(Beyond Pesticides, July 1, 2024) Comments on proposed new dicamba uses are due Friday, July 5 The U.S. Environmental Protection Agency (EPA) is accepting public comments until July 5 on whether it should allow the expanded use of the weed killer dicamba, which has been associated with adverse impacts related to its propensity to drift off of the target application site. The comment period addresses a BASF chemical company proposal for additional food use of a dicamba product on dicamba-tolerant cotton and dicamba-tolerant soybeans. (See Beyond Pesticides’ comments.) This application is similar to Bayer CropScience’s application for XtendiMax®, for which Beyond Pesticides submitted comments in June. The proposed label for BASF’s Engenia® allows for application preplant, at-planting, preemergence, and postemergence (in-crop) for broadleaf weeds. >> Tell EPA to ban use of dicamba and other drift-prone pesticides. The U.S. Supreme Court Reversal This proposal is under consideration on the heels of a U.S. Supreme Court decision on June 28 that reverses a 40-year old decision in Chevron v. Natural Resources Defense Council, which created a deference to federal agencies in the rulemaking process. In the dissent to this 6-3 decision of the court, the dissenters focus on the role of executive […]

(Beyond Pesticides, June 14, 2024) The influence of the chemical industry over public policy and regulation, especially in agriculture, is glaringly obvious and has little popular support, yet no one can seem to do anything about it. Numerous analyses have detailed the ways this influence is applied—through lobbying and political donations including dark money; industry experts named to regulatory agency scientific advisory boards; and the massive public relations machines that create and sustain public uncertainty using the tobacco industry playbook revealed by Naomi Oreskes and Erik Conway in their 2010 book Merchants of Doubt. A more insidious tendril of industry influence is explained in U.S. Right to Know’s (USRTK) report, released this month, on pesticide manufacturers’ infiltration of the Entomological Society of America (ESA). The report, “Anatomy of a science meeting: How controversial pesticide research all but vanished from a major conference,” examines the ESA’s 2023 annual meeting—its program, sponsorships, presentations, panelists, poster sessions, meet-and-greets, budget, revenue sources, and other aspects of the event. What is revealed is a systematic and comprehensive industry presence throughout the society and its meeting. A direct consequence is the near-elimination of any scientific presentations addressing the effects of neonicotinoid pesticides on insects, particularly bees. […]

(Beyond Pesticides, June 4, 2024) A study published in the most recent edition of the journal Ecotoxicology and Environmental Safety documents for the first time the presence of the herbicide glyphosate in human sperm. The study looked at 128 French men with an average age of 36 years who tested positive for glyphosate in their blood. Seventy-three out of the 128 men were found to also have glyphosate in their seminal plasma. Not only that, the amount of glyphosate in seminal plasma was nearly four times higher than what was detected in the blood.   Methods  The study involved a population of 128 infertile French men from whom seminal and blood plasma samples were collected. The study was conducted at the “Pole Santé Léonard de Vinci” medical center, located centrally near Tours, France. This region is recognized for its urban characteristics as well as being a major agricultural hub, particularly for grain and wine production. The study authors note, “This area reflects the common herbicide exposure in France” and the district ranks third highest in terms of pesticide purchases. While additional qualitative data was collected, only 47 of 128 participants fully completed a questionnaire about their profession, diet (organic or […]

(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 31, 2024) Among the many promises that have been made by agribusiness to farmers and consumers, the glories of crops genetically engineered (GE) to resist pests stand out. GE tools—genes—were touted as “natural,” and promised to reduce the use of toxic pesticides. The first such plants incorporating DNA or RNA from other organisms hit the market in the 1990s. Today more than 70% of all GE organisms are engineered to tolerate herbicides, and the overwhelming majority of corn, soybean and cotton varieties are engineered to to be toxic to insects. See Beyond Pesticides’ backgrounder on GE here. Despite a dramatic increase in the use of herbicides and the fast development of weed and insect resistance to plant incorporated pesticides, this month the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) jointly released a document entitled “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology.” It responds to a 2022 executive order by President Biden to “accelerate biotechnology innovation” and “support the safe use of biotechnology products” by using a “science- and risk-based, predictable, efficient, […]

(Beyond Pesticides, March 6, 2024) With over 2,500 pet deaths and 900 reports of adverse effects to people, an Office of Inspector General (OIG) report, published on February 29, 2024, reveals multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP), citing inadequate safety reviews of Seresto pet collars. The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data… No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars—the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid—proven to have adverse effects on the endocrine system as […]

(Beyond Pesticides, February 26, 2024) Beyond Pesticides today launched an action to stop a nationwide campaign by chemical manufacturers to shield themselves from liability cases filed by those who have been harmed by pesticide products. As widely reported, Bayer/Monsanto has been hit with numerous jury awards and settlements totaling billions of dollars for adverse health effects associated with their weed killer glyphosate (RoundupTM). After unsuccessfully seeking U.S. Supreme Court review of two of these cases, the industry is now pushing legislation in state legislatures that will shield them from future liability litigation. This is not the first time that the pesticide and toxic chemical industry has sought protection from the states after losing in the highest U.S. Court. After the Supreme Court upheld the right of localities to restrict pesticides more stringently than the U.S. Environmental Protection Agency and state regulatory agencies in Wisconsin Public Intervenor v. Mortier (501 U.S. 597, 1991), the industry went to every state legislature in the country to seek state preemption of their local jurisdictions’ authority to restrict pesticides. They were successful in putting state preemption laws in place in 43 states and have since added another.   Having failed in the courts, history is […]

(Beyond Pesticides, February 23, 2024) The latest string of billion-dollar plaintiff judgments against Bayer/Monsanto, the maker of Roundup™ with active ingredient glyphosate, does not yet signal a capitulation by Bayer or a win for public health or the environment in the United States. A jury award of $2.25 billion, the largest to-date, was handed down in Philadelphia in January. As Beyond Pesticides reported previously, Monsanto has a long history of challenging scientific findings on Roundup/glyphosate and evidence of harm to human health, the environment, and crops themselves (see resistant super weeds here and here), as it seeks to avoid liability claims by those suffering from cancer.  Bayer Looking to State Legislatures for Protection from Lawsuits  As result of its failure in quash lawsuits, Bayer has moved its case to state legislatures, where it is seeking the adoption of statutes that preempt liability claims by damaged parties.  As reported by Beyond Pesticides, a rash of state legislation has been introduced in Idaho, Iowa, Missouri, and Florida, which would block plaintiff liability claims when pesticide products, like Roundup, cause harm. The chemical industry pushes the notion that the registration of its pesticide products with the U.S. Environmental Protection Agency (EPA) is a […]

(Beyond Pesticides, Feb 22, 2024) The Idaho Senate failed to pass SB 1245 last week which would have provided legal protection to pesticide manufacturers from “failure-to-warn” liability. This legal framework has been pivotal not only for plaintiffs, who are typically users of a toxic product, seeking redress from exposure to glyphosate-based herbicide products such as Roundup, but can also potentially extend to any toxic pesticide products. Similar bills have recently been introduced in the Iowa, Florida, and Missouri state legislatures as petrochemical pesticide industry actors such as Bayer face billions of dollars in legal settlements from victims of pesticide injury. While the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) registration process permits the labeling of products with pesticidal claims based on compliance with testing requirements, the state legislation would establish EPA-authorized pesticide labels as definitive evidence that cannot be challenged in a court of law. The Idaho legislation, SB 1245, was introduced in January in the state Senate by Senator Mark Harris, who represents Soda Springs County, which has North America’s largest elemental phosphorus mine (phosphorus is a critical ingredient in developing glyphosate). Proponents of SB 1245 argue, “[This bill] protect[s] companies that produce safe pesticides critical to agriculture in […]

(Beyond Pesticides, December 19, 2023) Last week, farmworker organizations and Beyond Pesticides, represented by the Center for Food Safety, filed a petition with the U.S. Environmental Protection Agency (EPA) urging that the weed killer glyphosate be removed from the market. The petition cites 200 studies, which represent a fraction of the independent scientific literature on the hazards of glyphosate and formulation ingredients of glyphosate products. This action follows previous litigation in 2022 in which a federal court of appeals struck down EPA’s human health assessment, finding that the agency wrongfully dismissed glyphosate’s cancer risk. The farmworker groups petitioning include Farmworker Association of Florida, Organización en California de Lideres Campesinas, Alianza Nacional de Campesinas, and the Rural Coalition.   Meanwhile, verdicts against glyphosate’s manufacturer, Bayer, continue to pile up with a December jury verdict in Pennsylvania awarding $3.5 million and a November jury in Missouri ordering $1.56 billion to be paid to four plaintiffs. All link their cancer to use of the Roundup. Bayer has lost almost all of the cases filed against it for compensation and punitive damages associated with plaintiffs’ charge that its product (previously manufactured by Monsanto) caused them harm.  The petition summarizes its purpose and justification as […]

(Beyond Pesticides, December 14, 2023) It has been reported that the U.S. Environmental Protection Agency (EPA) is again considering allowing the use of the highly neurotoxic, carbamate insecticide aldicarb for use in Florida citrus, 13 years after the agency and the chemical’s manufacturer, Bayer Crop Science, announced that it was being banned (technically voluntarily canceled). A version of the current EPA proposal and the resource-intensive review process in EPA’s Office of Pesticide Programs—all being done at taxpayers’ expense—was rebuffed, first by the Florida Department of Agriculture and Consumer Services (April 2021), then by a U.S. Court of Appeals (June 2021). Internal EPA emails, as reported in The New Lede (November 21, 2023), expose the extent to which the agency’s science and political staff have tried to downplay aldicarb’s adverse health and environmental outcomes in order to meet the EPA’s broad, and often described as loose, risk parameters.  This Daily News piece on aldicarb is part of an ongoing story of the politicization of science by political appointees to an agency that is charged with protecting public health and the environment. The degree to which agency scientific staff are complicit in advancing agency positions that are not supported by the scientific […]

(Beyond Pesticides, October 16, 2023) After six years, the Environmental Protection Agency (EPA) finally responded to a citizen petition requesting that the agency evaluate complete formulations of pesticide products, not just the ingredients the manufacturer claims attack the target pest (so-called “active” ingredients). EPA’s response: No. Nowhere in EPA’s denial of the need for a more robust toxicological analysis is the problem more evident than in its refusal to require analyses of the so-called “inert ingredients” or “adjuvants” included in various formulations of pesticide products. The citizen petition [see more background] was followed by a lawsuit for the same purpose in 2022. Inerts and formulants are substances that enhance the distribution or adhesion of the active ingredient; adjuvants enhance the effectiveness of the active ingredient. These terms suggest that those chemicals have no effect on anything in the area where the pesticide is applied—a wildly inaccurate implication. At least as early as 1987, EPA had recognized that some inerts and adjuvants were “of toxicological concern,” yet it still requires very few toxicological tests of whole-formula pesticides or their purportedly inactive components. EPA responded to the petition as follows: “[T]he Agency appropriately assesses, as part of its review, the impacts to […]

(Beyond Pesticides, September 19, 2023) Farmworkers in Paarl, South Africa took to the streets on Friday, September 8, demanding an end to the indiscriminate importation and use of pesticides, herbicides, and fungicides containing substances prohibited by the European Union (EU). This protest is part of a broader global trend of outcry against systemic issues of environmental racism that disproportionately burden communities with environmental and health risks.   Organized by the Women on Farms Project, the protesters marched to the headquarters of Bayer. The German pharmaceutical, biotechnology, and pesticide company, responsible for producing and exporting agrochemicals known to be toxic to ecosystem and human health, has previously faced multiple lawsuits, including a multimillion-dollar one linking their glyphosate weed killer products (Roundup®) to non-Hodgkin Lymphoma. At the Bayer office, the protesters presented a memorandum demanding an end to the importation and use of EU-prohibited substances.    Protesters sought to expose the hypocritical tactics European agrochemical companies use to sell products in developing nations, even when those products are deemed unsafe in their home countries. Numerous farmworkers, like victim-turned-activist Antie Dina, spoke out about their health issues from petrochemical exposure. In her talk, Dina emphasizes that, “… enough is enough, we do not want any […]

(Beyond Pesticides, May 5, 2023) Low level exposure to pyrethroid insecticides found in common pesticide brands like RAID and ORTHO result in neurodevelopmental damage to laboratory animals, reinforcing evidence of harm found in epidemiological studies on human exposure to these chemicals. According to research published in PNAS Nexus, mice exposed to the pyrethroid deltamethrin displayed atypical behavior similar to humans with developmental disorders. “We are not saying these mice have autism or that they have ADHD. That’s not the goal here,” said James Burkett, PhD, study coauthor and assistant professor of neuroscience in the UToledo College of Medicine. “What we are saying is that something in their brain has been altered by this exposure and it’s resulting in the same kinds of behaviors that we see in children with autism.” Scientists arrived at this determination by exposing a group of mouse mothers to consistent low levels of deltamethrin in their food during preconception, pregnancy, and lactation. The study notes that the amount of pesticide provided was “well below the benchmark dose for regulatory guidance.” A separate control group was given no pesticide in its food. Offspring from the female mice were then put through behavioral tests on social behavior, restrictive […]

(Beyond Pesticides, April 5, 2023) A collective of Mayan beekeepers (Colectivo de Comunidades Mayas) in Mexico are implicating chemical industry giant Bayer/Monsanto in a massive die-off of more than 300,000 bees among their combined apiaries. According to Mexico News Daily, the total value of losses represent a staggering $663,000 U.S. dollars (12 million pesos). The incident is the latest instance of the pesticide  and agrichemical industry setting up shop in a local community and wrecking the health of the local ecology. Mayan beekeepers explain that Bayer/Monsanto recently started operations on a ranch near Crucero Oxá in the southern Mexican state of Campeche. A local businessman placed the 50 hectare ranch on loan to the company. Since that arrangement, the company has aerially sprayed row crops like corn and soy with undisclosed chemicals. “One of Bayer’s engineers or technicians allowed us to take samples from one of their crops after the bees started to die,” said beekeeper José Manuel Poot Chan, to the newspaper La Jornada Maya. “We are exhausting all possible legal instances, while members of the Welfare Ministry already came to offer humanitarian social aid to cover part of the damages.” Beekeepers suspect that the company is using the […]

(Beyond Pesticides, January 31, 2023) Glyphosate exposure induces oxidative stress in the body, a key biomarker known to heighten an individual’s risk of cancer, according to research published in the Journal of the National Cancer Institute by a team of scientists from the National Institutes of Health. The findings, which tracked study participants’ past use of glyphosate and exposure levels through urine, are particularly concerning in light of recent data showing that four out of five (81.6%) U.S. residents have detectable levels of glyphosate in their bodies. Despite these concerning data, evidence of widespread exposure to a carcinogen has so far failed to sway regulators at the U.S. Environmental Protection Agency, necessitating meaningful change by elected officials to reform pesticide regulation. Scientists began with the determination from the International Agency for Research on Cancer (IARC) that there is epidemiological evidence associating glyphosate with blood cancers like non-Hodgkin lymphoma, and strong evidence of carcinogenicity in laboratory animal research brought on by genotoxicity (DNA damage) and oxidative stress. “Oxidative stress occurs when the production of reactive oxygen species (ROS) and other free radicals exceeds the body’s antioxidant defense mechanisms, causing damage to DNA, proteins, and lipids,” the study explains. This process can […]

(Beyond Pesticides, December 16, 2022) A report released last week — Merchants of Poison: How Monsanto Sold the World on a Toxic Pesticide — exposes not only Bayer/Monsanto malfeasance in its “promotion” of its glyphosate-based herbicide products, including the notorious Roundup®, but also, the broader landscape of corporate efforts to white- or green-wash products that companies know are harmful to people and the environment. The report was issued by U.S. Right to Know (USRTK, a nonprofit investigative research group focused on promoting transparency for public health), Friends of the Earth (FOE), and Real Food Media. It carries the pithy subtitle, “A case study in disinformation, corrupted science, and manufactured doubt about glyphosate,” a description cited by the Friends of the Earth press release as “at the core of the pesticide industry’s public relations playbook.” Beyond Pesticides welcomes this report, which comports with much of our previous coverage of the pesticide industry’s egregious misbehavior, and of glyphosate, the world’s most widely used herbicide. FOE calls the report the “first comprehensive review” of the Bayer/Monsanto “defense strategy” employed in attempts to deny science, manufacture doubt, and discredit critics who have researched, reported on, and/or advocated against the company’s flagship glyphosate products because […]

(Beyond Pesticides, October 12, 2022) The U.S. Environmental Protection Agency (EPA) is asking a federal court for permission to go back and reconsider its decision to reapprove use of the highly hazardous herbicide paraquat, according to a filing submitted by the agency late last month. Advocates see the move as encouraging, since meaningful EPA action on this Parkinson’s-linked chemical is long overdue. Last year, advocates condemned the Biden Administration for its reapproval of the weed killer with fewer protections than those proposed by the Trump Administration, marking a deeply concerning sign for pesticide reform campaigners looking to the administration for positive change. EPA’s request is the result of a legal challenge brought by the California Rural Legal Assistance Foundation, Earthjustice, Farmworker Association of Florida, Pesticide Action Network, and the Michael J. Fox Foundation for Parkinson’s Research.  The groups argued that the agency’s decision to reregister paraquat was not legal based on substantial evidence that the chemical poses unreasonable risks to human health and the environment. While EPA made its initial decision to reapprove paraquat in the late days of the Trump Administration, it was under the Biden Administration that the agency reversed a proposed ban on aerial use, permitting broad-scale […]

(Beyond Pesticides, September 30, 2022) In late September, the U.S. Environmental Protection Agency (EPA) announced the withdrawal of its Interim Decision on glyphosate, the active ingredient in multiple herbicides, most notably Monsanto’s (now Bayer’s) Roundup. The action follows a slew of developments related to the herbicide, including: the 2015 International Agency for Research on Cancer’s declaration of its carcinogenicity; legal judgments and massive rewards to victims who developed cancers after chronic exposures; advocate efforts to get EPA to recognize the dangers of, and curtail, its use; and pushback from industry — most of the latter two coming in the form of litigation. The withdrawal of that Interim Decision means, on the ground that this harmful compound can continue to be used until a next regulatory review decision by EPA. Beyond Pesticides has long been engaged in education on and advocacy against glyphosate use, and was a plaintiff in the 2020 lawsuit, with the Center for Food Safety (CFS), et al., against EPA for this 2020 Interim Decision (ID). Under FIFRA (the Federal Insecticide, Fungicide and Rodenticide Act) each pesticide must be reviewed by EPA every 15 years “to ensure that existing pesticide products continue to perform their intended function without […]

(Beyond Pesticides, May 27, 2022) In a U.S. Environmental Protection Agency (EPA) court document filed on May 16, the agency signaled potential changes to the labeling it requires for “over the top” (OTT, or post-emergent) herbicides containing dicamba, a very problematic pesticide. The filing — in U.S. District Court for the District of Arizona, where EPA currently faces litigation about its 2020 dicamba registrations — comes as a result of Bayer, Inc.’s March 2022 proposed amendments to EPA registration for its XtendiMax herbicide, which contains dicamba and glyphosate. Beyond Pesticides has covered the dicamba saga for years, including the EPA Office of the Inspector General’s critical 2021 report citing an abandonment of science and assault on agency integrity for EPA’s dicamba decisions during the Trump years. Dicamba has been linked to cancer, reproductive effects, neurotoxicity, birth defects, and kidney and liver damage. It is toxic to birds, fish, and other aquatic organisms, and is known to leach into waterways after application. Dicamba also causes serious damage to non-GE (genetically engineered), non-target plants, damaging habitat and food sources for various organisms, especially for birds and insects. According to Progressive Farmer, EPA is currently considering some dicamba use restrictions after Bayer submitted them to […]

(Beyond Pesticides, May 25, 2022) Earlier this month, the U.S. Department of Justice urged the Supreme Court to deny a request by Bayer to review a verdict that found the corporation liable for damages from the use of its Roundup (glyphosate) herbicides. Now, Bayer is using proxy organizations to place pressure on the Biden Administration and Justice Department to rescind its decision. Alongside a range of chemical industry umbrella groups, many of which—like Croplife America—Bayer is a member of, a letter was sent to President Biden expressing “grave concern” about the opinion filed by Solicitor General Elizabeth Prelogar. Among a range of baseless claims, the agrichemical industry is deflecting lower court findings on the hazards and cancer risk of their products with the claim that their toxic chemicals are needed to feed the world, as crops shipments from Ukraine have been halted during the ongoing war. “The agrichemical industry has long tried to sell the idea that their toxic pesticides are needed to feed the world, as if to suggest that their motives are altruistic when, in fact, they have shown a callous disregard for life and a sustainable future,” said Jay Feldman, executive director of Beyond Pesticides. ” We […]

The organic solutions to problems highlighted in the latest issue of Pesticides and You—based on the importance of healthy ecosystems and public health protection—are within reach, and the data creates an imperative for action now that phases out pesticides within a decade, while ensuring food productivity, resilient land management, and safe food, air, and water. (Beyond Pesticides, April 15, 2022) The current issue of Pesticides and You, RETROSPECTIVE 2021: A Call to Urgent Action, is a look at a year of science, policy, and advocacy that informs both the existential problems that the U.S. and the world are facing due to toxic pesticide dependency, and solutions that can be adopted now. The information in this issue captures the body of science that empowers action at the local, state, and federal level, and provides a framework for challenging toxic pesticide use and putting alternatives in place. The issue finds that 2021 was a pivotal year in both defining the problem and advancing the solution. This year in review is divided into nine sections that provide an accounting of scientific findings documenting serious pesticide-induced health and environmental effects, disproportionate risk to people of color and those with preexisting conditions, regulatory failures, at the same time […]

(Beyond Pesticides, December 21, 2021)  A research team undertaking a review of industry-conducted glyphosate safety studies submitted to EU (European Union) regulators shows that most of the research fails to meet current international standards for scientific validity. The researchers find that of the 11 reviewed studies, which were submitted to regulators by Bayer AG (now owner of the Monsanto “Roundup” brand of glyphosate herbicide) and several other chemical companies, only two are scientifically “reliable”; six others are deemed “partly reliable,” and the remaining three, “not reliable.” These results go, in part, to the age of some of the studies (see below); but they also underscore the point Beyond Pesticides has made for years. Regulators, whether in the UK, the U.S., or anywhere else, ought not be relying solely and without adequate auditing on industry-generated and -funded safety research in making safety determinations that underlie regulations impacting the well-being of millions of people (and other organisms), never mind the environment writ large. The report, from a team working out of the Institute of Cancer Research (ICR) at the Medical University of Vienna, is timely: the European Food Safety Authority (EFSA) and European Chemicals Agency (ECHA) are currently considering whether or not […]