Document 0qj7gnyrNbxG0KK6E3ZJkJ2gM

March 7, 2025 The Honorable Robert F. Kennedy Secretary U.S. Department of Health and Human Services 200 Independence Avenue, S.W. Washington, D.C. 20201 The Honorable Brooke Rollins Secretary U.S. Department of Agriculture 1400 Independence Avenue, S.W. Washington, D.C. 20250 The Honorable Lee Zeldin Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Dear Secretary Kennedy, Secretary Rollins, and Administrator Zeldin, As organizations representing the food and agriculture community, we write to express our interest in working with you and the Make America Healthy Again Commission in advancing our shared goals of improving health outcomes for Americans while protecting our most vulnerable populations. At the same time, we are eager to share with the Commission our significant concerns regarding unfounded criticisms levied against the safety of the food and agricultural value chain. It is essential that as these topics are reviewed, the Commission respects and reinforces the robust science- and risk-based regulatory systems to which products are already subject and the abundance of fit-for-purpose scientific literature on these matters. We urge the Commission to draw conclusions from the significant body of sound, quality science and data while resisting policy changes based on misleading or outlier studies. The February 13, 2025, executive order, Establishing the President's Make America Healthy Again Commission, referenced several items important to our organizations. Modern agricultural tools like pesticides and biotechnology are critical components of a healthy and dynamic food system and farm economy. U.S. produced food and feed ingredients are the foundation of a safe and affordable food supply for all Americans. Pesticides are used in all types of agricultural production, from conventional to organic. These products are critical for ensuring a safe, abundant, and affordable supply of food, feed, fuel, and fiber. Without access to safe, well-regulated pesticidal tools, our nation's growers and agricultural producers would be vulnerable to devastating insects, fungal diseases, and weed pests that can completely destroy a crop. Economy-wide, this would impact the cost and availability of food for American consumers. Further, pesticides are vital for protecting public health from diseases carried by animal pests like bed bugs, rodents, and mosquitoes, which can carry diseases like West Nile virus or Dengue Fever. Leveraging the safe use of pesticides is also critical to supporting soil health conservation practices such as no-till; controlling weeds that could damage critical infrastructure; and controlling vegetation that contributes to wildfire fuel loads. Without risk-based scientific regulatory processes providing for access to and safe use of pesticides, U.S. growers and producers will become less competitive in the marketplace. Less U.S. production means Americans will increasingly rely on other countries for our food, leading to higher prices, reduced food security and compromised national security. A nation that chooses not to feed itself is not secure. Importantly, in 1996 Congress enacted the Food Quality Protection Act (FQPA), which directs that there must be "reasonable certainty" no harm will result from pesticide residue exposures, with explicit emphasis placed on protecting infants and children. In implementing FQPA--which EPA completed in 1 Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003061-00001 SC_EVERSPLIT0007345 2006 and periodically reviews--the agency regularly uses one or more safety factors, including a default "10x factor." This means residue limits are very low risk and consistently set 10 or even 100 times more conservative than is already found to be safe. These limits are established using a variety of literature sources that EPA's scientists independently determine are fit for regulatory purposes. In testing for residues, USDA and FDA annually find that more than 99% of food and feed products comply with these exceptionally conservative standards. As a result, the U.S. regulatory process is the global gold standard for ensuring the public is protected from pesticide residues. Similarly, the U.S. has in place appropriate, science-based processes for regulating products of biotechnology and genetic improvement technologies. In recent decades, these innovations have helped farmers reduce crop input use; mitigate pest pressures; enable soil health practices, such as no-till; and enhance the nutritional profile of foods to improve health outcomes for consumers. Biotechnology has also been crucial in allowing farmers around the world to increase yields on existing farmlands to feed a growing global population, reducing the need to convert environmentally-sensitive lands (e.g., forests) into cropland for food production. Additional research is underway exploring ways to use genetic innovations to reduce food spoilage and waste, improve drought tolerance, among many other important developments. USDA regulates biotechnology innovations to ensure they are safe for environmental release and do not pose a plant pest risk, while FDA evaluates new plant varieties produced using biotechnology to ensure they do not pose a food or feed safety risk. EPA also reviews biotechnology varieties intended to protect crops from pests to ensure they are safe for human health and the environment. Both long-term and short-term risks are evaluated in these assessments. Further, many of our trade partners evaluate biotechnology products to ensure compliance with safety standards around the world. In the more than 30 years since their initial agricultural uses, products of biotechnology are now safely grown globally on nearly 500 million acres each year to help meet food, feed, fuel, and fiber needs. It is also essential to note that the U.S. has in place a robust regulatory process for ensuring the safety of food and animal feed ingredients. The Federal Food, Drug, and Cosmetic Act (FD&C Act) gave FDA the authority to oversee food safety and approve ingredients and additives for human and animal consumption. The FD&C Act has been updated by Congress numerous times, most recently in 2024. Through the authority granted by this legislation, FDA establishes regulations for food and animal feed labels, ingredients, and additives that are generally recognized as safe (GRAS) or approved additives. Importantly, FDA requires that the safety of GRAS ingredients and food and animal feed additives must be science-based and meet FDA safety standards. Much like the oversight of agricultural tools, there must be a "reasonable certainty" that these food and animal feed additives and ingredients do not harm consumers. A domestic value chain for U.S. food products is the most efficient way to ensure continued access to safe, affordable food products. Limiting GRAS ingredients and additives due to dubious studies that do not meet appropriate data quality standards could lead to food shortages, limited options for consumers with dietary or religious food restrictions, intensified food waste, and increased imported food ingredients that would both spike costs and decrease food safety certainty. While we welcome the administration's focus on improving human health and the rigor of our regulatory systems, any reviews of these processes, or the products they regulate, must carefully consider the breadth and quality of scientific literature available on these topics. Reviews must also ensure necessary safeguards to protect scientific integrity. Too often, critics of modern agricultural production have singled out and relied on outlier studies that support their policy agendas, ignoring the strong consensus of available scientific evidence. They also have contorted screening level studies, such as those that feed 2 Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003061-00002 SC_EVERSPLIT0007346 test animals hundreds or thousands of times above the acceptable daily intake limits for humans, as a justification to ban substances. Sometimes they have gone as far as to design their own studies to obtain a predetermined outcome, such as selecting test animals genetically predisposed for health ailments. Regulatory agencies have data quality standards and protocols in place to screen out poor studies and ensure others are used appropriately. It is essential that agency scientists and experts retain the autonomy needed to determine the appropriateness of data considered in science- and risk-based regulatory systems. Our organizations support and share in the goal of improving health outcomes for Americans, but it is vital that any review efforts of the Commission or individual participant agencies are based on quality data and accept the strong scientific consensus on these topics. Further, any assessments must acknowledge the robust science- and risk-based processes our regulatory agencies already have in place and the extensive history of safe use that has resulted therefrom. Failing to maintain these indispensable standards is regrettably likely to result in Americans becoming less healthy. It risks not only harming our nation's growers, producers, and food processors, but also the consumers we proudly serve. We look forward to future dialogues with the Commission as we collectively seek to improve health outcomes in the U.S. and thank you for your attention to this important matter. Sincerely, Agribusiness Association of Iowa Agribusiness Association of Kentucky Agribusiness Council of Indiana Agricultural Council of Arkansas Agricultural Retailers Association Alabama Soybean and Corn Growers Association Alaska Farm Bureau Almond Alliance American Agri-Women American Cotton Producers American Dairy Coalition American Farm Bureau Federation American Feed Industry Association American Horse Council American Mushroom Institute American Pistachio Growers American Pulse Association American Seed Trade Association American Soybean Association American Spice Trade Association American Sugar Alliance American Sugarbeet Growers Association AmericanHort Aquatic Ecosystem Restoration Foundation Aquatic Plant Management Society Arizona Cotton Growers Association Arizona Crop Protection Association Arizona Farm Bureau Federation Arkansas Certified Crop Advisers 3 Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003061-00003 SC_EVERSPLIT0007347 Arkansas Crop Protection Association Arkansas Farm Bureau Federation Arkansas Rice Federation Arkansas Rice Growers Association Arkansas Soybean Association Association of Equipment Manufacturers Big Horn Basin Beet Growers Association Big Horn County Sugar Beet Growers Association Biotechnology Innovation Organization Burley & Dark Tobacco Producer Association California Alfalfa & Forage Association California Apple Commission California Association of Wheat Growers California Bean Shippers Association California Blueberry Commission California Cherry Growers and Industry Association California Citrus Mutual California Citrus Quality Council California Cotton Ginners and Growers Association California Farm Bureau California Fresh Fruit Association California Grain and Feed Association California Pear Growers California Seed Association California Specialty Crops Council California State Floral Association California Tomato Growers Association California Warehouse Association California Wild Rice Advisory Board Calorie Control Council Can Manufacturers Institute Cherry Marketing Institute Chippewa Valley Bean Co. Inc Colorado Association of Wheat Growers Colorado Livestock Association Colorado Nursery and Greenhouse Association Colorado Potato Administrative Committee Colorado Sugarbeet Growers Association Connecticut Farm Bureau Association Corn Refiners Association Council of Producers & Distributors of Agrotechnology CropLife America Delaware Farm Bureau Delta Council Edible Oil Producers Association Enzyme Technical Association Farm Credit Council Florida Farm Bureau Federation Florida Fertilizer & Agrichemical Association Florida Rice Growers Sierra Club FOIA Request: 2025-EPA-04193 4 ED_018475D_00003061-00004 SC_EVERSPLIT0007348 Georgia Cotton Commission Georgia Fruit and Vegetable Growers Association Georgia Green Industry Association, Inc. Georgia Urban Ag Council Georgia/Florida Soybean Association Great Plains Canola Association Hawaii Crop Improvement Association Hawaii Farm Bureau Idaho Eastern Oregon Seed Association Idaho Farm Bureau Federation Idaho Grain Producers Association Idaho Mint Growers Association Idaho Oilseed Commission Idaho Onion Growers' Association Idaho-Oregon Fruit and Vegetable Association Illinois Corn Growers Association Illinois Farm Bureau Illinois Fertilizer and Chemical Association Illinois Soybean Association Independent Bakers Association Independent Professional Seed Association Indiana Corn Growers Association Indiana Farm Bureau Indiana Soybean Alliance International Food Additives Council International Fresh Produce Association International Maple Syrup Institute Iowa Corn Growers Association Iowa Farm Bureau Iowa Soybean Association Kansas Agribusiness Retailers Association Kansas Association of Wheat Growers Kansas Corn Growers Association Kansas Cotton Association Kansas Farm Bureau Kansas Soybean Association Kentucky Corn Growers Association Kentucky Farm Bureau Kentucky Horticulture Council Kentucky Livestock Coalition Kentucky Sheep and Goat Development Office Kentucky Small Grain Growers Association Kentucky Soybean Association Kentucky State Horticultural Society Kentucky Vegetable Growers Association Louisiana Cotton & Grain Association Louisiana Farm Bureau Federation Louisiana Rice Producers' Group Maine Farmers Coalition Maine Potato Board Sierra Club FOIA Request: 2025-EPA-04193 5 ED_018475D_00003061-00005 SC_EVERSPLIT0007349 Malheur County Onion Growers Association Michigan Agri-Business Association Michigan Asparagus Association Michigan Bean Commission Michigan Bean Shippers Michigan Corn Growers Association Michigan Farm Bureau Michigan Soybean Association Michigan State Horticultural Society Mid Atlantic Soybean Association Midwest Council on Agriculture Midwest Dry Bean Coalition Midwest Food Products Association Midwest Forage Association Minnesota AgriGrowth Minnesota Association of Wheat Growers Minnesota Canola Council Minnesota Corn Growers Association Minnesota Crop Production Retailers Minnesota Farm Bureau Federation Minnesota Soybean Growers Association Mint Industry Research Council Mississippi Farm Bureau Federation Mississippi Rice Council Mississippi Soybean Association Missouri Agribusiness Association Missouri Corn Growers Association Missouri Soybean Association Montana Agricultural Business Association Montana Farm Bureau Federation Montana Grain Growers Association National Agricultural Aviation Association National Alfalfa & Forage Alliance National Alliance of Independent Crop Consultants National Association of State Departments of Agriculture National Association of Wheat Growers National Barley Growers Association National Black Growers Council National Christmas Tree Association National Confectioners Association National Corn Growers Association National Cotton Council National Council of Farmer Cooperatives National Farmers Union National Fisheries Institute National Grain and Feed Association National Oilseed Processors Association National Onion Association National Pasta Association National Pecan Federation Sierra Club FOIA Request: 2025-EPA-04193 6 ED_018475D_00003061-00006 SC_EVERSPLIT0007350 National Potato Council National Seasoning Manufacturers Association, Inc. (NSMA) National Sunflower Association National Watermelon Association NEBCO Sugar Beet Growers Nebraska Agri-Business Association Nebraska Farm Bureau Federation Nebraska Soybean Association Nebraska Sugarbeet Growers Association Nevada Farm Bureau Federation New Jersey Farm Bureau New York Corn & Soybean Growers Association New York Farm Bureau New York State Agribusiness Association North American Blueberry Council North American Millers' Association North Carolina Cotton Producers Association North Carolina Farm Bureau North Carolina Grange North Carolina Potato Association North Carolina Soybean Producers Association North Central Weed Science Society North Dakota Corn Growers Association North Dakota Grain Growers Association North Dakota Soybean Growers Association Northarvest Bean Growers Association Northeast Agribusiness & Feed Alliance Northeast Dairy Producers Association Northeastern Weed Science Society Northern Canola Growers Association Northern Pulse Growers Association Ohio AgriBusiness Association Ohio Corn & Wheat Growers Association Ohio Farm Bureau Ohio Soybean Association Oklahoma Agribusiness Retailers Association Oklahoma Cotton Council Oklahoma Farm Bureau Oklahoma Soybean Association Oklahoma Wheat Growers Association Olive Growers Council of California Oregon Dairy Farmers Association Oregon Farm Bureau Oregon Potato Commission Oregon Seed Council Oregon Wheat Growers League Oregon Women for Agriculture Oregonians for Food and Shelter Pacific Northwest Canola Association Pacific Seed Association Sierra Club FOIA Request: 2025-EPA-04193 7 ED_018475D_00003061-00007 SC_EVERSPLIT0007351 Peanut and Tree Nut Processors Association PennAg Industries Association Pennsylvania Farm Bureau Plains Cotton Growers, Inc. Potato Growers of Michigan, Inc Refrigerated Foods Association Rhode Island Farm Bureau Federation Rolling Plains Cotton Growers Snake River Sugarbeet Growers Association South Carolina Corn and Soybean Association South Carolina Farm Bureau South Dakota Agri-Business Association South Dakota Corn Growers Association South Dakota Farm Bureau South Dakota Soybean Association South Texas Cotton & Grain Association Southern Crop Production Association Southern Kansas Cotton Growers Coop Southern Weed Science Society Specialty Soya and Grains Alliance Tennessee Corn Growers Association Tennessee Farm Bureau Federation Tennessee Nursery & Landscape Association Tennessee Soybean Association Texas Corn Producers Association Texas Farm Bureau Texas International Produce Association Texas Rice Producers Legislative Group Texas Soybean Association Texas Wheat Producers Association The Breakthrough Institute The Fertilizer Institute The Good Food Institute U.S. Apple Association U.S. Canola Association U.S. Durum Growers Association U.S. Hop Industry Plant Protection Committee U.S. Peanut Federation US Dry Bean Council US Pea & Lentil Trade Association USA Dry Pea & Lentil Council USA Rice Utah Farm Bureau Federation Venture Dairy Cooperative Virginia Agribusiness Council Virginia Farm Bureau Virginia Grain Producers Association Virginia Peanut Growers Association Virginia Soybean Association Washington Association of Wheat Growers Sierra Club FOIA Request: 2025-EPA-04193 8 ED_018475D_00003061-00008 SC_EVERSPLIT0007352 Washington Farm Bureau Washington Friends of Farms and Forests Washington Mint Growers Association Washington Policy Center Office for Agriculture Research Washington Potato & Onion Association Washington State Potato Commission Weed Science Society of America Western Alfalfa Seed Growers Association Western Growers Western Plant Health Association Western Pulse Growers Association Western Society of Weed Science Western Sugar Cooperative Western Tree Nut Association Wheatland Beet Growers Association Wisconsin Agri-Business Association Wisconsin Dairy Products Association Wisconsin Potato & Vegetable Growers Association Wisconsin Soybean Association Wyoming Ag Business Association Wyoming Farm Bureau Federation Wyoming Wheat Growers Association Sierra Club FOIA Request: 2025-EPA-04193 9 ED_018475D_00003061-00009 SC_EVERSPLIT0007353