Sylvia Knight, Earth Community Advocate, sknightinvt73@gmail.com, Burlington, VT 05408
11 July 2025
Secretary
Anson Tebbetts (anson.tebbetts@vermont.gov)
Assistant Secretary Alyson Eastman
(alyson.eastman@vermont.gov)
PHARM Director Steven Dwinell (steven.dwinell@vermont.gov)
VT
Agency of Agriculture, Farm & Markets
116
State Street
Montpelier, VT 05620, by email.
Re: Clarifying the Presence of PFAS in Pesticides and Upholding Vermont’s Commitment to Public Health
Dear Secretary Tebbetts, Assistant Secretary Eastman, and PHARM Director Dwinell:
I write on behalf of VT.PAPAN and Vermont PFAS Coalition to express serious concern regarding recent statements made by Ms. Pam Bryer about the presence and regulation of per- and polyfluoroalkyl substances (PFAS) in pesticides. Her assertions, particularly in a May 23, 2024, email to Dr. Lori Cragin of the Vermont Department of Health, are inconsistent with both scientific findings and the legislative intent of Vermont’s Act 131 (S.25), which was signed into law by Governor Phil Scott on May 29, 2024.
Act 131 clearly defines PFAS as a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom. The law was passed in recognition of the environmental and health dangers these persistent chemicals pose. Unfortunately, Ms. Bryer’s recent comments misrepresent the facts and risk undermining public trust and the integrity of Vermont’s regulatory process.
Below are several of Ms. Bryer’s claims, followed by factual clarifications:
Claim: “PFAS are not allowed in pesticides.”
Fact: The EPA continues to register PFAS-containing active ingredients. For example, Minnesota Department of Agriculture has identified 95 EPA-registered pesticide active ingredients as PFAS in use in Minnesota.
Claim: “Soil depth penetration studies are part of the required data collected by EPA for pesticide registration.”
Fact: These studies typically focus only on the active ingredient, ignoring adjuvants and so-called inert ingredients that may significantly influence leaching behavior, particularly in Vermont’s sandy soils and shallow groundwater zones.
Claim:“There are pesticides that are never found deeper than 5 cm down in the soil following an application because of the chemical’s soil binding behaviors.”
Fact: Such generalizations are unsubstantiated. Soil composition, climate, and formulation all influence chemical behavior. In Vermont groundwater PFAS contamination is real and well-documented. Many PFAS are highly water soluble and readily move through soil and water. This solubility and chemical persistence allows them to travel great distances from where they were applied.
Claim: “It is sometimes hard to know what the public means when they say ‘PFAS.’”
Fact: Vermont residents, including those of us in VTPAPAN and Middlebury AirportNeighbors Association (MANA) understand that PFAS vary widely but are still dangerous to life as a class of chemicals combining fluorine and carbon. We are well aware of PFAS sources and pathways—including pesticide formulations. This comment is dismissive of public understanding and concern.
Claim: “EPA has clearly stated that the presence of PFAS (at the level of quantification) in any pesticide product is a violation of FIFRA.”
Fact: This claim lacks supporting documentation. The EPA continues to allow PFAS-based ingredients in registered products, contradicting Ms. Bryer’s assertion.
Claim: “What is confusing many people, however, is that some chemicals that have already undergone full regulatory review are now being called PFAS despite not sharing any of the same characteristics as those chemicals traditionally referred to as PFAS.”
Fact: Vermont law, like similar statutes in Maine and Minnesota, follows the OECD definition of PFAS, which includes a broad range of fluorinated organic compounds, many of which appear in pesticide ingredients.
In 2022 alone, more than 6,800 pounds of PFAS-containing pesticides were reported in use in Vermont—underscoring the urgent need for transparent, science-based regulatory practices.
Ms. Bryer’s continued denial of PFAS in pesticides misleads the public and jeopardizes Vermont’s ability to mitigate long-term environmental and public health harm. Given her influential role as a member of the Act 131 Working Group, her dismissal of PFAS in pesticides may have contributed to their exclusion from the law’s list of banned consumer products—a serious omission with lasting consequences.
We respectfully urge the Agency of Agriculture to take the following actions:
Publicly affirm Vermont’s legal definition of PFAS and acknowledge the presence of these substances in pesticide products.
Commit to transparent communication and science-based regulatory enforcement.
Reassess the appropriateness of Ms. Bryer’s continued involvement in PFAS policy development, should she be unwilling to align with the law and public health priorities.
Thank you for your attention to this critical issue. Please do not hesitate to contact me for additional information or to arrange a follow-up discussion.
Sincerely,
Sylvia Knight, VT PAPAN
Additional signatories:
Marguerite
Adelman,
Burlington, VT PFAS Coalition
Liza
Frankie Nanni,
Burlington, VT PAPAN
Pam
Ladds,
Friends of Memphramagog, Newport, VT
Jennifer
Decker,
Hinesburg, VT
Teresa
Gerade,
Newport, VT
Judith
D Schwartz
Environmental Journalist, Bennington, VT
Emily
Lanxner,
Hardwick, VT
Judy
Wiger-Grohs,
Middlebury, VT
Carol
Cannaveno,
E. Montpelier, VT
Polly
Jones,
Manchester, VT
Henry
Coe,
Danville, VT
Robert
K Wright,
Burlington, VT
CC:
Senator Ginny Lyons senatorginnylyons@gmail.com
Senator
Phil Baruth
Senator Martine Gulick
James Ehlers Chief of
Staff, Lt. Governor John Rogers
