EPA recently posted a “Fact Check” on PFAS and pesticide approvals. While we appreciated that the agency clearly noted organic as a strong consumer-choice alternative for those seeking to avoid PFAS in their diets, OTA was compelled to request correction of several inaccurate statements in the release.
Below is a summary of the issues raised in OTA’s letter to Administrator Zeldin which points out how EPA drifted into pesticide industry talking points rather than relying on factual descriptions of the organic program.
1. EPA suggested organic “relies on pesticides”
This is inaccurate. Federal law requires organic farmers to use ecological and cultural practices first, including crop rotation, soil management, sanitation, habitat disruption, and biological or mechanical controls. Only when these are insufficient may a producer use a limited set of approved inputs. Organic is built on a foundation of prevention and ecology, not chemical reliance.
2. EPA used misleading toxicity comparisons
In the press release, EPA referenced LD50 values to suggest some organic inputs are “more toxic” than modern synthetics. LD50 measures acute lethality in a lab, not chronic or real-world risks. By this metric, chocolate appears more toxic than DDT, illustrating how irrelevant these comparisons are for PFAS and for consumer health concerns.
3. EPA ignored its own review role
All substances used in organic production undergo EPA’s standard pesticide review, followed by an additional review by HHS and the National Organic Standards Board. Only about 25 synthetic substances meet these stringent criteria. Organic inputs face more scrutiny, not less.
4. EPA’s “organic is not pesticide-free” line lacked context
Organic does not claim to be pesticide-free, but it does follow a transparent national standard that covers soil health, biodiversity, animal welfare, GMOs, processing methods, and bans on PFAS-containing biosolids which requires segregation, traceability and oversight throughout the supply chain. USDA’s own data shows organic foods consistently have lower pesticide residues than conventional products or unregulated “pesticide-free” claims.
Why this request for correction matters
When EPA presents selective or incomplete information, it undermines public trust and spreads confusion about a federal program designed to protect human and environmental health. In its letter, OTA urged EPA to correct the record and avoid misleading comparisons in future communications.
Read OTA’s full letter to EPA