(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 11, 2016) Another campus, Macalester College in St. Paul, Minnesota has pledged to become a designated BEE Protective campus. This recognition comes from Beyond Pesticides’ and Center for Food Safety’s BEE Protective Campaign, which aims to protect bees and other pollinators from harmful pesticides like neonicotinoids. As part of its  commitment, Macalester College will  no longer use neonicotinoids on its  campus grounds. Neonicotinoids are a class of pesticides known to have severe impacts on bee populations. Macalester is now one of several campuses around the country that have pledged to protect pollinators and move away from using harmful pesticides that are toxic to these beneficial creatures. Just last month,  Antioch College in Yellow Springs, Ohio pledged to become a BEE Protective campus. In addition to these campuses, several local communities and states are also taking a stand for pollinators by passing policies that restrict the use of bee-toxic pesticides. For more on how your campus or student group can support pollinators and become BEE Protective, visit the BEE Protective Ambassadors webpage. “Macalester’s new resolution to help protect pollinators fits well with our Sustainability Plan and Sustainable Landscaping Master Plan. I’m glad that our college has this opportunity […]

(Beyond Pesticides, May 11, 2016) Beyond Pesticides is pleased to announce that videos are now available from Cultivating Community and Environmental Health: Models for sustainable and organic strategies to protect ecosystems, pollinators and waterways, the 34th National Pesticide Forum! The videos cover the range of topics that were discussed at the Forum and include keynote speeches, panel discussions, and workshops. This year’s forum focused on the adoption of policies to protect human health and the environment, and organic land and building management strategies. Beyond Pesticides encourages activists, community leaders, scientists, and policy makers to attend its annual National Pesticide Forum in person to get together, share information, and strategize create communities that are healthy and free of toxic pesticides. For those who are unable to attend in person, these videos expand the incredible knowledge of the experts to the broader public to help inspire and inform community action. Watch the videos here. You can access the playlist, which includes all of the available videos of the 2016 forum, as well as previous years, on Beyond Pesticides’ YouTube page. Notable presentations include: Pollinators, Biodiversity and Scientific Integrity, by Jonathan Lundgren, Ph.D. Dr. Lundgren is an agroecologist, director of ECDYSIS Foundation, and […]

(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 […]

(Beyond Pesticides, May 9, 2016) Beyond Pesticides joins a historic “civic mobilization” on May 23, 2016, alongside other citizen advocacy organizations leading in the fight to protect and improve human health and the environment. Breaking Through Power celebrates the 50th anniversary of Ralph Nader’s book Unsafe at Any Speed,  which unleashed fresh energies and sparked the creation of numerous advocacy organizations leading to major consumer, environmental and worker safety protections. This mobilization, organized by the Center for Study of Responsive Law, will be held at the Constitution Hall in Washington, D.C. from May 23-26, 2016.   Beyond Pesticides members and friends are invited and encouraged to attend this important event to help launch the next decade of public interest advocacy. If you are interested, please let us know by contacting Jen Ruocco at [email protected]. Beyond Pesticides executive director, Jay Feldman, will be presenting during the first session, Breaking Through Power: How it’s Done, on May 23, 2016. As Beyond Pesticides celebrates 35 years, we are honored to be joining the diverse group of organizations that, “over decades…have produced amazing accomplishments against powerful odds.” In addition to joining the lineup of incredible speakers, Beyond Pesticides will also be tabling. The theme […]

(Beyond Pesticides, May 6, 2016) Last week, the U.S. Environmental Protection Agency (EPA) published a long  awaited review of glyphosate, the active ingredient in Monsanto’s Roundup, concluding that the chemical is not likely to be carcinogenic to humans —then the agency removed the review from its website. After  pulling the report, the agency stated that the document was not final. In March 2015, the International Agency for Research on Cancer (IARC) released its findings that show  glyphosate to be a probable human carcinogen. The 86-page report was published Friday on  regulations.gov by EPA’s cancer assessment review committee (CARC) and was reviewed  by Reuters. While the report finds  that glyphosate is  not likely to be carcinogenic to humans, EPA told Reuters that it took the action it did because the assessment was not final. According to Reuters, “The agency said the documents were ”˜preliminary’ and that they were published ”˜inadvertently.’” But, a cover memo, which was part of the assessment, described the report as CARC’s final cancer assessment document. “Final” was printed on each page of the report, which was dated October 1, 2015. This only furthers speculation that EPA has concluded that it will  renew glyphosate’s registration. The European Union […]

(Beyond Pesticides, May 5, 2016) Yesterday, a large coalition of national organizations delivered over 500,000 petitions to EPA that demands an end to glyphosate use in the U.S. The groups held a rally outside the White House before marching over to EPA headquarters. The event, organized by Moms Across America and Care2, was also joined by Beyond Pesticides, Organic Consumers Association, Friends of the Earth, SumOfUs, and CREDO Action. Glyphosate  is a pervasive and toxic chemical found in Monsanto’s popular Roundup weedkiller and was classified by the  International Agency for Research on Cancer (IARC)  as a probable human carcinogen in 2015. This comes the week after news reports of the European Union indicating it  will re-approve glyphosate’s registration in the EU,  despite fierce public outcry, for another 10 years. Because EPA has not changed its classification of glyphosate as “not likely to be a carcinogen,” it is expected that  EPA will renew the registration  of glyphosate. (The report concluding that glyphosate is not likely  to be carcinogenic to humans was posted online  by EPA on Friday,  but taken down  the following Monday, pending the agency’s completion of its reevaluation.) “The current science confirms that glyphosate and Roundup are anything but […]

(Beyond Pesticides May 3, 2016) Last week, the Organic Consumers Association (OCA) filed lawsuits against two popular infant formula makers for falsely labeling their products as organic. The claims against both The Honest Co. and Hain Celestial Group allege that their products contain ingredients that are prohibited under the Organic Food Production Act (OFPA) of 1990 as well as non-organic and non-agricultural ingredients. The lawsuit against The Honest Company alleges the product contains 11 synthetic ingredients that are not allowed by federal law in organic products, including sodium selenite and taurine. In the court documents, OCA also claims that some of the ingredients have not been “assessed as safe for human foods — much less for infant formulas.” “No one is more concerned about food labels and ingredients than new mothers responsible for feeding infants whose immune systems and brain development are so underdeveloped and vulnerable. As consumers, these mothers must rely on truthful labeling in order to make the best choices for feeding their infants and toddlers. Our job as a consumer advocacy group is to call out and hold accountable companies like The Honest Co. and Hain Celestial when they knowingly and intentionally mislead consumers,” said OCA International […]

(Beyond Pesticides, May 3, 2016) In a bipartisan victory for bees, last week the Connecticut House of Representatives unanimously (147-0) passed a wide-ranging bill aimed at protecting declining pollinator populations within the state from toxic neonicotinoid (neonic) pesticides. Bill No. 231, An Act Concerning Pollinator Health, was also passed unanimously (36-0) through the Connecticut State Senate on April 21, and now goes to Governor Dannel P Malloy for his signature. Earlier in April, both houses of the Maryland legislature passed the Maryland Pollinator Protection Act, which is currently awaiting action by Governor Larry Hogan (R). Connecticut’s bill addresses a broad range of concerns relating to pollinator health, from pesticides to parasites and habitat remediation, within both residential and agricultural settings. In summary, the bill does the following: Prohibits applying neonicotinoid insecticide (a) to linden or basswood trees or (b) labeled for treating plants, to any plants when such plant bears   blossoms; Bee health experts identified the application of systemic neonicotinoids to Tilia trees as a significant concern for pollinator health after a spate of massive bee-kill incidents on the west coast. In June 2013, over 50,000 bumblebees were killed after a neonic was applied to a linden trees in […]

(Beyond Pesticides, May 2, 2016) A study published online last week has examined the effects of three neonicotinoids (neonics) on bumblebee colonies, from live bee kills to changed sex ratios. Neonics have been widely cited as contributing to  the demise of both managed and wild bee and pollinator populations. They can cause  changes in bee reproduction, navigation, foraging, and even the suppression of bee immune systems. The study, published in Scientific Reports, looked at field-relevant levels (2.5 parts per billion) of imidacloprid, thiamethoxam, and clothianidin, and found compound-specific effects at all levels, including within individual bee cells, individual bees, and whole colonies in semi-field conditions. Given the limitations of laboratory studies and field studies, researchers conducted a semi-field study to try to recreate and represent real world exposure patterns. The neonics were provided to the bees as an optional supply of sugar syrup, but were free to forage and did need to gather pollen in order to grow and raise offspring. Researchers found that imidacloprid and clothianidin displayed abilities to affect neuronal Kenyon cells, which help with learning, memory and multisensory integration. At the whole colony level, thiamethoxam altered the sex ratio, leaving more males than females. Both imidacloprid and […]

(Beyond Pesticides, April 29, 2016) Traces of pesticides, including the long-banned organochlorine chemical DDT, have been found in Western pond turtles, insects, and soil sediment at Sequoia National Park, according to a study.  The study, entitled Organic contaminants in western pond turtles in remote habitat in California  and published in the journal Chemosphere, surveys a suite of 57 current- and historic-use pesticides, polychlorinated biphenyls (PCBs), and polycyclic aromatic hydrocarbons (PAHs) in the western pond turtle, along with their potential prey items and habitat. California study sites include Sequoia National Park, Whiskeytown National Recreation Area, and Six Rivers National Forest, all of which are downstream of undeveloped watersheds and varied in distance from agricultural and urban pollution sources. Researchers found that organic pollutants are widespread in the western pond turtle, which has conservation status; that pesticides are prominent in Sequoia National Park, which is downwind of heavy agriculture; and that the legacy  pesticides and PCB concentrations indicate that bioaccumulation is occurring. Brian Todd, Ph.D., an associate professor of wildlife, fish, and conservation biology at University of California Davis, co-authored the study. Dr. Todd said controlling the flow of pesticides into national parks is pretty much impossible. “Sequoia National Park is very […]

(Beyond Pesticides, April 28, 2016) This week, Antioch College in Yellow Springs, Ohio,  became the third university to become a neonicotinoid-free campus.  Antioch College gains recognition from the Beyond Pesticides’ and Center for Food Safety’s  BEE Protective  Campaign, which seeks to protect honey bees and other pollinators from harmful pesticides. Signing the  BEE Protective  resolution, Antioch signaled its continued commitment to using neonicotinoid-free insecticides on campus, making them one of the leading higher education institutions committed to the protection of pollinator species. In addition to joining the Bee Protective Campaign, the Village of Yellow Springs, where Antioch is located,  is  considering an organic land care policy, and Beyond Pesticides is working with the Village to assist with a transition to organic turf care. “At Antioch College, we have an opportunity, and an urgency, to be change leaders in turning around pollinator decline, exposing misleading research and recognizing the importance of inter-species cooperation. To paraphrase our president Thomas Manley, ”˜If we are not leaders in discovering and implementing  new and better ways of living  , then what is the point?’” said Beth Bridgeman, the faculty member who drove the effort to ban neonicotinoids from campus. Antioch students and staff maintain about […]

(Beyond Pesticides, April 27, 2016) The  European Union (EU)  has placed a moratorium on two endocrine-disrupting herbicides that are linked to thyroid cancer, infertility, reproductive problems and fetal malformations. The chemicals, amitrole and isoproturon, will be banned as of September 30, 2016, after the European Commission voted unanimously, for the first time, to ban the two endocrine disruptors. Earlier this month, the European Commission’s Standing Committee on Phytopharmaceuticals voted to ban the uses of amitrole and isoproturon in accordance with 2009-EU pesticide rules,  which state that endocrine disrupting pesticides should not be allowed on the European market. The committee finds that amitrole is capable of causing malformations in offspring and inducing thyroid cancer, while isoproturon can cause adverse effects to reproduction and lower fertility. In 2013 amitrole was voluntarily cancelled by the registrant, while isoproturon is not registered for use in the U.S. According to the Guardian, amitrole is widely used in 10 EU countries, including the UK, in industrial farming. But  a European Food Safety Authority (EFSA) analysis concluded  that it was an endocrine disruptor that could damage unborn children, and have toxic effects on the thyroid and reproductive organs. Similarly, EFSA recommended classifying  isoproturon as toxic for reproduction […]

(Beyond Pesticides, April 26, 2016) A study published last month finds that exposure to endocrine-disrupting chemicals (EDC) plays an important role in the development of certain female reproductive disorders, and ultimately results in significant economic costs to society. The study, published in the Journal of Clinical Endocrinology &nMetabolism, and authorized by a team of scientists from New York University School of Medicine and Washington State University’s School of Molecular Biosciences, looked at the monetary impact of EDC-attributed female reproductive disorders in the European Union (EU). This economic valuation is part of series of analyses undertaken by the research team, which determined last year that over €150 billion ($162 billion) in yearly health care costs in the EU are attributable to the loss of brain function induced by EDCs. “There are substantial human and toxicological studies (in mice and other lab animals) that suggest that exposure to these endocrine-disrupting chemicals, many of which are increasing in use, are contributing to female reproductive conditions,” said study co-author Leonardo Trasande, MD, associate professor of pediatrics at NYU School of Medicine to CNN. The study found that the strongest data linking EDCs to female reproductive disorders was exposure to diphenyldichloroethene (DDE) resulting in fibroids, […]

(Beyond Pesticides, April 25, 2016) Last week, the City Council of Milwaukie, Oregon passed a resolution that halts the use of bee-toxic neonicotinoid insecticides on city government and public property,  joining the growing number of local governments protecting pollinators.  Neonicotinoids  (neonics) have been widely cited in the demise of both managed and wild bee and pollinator populations.  The resolution specifically  restricts city government agencies from purchasing plants and seeds that have been treated with neonicotinoids and other systemic insecticides and urges public and private landscapers and homeowners to plant bee-friendly habitats.  Clackamas County will join with the Mayor’s office and City Council of Milwaukie to adopt an Integrated Pest Management Plan that mirrors the resolution. In addition to these stipulations, the City of Milwaukie is using this resolution to: urge all businesses, homeowners, and homeowner’s associations operating within the City ensure no plants, seeds, or products containing neonicotinoids are purchased, sold, or used within the City; and to clearly and accurately label any plants or materials that have been treated with a neonicotinoid or neonicotinoid-like insecticide; require that commercial pest service providers performing services on behalf of the City provide landscape services that encourage pollinator populations and support pollinator services; […]

(Beyond Pesticides, April 22, 2016) Today is Earth Day! As honey bees and other pollinators continue to suffer from staggering global declines, Beyond Pesticides works year-round through the BEE Protective campaign, launched Earth Day 2013, to support nationwide local action aimed at protecting pollinators from pesticides. Pollinators are a vital part of the environment, a barometer for healthy ecosystems, and critical to the nation’s food production system. With one in three bites of food reliant on bees and other species for pollination, the decline of honey bees and other pollinators demands swift action. The BEE Protective campaign includes a variety of educational materials to help encourage municipalities, campuses, and individual homeowners to adopt policies and practices that protect bees and other pollinators from harmful pesticide applications and create pesticide-free refuges for these critical  organisms. In addition to scientific and regulatory information, BEE Protective also assists people and communities with  a model community pollinator resolution and a pollinator protection pledge. Insecticides, specifically neonicotinoids, have increasingly been linked to bee declines. These chemicals are used extensively in U.S. agriculture, especially as seed treatment for corn and soybeans. Agriculture is not the only concern however, as pesticide applications in home gardens, city parks, […]

(Beyond Pesticides, April 21, 2016) A report released Tuesday by the Alliance for Natural Health (ANH) shows that glyphosate residues are widely distributed in common breakfast foods, such as bagels, cereals, creamers, and eggs. Glyphosate is a pervasive and toxic chemical found in Monsanto’s Roundup weedkiller and was classified by the International Agency for Research on Cancer (IARC) as a probable human carcinogen in 2015. The report looks at conventional and organic-certified versions of 12  popular breakfast foods and ingredients (a total of 24 items) and finds that many of the sample foods or ingredients contain detectable levels of glyphosate. Testing was done by an independent laboratory using the ELISA (enzyme-linked immunosorbent assay) method. Categories tested were: flour, corn flakes, instant oatmeal, bagels, yogurt, bread, frozen hash browns, potatoes, cream of wheat, eggs, non-dairy creamers, and dairy based coffee creamers. Of note is the finding that a sample of organic cage-free eggs contain more glyphosate than the allowable tolerance level. The lab found glyphosate residue levels of 169 parts per billion (ppb), while the allowable tolerance level is only 50ppb. The report acknowledges that the effects of other chemical ingredients in glyphosate formulations have not been evaluated, and the consequences […]

(Beyond Pesticides April 20, 2016) A recently released study by the U.S. Government Accountability Office (GAO) assesses the actions of three government agencies responsible for regulating genetically engineered (GE) crops, finding several shortcomings in the process. The report, which was commissioned by U.S. Senator Jon Tester (D-MT), is entitled Genetically Engineered Crops:  USDA Needs to Enhance Oversight and better Understand Impacts of Unintended Mixing with Other Crops. The report finds that while the Environmental Protection Agency (EPA), Food and Drug Administration (FDA), and U.S. Department of Agriculture (USDA) have taken some steps to regulate GE crops, USDA’s failure to update its regulations that oversee GE crops has created a large data gap on the extent and impact of the unintended mixing of GE and non-GE crops. To address this, GAO recommends, among other things, that USDA set a timeline for updating its regulations and include farmer’s growing identity-preserved crops in its survey efforts to better understand the impacts of unintended mixing. The issue of coexistence between farmers using genetically engineered (GE) crops and non-GE farmers is as important as ever. GE crops pose a constant threat to the livelihood of organic farmers and undermine the burgeoning growth of the organic […]

(Beyond Pesticides, April 19, 2016) Last week the Environmental Working Group (EWG) released its annual Shoppers Guide to Pesticides in Produce, highlighting the critical importance of eating organic food to avoid pesticide residues that endanger human health. Beyond Pesticides’ Eating with a Conscience database complements EWG’s report by identifying the many additional reasons it is essential to choose organic for a healthy future. Although information on residues in conventional produce listed in the “Dirty Dozen” is helpful in alerting consumers and encouraging organic, it only tells part of the story. It turns out that even those food commodities in EWG’s “Clean Fifteen” may be grown with hazardous pesticides that get into waterways and groundwater, contaminate nearby communities, poison farmworkers, and kill pollinators and wildlife, while not all showing up at detectable levels on our food. For its report, EWG analyzed over 35,000 samples of pesticide residue collected by the U.S. Department of Agriculture. After 5 years at the top of the list, apples dropped to number two, replaced by strawberries. The organization reasons that a recent EU ban on the chemical diphenylamine, a fungicide linked to reproductive effects, kidney/liver damage, as well as groundwater contamination and toxicity to aquatic organisms, […]

(Beyond Pesticides, April 18, 2016) Major pesticide manufacturer Scotts Miracle Gro announced on Tuesday that it will immediately being phasing out neonicotinoid insecticides, including imidacloprid, clothianidin, and dinotefuran from its outdoor-use Ortho brand by 2017. Neonicotinoids (neonics) have  consistently been implicated  as a major contributing factor in pollinator declines. They can cause  changes in bee reproduction, navigation, and foraging, and even the suppression of bee immune systems. In its press release, the Ortho brand announced that it was partnering with Pollinator Stewardship Council to help educate homeowners on the “safe and appropriate use of pesticides.” “While agencies in the United States are still evaluating the overall impact of neonics on pollinator populations, it’s time for Ortho to move on.” Tim Martin, general manager of the Ortho brand said. “As the category leader, it is our responsibility to provide consumers with effective solutions that they know are safe for their family and the environment when used as directed. We encourage other companies and brands in the consumer pest control category to follow our lead.” Neonics have emerged as the leading class of pesticides responsible for bee decline. While neonicotinoid insecticides have been responsible for high profile bee kills from high doses […]

(Beyond Pesticides, April 15, 2016) Beyond Pesticides’ 34th National Pesticide Forum begins tonight at the University of Southern Maine in Portland, Maine. As pesticide use in communities is being debated in the Portland area, throughout Maine, and across the country, Cultivating Community and Environmental Health, the 34th National Pesticide Forum, is being held at the University of Southern Maine Abromson Center, April 15-16, 2016. Click here to register now! Registration, which is $45 for activists and $25 for students, includes access to all sessions as well as organic food and beverages. Join us tonight for a special performance of A Sense of Wonder, by Kaiulani Lee, followed by a talk and book signing by Kristin Ohlson, author of The Soil Will Save Us. Special Friday night only tickets are available for $10. A Sense of Wonder, which is a one-woman play written, produced, and performed by Kaiulani Lee, in which the actor portrays  Rachel Carson’s  love for the natural world and her fight to defend it, much of it taking place in Maine! It is the story of the extremely private Ms. Carson thrust into the role of controversial public figure with the publication of Silent Spring. This powerful two-act […]

(Beyond Pesticides, April 14, 2016) Two-thirds of Europeans support a ban on glyphosate, the  most widely used agricultural chemical in the world, according to a new poll. This as Germany plans to formally support a European Union (EU) plan to re-license the use of the chemical. Monsanto’s glyphosate, the active ingredient in the popular weedkiller, Roundup, has been classified as a probable carcinogen by the World Health Organization’s (WHO) International Agency for Research on Cancer (IARC), is detected in food, breast milk, and urine, and is increasingly used on genetically engineered (GE) crops, leading to the proliferation of resistant “superweeds” and environmental contamination. The poll conducted by Yougov, an international internet-based market research firm, surveyed more than 7,000 people across the EU’s five biggest countries and find  three-quarters of Italians, 70% of Germans, 60% of French and 56% of Britons support a ban on glyphosate. Despite this, the EU is moving forward on whether to approve a European Commission proposal to extend the authorization of glyphosate for another 15 years until 2031. The existing authorization is due to lapse in June 2016. The decision was delayed after the IARC classified glyphosate as a  Group 2a “probable” human carcinogen  based on […]

(Beyond Pesticides, April 13, 2016) The organic regulatory process provides numerous opportunities for the public to weigh in on what is allowable in organic production. The spring 2016 public comment period is coming to a close for the National Organic Standards Board’s (NOSB) proposed recommendations on  organic standards, materials and policy. Comments are due by tomorrow, April 14, 2016 at 11:59 PM. There are many important issues that are under  NOSB consideration. Your voice is integral to maintaining organic integrity and the value of the USDA organic label. Remember, the Secretary of Agriculture may not allow materials in organic production that are not first recommended by the NOSB. On our Public Comment Alerts page, we have listed our positions on some of our top priority issues, such as inert ingredients, sanitizers, ancillary substances, carrageenan, and paraciticides. We have now updated our Keeping Organic Strong  (KOS)  page  with the rest of our top priority issues (as of April 12, 2016), and included the newest ones below. Please feel free to develop your own comments or cut and paste from our sample comments below or our final comments on the above KOS page: Policy and Procedures Manual Revisions “I appreciate the response […]