(Beyond Pesticides, April 1, 2024) Comments are due 11:59 pm EDT, Wednesday, April 3. For the public comment period—deadline Wednesday, April 3—in the lead up to the National Organic Standard Board (NOSB) meeting, advocates have identified the following priority issues: Getting plastics our of organic; Removing endocrine disrupting nonylphenols (NPs) and nonylphenol ethoxylates (NPEs) iodine from dairy production and replace with available alternatives; and Continuing to improve the science supporting ongoing decisions of the NOSB. (See below for details and opportunity to submit comments on these with one click!) Previously, Beyond Pesticides has reported on three additional priority issues, including; Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production; Eliminate nonorganic ingredients in processed organic foods as a part of the Board’s sunset review of allowed materials; and  Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment.  (Please see the prior action on these issues and submit comments, if not done previously.) Beyond Pesticides asks the public to join in commenting on priority issues that protect health and the environment as part of the upcoming NOSB meeting. The NOSB is receiving written comments from the […]

(Beyond Pesticides, March 27, 2024) A preliminary experiment conducted by Public Employees for Environmental Responsibility (PEER) reveals concerning levels of toxic per- and polyfluoroalkyl substances (PFAS) on the skin of soccer players and coaches after playing on artificial turf fields. The Washington Post reported on March 12 on the PEER test results, which found PFAS levels increased on the skin in three out of four participants following soccer matches on artificial turf. In contrast, no similar increase was observed after games on natural grass fields. The presence of PFAS is alarming due to their association with several serious health issues, including cancer, birth defects, and developmental and immune deficiencies, among others. The U.S. Environmental Protection Agency (EPA) writes that PFAS exposure risks are particularly concerning for young children, who are more susceptible due to their developing bodies and at risk for higher levels of exposure than adults. Known as “forever chemicals” for their persistence in the environment, PFAS continue to accumulate in the human body, posing long-term health risks. Kyla Bennett, PhD, science policy director at PEER and a former scientist and lawyer with EPA, emphasized the need for further research. “Although this study is preliminary, it highlights the potential […]

(Beyond Pesticides, March 26, 2024) The authors of a case study in Canale D’Aiedda, Taranto, Italy, published in Scientific Reports, conclude that, “[T]he results of monitoring and modeling activities revealed a chronic risk associated with the presence of Cu [copper] from November to April in several river reaches and acute risk associated to the presence of glyphosate in several reaches mainly in the wet season.”  According to the authors, “The most important factor influencing the chronic risk for Cu were the combination of two factors: the high surface runoff and the Cu applications. The most important factor influencing the glyphosate peaks of concentration is the streamflow.” The authors of the study measure the flow of pesticide concentrations through the soil and water assessment tool (SWAT). The ecotoxicological data was collected at two stations in Germany that flow into Italy, within the Canale d’Aiedda basin. The streamflow was monitored between August 2017 and December 2019. Out of hundreds of pesticides and six metabolities investigated in this study, “only traces of copper and glyphosate were found.” The authors continue, “The banks and the bed of the river system are almost all covered by concrete. The hydrological regime is natural and intermittent in […]

(Beyond Pesticides, March 25, 2024) Because of their widespread infiltration into the environment and the bodies of all organisms, including humans, plastics contamination requires a holistic strategy to protect life— with consideration given to practices and chemical use that reduce or eliminate harm. Pesticides and other toxic chemicals are adsorbed (adhered) to microplastics, resulting in bioaccumulation and widespread contamination. This adds to the complexity of the problem, which is largely ignored by federal regulatory agencies. While most environmental policies attempt to clean up or mitigate health threats, new data reinforces the need to stop the pipeline of hazardous chemicals, wherever possible. With new data on the harm associated with plastics and related contamination, it becomes urgently necessary for all government agencies to participate in a comprehensive strategy to eliminate plastics and pesticides. Beyond Pesticides points to the evolving science on plastics contamination and their interaction with pesticides as yet another reason to transition to holistic land management systems that take on the challenge of eliminating hazardous chemical use. Organic land management policy creates the holistic systems framework through which plastics can be eliminated. >> Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food. […]

(Beyond Pesticides, March 22, 2024) With long-running efforts to keep organic land management in the forefront of public health and environmental measures to eliminate petrochemical synthetic substances, including pesticides and fertilizers, plastic again emerges as an increasing threat in a study linking microplastics to cardiovascular disease. The study by Italian researchers, published in the March 7 issue of the New England Journal of Medicine, finds an elevated risk factor for heart attack and stroke associated with plastics found in the plaque of the majority of patients’ carotid arteries. A holistic approach to agriculture that embraces principles and values to enhance biodiversity and protect health, the organic system requires that synthetic substances are compatible with that system. In this context, the environmental and public health effects of plastics are increasingly subject to scrutiny as they permeate nearly every aspect of food production, including fields, crops, foods, and food packaging. Plastics also migrate from other sectors into agriculture via wind and water and are now ubiquitous in every environment. Removing plastics from any ecosystem is extremely problematic, so getting them out of agriculture will be difficult – but necessary, given the accumulating evidence of their toxicity. Beyond Pesticides continues to push for […]

(Beyond Pesticides, March 21, 2024) Alarming levels of a hazardous pesticide plant growth regulator linked to reproductive and developmental effects, chlormequat, is found in 90% of urine samples in people tested, raising concerns about exposure to a chemical that has never been registered for food use in the U.S. but whose residues are permitted on imported food. Published in the Journal of Exposure Science and Environmental Epidemiology in February 2024 and led by Environmental Working Group toxicologist Alexis Temkin, PhD, a pilot study finds widespread chlormequat exposure to a sampling of people from across the country. U.S. Environmental Protection Agency (EPA) regulations only permit the use of chlormequat on ornamental plants and not food crops grown in the U.S. As explained in the journal article, “In April 2018, the U.S. EPA published acceptable food tolerance levels for chlormequat chloride in imported oat, wheat, barley, and some animal products, which permitted the import of chlormequat into the U.S. food supply.” In 2020, EPA increased the allowable level of chlormequat in food. Then in April 2023, EPA proposed allowing the first-ever U.S. use of chlormequat on barley, oat, triticale (a hybrid of wheat and rye), and wheat. Existing regulatory standards explain the […]

(Beyond Pesticides, March 18, 2024) Comments are due by 11:59 pm EDT on April 3, 2024. Organic standard setting provides for democratic input, full transparency, and continuous improvement. The current public comment period is an important opportunity for the public to engage with the organic rulemaking process to ensure that the National Organic Standards Board (NOSB) and the USDA National Organic Program uphold the values and principles set forth in the Organic Foods Production Act (OFPA). With the threats to health, biodiversity, and climate associated with petrochemical pesticide and fertilizer use in chemical-intensive land management, advocates stress that this is critical time to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards, public input, inspection system, and enforcement mechanism. But, organic will only grow stronger if the public participates in voicing positions on key issues to the NOSB, a stakeholder advisory board. Beyond Pesticides has identified key issues for the upcoming NOSB meeting below! The NOSB is receiving written comments from the public on key issues through April 3, 2024. This precedes the upcoming public comment webinar on April 23 and 25 and the deliberative hearing on April 29 through […]

 (Beyond Pesticides, March 14, 2024)  A recent review in the New England Journal of Medicine (NEJM) highlights the urgent need to address the widespread chemical pollution stemming from the petrochemical industry, underscoring the dire implications for public health. Tracey Woodruff, PhD, author and professor at the University of California San Francisco (UCSF), emphatically states in an email comment to Beyond Pesticides, “We need to recognize the very real harm that petrochemicals are having on people’s health. Many of these fossil-fuel-based chemicals are endocrine disruptors, meaning they interfere with hormonal systems, and they are part of the disturbing rise in disease.” Beyond Pesticides echoes this concern, noting that endocrine disrupting chemicals (EDCs) include many pesticides and are linked to a plethora of health issues such as infertility, diabetes, cardiovascular diseases, obesity, early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers.  (See Beyond Pesticides’ Disease database here and news coverage here). The review further calls on the clinical community to advocate for policy changes aimed at mitigating the health threats posed by petrochemical-derived EDCs and climate change. Beyond Pesticides urgently calls for the elimination of petrochemical pesticides and fertilizers and advocates for a systemic […]

(Beyond Pesticides, March 13, 2024) A comprehensive study released in Journal of Cleaner Production in August 2023 identifies the potential for organic agriculture to mitigate the impacts of agricultural greenhouse gas (GHG) emissions in the fight to address the climate crisis. In “The spatial distribution of agricultural emissions in the United States: The role of organic farming in mitigating climate change,” the authors determine that “a one percent increase in total farmland results in a 0.13 percent increase in GHG emissions, while a one percent increase in organic cropland and pasture leads to a decrease in emissions by about 0.06 percent and 0.007 percent, respectively.” This descriptive study affirms the urgency of Beyond Pesticides’ mission to ban toxic petrochemical pesticides by 2032, given the projected adverse impacts that conventional agricultural dependence on these toxic pesticides will continue to have on people, wildlife, and ecosystems. The study refers to various studies focused on a comparative analysis of conventional to organic farming on energy use, greenhouse gas emissions (GHGe), nutrient leaching, soil quality, and biodiversity. The consensus is that organic farming is more sustainable than conventional agriculture. For example, “[S]everal studies comparing conventional to organic agriculture found that the latter used 10%–70% […]

(Beyond Pesticides, March 7, 2024) As the threats to health, biodiversity, and climate converge in agricultural policy and practices, the question of defining the fundamental changes necessary to reverse these existential crises takes on life-sustaining importance. Despite the existence of an organic community with governing stakeholders (farmers, consumers, conservationists, retailers, processors, inspectors, and scientists) that has evolved over at least seven decades and is codified in the Organic Foods Production Act (OFPA) of 1990, 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) last month 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 to millions of acres in their supply chain practicing “regenerative” agriculture with target dates ranging from 2024 to 2050. The AFN author reporting on the “regenerative” trend states, “[O]ne big challenge is that ‘regenerative agriculture’ still has no set definition. While that still holds true, the bigger observation in […]

(Beyond Pesticides, March 4, 2024) With 14.7 million children and adolescents in the U.S. recognized as obese by the Centers for Disease Control and Prevention (CDC) and the established connection with endocrine disrupting contaminants, including many pesticides, Beyond Pesticides is calling on federal food assistance programs to go organic. The problem of childhood obesity is higher in people of color and, as a result, is an environmental justice issue. According to CDC, the prevalence of childhood obesity is “26.2% among Hispanic children, 24.8% among non-Hispanic Black children, 16.6% among non-Hispanic White children, and 9.0% among non-Hispanic Asian children.” While childhood obesity is recognized as a serious problem, the National School Lunch Program of the U.S. Department of Agriculture (USDA)—although improved by the Healthy, Hunger-Free Kids Act of 2010—still provides lunches laced with obesogenic pesticides. To take meaningful steps against childhood obesity, school lunches must be organic. The program served 4.9 billion meals in fiscal year 2022 in over 100,000 public and nonprofit schools, grades Pre-Kindergarten-12. Contrary to popular opinion, the blame for the obesity epidemic cannot be attributed solely to diet and exercise broadly, but relates directly to pesticide and toxic chemical exposures, including residues in food, that may lead […]

(Beyond Pesticides, February 15, 2024) The latest U.S. Department of Agriculture (USDA) pesticide residue report, the 32nd Pesticide Data Program (PDP) Annual Summary report, released in January, finds that over 72 percent of tested commodities contain pesticide residues (27.6 percent have no detectable residues), mostly below the level the U.S. Environmental Protection Agency (EPA) has set for tolerances (allowable residues) whose safety standards have been called into question by advocates. USDA spins its report findings as a positive safety finding because, as the Department says, “[m]ore than 99 percent of the products sampled through PDP had residues below the established EPA tolerances.” USDA continues, “Ultimately, if EPA determines a pesticide use is not safe for human consumption, EPA will mitigate exposure to the pesticide through actions such as amending the pesticide label instructions, changing or revoking a pesticide residue tolerance, or not registering a new use.” As Beyond Pesticides reminds the public annually when USDA uses the report to extol the safety of pesticide-laden food, the tolerance setting process has been criticized as highly deficient because of a lack of adequate risk assessments for vulnerable subpopulations, such as farmworkers, people with compromised health or preexisting health conditions, children, and perhaps, […]

(Beyond Pesticides, February 7, 2024) Sun + Earth Certified (SEC), a West Coast third-party regenerative organic certifier of cannabis products, approved the first certification for an East Coast farm in Brattleboro, Vermont – Rebel Grown. The expansion of independent certifications amidst the ongoing legalization of recreational and medicinal marijuana usage raises questions on the regulation of toxic petrochemical pesticides found in a range of cannabis products. SEC does establish, in its standards, the use of “biopesticides…[o]nly if the product brand name is approved for use in certified organic farming.” Additionally, the label goes beyond the stringency of the National Organic Program in its policy on potassium bicarbonate as an approved input. For example, SEC standards dictate that this input should be, “[f]or pest control as a last resort only… [and] only if the product brand name is approved for use in certified organic farming.” Rebel Grown– the new farm that acquired the SEC label – owner reported to Brattleboro Reformer, “Cannabis grown regeneratively, under the sun and in the soil, without toxic chemicals, is not only high quality but also the best for the earth.” Before delving into the weeds, there is important legal context on current regulations regarding marijuana […]

(Beyond Pesticides, January 25, 2024) Legislative efforts to curtail some life-threatening pesticides associated with birds and bees (and other pollinators) decline were weakened in New York State at the end of December 2023 as the governor negotiated and stripped elements of a bill relating to agriculture that had passed the legislature—again illustrating the grip of the agrichemical industry on public policy intended to begin to address the crisis in ecosystem collapse. (See “Study Cites Insect Extinction and Ecological Collapse.”) In passing the Birds and Bees Protection Act, New York joined New Jersey, Nevada, and Maine in banning most nonagricultural uses of neonicotinoid (neonic) insecticides, but, in last-minute changes to avoid the governor’s veto, failed to phase out corn, soybean, and wheat seeds coated with these chemicals. [Pointing to an exemption in federal law that has been challenged by advocates, the U.S. Environmental Protection Agency (EPA) does not regulate treated or coated seeds as pesticides despite their toxic pesticidal properties.] In New York State, the governor can, in consultation with the leadership of the legislative branch, negotiate language changes (called Chapter Amendments) in legislature-passed legislation (originally enacted) before deciding to sign it into law or can simply choose to veto the legislation. […]

(Beyond Pesticides, January 22, 2024) Today, Monday, January 22, is the last day for public comment on a three-year extension of U.S. Department of Agriculture’s (through its Agricultural Marketing Service’s National Organic Program (NOP)) authority to collect information from certifiers entrusted with ensuring compliance with organic standards. Beyond Pesticides, along with allied organizations and organic advocates, is urging USDA to use this process to clarify the need for USDA to collect key information needed to verify compliance with key language in OFPA (Section 6513(b))—a provision that requires farming practices that “foster soil fertility.” Advocates maintain that information on organic farmers’ practices to foster soil fertility, required in the law, is critical to organic integrity, public trust in the organic label, and certifier responsibility. As USDA states, “The Organic Foods Production Act of 1990 (OFPA), as amended (7 U.S.C. 6501–6524), authorized the Secretary of Agriculture to establish the National Organic Program (NOP) and accredit certifying agents to certify that farms and businesses meet national organic standards. Under OFPA, the purpose of the NOP is to: (1) establish national standards governing the marketing of certain agricultural products as organically produced products; (2) assure consumers that organically produced products meet a consistent standard; […]

(Beyond Pesticides, January 18, 2024) Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. A study published by researchers at Columbia and Rutgers universities (see article in the Proceedings of the National Academy of Sciences, January 2024) reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million tiny plastic pieces, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Last December, researchers at Norway’s MicroLEACH project published a study that analyzes the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys and balloons. (See summary.) The researchers found, like in previous studies, that many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products. This suggests that most plastics contain many unidentified chemicals, far beyond […]

(Beyond Pesticides, January 12, 2024) As we commemorate Dr. Martin Luther King Jr.—an inspiration for taking on the challenges of justice, equity, and safety as a central part of all our work for a sustainable future—through a day that stands for equality, justice, and the pursuit of a better world, it is crucial to reflect on issues that impact the health and well-being of communities. One such issue that echoes the spirit of Dr. King’s vision is the pervasive use of pesticides and the associated health risks. Drawing insights from prior articles on Beyond Pesticides’ Daily News, we delve into the intersection of environmental justice, public health, and the ongoing struggle for a safer and healthier world.  The Invisible Threat with Visible Consequence: Pesticides and Health.  Beyond Pesticides sheds light on the hidden dangers of pesticide exposure and the disproportionate impact it has on marginalized communities. Communities of color and economically disadvantaged areas bear a heavier burden of pesticide exposure, leading to higher rates of health issues, including respiratory problems, developmental disorders, and certain cancers.  From agricultural workers to residents of low-income neighborhoods, the adverse health effects of pesticides are not evenly distributed. The use of pesticides without adequate consideration […]

(Beyond Pesticides, January 5, 2023) The 28th United Nations Climate Change Conference of the Parties (COP28) wrapped up in Dubai on December 13 with what some hailed as a breakthrough agreement among almost 200 countries to reduce fossil fuel consumption that signals “the eventual end of the oil age.” To be successful and assure human survival, eliminating oil, gas, and coal use, Beyond Pesticides is calling for the elimination of petrochemical pesticides and fertilizers and support for organic, regenerative agriculture around the world. Because of the insurmountable crises that are caused or exacerbated by petrochemical pesticides and fertilizers, the adoption of organic land management practices and the need for foundational change in federal, state, and local policies and practices has come into focus. Under organic management, healthy soil can absorb and store 1,000 pounds of carbon per acre foot of soil annually. This translates to about 3,500 pounds of carbon dioxide per acre drawn down from the air and sequestered into organic matter in soil. (It is noteworthy that use of synthetic fertilizers actually compromises the carbon-capture ability of some kinds of terrain, such as salt marshes.) A fact often overlooked by policy makers in generating climate strategies is that carbon-sequestering soil practices […]

On behalf of the Beyond Pesticides team, we wish you and your loved ones a happy and healthy holiday season! We deeply appreciate the vital community-based work taking place across the country as we join together to confront the existential health and environmental challenges of our time. Meeting the challenges ahead with a transformative strategy  Beyond Pesticides shares the vision of people and communities that are striving to ensure a future that protects health and sustains life. We are facing existential crises—the climate crisis, biodiversity collapse, and severe public health threats—from cancer to neurological, reproductive, and endocrine system effects, including brain and behavioral impacts. To reverse these threats —which we can do— we advance model organic solutions that eliminate billions of pounds of fossil fuel-based pesticides and synthetic fertilizers and nurture biological systems that take dangerous pollutants out of our environment, protecting health and the ecosystems that sustain life.     Our audacious goal: to phase out petrochemical pesticides and fertilizers by 2032. Our solution: to provide hands-on assistance, funded by our supporters, to assist in the transition to organic land management in community parks, playing fields, and schoolyards.  The path moving forward: Advancing sustainable, organic practices and policies to […]

(Beyond Pesticides, December 20, 2023) A federal district court decision last week (December 13) found illegal the U.S. Environmental Protection Agency’s (EPA) decision to register the antibiotic streptomycin for use in Florida citrus to control Huanglongbing (HLB), also known as “citrus greening,” a plant disease spread by the Asian citrus psyllid. This decision comes just as EPA may allow yet another controversial pesticide, aldicarb, whose registration faces similar issues of agency malfeasance. The streptomycin lawsuit, filed in 2021 by a coalition of farmworker and public interest groups including Beyond Pesticides, raises critical issues of antibiotic resistance, public health protection, and impacts on bees. The case was filed by: Natural Resources Defense Council and U.S. PIRG, represented by NRDC; Beyond Pesticides, Environmental Confederation of Southwest Florida (ECOSWF), Farmworker Association of Florida, Farmworker Justice, and Migrant Clinicians Network, represented by Earthjustice; and the Center for Biological Diversity, represented by in-house counsel. The Ninth Circuit Court of Appeals took EPA to task for its failure to conduct required analyses and issue findings to support the use of streptomycin for citrus greening. The court is particularly concerned about the agency’s failure to reach findings on the impacts on bees and the agency’s responsibility for […]

(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 […]

Update: This Daily News is updated to address the organic status of the company cited in the piece, Merchant’s Garden. The article now indicates that the company is certified as organic under a different name (Merchant’s Garden Agrotech) than the name used in the USDA press release.  As a result, their name did not appear in USDA’s Organic Integrity Database (OID) at the time of the original Daily News and Action of the Week posting. USDA updated OID on December 8, 2023, the same day that it received a complaint on this matter from former National Organic Standard Board chair Jim Riddle. The critical focus of the piece remains the same: It is not disclosed to consumers on food products labeled “organic” when that food or ingredients are grown hydroponically. Beyond Pesticides, as indicated in the article, views hydroponic as a conventional growing practice that does not meet the spirit and intent of the organic system, as defined in the Organic Foods Production Act.  (Beyond Pesticides, December 11, 2023) U.S. Department of Agriculture (USDA) Secretary Tom Vilsack announced on November 27, 2023 funding that appears to be supporting the expansion of “organic” hydroponic, an approach to food production that has […]

(Beyond Pesticides, December 8, 2023) Nine pesticides have been found in nearly 40% of nonorganic conventional baby foods tested, according to a study conducted by Environmental Working Group (EWG). The study found no residues of the pesticides studied in a sample of certified organic baby food. While the study finds no traces of the highly neurotoxic insecticide chlorpyrifos, associated with brain damage in children, the chemical has been allowed back on the agricultural market after being removed in 2021—raising an alarm for parents who purchase baby food with ingredients grown in chemical-intensive (“conventional”) agriculture. In November 2023, a three-judge panel of the Eighth Circuit Court of Appeals reversed a 2021 U.S. Environmental Protection Agency (EPA) decision to ban chlorpyrifos’ agricultural uses, which came after a 2021 Ninth Circuit Court of Appeals decision found that the agency’s inaction violated federal pesticide law. Because of its neurotoxic effects on children, EPA had in 2000 negotiated Dow Chemical’s voluntary cancellation of most residential uses of the chemical, but left virtually all of the chemical’s agricultural uses in place. While the EWG study focuses on pesticide residues in food and the hazards associated with ingestion of dangerous chemicals, raising alarms, purchasing baby food processed with nonorganic […]