Image: USDA Organic label in public domain, integrated from Wikimedia Commons (Beyond Pesticides, November 21, 2024) Be it Patagonia Provisions or Brooklyn Brewery, there is a buzz around organic beer that is increasingly evident given interest by brewing and food companies. The expansion of the organic beer market in the United States would not have been possible without the leadership of advocates, farmers, breweries, and the National Organic Standards Board (NOSB), which led to the strengthening of organic standards for beer back in 2010. The growth of this sector and transition to truly organic beer speaks to the spirit of “continuous improvement,” the original design of Organic Foods Production Act (OFPA), and the importance of mobilizing the public to engage in the public input process that continues to keep organic law strong in opposition to those seeking an easier path to the organic label. Continuous Improvement and Organic Hops In the original drafting of OFPA, advocates came together to determine how to encourage the development of certified organic sectors despite the lack of available, verifiable organic inputs at the time for many products—beer included. With this spirit in mind, the improvement of standards for beer encapsulates the significance of OFPA […]

(Beyond Pesticides, November 20 2024) The perpetual use of pesticide coated seeds and tillage changed the composition of various beetle, spider, and other epigeal arthropod communities on New Hampshire farmland, according to a recent study published in Agriculture, Ecosystems, and Environment. Researchers fell short of finding conclusive results about the multi-variable impacts of both practices on biodiversity but raise notable issues on the impact of treated seeds. This research builds on the existing peer-reviewed scientific literature that highlights the threats of toxic pesticides and pesticide-coated seeds. Environmental and public health advocates are in agreement with organic and agroecological farmers who reject chemical-intensive land management practices. “At the root of the cascading crises of public health collapse, biodiversity loss, and the climate crisis is a reliance on petrochemical-based toxic products, rather than public policy and investments that strengthen consumer and institutional trust of nature-based, organic systems,” says Max Sano, organic program associate at Beyond Pesticides. “This is consistent with various interactions I have had with advocates across New England who are demanding action to stymie the impending biodiversity collapse enabled by government inaction.” Background and Methodology This study was coauthored and led by environmental researchers at the Department of Natural Resources […]

(Beyond Pesticides, November 18, 2024) With the reported appointment of former U.S. Representative Lee Zeldin (R-NY) to the position of Administrator of the U.S. Environmental Protection Agency (EPA), Senate confirmation hearings will be an important process that is intended to shine a light on individual nominations, the policies of an administration, and the science (or lack thereof) behind them. There have been reports in the media that the Trump administration may attempt to circumvent the “advice and consent” rule of the U.S. Senate by making recess appointments. Alexander Hamilton wrote in the Federalist Papers: No. 76 that Senate confirmation hearings act as a safeguard against the appointment of “unfit” officials. Numerous interviews and critiques are painting a picture of what the future holds for environmental protection and all that means for addressing the serious catastrophic threats of ongoing and escalating health, biodiversity, and climate crises. “Mr. Trump, who has called climate change a “hoax,” has targeted “every one” of Mr. Biden’s policies designed to transition the United States away from fossil fuels,” according to The New York Times reporting on June 26, 2024. The Guardian reported on October 1 after Hurricane Helene, “As the hurricane continued to ravage the region over […]

(Beyond Pesticides, November 15, 2024) There are many pie-in-the-sky ideas to address the climate crisis while allowing business as usual in the extractive and industrial systems that are causing the crisis. Prominent among them are geoengineering to block sunlight and building industrial plants to prevent carbon dioxide (CO2) from reaching the atmosphere, known as carbon capture and sequestration (CCS). Like geoengineering, CCS is a “solution for the future that always will be.” It has garnered decades of hype, research, and government funding of prototype projects without doing much of anything to remove carbon and keep it out of the atmosphere. The Biden administration’s Inflation Reduction Act (IRA) contains numerous revenue streams aimed at coping with the climate crisis, including CCS. But it is a mixed bag of good and bad ideas. Beyond Pesticides analyzed the IRA in 2022, lauding the act’s “provision of unprecedented sums to address the existential threats we face related to climate, biodiversity, and health.” These include about $21 billion for “climate smart” agriculture and programs to reduce petrochemically dependent farming. But the analysis also details the many provisions for infeasible and counterproductive projects. Rather than complex and expensive technological projects, the best practitioners of CCS are […]

(Beyond Pesticides, November 8-11, 2024) On Veterans Day 2024 we honor those who have served the country and allies. In the 117th (2021-2022) U.S. Congress, legislators enacted The Sergeant First Class Heath Robinson Honoring Our Promise to Address Comprehensive Toxics Act of 2022 (PACT Act). Since the law passed just over two years ago, there has been just under 1.3 million total approved claims marking a roughly 75% approval rate for PACT Act related claims, according to Department of Veteran Affairs (VA) accounting of progress between August 10, 2022, and October 12, 2024 through its dedicated bimonthly VA PACT Act Performance Dashboard. The legacy of toxic burn pits (open air areas where the military has burned toxic waste) and other avenues for toxic exposure in military bases oversees, as well as within the United States in Hawai’i (See coverage on asbestos exposure continuously impacting veterans, as reported on by Honolulu Civil Beat) and Puerto Rico (See peer-reviewed literature review here on toxic heavy metals in International Journal of Environmental Research and Public Health), among other areas, comes at a time when the country assesses the ongoing impacts of a history that has been characterized by critics as colonial or imperialist. […]

(Beyond Pesticides, November 7, 2024) Organic banana production is significantly more conducive to microbial decomposition than its chemical-intensive counterparts in the Caribbean nation of Martinique, according to a recent study published in Applied Soil Ecology. “Macrofaunal decomposition was increased more (55%) than microbial decomposition (20%), indicating that organic farming removes a constraint of conventional farming especially affecting macrofauna.” Biological activity in the soil is foundational to organic land management and critical to the cycling of nutrients that feed plant life while contributing to resiliency and soil water retention. Bananas are one of the most highly consumed fresh fruits in the U.S. marketplace. A consumer survey conducted by the International Fresh Produce Association in 2023 identified 84% of households purchasing bananas that year. The U.S. Department of Agriculture (USDA) Economic Research Service identifies bananas as the third most consumed fruit product in the United States, with the average person eating 13.2 pounds that year. Since bananas require specific bioclimatic conditions for commercial production that meets ongoing consumer demand, the proliferation of industrial-scale monoculture banana plantations in various Central and South American countries and territories has and continues to devastate local and Indigenous communities for generations. Environmental justice and public health advocates […]

(Beyond Pesticides, November 6, 2024) An analysis in the International Journal of Research Publication and Reviews emphasizes the role of biodiversity in agriculture, adding to a wide body of science on its importance. The authors, from Western Illinois University in the United States and Rome Business School in Italy, find that biodiversity supports critical ecosystems and organisms needed for sustainable food production. Through literature reviews and case studies, the interconnectedness of agriculture with plant and animal diversity, beneficial insects, soil health, and climate change is highlighted, as well as the need to manage land organically to support biodiversity. Plant and Animal Diversity As the researchers note, “A diverse agricultural system can better absorb shocks and maintain productivity, ensuring food security in the face of uncertainty.” A wide range of species present within ecosystems protects from changing environmental conditions and improves resilience. When farmers use monocultures for their crops, this leads to reduced ecosystem services from beneficial insects and increased vulnerability to pests and diseases. “By contrast, diverse cropping systems can enhance resilience, providing a buffer against environmental changes and fostering sustainable food production,” the authors say. Research shows that higher plant diversity disrupts pest life cycles and promotes beneficial insects, […]

(Beyond Pesticides, November 4, 2024) The U.S. Environmental Protection Agency (EPA) last week opened a public comment period on the regulation of endocrine-disrupting pesticides, a proposal that lays out a drawn-out 10-year process that is narrow in evaluating the underlying mechanism that causes endocrine disruption. The proposal, published in the Federal Register as a partial settlement agreement and consent decree, responds to a lawsuit filed by farmworker and health groups challenging the agency’s failure to test and regulate endocrine-disrupting pesticides. Earlier in the year, after over 25 years of delay following the 1996 Congressional mandate to determine whether pesticides disrupt the endocrine system of humans and other organisms, EPA issued a proposal for modifying its approach to the implementation of the Endocrine Disruptor Screening Program (EDSP).  The National Institutes of Environmental Health Sciences explains endocrine disruptors this way: “Endocrine-disrupting chemicals (EDCs) are natural or human-made chemicals that may mimic, block, or interfere with the body’s hormones, which are part of the endocrine system. These chemicals are associated with a wide array of health issues. . . Endocrine glands, distributed throughout the body, produce the hormones that act as signaling molecules after release into the circulatory system. The human body is […]

(Beyond Pesticides, November 1, 2024) In a study published earlier this year in Soil Science Society of America Journal, researchers at Kansas State University document direct evidence that organic amendments (e.g., manure and compost) in a no-till agricultural system “facilitat[e] microbial diversity” that cycles plant-available nutrients. The study was published just as farmers are looking for less expensive practices that support the economic vitality of their farms amid surging prices for petrochemical pesticides and fertilizers and as agricultural support programs are threatened by unresolved issues in Farm Bill talks on Capitol Hill. [See the recent Action of the Week calling on Congress to take action.] Simultaneously, awareness is growing among environmental and public health advocates about the importance of soil health to ecosystem stability in combatting climate change-induced natural disasters and stopping plummeting biodiversity. Demands for new systems rooted in organic principles and land management practices continue to become more widely recognized by farmers, environmentalists, and the broad public. The study adds to earlier findings and contributes to the body of scientific literature on soil health and its importance to ecosystem and human health. Methodology and Results The study was led by researchers at Kansas State University specializing in agronomy […]

(Beyond Pesticides, October 30, 2024) STARTS TODAY at 2 PM EDT—NATIONAL FORUM: IMPERATIVES FOR A SUSTAINABLE FUTURE. Beyond Pesticides has filed suit against The Scotts Miracle-Gro Company and GreenTechnologies, LLC for allegedly misleading consumers on the hazardous nature of their fertilizer products, which contain sewage sludge (often referred to as biosolids) contaminated with per- and polyfluoroalkyl substances (PFAS). The group filed two cases, Beyond Pesticides v. Miracle-Gro Co. and Beyond Pesticides v. GreenTechnologies, LLC, in D.C. Superior Court on October 25, 2024. The complaint alleges that, as part of their marketing, these companies tell consumers that their fertilizers are “eco-friendly” and “sustainable,” when, in fact, the products contain hazardous substances. The complaint cites test results showing PFAS residues in the companies’ fertilizers and numerous scientific studies on the adverse effects of PFAS to public health, wildlife, and pollinators.   PFAS, known as “forever chemicals” due to their ability to persist in the environment, are endocrine disruptors linked to developmental issues, cancers, metabolic, cardiovascular and reproductive harm, damage to the liver, kidneys, and the respiratory system, as well increased chances of disease infection and severity. The chemicals’ immunotoxic effects threaten human health.  Beyond Pesticides alleges that consumers are, thus, misled by advertising in which Scotts Miracle-Gro […]

(Beyond Pesticides, October 28, 2024) STARTS WEDNESDAY—NATIONAL FORUM: IMPERATIVES FOR A SUSTAINABLE FUTURE. As scientific articles and regulatory reviews by the U.S. Environmental Protection Agency (EPA) focus on individual pesticides or families of pesticides and specific health outcomes associated with exposure, legislation introduced by U.S. Senator Cory Booker (D-NJ), S. 5084, Safe School Meals Act (SSMA), proposes a holistic response to the protection of children by banning pesticides in school lunches. While focused on the elimination of certain individual pesticides and other chemicals of known concern, the bill unilaterally allows children to be served food from certified organic farms. The overwhelmingly large body of scientific findings on the adverse effects of pesticides in the food that children eat in schools and generally. For example, last week Beyond Pesticides commented on EPA’s Draft Human Health and/or Ecological Risk Assessments for Several Pesticides, citing scientific findings that, “Neonicotinoids . . .have been found to affect mammalian nicotinic acetylcholine receptors (nAChRs) [which] are of critical importance to human brain function, especially during development and for memory, cognition, and behavior.” (See more here.) This month, Jennifer Sass, PhD, et al., in Frontiers in Toxicology, published a review of  unpublished rodent developmental neurotoxicity (DNT) studies […]

(Beyond Pesticides, October 24, 2024) When U.S. Senator Cory Booker (D-NJ) introduced S. 5084, Safe School Meals Act (SSMA) in September, he identified four objectives: Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals. The limits will be based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure. Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement. Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals. Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA’s analysis. While groups like Beyond Pesticides applaud Senator Booker’s initiative to restrict exposure to some of the most hazardous toxicants, especially the most vulnerable subpopulation of children, their goal is to provide organic food to school children. In this spirit, groups have advocated that the U.S. Department […]

(Beyond Pesticides, October 23, 2024) The stark contrast of two political parties emerged around this summer’s reporting of the Project 2025 blueprint—created by extreme right-wing conservatives—that proposes the gutting of environmental and public health policy and implementation. Many political observers say “Project 2025 Presidential Transition Project,” formally titled “Mandate for Leadership: The Conservative Promise,” will be embraced by a second Trump Administration, despite denials that are challenged by insiders as outright lies. While the public became aware of Project 2025 plans to gut the U.S. Environmental Protection Agency (EPA) and many other agencies, the Biden Administration was announcing the emergency ban (see also August 6 announcement), finalized yesterday, of the weed killer Dacthal, exercising an EPA authority that has not been used in 45 years since the banning of 2,4,5-T (50% of the mixture of Agent Orange). With this decision, EPA set an important precedent for proclaiming (i) an unacceptable harm, (ii) its inability to mitigate the pesticide’s hazards with typical risk mitigation measures, and (iii) the availability of alternatives that made the chemical unnecessary. In dramatic contrast, the Trump supporters behind Project 2025 are intent on politicizing science to undermine governmental structures and laws established to protect public health […]

(Beyond Pesticides, October 21, 2024) To solve the existential crises of climate change, biodiversity loss, and human disease, Beyond Pesticides is urging that organic agriculture grows—over the next decade becoming universally adopted for all agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic. The OCCSP will disappear in 2025 unless Congress passes a five-year Farm Bill with funding or includes sufficient funding in a stopgap bill this fall. Chemical-intensive agriculture, with its dependence on petrochemical pesticides and fertilizers, is a major contributor to the existential health and environmental crises and contamination of air, land, and water. Organic agriculture, certified and labeled in compliance with the Organic Foods Production Act (OFPA) provides: A definition of organic agriculture that defines health-biodiversity-climate friendly practices; A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests; A rigorous process for an allowed/prohibited substances list with a mechanism for […]

Beyond Pesticides (October 17, 2024) On September 30, 2024, the U.S. Environmental Protection Agency (EPA) opened a public comment period about production of specific per- and polyfluoroalkyl substances (PFAS, also known as ‘forever chemicals’)—including perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), and perfluorodecanoic acid (PFDA). EPA is collecting information on the fluorination process of high-density polyethylene (HDPE) and other plastic containers to inform possible regulatory action under the Toxic Substances Control Act (TSCA). The deadline for submitting comments is November 29, 2024. PFOA and twelve other PFAS compounds are created during the fluorination of HDPE plastic containers by Inhance Technologies, LLC, the only U.S. company manufacturing containers using this fluorination technique (see here). Studies by EPA, independent researchers, and the company itself demonstrate that PFAS leaches from container walls into contents, exposing millions to these toxic chemicals without their knowledge. EPA notes, “Long-chain PFAS like PFOA, PFNA, and PFDA build up in our bodies and the environment over time. Even small amounts can significantly contribute to people’s long-term exposure and health risk for cancers, impacts to the liver and heart, and immune and developmental damage to infants and children.” The adverse effects of PFAS exposure are linked to serious health issues, […]

(Beyond Pesticides, October 16, 2024) In a study published in the Journal of Agriculture, Food Systems, and Community Development (JAFSCD), researchers from New York University (NYU) identify gaps in various federal agricultural support systems for organic farmers in a sweeping analysis. The research was spearheaded by Carolyn Dimitri, PhD, chair of the Nutrition and Food Studies program at NYU and a current member of the National Organics Standard Board (NOSB) as a public interest/consumer interest representative serving through January 2026. According to this study, there is a deficiency in institutionalized knowledge of national organic standards among existing U.S. Department of Agriculture (USDA) agents and staff working in various agencies, including Risk Management Agency (RMA), Natural Resources Conservation Service (NRCS), and Farming Service Agency (FSA). “A key recommendation from this study is the creation of specialized, highly trained crop insurance and conservation agents with expertise in organic farming systems to facilitate the application process and program use for conservation programs and crop insurance,” according to the researchers. The authors continue by echoing the sentiments of organic advocates and farmers across the nation on building organic integrity, saying, “The Organic Cost Share Program [a program of USDA’s FSA] would have more impact […]

(Beyond Pesticides, October 11-14, 2024) Indigenous Peoples’ Day is celebrated this year on Monday, October 14, 2024 and has been described as follows: “[T]hroughout our Nation’s history, Indigenous peoples have faced violence and devastation that has tested their limits. . . Today, Indigenous peoples are a beacon of resilience, strength, and perseverance as well as a source of incredible contributions. . . They challenge all of us to celebrate the good, confront the bad, and tell the whole truth of our history.  And as innovators, educators, engineers, scientists, artists, and leaders in every sector of society, Indigenous peoples contribute to our shared prosperity.  Their diverse cultures and communities today are a testament to the unshakable and unbreakable commitment of many generations to preserve their cultures, identities, and rights to self-governance.  That is why, despite centuries of devastation and turmoil, Tribal Nations continue to thrive and lead in countless ways.” This language is taken from a Proclamation issued by President Biden (2023), first issued in 2021 and then again last year. This year’s Proclamation states: “On Indigenous Peoples’ Day, we honor Indigenous peoples’ strength, courage, and resilience.  We celebrate the vast contributions of Indigenous communities to the world.  And we recommit […]

(Beyond Pesticides, October 9, 2024) An agrichemical industry-funded study published in International Journal of Agricultural Sustainability dissects the development of national organic standards and opportunities that can be applied in expanding the use of “regenerative” agriculture. Not surprisingly, the study authors offer support for integrated pest management (IPM) and reassurance of a rigorous pesticide registration review process before the chemicals are marketed. The study included a survey of five farmers, who farm a total of 100,000 acres, but do not have extensive experience farming organically. For those practicing regenerative organic practices and organic advocates, the bottom line is that the study concludes that a list of criteria that would be needed for regenerative agriculture criteria (e.g., list of allowed substances) already exists within the standards and requirements of the 1990 Organic Foods Production Act (OFPA) and the National Organic Program. Environmental and public health advocates are concerned about this piece representing an industry position being cloaked in an academic journal serving as an obstacle to the widespread adoption and improvement of organic principles and practices. The study was written by four authors with varying levels of connections to CropLife America (the major agrichemical industry trade group), including academic researchers with […]

(Beyond Pesticides, October 4, 2024) Coffee is a staple of morning routines for millions around the nation—and as the demand for coffee remains high, so goes the surge in certified organic coffee, offering space for coffee lovers to enjoy the drink and lower their carbon footprint, according a study in Cleaner and Circular Bioeconomy. A 2024 survey conducted by the International Food Information Council found that “[t]he majority of Americans (88%) consume caffeine, with 8 in 10 reporting they consume it daily, and nearly half (47%) reporting they consume it multiple times a day.” Coffee overwhelmingly leads in popularity, with 54% of respondents indicating the beverage as their preferred source of caffeine with soft drinks a distant second (17%). Researchers found in the new coffee production study that certified organic coffee producers in Peru have a lower carbon footprint than transitional organic coffee farmers. As organic land management practices and principles continue to proliferate, advocates continue to stress the importance of third-party certification as an integral part of the integrity of the USDA organic label, overseen by the National Organic Program. As the National Organic Standards Board goes through its mandatory public comment review this month, consumers, companies, farmers, and […]

(Beyond Pesticides, October 3, 2024) The American Academy of Pediatrics published a technical report in September on antimicrobial resistance, which it calls a global public health threat, identifying the health implications of antibiotic use in animal agriculture. The lead authors, both medical doctors from the Department of Pediatrics at Vanderbilt University Medical Center, note the rise in antimicrobial-resistant infections that result in increased morbidity, mortality, and health care costs for not only adults, but infants and children as well. “[A]ll use of antimicrobial agents exerts selective pressure that increases the risk of development of resistance,” the authors state, highlighting the importance of limiting antimicrobial uses. “Antimicrobial resistance is an organism’s ability to survive exposure to an antimicrobial agent that was previously an effective treatment. Resistance traits can be acquired either through new mutations or through transfer of genetic material between organisms,” the authors report. Antimicrobial-resistant pathogens, such as bacteria and viruses, can be transmitted “through the food supply, direct contact with animals, environmental pathways, and contact with infected or colonized humans,” they continue. Use of antimicrobial agents, especially over extended periods of time or with repeated exposure, can cause resistance to not only that agent, but to multiple agents. As […]

(Beyond Pesticides, September 30, 2024) Public Comment Period on Issues of Organic Integrity Closes Today. Farming is a notoriously risky enterprise, and organic farming presents further challenges along with its multiple benefits. Generally, organic has made great strides over the last several years and is strongly supported by American consumers, findings in the latest U.S. Department of Agriculture (USDA) Census. Even late this year, there is the prospect of several more important changes that will improve the organic certification process and some issues that will take more policy changes to resolve in the future. As a part of this process to ensure the integrity of the USDA organic label and the permitted production practices, Beyond Pesticides urges that the public submit comments TODAY (the last day for the comment period) on issues currently before the National Organic Standards Board (NOSB). See two sets of comments on key issues that can be submitted with one click each. Click here on issues related to use of plastic, nonorganic ingredients in processed food, and seeds and plant starts. Click here on inert ingredients, contaminants in compost, and drugs in livestock production. U.S. agriculture overall has remained fairly robust between the USDA Census in […]

(Beyond Pesticides, September 27, 2024) A recent article in Flatwater Free Press identifies a growing trend of companies, communities, and farms nationwide advancing organic agriculture and land management. Among the signs of this change is Belltown Farms, a Philadelphia, PA owner and operator of organic and organic-transitioning farms, that, according to Flatwater, is “the second-largest buyer of Nebraska’s increasingly expensive farmland by money spent between 2018 and 2022” with plans to expand to 50,000+ acres in various states across the country. Similarly, the continued success of the Nebraska-based, on-farm processing operation, Grain Place Foods, and its collaboration with farmers focused on small-scale organic production, represents the diversity of economic and organizational models that can exist in local, regional, national, and even international food systems. This National Organic Month, organic advocates, consumers, and farmers continue to call on federal policymakers to expand opportunities for the proliferation of small-scale farming operations. In advancing growth of organic and integrity of the organic food label, organic advocates are seeking to ensure equity and access to land as integral to any growth. In this context, Beyond Pesticides had identified the promise of organic in fighting existential health, biodiversity, and climate crises and ongoing threats to the […]

Image: Shelf labeling at Blue Hill Coop, Blue Hill, Maine. Note three levels of information: Local Maine Organic, Organic, and Local Maine, as well as country of origin. Photo by Jay Feldman, heading to the Maine Organic Farmers and Gardeners Assn (MOFGA) Common Ground County Fair. (Beyond Pesticides, September 23, 2024) Public Comments on organic standards are due by 11:59 PM EDT on September 30, 2024. Beyond Pesticides is calling for the public to submit comments to the National Organic Standards Board during its Fall review of standards and allowed substances—a second action in a two-part request for the public to weigh in on key issues that go to the heart of the integrity of practices allowed under the USDA organic food label. The issues addressed in this call for action include the following: end plastic in organic production and processed food as a research priority; eliminate nonorganic ingredients in processed organic food; and, require organic products to be produced using only organic seeds and starts. The first action during the current comment can be found here and includes the following issues: full review of “Inert” ingredients used in organic production; strengthened compost regulations; and, rejection of proposal for new animal drug […]