(Beyond Pesticides, July 21, 2016) An investigative report released yesterday by Center for Biological Diversity (CBD) concludes  that, over the past six years, the U.S. Environmental Protection Agency (EPA) has approved nearly 100 pesticide products with chemical mixtures that elevate the formulations’  toxicity, but are not specifically evaluated  by the agency. CBD finds that these formulations add  more stress to already-jeopardized pollinators and rare plants. The report Toxic Concoctions: How the EPA Ignores the Dangers of Pesticide Cocktails, highlights a long-running blind spot within EPA’s pesticide evaluation program, which Beyond Pesticides has long sounded the alarm on: the risk associated with combining mixtures of different pesticide active ingredients, which independent science shows may be more toxic than a single active ingredient by itself, also known as pesticide synergism. The mixtures occur as a result of multiple ingredients in individual products or  because of exposure to multiple pesticide product residues in food, air, water, and land areas, such as lawns, playing fields, and parks. “It’s alarming to see just how common it’s been for the EPA to ignore how these chemical mixtures might endanger the health of our environment,” said Nathan Donley, Ph.D., a scientist with the CBD, and author of […]

(Beyond Pesticides, July 20, 2016) Farmers and land managers across the U.S. are being encouraged to plant pollinator habitat adjacent to farmlands to provide shelter and food for pollinator species. But according to a new study published last week, these conservation areas still put bees at risk for pesticide contamination, as they fail to provide spatial or temporal relief. This study emphasizes that meaningful solutions to reversing pollinator decline does not lie with focusing on planting pollinator habitat, but ensuring that these refuge areas are free from pesticide contamination, highly toxic to bees and other pollinators, and reducing the reliance on toxic chemical inputs in agriculture and other landscapes. The study, “Neonicotinoid-contaminated pollinator strips adjacent to cropland reduce honey bee nutritional status,” finds that pollinator habitat adjacent to agricultural areas not only becomes a source for pesticide, especially neonicotinoid, exposures, but also poses significant risk to honey bees. The authors, Christina Mogren, PhD, and former USDA entomologist, Jonathan Lundgren, PhD, initially sought to study whether increasing forage by planting pollinator habitat in an agricultural-dominated region would serve to buffer against the harmful effects of plant-incorporated pesticides. However, the authors note that it soon became apparent that the unintended consequence was […]

(Beyond Pesticides, July 19, 2016) Exposure to common pesticides at levels often found in the environment can have subtle but significant impacts on the behavioral health of fish, amphibians and other aquatic invertebrates. According to researchers at Northern Arizona University, who analyzed data from nearly 40 experiments to reach their conclusion, fish and amphibians swam 35% slower and were 72% less active after pesticide exposure. Chemical Class Type Example Pesticides Carbamates Insecticide Carbaryl, Aldicarb Organochlorine Insecticide DDT, Endosulfan, Chlordane Organophosphates Insecticide Diazinon, Chlorpyrifos Organotins Biocide Tributyltin Phosphonoglycines Herbicide Glyphosate, Glufosinate Pyrethroids Insecticide Permethrin, Bifenthrin, Esfenvalerate Triazines Herbicide Atrazine, Simazine The study, published in Science of the Total Environment, found that the overall effect on aquatic wildlife varied based on the chemical class the animals encountered. While pyrethroids, carbamates, and organophosphates resulted in a significant decrease in swim speed, triazines and phosphonoglycines showed no overall effect. Pyrethroids, carbamates, organophosphates, organochlorines, and organotins decreased activity, while phosphonoglycines had no overall effect, and triazines actually increased activity. “I didn’t think that we would see [an effect] across such a wide range of pesticides so consistently, but we did,” said study co-author, Catherine Propper, PhD to KNAU, “and that leads to some concerns about […]

(Beyond Pesticides July 18, 2016) A  review of the scientific literature links  glyphosate, one of the most popular weed killers in the U.S. and the active ingredient in Roundup, to a wide range of diseases through a mechanism that modifies DNA functioning, adding a new even more troubling dimension to the herbicide’s cancer classification by the International Agency for Research on Cancer. According to the most recent review, Glyphosate pathways to modern disease V: Amino acid analogue of glycine in diverse proteins, conducted by independent scientists Anthony Samsel, Ph.D. and Stephanie Seneff, Ph.D., a scientist at Massachusetts Institute of Technology (MIT), glyphosate acts as a glycine analogue that  incorporates into peptides during protein synthesis. In this process, it alters a number of proteins that depend on conserved glycine for proper function. According to the authors, glyphosate substitution for glycine correlates with  several diseases, including diabetes, obesity, asthma, Alzheimer’s disease, amyotrophic lateral sclerosis (ALS), and Parkinson’s disease, among others. Glycine, the smallest amino acid commonly found in proteins, has unique properties that support flexibility and the ability to anchor to the plasma membrane or the cytoskeleton.  This new direct biological evidence, taken together with correlational data, make a compelling case that […]

(Beyond Pesticides, July 15, 2016) A toxic algae bloom that has expanded throughout Florida’s largest freshwater body, Lake Okeechobee, and around south Florida beaches, has created vast problems for residents, compelling Governor Rick Scott to declare an environmental state of emergency.  However, the Governor’s  declaration fails to address the root of the problem””including the extreme levels of nutrient buildup and the dangerous amount of phosphorous and nitrogen found in the water, caused by excess fertilization runoff from both chemically-intensive agricultural and residential sources. Instead, Gov. Scott has placed blame on the federal government due to their lack of proper maintenance on the Herbert Hoover Dike, which prevents Lake Okeechobee from overflowing into nearby water sources. While this is certainly problematic, the crux of the issue stems from the polluted water itself, which allows bacteria to grow swiftly when nutrients like phosphorus and nitrogen are abundant. “We just are putting way too much nitrogen and phosphorus into our natural waters, and they respond,” Florida Atlantic University research professor, Bill Louda, Ph.D. told CBS news. A few weeks ago, the U.S. Army Corps of Engineers, Jacksonville District, as a means of flood prevention,  released  the lake’s water  into local canals  with a […]

(Beyond Pesticides, July 14, 2016) A funding bill (H.R. 5538) for the Environmental Protection Agency (EPA) and Interior Department is receiving pushback from conservation groups, environmental lobbyists, and workers’ rights advocates for containing dozens of controversial amendments, including  one that would strip funding for parts of the Agricultural Worker Protection Standard (WPS), which establishes many  protections for  those  in the country who experience the highest and most dangerous pesticide exposure — farmworkers. Title IV, Section 437 of H.R. 5538 states that, “None of the funds made available by this or any other Act may be used to implement or enforce, or to require States to implement or enforce, the provisions of 40 CFR 170.311(b)(9) as published in the Federal Register on November 2, 2015.” The provisions of 40 CFR 170.311(b)(9) refer to the WPS revisions passed in 2015, which had previously not been updated for over 20 years. The revisions are designed to provide at least some protections from pesticide exposure to farmworkers and their families is scheduled to effect in  December 2016. Historically, farmworker advocates have criticized  WPS as woefully inadequate in protecting the health of agricultural workers, but these new revisions strengthen the standards through increased training for […]

(Beyond Pesticides, July 8, 2016) Researchers at the University of Montana (UM) recently released a study that found a lack of government data and accountability on  the use of herbicides on public lands to kill invasive and non-native plants. The report raises serious questions about the widespread management practice, which the researchers say may be causing more harm than good. UM researchers, Cara Nelson, Ph.D. and Viktoria Wagner, Ph.D., along with two researchers from Canada, looked at government agencies and agricultural statistics companies in the U.S., Canada, and Mexico to find their data. The study found that the government agencies in Canada and Mexico kept no archived database of herbicide usage for invasive plant management. In the U.S., five out of seven agencies that were contacted by the researchers tracked herbicide usage, and only four of those agencies shared their data. These agencies include the Bureau of Indian Affairs, Bureau of Land Management, Fish and Wildlife Service, and National Park Service. The U.S. Forest Service, which oversees 193 million acres in the U.S., declined to share its data on herbicide use. The report found that even the agencies that did share their data did not consistently archive information on the […]

(Beyond Pesticides, July 6, 2016) Unable to come to a formal decision on glyphosate, the European Commission has issued a limited license extension for  glyphosate,  the pesticide in Monsanto’s flagship product Roundup. The decision also comes with some restrictions, including obligations for member states to minimize use on playgrounds, and a ban on formulations with the ingredient POEA. The  18-month interim license will allow glyphosate-containing products to remain on the market until the European Chemicals Agency rules  on glyphosate’s safety, an action  due by the end of 2017. According to the European Commission, “Despite repeated efforts from the Commission to address concerns expressed about the re-approval of glyphosate, Member States were not prepared to take responsibility for a decision  as no qualified majority was reached”¦” Debate has been raging in Europe about the continued use of glyphosate in light of the 2015 classification by the World Health Organization’s (WHO) International Agency for Research on Cancer (IARC) of glyphosate as a “probable human carcinogen.” However, confusion peaked when a few short months later the European Food Safety Authority (EFSA) published its report finding that glyphosate is  “unlikely to pose a carcinogenic hazard to humans.” However, EFSA’s report is  limited in that […]

(Beyond Pesticides, June 27, 2016) A new report released last  week by the Organic Seed Alliance (OSA) found that the supply of organic seeds is not keeping up with the rising demand for organic products. The organic sector grew 11 percent between 2014 and 2015, with sales last year totaling $43 billion. The United States Department of Agriculture (USDA)’s National Organic Program (NOP) does require the use of organic seed when commercially available, but because the organic seed sector was almost nonexistent when the program began, it is still working to meet demand. In cases where organic seeds are not commercial available, organic farmers are allowed to turn to conventional seed alternatives. According to OSA’s State of Organic Seed report, funded by the Clif Bar Family Foundation’s Seed Matters Initiative, the UNFI Foundation, and New Belgium Brewing Company, the biggest organic operations actually use a relatively small amount of organic seed. They found that vegetable farmers that grow on less than ten acres use, on average, 75 percent organic seed, while growers that farm over 480 acres use only 20 percent organic seed. The authors of the report surveyed 1,365 organic farms, 16 seed companies, 46 researchers and 22 accredited […]

(Beyond Pesticides, June 24, 2016) The U.S. Department of Agriculture (USDA), during its Pollinator Week Festival at the “People’s Garden” on Friday, has shut out environmental public interest groups that are advocating pesticide restrictions to protect bees. Instead, the agriculture agency is teaming up with other federal agencies and chemical industry groups that advocates say have been tone deaf to beekeepers’ pleas for federal government action. This new controversy emerges in the midst of an escalating pollinator crisis with 44% bee colony losses in the last year. Advocates, who bring the voice of independent science and point to the dangers of bee-toxic neonicotinoid insecticides as a major contributor to the decline in pollinator populations, have been disinvited to the event. Meanwhile, the Pollinator Partnership, an organization closely affiliated with the chemical industry (Bayer, Syngenta, BASF, CropLife, have all been previously listed as sponsors) will be in attendance. Groups like Beyond Pesticides, which bridges environmental, consumer and farm interests, have participated for several years in the Festival. “The foundation for a constructive dialogue between federal agencies and the public regarding the decline of our critical pollinator populations rests upon the free exchange of information and viewpoints,” said Jay Feldman, executive director […]

(Beyond Pesticides, June 22, 2016) In a ruling that organic advocates say is critical to the integrity of the USDA organic label, a U.S. District Court judge found Monday that the U.S. Department of Agriculture (USDA) violated public process when it decreed that pesticide-contaminated compost is allowed in organic production. Three groups that bridge environmental, consumer, and farmer interests sued USDA for ruling that green waste compost, which comes from lawn clippings and plants, may contain levels of the insecticide bifenthrin and other pesticides that have not been approved for use in organic systems through proper public hearing and comment procedures. The case focused principally on whether USDA, in failing to conduct a formal public review, was operating “at its whim.” The court found that is exactly what USDA did and ordered the agency to stop allowing the use of contaminated compost by August 22, 2016. U.S. District Judge Jacqueline Scott Corley of the Northern District of California found that USDA’s National Organic Program (NOP) operated without the required notice and comment. She explained, “the reach of the Agency’s  new rule stretches beyond bifenthrin and instead allows green waste or green waste compost used in organic production to contain any […]

(Beyond Pesticides, June 17, 2016) The pesticide industry has weakened and delayed pesticide reforms and is shaping new state pollinator “protection” plans nationwide that do little to protect bees, according to a new Friends of the Earth report.  The report is being released in advance of  Pollinator Week (June 20-26, 2016), as people assemble to ask for improved protection for pollinators. The investigation, Buzz Kill: How the Pesticide Industry is Clipping the Wings of Bee Protection Efforts Across the U.S., reveals an array of pesticide industry tactics to slow urgently needed pollinator protection measures at federal and state levels. The report details how new state pollinator protection plans, many still unfinished, have been heavily influenced by pesticide industry interests. According to the report, industry is spending hundreds of thousands of dollars on lobbying to delay state and federal action on the chemicals they manufacture. As a result, state pollinator protection plans across the U.S. are falling short in several ways, including: State pollinator protection plans currently provide more protections for pesticides and pesticide users than for bee keepers and bee colonies. Pesticide industry influence is pervasive throughout states’ legislative and regulatory planning efforts. Plans lack metrics to measure effectiveness, improvement […]

(Beyond Pesticides June 13, 2016) A federal judge in California handed down a decision last week agreeing with the Environmental Protection Agency’s (EPA) that it has no responsibility under federal pesticide law to complete rulemaking on the disclosure of hazardous ingredients in pesticide products. That means that if the decision stands EPA will be allowed to keep the public in the dark on the full list of toxic ingredients in pesticides registered by the agency. A lawsuit filed by the Center for Environmental Health, Beyond Pesticides, and Physicians for Social Responsibility argues that EPA fails to protect consumers from “inert” ingredients found in pesticides. U.S. District Judge William Orrick stated in his ruling,“The EPA has no mandatory duty to require disclosure of “inert” ingredients in pesticides, even if those ingredients qualify as hazardous chemicals under separate statutes.” Advocates have said for decades that people and communities cannot make informed decisions on pesticide products without full disclosure of all product ingredients and that the stated proprietary interests of chemical manufacturers is bogus, given the burgeoning market of pesticide products exempt from registration under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) 25(b) provision, which are required to disclose all ingredients. An […]

(Beyond Pesticides, June 10, 2016) A proposal for a temporary ‘technical extension’ of the EU approval of the herbicide glyphosate failed to secure the support of a majority of EU governments at a meeting of the EU standing committee on plants, animals, food and feed on Monday. This action may force the withdrawal of the herbicide, widely sold as Monsanto’s Roundup, from shelves if no decision is reached by the end of the month, when its license expires. After a proposal to renew the license for glyphosate for up to 15 years failed to win support in two meetings earlier this year, the EU executive offered a limited 12 to 18 month extension to allow time for further scientific study. Yet, despite this compromise, the proposal failed to win the support of member states representing at least 65% of the EU’s population, which is needed for adoption, an EU official told The Guardian. Seven member states abstained from Monday’s vote, 20 backed the proposal and one voted against, a German environment ministry spokeswoman said. According to the news source, Germany was among those that abstained from Monday’s vote. Of note is that Bayer, the German chemical company, recently offered to […]

(Beyond Pesticides, June 9, 2016) The U.S. Congress passed a bill Tuesday to reform the Toxic Substances Control Act (TSCA) of 1976, the national law that regulates industrial chemicals, but in the process took away the right of state governments to adopt more stringent standards than the federal government. A Senate voice vote late Tuesday passed the bill, following a House vote in late May. The bill will now go to President Obama’s desk for signature or veto, but it is likely that he will sign it into law. Congress has taken steps to address the vast shortcomings of the law to protect human health and safety, and  in the process has created opportunities for serious delays and restrictions on states’ ability to enact their own toxic chemical regulations.  As the bill heads to President Obama, environmental advocates are concerned that they will lose an important tool in the fight for public protections —with the adoption of federal legislation that will  diminish the right of states and communities to establish protective laws, regulations, and standards in the face of involuntary toxic chemical exposure. Under  current TSCA law, around 64,000 chemicals are not subject to environmental testing or regulation by the […]

(Beyond Pesticides, June 7, 2016) A wholesale change in agricultural practices is necessary to ensure protection of human health and the environment over the long-term, according to a wide-ranging report authored by the International Panel of Experts on Sustainable Food Systems (IPES), “a fully independent panel, without financial or organizational ties to any corporations, governments or intergovernmental agencies.” The report, From Uniformity to Diversity, calls for a paradigm shift from industrial agriculture to diversified agroecological systems. According to the report, diversified agroecology focuses on maintaining multiple sources of food production, and farming by applying ecological concepts and principles to the design and management of food systems. Industrial agriculture, on the other hand, requires highly-specialized production of a single food crop, and, through scale and task separation, focuses on increasing productivity through intensification. While monocultures and concentrated animal feeding operations (CAFOs) are characteristic of industrial agriculture, agroecological practices embrace spatial and temporal diversification (through practices like crop rotation and intercropping), and focus on multiple outputs. Oliver De Schutter, Ph.D., former United National special rapporteur on food and co-chair of IPES, notes to The Guardian: “Many of the problems in food systems are linked specifically to the uniformity at the heart of […]

(Beyond Pesticides, June 3, 2016) Despite recent reports of continuing bee losses across the U.S., the U.S. Environmental Protection Agency (EPA) has announced plans to reevaluate the use of the bee-toxic insecticide sulfoxaflor, and is proposing an amended registration. Sulfoxaflor’s initial 2013 registration was challenged by beekeepers and subsequently vacated by the Ninth Circuit Court of Appeals due to overwhelming risks to bees and EPA’s inadequate review of the data. Last September, the  Ninth Circuit Court of Appeals unequivocally rejected  EPA’s registration of sulfoxaflor. The Court concluded that EPA violated federal law when it approved sulfoxaflor without reliable studies regarding the impact that the insecticide may  have on honey bee colonies. The Court vacated EPA’s unconditional registration of the chemical, meaning that sulfoxaflor could no longer be used in the U.S. This decision was in response to a suit filed by beekeepers challenging EPA’s initial registration of sulfoxaflor, which cited the insecticide’s threat to bees and beekeeping. The case:  Pollinator Stewardship Council, American Honey Producers Association, National Honey Bee Advisory Board, American Beekeeping Federation, Thomas Smith, Bret Adee, Jeff Anderson v. U.S. EPA  (9th Circuit U.S. Court of Appeals,”¯No. 13-7234) According to the court decision, EPA skirted its own regulations […]

(Beyond Pesticides, June 1, 2016) A study  by researchers at Purdue University has concluded  that honey bees collect most of their pollen from non-crop plants that are frequently contaminated with agricultural and urban pesticides. The researchers found this to be true even in places where croplands dominate the area.  The study, which detected neonicotinoids, pyrethroids, fungicides, and others, highlights the large number of toxic pesticides to which bees are exposed to in the environment. Researchers collected pollen from Indiana honey bee hives at three sites over 16 weeks. The hives were placed in a variety of settings, such as an open meadow with wildflowers, woody shrubs and trees present (non-agricultural), the border of a corn field that was treated with the neonicotinoid clothianidin and three fungicides, and the border of a non-treated corn field. The pollen samples that were collected by the bees represented up to 30 plant families and contained residues from pesticides spanning nine chemical classes. The researchers found 29 pesticides in pollen from the meadow site, 29 pesticides in pollen from the treated cornfield, and 31 pesticides in pollen from the untreated cornfield. The most common chemical products found in pollen from each site were fungicides and […]

(Beyond Pesticides, May 20, 2016) With Monsanto’s  earnings forecast cut and shares down 19%, Bayer AG has made a takeover bid for  the company, worth $42 billion, in an attempt to swallow the global seed producer and become the world’s biggest farm chemical supplier. Although the terms of the proposal have not yet been disclosed, Bayer confirmed the bid to Bloomberg News, and Monsanto said it is reviewing the offer. If the offer is accepted, it could be the biggest acquisition globally in 2016, and the largest German deal ever, according to Bloomberg data analysis. Bayer is known for a wide range of products, from aspirin and birth control to flea and tick collars and insecticides. Monsanto is the creator of the widely used and controversial herbicide formulation Roundup, which has glyphosate as its active ingredient. In order to finance the takeover, Bayer may consider selling off its stakes in its animal health business and plastics/foam chemicals business (Covestro AG), worth an estimated $6 billion and $5.5 billion, respectively. The takeover would solidify both companies in certain ways; Monsanto would strengthen Bayer’s seed business, while a deal with Bayer would help reduce Monsanto’s reliance on the agricultural industry. There has […]

(Beyond Pesticides, May 17, 2016) It was 10 years ago that commercial beekeepers first reported widespread, unsustainable winter losses of their honey bee colonies. A decade after the alarm was first sounded on pollinator declines, results of 2015-16 Colony Loss Survey show no sign the crisis of abating. According to the Bee Informed Partnership survey, beekeepers lost 28.1% of their colonies over this past winter, and a total of 44% of their colonies over the last year. This marks the second year in a row that summer declines (28.1%) were on par with declines experienced during winter. Beekeepers factor in that a small percentage, <15% of their colonies, will be lost each winter, but do not expect to lose colonies during the summer, when there is amble forage and nectar for bees. The costs beekeepers must incur to keep their hives alive continue to increase. More time and money is spent to maintain their hives, yet losses continue to be staggering ”” and unsustainable. As colony collapse disorder (CCD), the cryptic loss of honey bee colonies with no sign of dead bees in or around the hive, has faded from public discussion, concerns over pollinator declines in general, from bees […]

(Beyond Pesticides, May 16, 2016) Pesticide exposure may increase the risk of amyotrophic lateral sclerosis (ALS), according to a study entitled Association of Environmental Toxins With Amyotrophic Lateral Sclerosis, which was  published in JAMA Neurology. ALS, also known as Lou Gehrig’s disease, is a progressive neurodegenerative disease that affects nerve cells in the brain and spinal cord. The study, which investigated a total of 122 persistent environmental pollutants, including organochlorine pesticides (OCPs), polychlorinated biphenyls (PCBs), and brominated flame retardants (BFRs), found that pesticide exposure increased ALS risk five-fold. Researchers conducting the study  looked at 156 patients with ALS and 128 without the disease. Participants were asked about occupational and residential exposure to environmental toxicants  and blood samples were taken to measure their concentrations. Researchers found that the organochlorine pesticides pentachlorobenzene and cis-chlordane increased ALS risk two-fold and nearly six-fold, respectively. This study does not prove that pesticides cause ALS, but it does build on an association suggested in previous research, study co-author Stephen Goutman, MD, told  HealthDay. Dr. Goutman recommends avoiding pesticides. This is especially wise for anyone with a family history of ALS, he added. The link between pesticide exposure and neurological damage has been studied extensively. In 2008, […]

(Beyond Pesticides, May 13, 2016)  Raising questions about Roundup’s (glyphosate) effects on soil health, a study published last month shows that the chemical  is toxic to soil fungus at doses well below levels which are recommended for agricultural use. The commercial formulation of Roundup is  more toxic than technical active ingredient,  glyphosate, highlighting the need to evaluate  full formulation  effects, including  so-called inert ingredients. The study, published in Environmental Science and Pollution Research, looked at Roundup’s effects on  a soil fungus, Aspergillus nidulans. Researchers found that a dilution of Roundup at a rate 100 times less than that  allowed in agricultural production corresponded with 50% mortality of the fungus. A dose only 50 times lower than the recommended application rate for agricultural uses resulted in 100% mortality of the fungus. Even at the median lethal dose (LD50) and lower concentrations, researchers saw impaired growth, cellular polarity, endocytosis and mitochondria (impaired average number, volume and metabolism). The study also found that Roundup has an effect on the soil fungus’ ability to break down nutrients for energy use. Rather than depleting mitochondrial activity, as found in animal cell studies, researchers found a stimulation of mitochondrial activity in the fungal cells, indicating a […]

(Beyond Pesticides, May 10, 2016) Following an apparent accidental release of documents relating to the safety of the herbicide glyphosate, late last month the U.S. Environmental Protection Agency (EPA) also released and then retracted a preliminary ecological risk assessment of another toxic herbicide, atrazine. Under federal law, every pesticide registered in the United States is required to undergo a 15-year registration review to analyze human health and environmental impacts and determine whether the chemical’s use should continue another 15 years. The last decade and a half have seen plethora of studies underscoring that atrazine is harmful to human health, and poses unreasonable adverse risks to ecological health, despite attempts by its major manufacturer, Syngenta, to silence and discredit its critics. EPA’s preliminary ecological risk assessment finds that for current uses at prescribed label rates, atrazine may pose a chronic risk to fish, amphibians, and aquatic vertebrate animals. Where use is heavy, the agency indicates that chronic exposure through built-up concentrations in waterways is likely to adversely impact aquatic plant communities.  Levels of concern, a wonky equation that EPA produces to measure risk, were exceeded for birds by 22x, fish by 62x, and mammals by 198x. Even reduced label rates were […]