Source: Austin Valley (used under Creative Commons licensing)

Fundamentally Flawed: Environmental Working Group’s Dirty Dozen and Clean 15

The quick take:

• The new OrganicEye white paper challenges the legitimacy of encouraging shoppers to purchase commonly contaminated conventional (non-organic) produce

• Abundant published research illustrates demonstrably lower agrochemical residues in organic versus conventional fruits and vegetables

• Even conventional produce described as “clean” can be contaminated with 1-19 different synthetic pesticides, according to USDA data

• Additional research indicates that when adults and children switch to all-organic diets, levels of pesticide metabolites in their urine drop dramatically

• The rhetoric from EWG’s report is consistent with messaging from the food industry and regulators in Washington: that price and convenience are of paramount importance in food purchasing decisions rather than familial, and national, health and economic impacts

• One of the key drivers for consumers choosing certified organic food is the desire to avoid ingesting genetically modified organisms (GMOs) — none have ever been tested as part of the human diet. The EWG “clean” list of conventional produce includes at least two different cultivars that are available on the market as GMOs (and one other in their general, unrated listings)

LA FARGE, Wis. — Every spring the Environmental Working Group (EWG) releases their Shopper’s Guide to Pesticides in Produce™. For nearly 20 years, this guide has been designed for consumers concerned about pesticide contamination in fruits and vegetables. A new white paper critiques the legitimacy of encouraging shoppers to purchase commonly contaminated conventional, non-organic produce.

Organic industry watchdog OrganicEye applauds the work EWG has done producing their Dirty Dozen™ list of the most pesticide-contaminated fruits and vegetables— and recommending shoppers choose certified organic alternatives. However, the EWG Clean 15™ list recommends conventionally grown fruits and vegetables with lower levels of pesticide residues, instead of promoting an all-organic diet which would truly provide the lowest exposure to toxic and carcinogenic chemicals. 

“The US population has been turned into lab rats in a scientific experiment as more than 90 percent have detectable pesticide biomarkers in their blood or urine,” said Mark Kastel, Executive Director of OrganicEye and its senior farm policy analyst. “To reduce pesticide residue exposure, the EWG, in essence, recommends consuming 15 conventionally grown fruits and vegetables, not crops grown organically. Many of those are far from “clean” and are certainly not the safest choices on the market.”

Based on a wide variety of published research, the primary reason people choose to eat organic is to avoid agrochemicals, including pesticides, in conventional produce and prepared foods, along with hormones and antibiotics used to treat livestock. Avoiding genetically engineered ingredients is also a key market-driver in creating organic demand. Clearly, organic is considered a cleaner way to grow and process food by consumers.

Consumers consider what organic doesn’t have to be of paramount importance in their purchasing decisions. Organic means: 

  • Most drugs typically administered to livestock, such as antibiotics and growth hormones, are banned
  • No dangerous, toxic, synthetic pesticides 
  • No synthetic and petroleum-based fertilizers
  • No genetically modified organisms (GMOs) in the crops themselves or in ingredients or processing agents

Eating an organic diet allows consumers to avoid pesticide residuals that can be harmful. Studies clearly show that in controlled testing where both children and adults first ate conventional foods for a limited time and then consumed only organic foods, the organic diet resulted in demonstrably lower urinary concentrations of pesticide residue markers than consumption of conventional alternatives.

“This research indicates that, especially for fetuses in utero, lactating mothers, and developing children, a lifetime of risk, including developmental abnormalities, can be mitigated by the modest upfront investment in a safer and more nutritious diet,” Kastel added.

In addition to protecting the safety, nutritional quality, and flavor of food, there are a number of societal benefits when shoppers choose organic food in the marketplace, including protecting the health of farmers, farm workers, and livestock, as well as the quality of air, soil, and water. 

What organic has in every bite, based on published, peer-reviewed studies, is as important as what it avoids and eliminates. Organic food:

  • Provides superior nutritional density
  • Protects the health of farmers, farm workers, and their families
  • Requires a more humane animal husbandry standard for livestock 
  • Safeguards the water we depend on from carcinogenic and toxic agrichemical contamination
  • Protects soil fertility and beneficial microorganism health, and reduces erosion

“In these days of high inflationary pressures,” added Kastel, “it should not be a case of organic versus conventional — even a “cleaner-but-not-all-that-clean” conventional choice — but rather the decision to invest in quality food instead of the latest technological gadget or other consumer goods. It is a long-term investment in the health and well-being of all families and children, yielding a lifetime of benefits.”

Given the prevalence and expense of chronic disease in the United States, far eclipsing that in other developed countries, the investment in safer organic food, and fresh whole foods rather than processed, has the potential to have a profoundly positive fiscal impact, both individually and collectively.

If organic food is difficult to find or challenging to afford, some alternatives might include:

  • Growing your own produce at home or in a community garden
  • Shopping locally at a farmers market
  • Joining a CSA farm (Community Supported Agriculture)
  • Joining a member-owned food co-op where sale prices and case discounts are often available 

“For many, investing more time, money, and intention in shopping, and cooking at home, adds meaning and a spiritual connection to food, over and above the documented health benefits,” Kastel concluded. “Buying organic is not just about health, it’s about enjoyment and quality of life.”




The following quotations can be attributed to OrganicEye and/or its Executive Director, Mark A. Kastel.

“Conventional produce can be commonly contaminated with 1-19 different synthetic pesticides! The best way to avoid ingesting herbicides, insecticides, fungicides, and rodenticides is by choosing certified organic food when shopping.” 

From the OrganicEye white paper: 

Historically, potatoes have been the number one vegetable crop consumed in the US. In 2021, each American consumed 29.3 pounds of fresh potatoes1; they also ate 54.6 pounds of processed potatoes (primarily French fries and potato chips2).

It’s a dirty little secret that conventional potato farmers use toxic herbicides to desiccate—kill and dry down—potato crops to even out the harvest and to regulate tuber size prior to mechanical harvesting. Herbicides such as carfentrazone-ethyl, diquat, glufosinate-ammonium, paraquat, pyraflufen-ethyl, and sulfuric acid can be applied between 5 and 9 days before harvest, depending on the product.3 And that’s in addition to other chemicals that are sprayed on the crop post-harvest. 

Potatoes do not consistently appear on EWG’s Dirty Dozen list. They are #13 on the EWG 2022 Shopper’s Guide list4  but consumers would only be aware of that if they accessed the full list on the website. As of this writing, the last year potatoes appeared on the Dirty Dozen list was 2020. The only way to avoid these highly toxic chemicals is to buy organic.

“If we don’t accomplish one other thing in addition to promoting the health and well-being of our families and the environment through our purchase of organic food, we are protecting the farmers and farm workers who, every day, are responsible for the bounty on our tables.”

“Farmers, farmworkers, and their families and children, who very commonly live in housing that is contiguous to farm fields being treated with toxic pesticides, have some of the higher rates of certain cancers and the children have higher rates of asthma. Our food dollars determine the health risks these hard-working people are exposed to.”

I first came to organics, myself, after nearly being disabled from pesticide poisoning. My physician at the time, a nationally preeminent environmental allergist, recommended I eat an all-organic diet while recovering. Today I generally enjoy robust health, not only due to avoiding the agrochemical and drug residues often found in conventional food, which are deleterious to our immune systems, but also because of the unparalleled nutrition inherent in authentic organic production.” 

Lack of focus by the Environmental Working Group on food groups other than fruits and vegetables in their report is an unfortunate omission. Animals producing meat, eggs, or dairy foods concentrate, or bio accumulate, far more contaminants through their feed than would exist in food produced for human consumption. With what we know about toxins as a cause of cancer and endocrine disruption, consumers would be well-served to prioritize all organic food, not just fresh and frozen produce.”

“The messaging in the EWG report is consistent with the overall food industry and regulators in Washington: that the price we pay for food is of paramount concern, with the convenience of processed foods being a close second.”

“The United States has the cheapest food, as a percentage of our gross national product and the incomes of most families, and, by multiples, the most expensive healthcare. This dynamic of cheap, subsidized, industrially produced food has made a lot of agribusiness and healthcare industry investors rich but does not generally serve the citizenry well.”