polluter in the world.1 This should include (but doesn’t) the manufacture and use of pesticides and fertilizers, fuel and oil for tractors, equipment, trucking and shipping, electricity for lighting, cooling, and heating, and emissions of carbon dioxide, methane, nitrous oxide and other green house gases. Unfortunately, the EPA estimate of 18% still doesn’t include a large portion of the fuel, the synthetic nitrogen fertilizer, some of the nitrous oxide, all of the CFCs and bromines, and most of the transport emissions. When they are counted, agriculture’s share of the U.S. carbon footprint will be at least 25 to 30%.

Oftentimes we see all greenhouse gasses as being equivalent to carbon dioxide (CO2). But, methane emissions are 21 times and nitrous oxides 310 times more damaging as greenhouse gasses than CO2. Since agriculture is one of the largest producers of methane and nitrous oxide, the extent of the agricultural impact is staggering. Unless we change our bad habits of food production and long distance delivery, we will not be able to deal with climate change.

Fertilizer Pollution/Dead Zones: Factory farming is polluting the ground, river, and ocean water with high amounts of nitrogen, phosphorous, and other fertilizers. High levels of nitrates and nitrites were found in twenty-five thousand community wells that provided drinking water to two thirds of the nation’s population. More than fifteen million people in two hundred eighty communities are drinking water with phosphorous or phosphates which mostly come from industrial farming operations.2

Nitrate and phosphorous fertilizer runoff flow into the rivers and ultimately end up in the ocean.  The river water rides up over the heavier salt water when it reaches the ocean and algae blooms develop on the fertilizer rich water. When the algae die, the bacteria use up all of the oxygen in decomposing them. This creates an oxygen dead (or hypoxic) zone. In 1995, scientists identified 60 dead zones around the world.

Recent results published in 2008 identified 405 oceanic dead zones.3 The prime cause for dead zones is the use of highly soluble synthetic fertilizers, which are overused to obtain maximum yields. The government regulations on the total maximum daily load (tmdl) of synthetic nitrogen, or phosphorous fertilizer coming off of farms were established under the Clean Water Act. But those statutes are routinely not enforced. There are exceptions, but in general the regulators have been in a thirty-year coma.

Pesticides in Water: In addition to fertilizer pollution of our food and water, high amounts of pesticides, antibiotics, and hormones are also in the food, soil, water, and air. More than twelve thousand wells that provide water to 100 million people have arsenic or lead concentrations above the health based limits established by the U.S.EPA. Arsenic has been used on crops in the U.S. since 1867 and lead-arsenic since 1890. Arsenic is still widely used today on turf crops, corn, soy, and cotton as an herbicide or defoliant. The EPA, FDA, USDA and almost all state agencies, however, do not even keep good track of arsenic use. It is hard to regulate when you don’t know how much is being used.

While we don’t know how much was used, we do know that nearly 30 million people in the U.S. are drinking water contaminated with Atrazine, Simazine, Telone II, 2,4-D, or 2,4,5-T. All of these chemicals are related to DDT and were first sold in the 1940s, after they were developed in World War II. Simazine and 2,4,5-T had their EPA registrations cancelled more than twenty years ago because they were so deadly; yet millions of people in the U.S. still drink water contaminated with these two terrible war toys.  All these DDT relatives caused cancer and multiple birth defects in tests on laboratory animals. They continue today to greatly damage bird populations in farm country.

Two of these war materials, 2,4-D, and 2,4,5-T along with Dioxin were the poisons in Agent Orange, the defoliant that killed and crippled so many Vietnamese and American soldiers and turned jungle into denuded ghost lands.  Somehow, the officials at EPA and FDA seem to think that it is OK for millions of U.S. citizens to have these two killer chemicals in their drinking water.4

Excessive Pesticide Use Today: Factory farmers continue to use enormous quantities of the most toxic poisons.5 In 2006, four of the six most used farm pesticides in California were among the most dangerous chemicals in the world. Farmers applied more than 35.7 million pounds of four pesticides: Metam sodium, Methyl bromide, Telone II, and Chloropicrin.

Metam sodium, the third most used California pesticide in 2006, is closely related to the chemical gas that escaped in Bhopal India in 1984 and killed 30,000 people and injured 200,000. Fourteen million, eight hundred thousand pounds were used in California in 2006. Metam sodium is a biocide, causes multiple birth defects, farmworker injuries, and is very toxic to birds and fish.

In 2006, California farmers used seven million pounds of Methyl bromide, the fourth most used farm pesticide in the state, and the notorious destroyer of the ozone. The EPA registration for Methyl bromide was scheduled for cancellation in 1995 as a result of Montreal Protocol agreements. But, wealthy and politically connected California strawberry, fruit, and carrot farmers found their way around those restrictions and still were allowed to apply 7 million pounds in 2006 (the last year for which we have records). Methyl bromide causes birth defects, cardiac arrest, nervous system damage, and is responsible for many thousands of deaths since 1936.

The fifth most used chemical in California in 2006 was Telone II (1,3-Dichloropropene). Telone II is a cancer and birth defect-causing fumigant that has been very deadly and dangerous to farmers, farmworkers, school kids, and rural residents since the 1940s. When it first came out it was called 666. This is supposedly “The Mark of the Devil”. Telone II has lived up to that name, killing and injuring untold thousands. Its California registration was due to be cancelled in 1995 because it was a cancer causing air pollutant. But, with the pending loss of methyl bromide, it was reregistered for limited use. They didn’t apply real strict limitations, hovever, because California farmers used about 7 million pounds in 2006.

The sixth most used farm chemical in California was Chloropicrin. This chemical is tear gas, the highly effective anti-riot gas that is released in major demonstrations. One might ask “Why are we using tear gas on our food?” The answer is that it is a deadly biocide. It is usually combined with methyl bromide to provide a warning taste and smell (that methyl bromide lacks) and because it greatly increases the fumigation toxicity of both poisons. It causes several birth defects, causes severe respiratory damage, and is very toxic to fish. California farmers used 6.9 million pounds in 2006.

In 2004, California Strawberry growers used 184 pesticides. They applied an average of more than 335 pounds of pesticides per acre. Metam sodium, methyl bromide, chloropicrin and Telone II accounted for 74% (or 248 pounds) of the pesticides used on each acre of strawberries. Four of the world’s most toxic chemicals, accounted for almost three-quarters of all pesticides used.  Strawberry shortcake, anyone?

Data? What Data?: California is the only state that has collected pesticide use data in the U.S. (New York recently passed the same law). Unfortunately, for all the other states, we do not have good data. California began collecting use data from farmers and applicators in 1970. The USDA and most states only collect survey data, not actual usage amounts. Because California has real data, and because California provides half of the fresh produce in the country, their information is an invaluable guide to the level of poisonous exposure that U.S. farmers, farmworkers, food handlers, and customers have endured on farm products for almost forty years.

We analyzed the use of pesticides on crops from California’s data set for the Sustainable Cotton Project and for The War on Bugs book. We found that factory farming has been very dependent on the worst poisons for all of the forty years that records have been kept. Although California has good data and toxicological analyses, it has not been aggressive in acting to cancel the registrations on even the chemicals it knows to be most poisonous, even those that cause multiple birth defects and cancer.

The USDA and each state should collect pesticide and fertilizer use data as California has for pesticides. Without real data, claims of increased or decreased use are groundless. Having the data will enable us to set real goals for chemical use reduction as European countries have. Then, and only then, will we be able to see if usage is declining or increasing and how many of the most toxic chemicals are used on our food and in our communities.

Besides collecting actual use data, we must evaluate all the farm and industrial chemicals as they are doing in the E.U. with REACH (Registration, Evaluation, And Authorization of Chemicals). Such data would greatly supplement the evaluations by Cal EPA and U.S.EPA, which are good, but significantly incomplete because they grandfathered in many chemicals that required no testing. REACH is currently evaluating even the grandfathered chemicals!

Even though our existing analyses are incomplete, the data from both CalEPA and U.S.EPA are sufficient to begin to phase out dozens of the most toxic pesticides. Many chemicals are so toxic that we need a goal of a 50% reduction every five years. We must begin these reductions because cancer and birth defect clusters are now common in most U.S. farm communities and people are being exposed to multiple pesticide residues on their fresh and processed food and on their clothing.

Confinement Animals/Excess Antibiotics and Hormones: I have pointed out in The War on Bugs and in other articles that our confinement animal operations (where most of our meat comes from) are a serious health and safety threat.6 And, as we have all come to realize, they are very poorly regulated. Overuse of hormones and antibiotics has left us with antibiotic resistant meat, large quantities of antibiotics in rivers and drinking water, and even antibiotic resistant pork farmers and consumers. Beef cows are often injected with hormones, milk cows with genetically modified growth hormones. The U.S. meat supply is so dangerously unhealthy that large amounts of it are regularly recalled (about 200,000,000 pounds of beef in 2008) and some of the more suspicious or contaminated meat has been allowed by the FDA to be irradiated since the 1990s. Nuked meat?

We raised 11 billion meat, milk, and egg-laying animals in the U.S. in 2008. By 2008, we produced nearly 69 million pigs, 95% in confinement. We raised 300 million commercial laying hens in battery cages, Ten billion meat chickens, and half a billion turkeys were confined in abusive close quarter conditions. About 33 million beef cows and 9.7 million dairy cows spent their dreary days in disgusting feedlots and dairy barns.7 These facilities and their meat products are rife with disease that the public is advised to combat by thorough cooking. In December, 2008 Consumer Reports found that 83% of the 525 meat chickens they studied had salmonella or campylobacter. With deadly diseases on all but 17 chickens out of 100, customers are asking: What about the salmonella on my drain board or my hands? No wonder there is so much food borne illness!

These enormous populations of animals also produce a lot of manure, and massive amounts of methane and nitrous oxide. The largest amount of nitrous oxide comes from fertilizer used on farmland that produces feed for confined animals. High methane emissions come from mountains of animal manure and digestive gasses, and a lesser though significant amount, from unsustainable grazing. Seventy to eighty percent of our farm production and acreage is used to produce the aforementioned 11 billion beef cows, pigs, poultry, milk cows, sheep, and goats. Fertilizer use in the U.S. is variable depending on the needs of the crop and the natural fertility of the land. Corn and cotton farmers, who grow the corn and cottonseed to feed these confined animals, use 200 to 300 pounds of nitrogen per acre and about 100 pounds of phosphorous.  This is much more nitrogen and phosphorous than the crops can use in a single season, but the farmers are advised to use “enough” to get the highest possible yields. So, most of the nitrogen and phosphorous fertilizer that the plants don’t need and can’t use are flushed into rivers, lakes and the ocean.

I could continue further with this litany of unregulated farm problems, but these are the major issues. We are living in a very polluted and dangerous food world, partly because of the unregulated excesses of U.S. industrial farming. If we are going to bring down our high rates of obesity, diabetes, heart disease, cancer, and birth defects we have to change our food choices and how that food is raised. Besides creating profound health and safety problems, industrial farming is a huge unregulated contributor to global warming and an enormous user of energy. We must regulate and significantly reduce the U.S. farm use of fuels, pesticides, and fertilizer. These are not choices! These are necessities! If we are going to seriously tackle climate change and fix our health system, we have to change our form of agriculture.

We Can’t Fix Factory Farming!: The Pew Charitable Trust and the Johns-Hopkins Bloomberg School of Public Health conducted a study in 2008 and determined that the U.S. factory farming system is dangerously out of control and that many practices, including animal confinement, and the prophylactic-use of antibiotics and hormones must be phased out. A second study, also in April of 2008, by the Union of Concerned Scientists concluded much the same.8 Both studies found that the current factory farming paradigms are simply not sustainable for the land, the drinking water, the confined animals, the rivers, and the oceans, and they are seriously damaging our public health. The Union of Concerned Scientists reminded us that we will be subsidizing these bad farming practices once again on April 15th when we pay our taxes. That is the second payment for “cheap food”.

For more than one hundred years U.S. and European safe food activists’ demanded real regulation of farm chemicals. But, it was always a pipe dream, since chemical firms, the universities and the government all alleged that the pesticides were safe and that farmers couldn’t get good yields without chemicals. So, the regulators looked the other way. However, farmers around the world have demonstrated that they can produce as good or better yields of quality food and fiber without dangerous and damaging chemicals. Still, the regulators continue to look the other way and still refuse to stop the poisoning.

Salmonella contaminated pistachios, peanuts, tomatoes, melons, and jalapenos and the slaughtering of downer beef are glaring examples of sloppy farming and processing combined with regulatory failure. All of these regulatory failures and bad farming practices didn’t just cause bankruptcy or a huge cut in 401-Ks, they sickened hundreds of millions and killed hundreds of thousands of people over the last thirty years!9

Each day seems to bring more pesticide spills and injuries, more poisoned food, more contaminated drinking water, more dead zones and more residues on our food. Consequently, immediate regulation of and a rapid phase-out of the most toxic farm chemicals now seem like urgencies, instead of pipe dreams.

If We Can’t Fix it, Let’s Change it!: While U.S. factory farming can’t be fixed, the good news is that changing U.S. agriculture it is not an unattainably complex goal. However, it does call for a paradigm shift. We must stop pretending that fossil based fertilizer and fuel is endless, sustainable, or environmentally justifiable. The Green Revolution is over! After one hundred years of use the jury is in. What looked in 1909 like a cheap and efficient fertilizer has polluted our drinking water, turned deadly to the oceans, is increasingly more expensive, and today is doing more harm than good. We must dramatically reduce the use of synthetic nitrogen fertilizer and began an immediate phase out.

In 1945, only five percent of the nitrogen used on U.S. farms was synthetic. Now, more than ninety-five percent is. Before the synthetic takeover, farmers grew fertilizer crops and applied small amounts of composted manure for fertility and tilth, to increase organic matter, and to feed the microorganisms. These techniques and more modern ones are used by both organic and non-organic farmers today and enable them to produce high yields of quality produce, meat, fiber, oilseeds, and grains. Farmers all over the world are getting higher yields of calories per acre on diversified organic farms than on monocultural chemical or GMO farms.

We can solve the dead zone problem by switching back from synthetic nitrogen and soluble phosphorous fertilizers to organic plant-based fertility. This is not rocket science and it is not a long shot with outmoded technology. It is, in fact, achievable within a few years. As a plus, fertilizer crops sequester carbon, which our currently barren soils in the fall and winter don’t.

We can eliminate the cancer and birth defect clusters and high pesticide residues on our favorite foods by using biological IPM strategies to control pests and diseases. Releasing beneficial insects, altering our growing practices, rotation of crops, soil balancing, and careful monitoring of pest damage are a few of the successful techniques that thousands of farmers are using to control pests and eliminate poisonous pesticides on their farms.

This is a challenging time for farmers, with many sorting out how can they produce their own energy on the farm as well as auditing and reducing their use. Most of us know that the cheap era of fossil fuel is over. With agriculture being responsible for such a large percentage of fossil fuel consumption, it is essential that resources be invested in alternative energy strategies by farmers, entrepreneurs, and by state and federal government agencies.

At this critical juncture, we should see these factory farm problems and their solutions as an opportunity. This is an opportunity for us to demand that Washington regulate our food supply. It is a chance to make real changes in our own diets by eating safe foods, supporting local organic farms, and frequenting farmers markets. Additionally, each of us can grow chemically free vegetables and fruits in our own yards, like the Obamas are doing at the White House.

It is also a time of opportunity to assist farmers and merchants in converting U.S. farming and the food system. To do this, we need much more government investment in the reinvigoration of our agricultural extension service. These new or retrained extension agents would help farmers make the transition to sustainable and organic agriculture (as some currently are). We also need access for young and not so young farmers to financial aid and government held farmland. Clearly, we also need lots more regulators. Only the government can address these issues. But, we must pressure the Obama run EPA, USDA, and FDA to address them as if they were urgent.

U.S. organic farmers developed a set of standards in the 1970s and 1980s to regulate farms and farmers with third party inspections. They did this to assure a suspicious public that the food they produced was really organic. The standards they enforce require crop rotation, an organic fertility and pest control program and prohibit the use of toxic fertilizers, chemical pesticides, hormones, antibiotics, genetic modification, sewage sludge, irradiation, and the feeding of animal protein to animals.

“Conventional” food in the U.S can be grown with all the farming practices outlawed in organic. Conventional is a semantic ploy to avoid calling the food “chemical”, or “poisonous”. Whatever you call it, it should be regulated and the most damaging practices should be made illegal.

Finally, we need to internationally harmonize our regulations, so that there is as much unanimity to the rules as possible and the enforcement is transparent. This is just as important in food as it is in finance. We are all too connected globally to pretend that we should not worry about another culture’s food regulations or health concerns. Ideally, we should all embrace a more rigorous international REACH-like program that would protect farmers, farmworkers, processors and consumers.
Hopefully, the Obama administration attitude toward regulation will extend to U.S. agriculture. If it doesn’t, we are in deep shit! And, I’m not talking manure.


  1. U.S.EPA Inventory of U.S. Greenhouse Gas Emissions and Sinks, 1990-2005 (April, 2007)
  2. Environmental Working Group (EWG), National Tap Water Quality Database. U.S. EPA Data Bases on Water Pollution, required by the Clean Air Act.
  3. Dr. Robert J. Diaz, Professor of Marine Biology at the Virginia Institute for Oceanography, and Rutger Rosenberg, Science, Aug. 15, 2008, Spreading Dead Zones and Consequences for Marine Eco Systems.
  4. Environmental Working Group (EWG), National Tap Water Quality Database. U.S. EPA data bases on water pollution required by the Clean Air Act.
  5. California Environmental Protection Agency (CalEPA), Department of Pesticide Regulation, Pesticide Use Reports: 1970-2006.
  6. See Allen, Will, The War on Bugs, Chelsea Green, Vermont, March, 2008, The Death of Food, Alternet, April, 2008. The Real Cost of Cheap Food, Alternet. June, 2008.
  7. Data gleaned from USDA, ERS , Orange County People for Animals, U.S.EPA,
  8. CAFOs Uncovered: The Untold Costs of Confined Animal feeding Operations,  Doug Gurian-Sherman, Union of Concerned Scientists, April, 2008. Putting Meat on the Table: Industrial Farm Production in America, Pew Charitable Trusts and Johns Hopkins School of Public Health, April, 2008.
  9. The U.S. Center for Disease Control and Prevention estimated in 1999 that food borne illness in the U.S. sickens 76 million people, 325,000 end up in the hospital and more than 5,000 die, every year. Food And Water in 1996 estimated that pesticides kill about 10,000 people a year. Adding these figures over a 30 year period equals several hundred thousand dead from the U.S. food system.

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