(Beyond Pesticides, July 9, 2024) Last month, California cannabis regulators recalled a pesticide-tainted vape, one of the contaminated products identified in a Los Angeles Times investigation. The report reveals that the California Department of Cannabis Control (DCC) has for months been aware of the presence of dangerous chemicals in legal cannabis sold to the public. Conducted by Los Angeles Times and WeedWeek, a cannabis industry newsletter, the investigation has uncovered alarming levels of the insecticide chlorfenapyr in legal cannabis products sold in state dispensaries. According to an article via the National Institutes of Health, “Although [chlorfenapyr] has been identified as a moderately toxic pesticide by the World Health Organization (WHO), the mortality rate of poisoned patients is extremely high. There is no specific antidote for chlorfenapyr poisoning.” The chemical is associated with adverse liver effects and is toxic to bees, birds, and aquatic organisms. Despite claims that the state’s cannabis is safe and regulated, many popular brands of vapes and pre-rolled joints were found to contain dangerous pesticides at levels exceeding state limits and federal standards for tobacco. This investigation comes on the heels of the discovery of large amounts of illegal Chinese pesticides at cannabis grow operations around the state. […]

(Beyond Pesticides, July 8, 2024) Please submit comments by Wednesday, July 31, 2024. Acephate, an insecticide and member of the highly toxic organophosphate (OP) family, is so toxic that EPA is proposing to ban all uses except the systemic injection into trees. A comment period is open, and EPA is accepting comments through Wednesday, July 31, after extending the earlier July deadline. With this remaining use, EPA is still not recognizing that systemic neonicotinoid pesticides can cause serious environmental harm to the ecosystem through indiscriminate poisoning of organisms. >> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically.  EPA proposes to cancel all uses of acephate other than tree injection to eliminate all risks of concern it has identified that exceed its level of concern for dietary/drinking water risk, residential and occupational risks, and risks to non-target organisms. As Beyond Pesticides points out, although the tree injection method does not pose excessive dietary or aggregate health risk and does not pose any untoward occupational or post-application human health risks of concern, there are significant ecological risks posed that the agency has neglected. Rather than assessing the ecological risks of tree […]

(Beyond Pesticides, July 3, 2024) In June, the Vermont legislature officially passed H.706 into law – a bill that narrows and reduces the use of neonicotinoid insecticides and neonicotinoid-treated seeds. The legislature came together to override a veto of the bill issued by Governor Phil Scott (R). Gov. Scott said the bill’s language had “the potential to produce severe unintended environmental and economic consequences–—particularly for Vermont’s dairy farmers.” The advocacy in support of the legislation called for a holistic, systems change approach to legislative priorities that considers economic, ecological, public health, and climate resilience. The Vermont legislation builds on New York legislation, which in turn is inspired by Quebec’s “verification of need” prescription model (a.k.a. emergency exemptions) that has proven to dramatically reduce the use of certain neonicotinoids, yet enables the continued use of toxic pesticides and a legacy of pesticide dependency in land management and crop production. Vermont Bill Building on New York The Vermont Bill (See pages 29 to 44 for final text) mirrors the language of New York’s Birds and Bees Protection Act (S. 1856-A and A. 7640) and adopts New York’s language on timing regarding when critical sections go into effect. The Vermont language contains trigger language that […]

(Beyond Pesticides, July 2, 2024) Men’s Mental Health Awareness Month, which took place last month, evokes concern about the growing body of science linking pesticide exposure to neurological effects linked to depression. Recent studies reveal elevated rates of psychiatric disorders, including suicide, among farmers, with problems more common for males.  Through systematic reviews, meta-analyses, surveys and interviews, and blood sampling, these three studies add to the growing body of science linking pesticide exposure to neurological impacts. First, in the Journal of Agromedicine, researchers from Greece and the United Kingdom review eight studies and find a significant positive association between pesticide poisoning and depression in agricultural populations.1 Second, a study in Toxicology shows a link between depression in Brazilian farmers and pesticide exposure, most notably with glyphosate usage.2 Third, the latest study in Environmental Toxicology and Pharmacology focuses on work by researchers from Spain in identifying farmers exposed to chlorpyrifos, mancozeb, and malathion that have higher rates of depressive symptoms and suicide attempts.3  Through a meta-analysis of published research, the authors of the Agromedicine journal article identify pesticide poisoning as a risk factor of depression. With depression affecting more than 264 million individuals worldwide, this is a field of interest with […]

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

(Beyond Pesticides, July 28, 2024) Most people don’t like bugs, but the fact is that insects form the foundation of human flourishing, both for their ecosystems services, like pollination of food crops, and for their aesthetic joys. But insect populations globally are declining two to four percent a year, with total losses over 20 years of 30-50 percent, according to a new study of the interacting effects of pesticides, climate, and land use changes on insects’ status in the Midwest. Teasing out the relative influence of these stressors has been a major obstacle in determining the causes of the declines and ways to mitigate them. The icon of insect beauty in the U.S. is the monarch butterfly, whose vibrant coloring, elegant form, and spectacular migrations inspire everyone. Beyond Pesticides has covered the distressing decline of these creatures, most recently in the June 24 Daily News. Monarchs prefer milkweed plants, but also visit many other flowers. Milkweed often grows along the margins of fields, so monarchs are widely exposed to pesticides and habitat disturbances associated with agriculture. The new study was published in PLoS One by a team of scientists from the Washington Department of Fish and Wildlife, Michigan State University, […]

(Beyond Pesticides, June 27, 2024) Earlier this month, Public Employees for Environmental Responsibility (PEER) filed a lawsuit against the U.S. Environmental Protection Agency (EPA) on behalf of a group of ranchers and farmers in Texas harmed by biosolids contaminated with per- and polyfluoroalkyl substances (PFAS). The plaintiffs charge that their health and livelihoods were severely damaged due to contaminated biosolids leaching from neighboring properties onto their land. Despite EPA’s responsibility under the Clean Water Act (Section 405(d) and 40 CFR Part 503) to identify toxic pollutants in biosolids and regulate them to protect human health and the environment, the agency has not effectively addressed the dangers posed by PFAS in biosolid fertilizers. EPA’s failure has dramatic impacts on farmers as well as the public, who are eating or drinking PFAS-contaminated crops, dairy milk, beef, or other meat products. The shortcomings of federal regulations underscore the urgent need for a shift in how federal and state agencies approach these issues, prioritizing precaution to prevent future harm. The persistence of these legacy or “forever” chemicals in the environment illustrates the severe consequences of a historically lax regulatory framework in the U.S.  The National Association of State Departments of Agriculture (NASDA) has identified […]

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

(Beyond Pesticides, June 21, 2024) A recent review of the scientific literature, published in Science of The Total Environment, analyzes multiple species of bees on a molecular level to better understand the poisoning mechanisms that could, as the authors see it, inform chemical risk assessments with more precision. The mechanisms “implicated in the tolerance of bees to specific pesticides, and thus as determinants of insecticide sensitivity, … include metabolic detoxification, insecticide target proteins, the insect cuticle and bee gut microbiota,” the authors write. This review references more than 90 studies performed over the last 30+ years, with most being published in the last 5-10 years, as the understanding and importance of molecular determinants of bee sensitivity has emerged. Pollinators, such as bees, provide crucial ecosystem services by pollinating both wild plants and essential crops. The exposure these insects are subjected to threatens their existence, which occurs through pesticide contamination that can lead to impacts on growth and development or even colony collapse.    “While bees have only been exposed to human-made pesticides over the recent past (last 80 years) they have co-evolved with plants and fungi which produce a range of xenobiotics, including plant allelochemicals and mycotoxins,” the authors state. […]

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

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

(Beyond Pesticides, June 12, 2024) A study of pesticide contaminated algae finds that the disruption of algal communities has a devastating effect on the health of the aquatic food web. The study findings show that contact with pesticides can result in changes to “algal physiology, causing tissue injury, developmental delay, genotoxicity, procreative disruption, and tissue biomagnification” that alters the dominance of algae species in the environment. This in turn “can impact higher trophic levels and have a domino effect on the aquatic food web. It is possible for biodiversity to disappear, reducing ecosystem stability and resistance to environmental alterations,” the authors state. The study, a worldwide literature review conducted by researchers from India, South Korea, and Saudi Arabia, appears in Aquatic Toxicology.  The health of aquatic ecosystems is at risk with indirect effects on nontarget species from pesticides in the environment. This includes impacts on species of fish, invertebrates, microbial communities, and marine mammals. In explaining the importance of extensively studying effects of pesticides, the researchers note, “Different pesticide classes have different chemical structures, which define their modes of action and affect how they interact with both target and nontarget organisms.” Because of this, the range of effects seen from […]

(Beyond Pesticides, June 11, 2024) Published in Science of The Total Environment in May, a comprehensive literature review of population-based studies finds strong linkages between direct and acute pesticide exposure and elevated risk of breast cancer (BC). A majority of the studies analyzed in this review were based on population groups in the United States, but also extends to Australia and three European countries (Greece, France, and Italy). Included in these studies are women who worked in chemical-intensive agricultural settings, directly sprayed pesticides in their at-home gardens, and/or handled pesticide-contaminated clothing. The findings in this literature review underscore organic advocates’ concerns of relying on pesticide substitution models that inevitably impact the health of land stewards, farmers, farmworkers, and the broader public rather than transforming food systems to an organic model that bans the use of toxic petrochemical-based pesticides. The goal of this review was to synthesize existing literature on pesticide exposure and breast cancer to determine the specific pathways and underlying mechanisms that contribute to female participants’ heightened risk. This literature review was published online by researchers at the University of Arizona’s R. Ken Coit College of Pharmacy and Coit Center for Longevity and Neurotherapeutics and the Laboratory of Tumor […]

(Beyond Pesticides, June 6, 2024) Researchers link pesticide exposure to behavioral effects on zebrafish (Danio rerio) larvae, signaling a larger issue for overall population and ecosystem effects. In a study published in Biomedicines, the authors conduct a multi-behavioral evaluation of the effects of three pesticides, both individually and as mixtures, on larvae. As the authors state, “Even at low concentrations, pesticides can negatively affect organisms, altering important behaviors that can have repercussions at the population level.” By analyzing effects on individual zebrafish with single compounds and mixtures, this study shows the dangers of pesticides in aquatic systems regarding synergy (a greater combined effect when substances mix) and the ripples created throughout entire ecosystems. Researchers from the Department of Morphology and Animal Physiology, as well as the Department of Physics, from the Rural Federal University of Pernambuco in Brazil collaborated with the Department of Biology at Indiana University in Indianapolis to perform the study. The researchers exposed zebrafish larvae to carbendazim, fipronil, and sulfentrazone to determine any behavioral effects on anxiety, fear, and spatial/social interaction for each compound separately and in combination. Each compound and mixture were applied to embryo medium, exposing fertilized zebrafish eggs. The embryos of zebrafish hatch, or […]

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

(Beyond Pesticides, May 24, 2024) Even allegedly “low-toxicity” pesticides such as flupyradifurone (insecticide), azoxystrobin, and difenoconazole (fungicides) pose adverse health effects to solitary ground-nesting squash bees (Xenoglossa pruinose), according to a study published in Biological Sciences. Fungicide exposure led to less pollen collected per flower, while exposure to flupyradifurone (FPF) produced larger offspring (which make it more challenging for them to fly). Simultaneous exposure to the three pesticides “induced hyperactivity in female squash bees relative to both the control and single pesticide exposure, and reduced the number of emerging offspring per nest compared to individual pesticide treatments.” With United Nations Food and Agriculture Organizations-sponsored World Bee Day earlier this week, now more than ever advocates are calling for the elimination of toxic insecticide classes, such as neonicotinoids and butanolides, and their wholesale replacement with organic land management principles. This study was written by Sabrina Rondeau, PhD, postdoctoral Fellow in the Department of Biology at the University of Ottawa, and Nigel E. Raine, PhD, professor at University of Guelph’s School of Environmental Science. Published on March 20, 2024, the researchers delve into the individual and co-exposure impacts of two fungicides and one insecticide, which is important, given the documented synergistic effects […]

(Beyond Pesticides, May 22, 2024) A study in the journal of Environmental Science and Technology Letters, funded by the National Oceanic and Atmospheric Administration, is the first to find halogenated organic compounds (HOCs) in deep ocean sediment and biota off the coast of California. The test area, known as the Southern California Bight (SCB), is home to historic offshore DDT waste dumping, with part of the SCB designated as a U.S. Environmental Protection Agency (EPA) Superfund site. 49 HOCs were detected in the sediment and biota, many of which are DDT-related and not previously screened for. The presence of these “unmonitored compounds can significantly contribute to the contaminant body burden across a range of marine taxa,” the study states, which leads to impacts on critical food webs and biodiversity. While this study is the first to specifically analyze previously overlooked DDT+ compounds, the results are nothing new. There is a body of science around the bioaccumulation and biomagnification of harmful pollutants that continue to lead to a decline in biodiversity, negative impacts on water and soil, and detrimental human health effects.       To assess the bioavailability of DDT+ and HOCs in the deep ocean food web, this study focused on […]

(Beyond Pesticides, May 21, 2024) In a first-of-its kind series of biomonitoring studies published in Agrochemicals, researchers identified the presence of the herbicides dicamba and 2,4-D in all pregnant participants from both cohorts in 2010-2012 and 2020-2022. The findings from this research are not surprising given the explosion of toxic petrochemical pesticides in the Midwest region of the United States. “The overall level of dicamba use (kilograms applied in one hundred thousands) in the U.S. has increased for soybeans since 2015 and slightly increased for cotton and corn,” the authors report, based on U.S. Department of Agriculture National Agriculture Statistics Service surveys. “The overall level of 2,4-D use (kilograms applied in one hundred thousands) in the U.S. was highest in 2010 for wheat, soybeans, and corn. The amount of 2,4-D applied increased the most for soybeans and corn from 2010 to 2020.” The researchers focused on the states of Illinois, Indiana, and Ohio, given the increase in dicamba and 2,4-D during the study period for both cohorts (2010-2022). The researchers are based at Indiana University School of Medicine in the Department of Biostatistics and Health Data Science and Department of Obstetrics and Gynecology, Quebec Toxicology Center within the Institut national […]

(Beyond Pesticides, May 16, 2024) In a recent study at the Institute of Biochemistry and Molecular Biology at Ulm University in Germany, published in Current Research in Toxicology, scientists exposed embryos of South African clawed frogs (Xenopus laevis) to three neonicotinoids (NEOs), which led to developmental effects down to a molecular level. These frogs are a well-established model species often used in ecotoxicology studies as bioindicators for overall environmental and ecosystem health. When amphibian species like Xenopus laevis are exposed to contaminants in the water, it leads to negative impacts in the food chain and harms biodiversity. The study concludes that exposure to NEOs directly or through contaminated water leaves entire ecosystems vulnerable.    The NEOs that the embryos were subjected to include imidacloprid (IMD), thiamethoxam (TMX), and its metabolite clothianidin (CLO). NEOs are a class of insecticides that target the central nervous system of insects and lead to death. These insecticides pose a potential hazard to nontarget organisms, such as animals and humans, since they are persistent in the environment and “are found in natural waters as well as in tap water and human urine in regions where NEOs are widely used,” this study states. The authors continue by […]

(Beyond Pesticides, May 15, 2024) A study published recently in the journal Environmental Research finds a significant correlation between exposure to certain pesticides and an elevated risk of inflammatory bowel disease (IBD), a chronic autoimmune condition of the gastrointestinal tract. The study, adding to the body of science on this subject, evaluates self-reported data from licensed pesticide applicators and their spouses exposed to pesticides for over 20 years. In addition, while some of the chemicals found to be most closely associated with incidents of IBD have been banned from use, they are “forever” chemicals that persist in the environment for generations. These findings demonstrate once again the failings of the current regulatory process to identify hazards before they are put into the environment. The study found evidence that exposure to several organochlorine insecticides (dieldrin, DDT, and toxaphene), as well as organophosphate insecticides (parathion, terbufos, and phorate) and herbicides (2,4,5-T, 2,4,5-TP, and metolachlor), is associated with elevated IBD risk. IBD is a generic term for diseases that result in chronic inflammation of the gastrointestinal tract, such as Crohn’s disease and ulcerative colitis. It is estimated that 6.8 million patients globally suffered from IBD in 2017. IBD may result from an imbalance […]

(Beyond Pesticides, May 13, 2024) A study published in Environmental Research finds that “early life organophosphate pesticide exposure has been linked with poorer neurodevelopment from infancy to adolescence.” Researchers in this study acknowledge that there is still much more to be done in furthering understanding of “neural mechanisms underlying these associations,” and yet there is “notable consistency” in their Center for the Health Assessment of Mothers and Children of Salinas (CHAMACOS) birth cohort study. This study’s findings are consistent with decades of substantial, peer-reviewed scientific literature documenting the adverse health impacts of organophosphate pesticides on public and ecological health. Organic advocates believe that a transition away from chemical-intensive agriculture and land management is the most viable solution to avoid adverse health impacts and end reliance on toxic chemicals in households and communities. The researchers for this study are based at the University of California, Berkley (Center for Environmental Research and Community Health as well as Center for Interdisciplinary Brain Sciences Research), Department of Public Health at University of California, Merced, and Stanford University (Departments of Radiology and Pediatrics in the School of Medicine). “We have reported associations of prenatal [organophosphate] exposure with poorer cognitive function and executive function, and more attention and […]

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

(Beyond Pesticides, May 8, 2024) In an unexpected turnaround, the U.S. Environmental Protection Agency (EPA) announced at the end of April a Proposed Interim Decision (PID) to discontinue all but one application of the insecticide acephate. Acephate is an organophosphate pesticide, a well-known neurotoxicant, widely banned globally, including in the European Union. Under the proposal, all uses would end except for the injection of trees that do not produce fruit or nuts. In its proposed action, EPA asks the manufacturer to offer the agency a voluntary settlement, a process that typically compromises the health of the public, workers, and the environment. Acephate, an organophosphate (OP) pesticide, is approved for use in both agricultural settings, including crops like cotton and soybeans, and nonagricultural applications, such as injections for forestry trees. Acephate affects the nervous system by inhibiting the acetylcholinesterase (AChE) enzyme. Importantly, chronic, low levels of exposure can cause a range of adverse human health outcomes, from cancer to birth defects, reproductive and developmental problems, and learning disabilities. While the proposed April interim decision, if it comes to pass, is welcomed by advocates, some are concerned that EPA’s proposal does not fully critique the scientific documents and conclusions on risk that […]