(Beyond Pesticides, July 17, 2024) National election results in the United Kingdom (UK) and France in recent weeks have shocked the world amidst concerns of a rising tide of right-wing authoritarianism on the eve of European Parliament election results—trending toward what was initially perceived as a conservative majority earlier in June. With new leadership in some of the biggest economies and policy leaders across the Atlantic, environmental and health advocates are hopeful that this will signal a new momentum to advance the mission of transitioning to a fully organic land management and food system that replaces the status quo reliant on toxic petrochemical-based pesticides and fertilizers that exacerbate the climate crisis, biodiversity collapse, and public health fragility. Citizens of the United Kingdom overwhelmingly voted for the center-left Labour Party, which won an unprecedented margin of 291 seats, winning 412 seats out of the 650 total seats up for grabs. The Conservative Party won just 121 seats, a clear rejection of their nearly fifteen-year leadership position in UK politics. UK-based advocates welcome the news given the Labour Party platform to “ban neonicotinoid pesticides imidacloprid, clothianidin, and thiamethoxam due to their impact on bees,” according to reporting by Politico. Neonicotinoids have long […]

(Beyond Pesticides, July 15, 2024) It is hot. Really hot. A serious response to this climate emergency requires, according to environmental advocates, a dramatic transformation in land management and an end to the use of petrochemical pesticides and fertilizers. Beyond the real-world adverse effects of the climate crisis— more intense and frequent fires, floods, hurricanes and hail storms, as well as the harm to health and biodiversity—the rising insurance premiums imposed by the insurance industry speaks to the need for an urgent systemic response. According to the paper, Pricing of Climate Risk Insurance: Regulation and Cross-Subsidies, “The unprecedented rise in natural disasters has led to catastrophic losses of more than $600 billion in the United States over the last two decades, roughly twice the losses of the previous 40 years combined.” While the events associated with climate are more accurately described as “human-made” rather than “natural” disasters, a 2023 Washington Post article reports that, “U.S. insurers have paid out $295.8 billion in natural disaster losses from 2020 to 2022, a record for a three-year period.” This has led to dramatic changes in the cost of insurance coverage and the decision of many carriers to deny coverage. The Washington Post writes, “At least […]

(Beyond Pesticides, July 12, 2024) No one can deny that the dominant agricultural system developed in the 20th century is unsustainable, and indeed is in escalating crisis from the combined effects of pesticide resistance, climate change and resource overexploitation. The frontline members of this system are farmers, who must juggle numerous considerations to maintain their livelihoods. Any proposal for improvement that threatens their bottom lines is likely to encounter resistance, and any proposal that promises to improve the bottom line is more likely to be implemented. Thus there is a powerful incentive to accept suggestions from “crop advisors”—usually known as agronomists—a category that includes government extension agents, independent consultants usually paid directly by farmers, and those who work for agribusiness, particularly chemical companies. A study published in the Journal of Rural Studies in April by Iowa State University sociologist Katherine Dentzman, PhD examines the relationships among agronomists, farmers and farming communities. Dr. Denzman conducted focus groups with agronomists in in Mid-Atlantic, Midwest, Northwest, and Southwest states to determine what pressures limit the types of advice they give farmers. When it comes to pesticides and resistance to them, the advice provided by typical agronomists has generally led to more pesticide use, despite […]

(Beyond Pesticides, July 4, 2024) In reflecting on recent U.S. Supreme Court decisions that reduce federal government powers to restrict hazardous chemicals, including pesticides (see Clean Water Act decision and federal restrictions of toxic hazards under the reversal of Chevron decision), two remaining authorities in state and local governments and in the courts have become the next battleground to protect health and the environment. What is at stake are two major backstops to weak federal controls and chemical company disregard for safety: the critical importance of state and local governments’ exercise of authority to restrict toxic chemicals, and the ability of people to sue corporations for their failure to warn about their products’ hazards.  The attack on state and local authority in the Farm Bill The Farm Bill in the U.S. House of Representatives: Prohibits the rights of states and local governments to restrict pesticides and protect public health and the environment. The language says the Farm Bill will “prohibit any State, instrumentality or political subdivision thereof… from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or packaging that is in […]

Image: Globetrotter19, CC BY-SA 3.0 <https://creativecommons.org/licenses/by-sa/3.0>, via Wikimedia Commons (Beyond Pesticides, June 26, 2024) The Hungarian city of Törökbálint (featured above) is one of several dozen towns to join the European Pesticide Free Towns Network, an initiative of Pesticide Action Network (PAN) Europe, based on a recent blog post welcoming the city into its Network. With elections coming up in European Union Parliament and EU member state nations across the continent, advocates believe in the importance of proactive actions local governments and towns launch to address the cascading crises of climate change, biodiversity deterioration, and public health fragility. In the U.S., Beyond Pesticides is working with communities nationwide, providing hands-on technical assistance in the adoption of organic land management practices. “In recent years, our municipality has begun to explore the possibility of tackling an increasing number of city management problems with environmentally friendly solutions,” says Sándor Elek, mayor of Törökbálint in a public statement announcing the city’s membership. “We are phasing out chemical treatments in public areas and working on the continuous information and awareness-raising of the public. We are also working to promote the public acceptance of environmentally friendly mosquito control.” In joining the European Pesticide Free Towns Network, each […]

(Beyond Pesticides, June 25, 2024) It has been a couple of weeks since U.S. Senator John Boozman (R-AR), ranking GOP member on the Senate Agriculture Committee, released the Republican framework vision without statutory language for a Senate Farm Bill that would renew the law’s commitment to chemical-intensive agriculture and undermines efforts to curtail pesticide use and hold chemical company polluters accountable. In his press statement, Sen. Boozman issues an approach that largely mirrors the House-side text, passed by the House Agriculture Committee earlier this month in a 33-21 vote. On the same day that Sen. Boozman announced the framework, the House Agriculture Appropriations Subcommittee approved the federal food and agriculture budget for Fiscal Year 2025 with a $355 million cut from last year’s budget, affecting specific programs that support pollinator health, ecosystem health, and public health related to pesticide use and organic agriculture. The full House Appropriations Committee will vote on this budget on July 10 before moving to the House floor. Advocates are adamant in their resolve to demand more – not less – support from Congress to address the climate emergency, insect apocalypse, and public health implications borne from reliance on toxic petrochemical pesticides and fertilizers. The Senate […]

(Beyond Pesticides, June 24, 2024) National Pollinator Week ended last week, but the crisis associated with pollinator decline and biodiversity collapse continues. If there were not enough data to prove that regulators are woefully behind the curve in protecting pollinators, yet another study was published during Pollinator Week that reminded regulators, elected officials, farmers, gardeners, all eaters, and lovers of nature that federal, state, and local environmental laws in place have been an abject and unconscionable failure in protecting the biodiversity that supports all life. The study, “Insecticides, more than herbicides, land use, and climate, are associated with declines in butterfly species richness and abundance in the American Midwest,” published in PLOS ONE, cries out as a further warning that the U.S. Environmental Protection Agency’s (EPA) “mitigation measures,” which tinker with limited pesticide restrictions, represent a catastrophic disregard for the scientifically documented facts, according to environmental advocates. Daily News will cover this study in more detail in a later piece, however, the abstract of the journal piece is worth reprinting here in reflecting on Pollinator Week: “Mounting evidence shows overall insect abundances are in decline globally. Habitat loss, climate change, and pesticides have all been implicated, but their relative effects […]

(Beyond Pesticides, June 13, 2024) A study published in Conservation Letters, a journal of the Society for Conservation Biology, exposes critical shortcomings in the U.S. Environmental Protection Agency’s (EPA) ecological risk assessment (ERA) process for modeling the risks that pesticides pose to bees and other pollinators. For the study, “Risk assessments underestimate threat of pesticides to wild bees,” researchers conducted a meta-analysis of toxicity data in EPA’s ECOTOX knowledgebase (ECOTOX), an EPA-hosted, publicly available resource with information on adverse effects of single chemical stressors to certain aquatic and terrestrial species. The meta-analysis found that the agency’s approach, which relies heavily on honey bee data from controlled laboratory studies, drastically underestimates the real-world threats from neonicotinoid insecticides (and likely other pesticides) to native bees and other pollinators. The study “challenges the reliability of surrogate species as predictors when extrapolating pesticide toxicity data to wild pollinators and recommends solutions to address the (a)biotic interactions occurring in nature that make such extrapolations unreliable in the ERA process.” Beyond Pesticides executive director Jay Feldman remarked, “EPA’s ecological risk assessment process is fundamentally flawed and puts thousands of bee species at risk of pesticide-caused population declines and extinctions.” Mr. Feldman continued, “This underscores the urgent […]

(Beyond Pesticides, June 3, 2024) Environmental advocates continue to raise concerns about the Farm Bill (H.R.8467—Farm, Food, and National Security Act of 2024) that emerged from the House Agriculture Committee on May 23 with provisions they say will allow the escalation of environmental threats and then insure big agriculture commodity producers for losses attributable to those environmental disasters through an expansion of USDA’s crop insurance program. Through this taxpayer supported program, USDA covers farm revenue losses due to “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” Petrochemical pesticide and fertilizer use in chemical-intensive land management and agricultural production contributes to the climate emergency and associated weather, insect, and plant disease threats. Advocates point out that the House Agriculture Committee Farm Bill reduces environmental protections by (i) preempting local and state government authority to allow more restrictive standards at the municipal level, (ii) taking away the right to sue pesticide manufacturers and allied companies for a failure to fully disclose adverse effects of the products they produce or use, and (iii) weakening the regulatory process intended to protect endangered species and biodiversity from pesticides.   Tell Your U.S. Representative and Senators To Support […]

(Beyond Pesticides, May 28, 2024) Public comments are due May 29, 2024. With 40 percent of all vegetables grown in the U.S. coming from the state of California, the current state level process to define “regenerative agriculture” could have major impact on land management practices that address the current climate, biodiversity, and health crises. That is, according to advocates, if the process, directed by the California Department of Food and Agriculture (CDFA) departs from a history of poorly defined and unenforceable terms like Integrated Pest Management (IPM) and Sustainable Agriculture. Virtually all consumers of food have a stake in the outcome of the definition of “regenerative,” so the current public comment period, which closes tomorrow, May 29, 2024, can help influence the outcome. As Beyond Pesticides has reported previously, the term “regenerative” is now increasingly being advanced as a loosely defined alternative to the organic standard and label, which is transparent, defined, certified, enforced, and subject to public input. The  publication AgFunderNews (AFN) in February published its updated “2024 list of agrifood corporates making regenerative agriculture commitments,” a who’s who of the largest food and agribusiness corporations worldwide. The list includes companies such as ADM, Cargill, Danone, General Mills, Tyson, Unilever, Walmart, and more with commitments […]

(Beyond Pesticides, May 23, 2024)  A study recently published in the journal Nature compared the impact of organic and conventional food production using eight environmental health indicators and found that organic food has a significantly lower environmental impact than conventional food production for six of the eight indicators, including a lower potential for contributing to acidification of the environment, energy use, and biodiversity loss. For the analysis, scientists reviewed 100 different “life cycle assessments” (LCA) of organic and conventionally grown food products from cradle-to-farm gate.    LCA is a commonly used methodology to estimate food production system impacts on the environment through resource depletion and pollutant emissions. The results—that organic food production is less impactful on the environment—add to the robust body of research that underscores the importance of organic farming to the development of a sustainable global food system while addressing climate change. Beyond Pesticides has long argued that one of the most powerful tools in fighting global warming is organic agriculture, as it sequesters atmospheric carbon, eliminates the use of fossil fuel-based synthetic fertilizers and synthetic pesticides, and provides environmental and human health benefits. This study and most of the 100 studies it evaluates, do not recognize that conventional […]

(Beyond Pesticides, May 20, 2024)  (Beyond Pesticides, May 20, 2024) The Republican Farm Bill draft in the U.S. House of Representatives, released on Friday, May 17, is a broad attack on pesticide restrictions and the right to sue chemical manufacturers and allied users of pesticides when harmed. “This legislation is a complete nonstarter for the millions of people who want stronger pesticide restrictions, democratic decision making on toxic chemicals in communities, and the right to sue manufacturers and pesticide users when harmed and misled on the hazards of pesticides,” said Jay Feldman, executive director. “We vehemently oppose this Republican legislation with the understanding and experience—bridging farmers, medical practitioners, land managers, local policy makers, and families—that we can and must transition to safe practices and products that protect our health, biodiversity, and climate,” Mr. Feldman continued. The Farm Bill attack takes place on many critical fronts. The draft legislation: 1. Takes away the right to sue for failure to warn when harmed by pesticides. The language says: “prohibit. . .a court from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or […]

(Beyond Pesticides, May 14, 2024) As research continues to emerge on the value of organic farming, U.S. Congress debates its future as Farm Bill negotiations have been stalled for months. Recent studies published within the past few months show the significance of organic agriculture’s support of fungal and microbial life, which is essential to soil health. Meanwhile, last week the Democrat-led Senate and Republican-led House of Representatives presented their respective visions to amend the 2024 Farm Bill. The office of U.S. Senator Debbie Stabenow (D-MI), chair of the Senate Agriculture Committee, released an initial Senate framework for the (now 2024) Farm Bill. At the same time, U.S. Representative Glenn Thompson (R-PA), chair of the House Agriculture Committee, released an outline of the House version, then followed up with more details. While the Senate Democratic proposal includes more robust support for expanding and strengthening organic product supply chains and domestic production, the House Republican support for organic land management principles and practices demonstrates that the Farm Bill could recognize, across the political spectrum, its economic, ecological, and public health benefits in the United States. Despite this, a growing coalition of advocates is alerting the public and members of Congress that the […]

(Beyond Pesticides, May 10, 2024) A study published by scientists in France from La Rochelle University’s Chizé Center for Biological Studies, in collaboration with the University of Strasbourg and the University of Burgundy, finds lower pesticide load in chicks from a bird of prey species in areas with organic farming. A correlation between lower numbers of pesticides in the blood of birds with the presence of organic farms surrounding the habitats was determined after analyzing 55 Montagu’s harrier (Circus pygargus) nestlings from 22 different nests in southwestern France. As the percentage of organic agriculture around the nests increased, there was a significant decrease in the quantity and types of pesticides detected within the chicks’ blood.  In beginning this study, the scientists hypothesized that “the application of organic farming practices is expected to reduce contamination levels in the environment and consequently in wildlife.” They also referenced studies, such as a soil study, that aided in this speculation: “In an analysis of topsoil samples collected across Europe, samples from organic farms showed significantly fewer pesticide residues and in lower concentrations than those from conventional farms … [with] 70 to 90% lower concentrations.”   This study screened for 104 total compounds, 28 of which […]

(Beyond Pesticides, May 8-9, 2024) In its proposal on mushrooms and pet food, the U.S. Department of Agriculture’s (USDA) National Organic Program is following up on recommendations of the National Organic Standards Board (NOSB) to ensure that two areas of organic production are clarified and in compliance with the Organic Foods Production Act (OFPA). The notice raises questions of standards that ultimately grow the organic market while ensuring that the USDA organic label is backed by standards that have integrity and garner the public’s trust. In this spirit, Beyond Pesticides participates in the NOSB review/recommendation process and USDA rulemaking through public comments. [Note: Beyond Pesticides has served on the NOSB for a five-year term (2010-2015) and urges other environmental organization representatives to consider self-nominating for service on the board.] The issues relating to clear standards for mushrooms and pet food have been before the NOSB and in discussion for some time as a part of ongoing efforts to ensure continuous improvement of standards governing the organic sector. While virtually all in the organic community and industry agree that the USDA proposals are needed and long overdue, Beyond Pesticides points to problems in the proposed rule that need correcting: (i) Re. […]

(Beyond Pesticides, May 6, 2024) The pattern of failure to protect the public from pesticides is again brought to public attention by an analysis by Consumer Reports (CR) that effectively updates its previous report released in 2020. The report and its earlier iteration identify deep structural weaknesses with the institutions charged with protecting the public’s health and safety. The health risks outlined by CR in 2020 and related to ongoing pesticide exposure, even at low levels, include cardiovascular diseases, cancers, reproductive dysfunction, respiratory problems (e.g., asthma, bronchitis), neurological impacts (e.g., developmental effects and dementia/Alzheimer’s), and endocrine dysfunction, among others. Previously, the magazine reported, “CR’s experts say the government hasn’t upheld its responsibility to protect consumers [and that] the research used to set [pesticide residue] tolerances is imperfect, and they’re often too high.” CR has cited the U.S. Environmental Protection Agency (EPA), which is primarily responsible for pesticide regulation, for multiple inadequacies. According to the latest CR analysis, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% […]

(Beyond Pesticides, May 1, 2024) According to a new analysis by Consumer Reports, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. A review of seven years of PDP data show that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day, according to Consumer Reports analysis. Consumer Reports contend that U.S. Environmental Protection (EPA) pesticide residue tolerances are too lenient. To better evaluate potential health risks associated with various foods, Consumer Reports applied stricter residue limits than the EPA tolerances (see here for CR’s analytical methodology). Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a function of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. The Consumer Reports results fly in the face of the rosy outlook reported by the USDA in its 2022 […]

(Beyond Pesticides, April 24, 2024) On April 16, 2024, the U.S. Environmental Protection Agency (EPA) posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency’s efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers’ “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, advocates are again questioning EPA’s commitment to fulfilling legal requirements under the Endangered Species Act (ESA) or protecting endangered species and their habitats in the midst of an unprecedented rate of global extinction. ESA is celebrated as one of the most far-reaching conservation laws globally, credited with preventing the extinction of 99 percent of those species the government targets for protection, according to the U.S. Fish and Wildlife Service (USFWS). ESA establishes a framework to categorize species as “endangered” or “threatened,” granting them specific protections. Under ESA, EPA is required to consult with relevant agencies […]

(Beyond Pesticides, April 22, 2024) Today, on Earth Day, the future of the planet and the health of all its inhabitants come into focus from numerous human and ecosystem health perspectives, with particular concern for the health of the next generation—as childhood cancer continues to be a leading cause of death from disease among children. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring. Taking Action in Your Community: On Earth Day, Beyond Pesticides invites communities to join together in its nationwide campaign to convert parks to organic land management practices through the Parks for a Sustainable Future program. Through this program, Beyond Pesticides works with park managers, bringing hands-on horticultural support to eliminate petrochemical pesticides and fertilizers and instead nurture soil organisms to cycle nutrients naturally while creating resilient landscapes that resist weeds, insects, and disease. This program outlines the steps to become a parks advocate and how Beyond Pesticides works with communities committed to safe parks and playing fields for communities, children, and pets. One major impetus for the Parks program are the many studies that find prenatal and early-life exposure to environmental toxicants increases disease susceptibility. For decades, studies have […]

(Beyond Pesticides, April 17, 2024) With headlines drawing public attention to the contamination of drinking water after years of federal government neglect, the U.S. Environmental Protection Agency (EPA) announced on April 10 new standards to reduce public exposure to PFAS, or per- and polyfluoroalkyl substances, commonly referred to as “forever chemicals” because of their persistence. EPA has finalized a National Primary Drinking Water Regulation (NPDWR) for six PFAS, including PFOA and PFOS, which EPA has recognized have no safe level of exposure, regulating new chemicals for the first time since the 1996 amendments to the Safe Drinking Water Act (SDWA). PFAS persistence and bioaccumulation in humans, wildlife, and the environment is due to the strength of a resulting fluorine–carbon atom bond. PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply—among other resources—is ubiquitous worldwide. PFAS is used in everyday products, including cookware, clothes, carpets, as an anti-sticking and anti-stain agent, in plastics, machinery, and as a pesticide. The action was welcomed by environmentalists and public health advocates as an important step but left many concerned that any level of exposure to these chemicals is unacceptable and critical of EPA’s ongoing failure to act despite years […]

(Beyond Pesticides, April 12, 2024) In honor of Earth Month, Natural Grocers® is partnering with Beyond Pesticides for its seventh annual Ladybug LoveSM campaign. Natural Grocers, a longtime leader of the organic movement through national advocacy efforts and rigorous product standards, encourages its communities to pledge to protect beneficial insects and further Beyond Pesticides’ critical mission of converting local parks and playing fields to organic landscape management practices.   Natural Grocers’ annual Earth Month fundraising efforts benefit the nonprofit organization, Beyond Pesticides and its Parks for a Sustainable Future program. Cleaner air, water, and land make for a healthier food supply – a principle Natural Grocers has championed since 1955. Click here to see the campaign from last year. April shoppers at Natural Grocers’ 168 stores are also invited to donate to Beyond Pesticides at checkout. Ladybug Love also features in-store promotions! LADYBUG LOVE & BEYOND PESTICIDES Natural Grocers’ Ladybug Love campaign aims to bring awareness to the precious insects that play a crucial role in the stability of our food supply and regenerative farming. The annual Earth Month fundraising efforts benefit Beyond Pesticides and its Parks for a Sustainable Future program, designed to assist communities in transitioning away from pesticide use at local parks […]

(Beyond Pesticides, April 11, 2024) Scientists are moving forward in testing an agroecological method of “push-pull” pest management (reducing the attractiveness of the target organism and luring pest insects towards a trap) to fight the Asian citrus psyllid (ACP) in Florida orange groves, as it spreads a plant disease known as the pathogenic bacteria huanglongbing (HLB), also known as citrus greening, which is deadly to citrus trees. The disease is spread by the pathogenic bacteria Candidatus Liberibacter asiaticus (CLas).  The chemical-intensive, or conventional, citrus industry is under intense pressure to find alternatives, as synthetic antibiotic use for this purpose has been successfully challenged in court. ACP is the carrier, or vector, for HLB, spreading it through the citrus groves and killing the trees. The chemical-intensive industry has focused on using antibiotics, which the environmental and public health community has rejected because of serious medical concerns associated with life-threatening bacterial resistance to antibiotics used to protect humans. A federal district court decision in December 2023 found illegal the U.S. Environmental Protection Agency’s (EPA) decision to register the antibiotic streptomycin in Florida citrus without adequate review of its impact on endangered species. The streptomycin lawsuit, filed in 2021 by a coalition of […]

(Beyond Pesticides, April 9, 2024) The United States Court of Appeals for the Fifth Circuit, in an opinion authored by Circuit Judge Cory T. Wilson, has vacated an action by the U.S. Environmental Protection  Agency (EPA) that had ordered the Texas-based manufacturer Inhance Technologies, L.L.C. to stop producing plastic containers that leach toxic per- and polyfluoroalkyl substances (PFAS) into pesticides, household cleaners, condiments, and additional products. EPA has taken action after the agency determined that the PFAS created during the fluorination process “are highly toxic and present unreasonable risks that cannot be prevented other than through prohibition of manufacture.” While the court is not challenging EPA’s authority to determine the hazards associated with PFAS exposure to be unacceptable, on a technicality, it is finding that the agency used the wrong section of the Toxic Substances Control Act (TSCA), Section 5, which the court says is focused on new uses. According to the Court, “The EPA is just not allowed to skirt the framework set by Congress by arbitrarily deeming Inhance’s decades-old fluorination process a “significant new use,” even though EPA’s awareness of the PFAS contamination was “new” to the agency and not disclosed by the manufacturer. Even if EPA were […]