(Beyond Pesticides, March 6, 2013) The Minnesota Pollution Control Agency announced on March 3rd that state agencies have been ordered by Governor Mark Dayton to stop buying products that contain triclosan, a synthetic, broad-spectrum antimicrobial agent that has become ubiquitous in consumer products ranging from face-washes to fabrics. This ban, which will go into effect in June, comes as the debate over the efficacy and necessity of triclosan intensifies in the Minnesota State legislature. A bill banning triclosan’s use outside of medical settings is expected to be introduced this week, and the legislature conducted a hearing Tuesday on the possible human health and environmental consequences of the chemical. The state government, about 100 school districts, and local governments together currently buy about $1 million worth of cleaning products annually through joint purchasing contracts. Many of these products contain triclosan, but the U.S. Food and Drug Administration concluded in 2010 that products containing triclosan are no more effective than plain old-fashioned soap and water. “There are alternatives, and they are at the same price,” said Cathy Moeger, sustainability manager for the Minnesota’s Pollution Control Agency. “If it has an environmental benefit, why not do it?” Triclosan has been used for over […]

(Beyond Pesticides, March 1, 2013) In a literature review published in Toxicology last week, researchers found that environmental and occupational pesticide exposure was strongly associated with declines in sperm count. Researchers Sheena Martenies, BS, and Melissa Perry, ScD., MHS., determined that of the 17 studies evaluated, 15 of them reported significant associations between pesticides and semen quality. The researchers counted semen quality according to concentration of sperm over an area, their motility and ability to move, as well as their shapes. Researchers targeted studies on DDT, HCH, and abamectin, grouping pyrethroids and organophosphates by class. What they found was striking: almost all the studies reported a decrease in sperm concentration; decreased motility was also reported though less frequently; while morphological changes were not strongly associated in studies””only two indicated any changes to sperm shape. These findings build on a growing body of evidence that pesticide exposure at environmental or occupational levels diminished sperm health. In addition to the U.S. findings,  studies conducted on French, New Zealander, Indian, Tunisian, and Israeli men have all found decline in sperm count. Some studies record a drop by approximately 50% between 1940 and 1990, no small amount. These results might not be surprising as […]

(Beyond Pesticides, February 27, 2013) Last week a U.S. Court of Appeals found that pesticide restrictions to protect endangered salmon and steelhead proposed by the National Marine Fisheries Service (NMFS) in its Biological Opinion (BiOp) were “arbitrary and capricious,” supporting Dow AgroSciences LLC and other pesticide makers’ claims that the restrictions were based on “unsupported assumptions and conclusions.” The BiOp concluded that the pesticides chlorpyrifos, malathion and diazinon, three of the most highly toxic pesticides still in use, pose risks to salmon, steelhead and their habitat. In collaboration with NMFS, the U.S. Environmental Protection Agency (EPA) is tasked with implementation of any recommended pesticide restrictions to satisfy the mandate under Section 7 of the Endangered Species Act (ESA). However, to date, EPA has not taken any actions to implement any of the proposed measures to protect endangered salmon and steelhead, in part due to challenges from industry. Dow AgroScience LLC, Makhteshim Agan of North America, Inc., and Cheminova, Inc. USA first filed a suit in 2009 (Dow Agrosciences v. National Marine Fisheries ), challenging the NMFS’ 2008 BiOp to restrict  chlorpyrifos, malathion and diazinon as being based on numerous unsupported assumptions and conclusions, and faulty analyses. The U.S. District Court […]

(Beyond Pesticides, February 26, 2013) The world’s most commonly used synthetic insect repellent is not  as effective as it once was, according to scientists at the London School of Hygiene and Tropical Medicine. While researchers found DEET to be an effective repellent after an initial application, subsequent rounds of testing mere hours later showed mosquitoes to be unaffected by its presence. The study, published in the journal PLOS One, underlines the need to develop safe, natural, effective alternative preventions to this hazardous chemical. To perform their experiment, researchers took the mosquito species Aedes aegypti, a carrier for dengue and yellow fever, and exposed it to a human arm covered in DEET. A few hours later they repeated the experiment, but this time the mosquitoes largely ignored the presence of the chemical. To find out what caused this to occur, researchers placed electrodes on the antennas of the insects. “We were able to record the response of the receptors on the antenna to DEET, and what we found was the mosquitoes were no longer as sensitive to the chemical, so they weren’t picking it up as well,”   co-author James Logan, PhD told the BBC.  “There is something about being exposed […]

(Beyond Pesticides, February 21, 2013) On February 6, the U.S. Environmental Protection Agency (EPA) released its preliminary volatilization assessment for the registration review of chlorpyrifos, finding that vapor phase chlorpyrifos may be emitted from treated fields at levels resulting in exposure to children and others who live, work, attend school, or otherwise spend time nearby.  In some circumstances, these bystanders may be exposed to chlorpyrifos and/or the transformation product chlorpyrifos-oxon at concentrations that could cause adverse effects. Citing uncertainties, the agency is requesting comments by March 8, 2013 on the potential risks to children and other bystanders from volatilization of chlorpyrifos from treated crops. EPA’s preliminary volatilization assessment is also in response to a petition filed by the Natural Resources Defense Council (NRDC) and the Pesticide Action Network North America (PAN) in 2007, which requested that the agency revoke all tolerances and cancel all registrations for chlorpyrifos. In a letter to NRDC and to PAN dated January 25, 2013, updating these groups on EPA’s response to their September 12, 2007 joint petition regarding chlorpyrifos, EPA stated that, “This assessment represents a significant advancement in the evaluation of pesticide risks, as it will be the first probabilistic assessment of the risks […]

(Beyond Pesticides, February 12, 2013)   Is 2013 the year colony collapse disorder (CCD) begins impacting our food supply? According to the American Bee Journal, almond growers in California may not have access to the honey bee colonies necessary to pollinate this year’s crop. “We need 1.6 million colonies, or two colonies per acre, and California has only about 500,000 colonies that can be used for that purpose. We need to bring in a million more colonies but due to the winter losses, we may not have enough bees,” says Eric Mussen, PhD,  extension apiculturist at the University of California Davis (UC Davis) Department of Entomology. The problem, Dr. Mussen explains, is due to heavy losses this winter and less populous hives overall. Some beekeepers are reporting astonishing winter losses upwards of 90 percent, and in select cases complete colony loss. Honey production in 2012 was one of the worst years in the history of the United States, Dr. Mussen notes. Less honey means less food for overwintering bees, putting increased stress on colonies attempting to fight off the spread of CCD. CCD is the name given to the precipitous decline of honey bee populations around the world beginning in […]

(Beyond Pesticides, February 11, 2013) The U.S. Environmental Protection Agency (EPA) has announced its decision to allow residues of the cancer causing insecticide endosulfan on imported Chinese teas until July 31, 2016. Its decision to provide “additional time to transition to an alternative to endosulfan” raises serious concerns of further exposure to the toxic carcinogen for farmworkers and consumers. In May 2011, EPA proposed to revoke all tolerances for endosulfan, as, “It can pose unacceptable health risks to farmworkers and wildlife and can persist in the environment.” The agency proposed transition time that would allow growers time to adopt alternatives, with the last four uses ending on July 31, 2016. For tea, EPA proposed an immediate revocation, since there is little if any endosulfan used in tea production in the U.S. However, the Chamber of Commerce of the Zhejiang International Tea Industry filed a complaint indicating that it would need five years or less to find feasible alternatives to endosulfan. It also indicated that it was unable to provide comment on the tolerance revocation ruling as the EPA did not provide proper notice to the World Trade Organization. In acknowledging this oversight, EPA will allow endosulfan residues of 24 parts […]

(Beyond Pesticides, February 8, 2013) A recent study conducted at the University of Granada, Spain and published in the Journal Environmental Research proposes a link between exposure to persistent organic pollutants (POPs) in food, air, and water and prevalence of type 2 diabetes in adults, regardless of age, gender, and body mass index. The paper concludes that people with higher concentrations of DDE, the break down product of DDT, are four times more likely to develop type 2 diabetes compared to other participants in the study. Increased rates of type 2 diabetes are also associated with exposure to beta-hexachlorocyclohexane, a break down product of the toxic chemical lindane, which in still allowed for use in agriculture and certain formulations of products used to treat lice and scabies. The study was carried out by analyzing the concentrations of specific POPs in adipose, or fat, tissue of 386 adults undergoing non-cancer-related surgery in Spain. According to one of the authors of the study, Juan Pedro Arrebola, “Human adipose tissue acts as an energy reservoir and has an important metabolic function. However, adipose tissue can store potentially harmful substances, such as POPs.”    The study found that as concentrations of POPs grows in […]

(Beyond Pesticides, February 6, 2013) The U.S. Environmental Protection Agency (EPA) has proposed to register a new insecticide, sulfoxaflor, which the agency has classified as “very highly toxic” to honey bees. Despite efforts underway in Europe to protect bee populations, and continued warnings from beekeepers, EPA is poised to allow another chemical toxic to bees into the environment without proper field studies evaluating long-term effects to bee colonies and with label statements that are impractical and unenforceable. With continuing reports of bee deaths, would sulfoxaflor be yet another bee disaster waiting to happen? Take action and tell EPA not to repeat past missteps and protect pollinators from sulfoxaflor by providing a public comment to EPA.   (see below for sample comments). Last month, EPA opened the comment period for the proposed conditional registration of sulfoxaflor, a new active ingredient, whose mode of action is similar to that of neonicotinoid pesticides -it acts on the nicotinic acetylcholine receptor (nAChR) in insects. Even though it has not been classified as a neonicotinoid, it elicits similar neurological responses in honey bees, with many believing that sulfoxaflor is the new generation of neonicotinoid.  EPA has noted that sulfoxaflor is highly toxic to bees, and […]

(Beyond Pesticides, February 1, 2013) The European Commission announced yesterday its position against the use of neonicotinoid insecticides, pushing nations within the European Union (EU) to impose a two year suspension on their use. The proposal, put forward at a meeting of the Standing Committee on the Food Chain and Animal Health, would restrict the application of neonicotinoids as granules, seed-treatment or spray, on crops that are attractive to bees, particularly, sunflowers, rapeseed, corn, cotton, and cereal crops. Environmental groups say that this decision should signal the way forward for the U.S. Environmental Protection Agency (EPA) to suspend neonicotinoids in the U.S. “It’s a great thing,” said New York beekeeper Jim Doan, “I’m hoping that the EPA follows in their footsteps. While I recognize our government works differently, it says something that the European government has recognized the overwhelming data on the impact of these pesticides.” The announcement comes on the heels of research conducted by the European Food Safety Authority (EFSA) which indicated that three neonicotinoid insecticides””imidacloprid, clothianidin, and thiamethoxam, produced by Switzerland’s Syngenta and Germany’s Bayer, pose an unacceptable hazards to honey bees. In its report released January 16th, EFSA concludes that systemic contamination of neonicotinoid-treated crops, neonicotinoid […]

(Beyond Pesticides, January 31, 2012) A new study finds that a mother’s exposure to pesticides before, during and after pregnancy may increase the risk of infant leukemia diagnosed before the age of two. Researchers in Brazil found that children are twice as likely to develop the rare cancers if their mothers were exposed three months before conception when compared to mothers who reported no exposures. A mother’s exposure at any time to the insecticide permethrin also raised the cancer risk for infants. The results support recommendations for women of reproductive age to minimize their pesticide exposure before and during pregnancy and while breastfeeding, and adds to the growing weight of evidence of the dangers of using synthetic pyrethroid pesticides. The study, entitled, “In utero pesticide exposure and leukemia in Brazilian children less than 2 years of age,” is published in Environmental Health Perspectives. Researchers asked mothers in Brazil about their pesticide exposure three months before pregnancy, while pregnant and three months after pregnancy when they were nursing. The women reported their home, work and agricultural contact with pesticides (at least once) between 1999 and 2007. Pesticide exposures from mothers of 252 children younger than two years old and diagnosed with […]

(Beyond Pesticides, January 29, 2013) A new study has discovered the anti-bacterial chemical triclosan and several of its toxic derivatives in sediment samples taken from freshwater lakes. Research published in the journal Environmental Science and Technology reveals the chemical to be present in increasing concentrations since it was first invented in the 1960’s. The results of this study put increased pressure on lawmakers and cosmetic companies to remove this chemical from consumer products. Beyond Pesticides and other groups, which have petitioned the U.S. Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) to remove triclosan from a vast array of consumer products, continues to urge cosmetic companies to take action on the chemical in the face of inadequate regulation to protect human health and the environment. Scientists tested  eight sediment samples from freshwater lakes across Minnesota, including Lake Superior. Bill Arnold, Ph.D.,  co-author of the study and professor at University of Minnesota notes, “We found that in all the lakes there’s triclosan in the sediment, and in general, the concentration increased from when triclosan was invented in 1964 to present day. And we also found there are seven other compounds that are derivatives or degradation products of […]

(Beyond Pesticides, January 28, 2013) Research published Thursday indicates that pesticides widely used on farms are highly toxic to frogs. Researcher Carsten Brühl, Ph.D., at the University of Koblenz-Landau in Germany called the results “alarming” with the potential for “large-scale effects” on amphibians. Two chemicals commonly used in orchards and on grains demonstrated a 100% mortality rate when researchers applied doses recommended on the label, raising serious concerns about the strength of pesticide regulations. The research builds on Brühl’s previous work on the ability of frogs to absorb pesticides through their porous skin, which is necessary for breathing underwater. More importantly, the study highlights the threats that pesticides post to biodiversity. Amphibians are considered the most threatened and rapidly declining vertebrate group, with more than a third of all amphibians listed in the International Union for Conservation of Nature and Natural Resources (IUCN) “Red List” of threatened species. The organization lists loss of habitat, climate change, and disease as the most serious threats to amphibian populations. The scientific community is increasingly recognizing the role of chemical pollutants in amphibian decline. Though sadly, regulatory agencies do not: pesticides are not even required to be tested on amphibians before the pesticide is […]

(Beyond Pesticides, January 24, 2013) Checks are now being sent to 1,085 community water systems across the U.S. in the final phase of a $105 million settlement with Syngenta, the largest manufacturer of the toxic weed killer atrazine. The class action settlement, City of Greenville v. Syngenta Crop Protection, Inc., Case No.: 3:10-cv-00188-JPG-PMF, stems from a lawsuit spanning eight years and is meant to help reimburse communities for past expenses associated with atrazine removal. “Science has been fighting an uphill battle against giant pesticide manufacturers like Syngenta who claim that a little weed killer in your drinking water won’t hurt you. Independent scientists now believe that even trace amounts can harm you and your children for generations to come,” the lead plaintiff’s lawyer Stephen M. Tillery told the media. Atrazine is used nationwide to kill broadleaf and grassy weeds, primarily in corn crops. A potent toxicant, it is the most prevalent herbicide found in Minnesota’s waters. It is widely applied in the midwestern states and has been found in the drinking water supplies in the Midwest at high levels. Researchers at the Centers for Disease Control (CDC) have determined that previous studies that assessed population-based exposure to atrazine were significantly […]

(Beyond Pesticides, January 23, 2013) A new federal report finds toxic contamination remains widespread in the Chesapeake Bay, with severe impacts in some places, which health and environmental advocates say lends support to their push in Maryland for legislative action on pesticides and other hazardous chemicals. In spite of some cleanup, the health of the Bay has not significantly improved. The report, “Technical Report on Toxic Contaminants in the Chesapeake Bay and its Watershed: Extent and Severity of Occurrence and Potential Biological Effects” is based on a review of integrated water-quality assessment reports from the jurisdictions in the Bay watershed (Delaware, Maryland, New York, Pennsylvania, Virginia, West Virginia, and Washington, D.C.), Federal and State reports, and articles in scientific journals. It notes that nearly three-fourths of the Bay’s tidal waters are “fully or partially impaired” by toxic chemicals, with people warned to limit fish consumption from certain areas. Contamination is severe in a handful of “hot spots” around the Bay, including Baltimore’s harbor, largely a legacy of past industrial and shipping activity. Previous reports have called on federal, state and local government to accelerate research into what threats chemical contamination may pose to the Bay, and to step up efforts […]

(Beyond Pesticides, January 22, 2013) The U.S. Environmental Protection Agency (EPA) recently faced tough questioning from the U.S. Court of Appeals for the Ninth Circuit over its decision to conditionally approve a pesticide product containing nanosilver as the active ingredient. The antimicrobial pesticide product, HeiQ AGS-20, contains microscopic particles of silver and has been applied to textiles such as clothes, blankets, and pillowcases, in an attempt to suppress odor and bacterial growth. The main argument in the Natural Resource Defense Council (NRDC) v. EPA lawsuit is that EPA was wrong  to assume that 3-year-olds would be the most vulnerable consumers. Instead, NRDC attorney Catherine Rahm of Washington argued that, “Infants are more likely than any other subgroup to chew on fabrics that could contain this pesticide.” In arguments over whether EPA lawfully granted conditional registration to HeiQ AGS-20, NRDC challenged EPA’s risk assessment for infants and children claiming the agency erred by assuming in its risk assessment that 3-year-olds would be the most vulnerable consumers. Up for debate is oral exposure to the product and whether 3-year-olds chew more aggressively than infants and produce more saliva, an important factor for extracting nanoparticles from products and becoming exposed. NRDC contends EPA’s […]

(Beyond Pesticides, January 17, 2013) The European Food Safety Authority (EFSA) yesterday presented its report which finds that the neonicotinoid class of insecticides poses unacceptable hazards to bees. The report concludes that certain crops treated with neonicotinoid chemicals –imidacloprid, clothianidin and thiamethoxam– are of “critical concern” for bee health. Beekeepers and environmental activists welcome these recent scientific findings that they say support a U.S. ban on these chemicals. According to Jay Feldman, Executive Director, Beyond Pesticides, “The EFSA report confirms what we have been asking EPA to recognize. Clothianidin and other neonicotinoids are highly toxic to bees, and should be banned by EPA and removed from the environment.” In its investigation, EFSA, which was tasked with assessing the risks associated with these chemicals to bee colony survival and development, found that systemic contamination of neonicotinoid-treated crops and contamination via dust place honey bees and the hives they return to at high risk. Exposure to contaminated dust pose a high risk to honey bees for all three neonicotinoids used on corn and certain other crops, as well as exposure to residues in nectar and pollen. High risks were also identified from exposure to guttation fluid from corn for thiamethoxam. EFSA considered […]

(Beyond Pesticides, January 16, 2013) Children living near chemical-intensive or conventional plantations in Costa Rica are exposed to twice as much of the insecticide chlorpyrifos compared to children living near organic plantations, a study reports. More than half the children, mostly from indigenous tribes- Ngäbe and Bribri – have a  higher daily exposures than allowed under U.S. federal standards. Chlorpyrifos is linked to neurological effects, especially in children, and is still permitted for use on crops. The study,  Indigenous children living nearby plantations with chlorpyrifos-treated bags have elevated 3,5,6-trichloro-2-pyridinol (TCPy) urinary concentrations, was lead by Berna van Wendel de Joode, PhD  (Central American Institute for Studies on Toxic Substances (IRET), Universidad Nacional, Heredia, Costa Rica). It was conducted in Costa Rica’s banana and plantain plantations in the Talamanca region, and  targeted villages situated nearby to the plantations where blue bags treated with chlorpyrifos are routinely used to protect banana and plantain crops from pests. Two villages under study are near plantations that use chlorpyrifos-treated bags, while the organic village is near several plantations  that use little or no insecticide. For 140 children, aged 6 — 9, mostly indigenous Ngäbe and Bribri, parent-interviews and urine samples were obtained. Chlorpyrifos’ environmental levels […]

(Beyond Pesticides, January 15, 2013)  Research published in the journal Environmental Monitoring and Assessment calls into question the value of environmental monitoring, such as water sampling,  on a  fixed date schedule (i.e., once per month), finding that this approach underestimates actual risks. These findings could have a significant impact on how we assess the safety of both endangered species and drinking water supplies. Researchers explain that, although insecticides are applied less often than herbicides and fungicides, they are usually applied in very large amounts when used in response to acute insect infestations. Scientists found that monitoring for insecticides at pre-set intervals, even weekly or daily, did not detect the occurrence of peak concentrations for these chemicals. Co-author of the study, Ralf Shulz, PhD, explains, “Accordingly, by way of example, on the basis of weekly monitoring of a typical agricultural stream none of the total of six insecticide concentration peaks per year described by model calculations is found. Daily sampling detects only two of the six peaks. Only event-related sampling enables the detection of all these peaks.” Authors of the study point to the need for events-related sampling, both to ensure more accurate detections are taken and to reduce costs. Events-related […]

(Beyond Pesticides, January 11, 2012) Environmentalists, farmworkers, and farmworker advocates have become increasingly uncomfortable with the new proposal for pesticide safety measures which does not include details on how the proposed rule will protect agricultural workers, farmers, and applicators. These sentiments stem from the concern that this may mean less stringent regulations than those originally proposed. In 2010, the U.S. Environmental Protection Agency (EPA) released a   document proposing Worker Protection Standards (WPS) that would determine ways to increase training, improve safety requirements, provide clear emergency information, and create strong protection for applicators. However, a recent EPA handout distributed  during a November 2012 Pesticide Program Dialogue Committee (PPDC) meeting downplays the details within those goals, and brings into question the agency’s  previous commitments. Advocacy groups have raised pointed complaints on the new document’s prose: “I have to agree that we are just really in the dark,” said one environmental group lawyer, “It is mysterious that it’s taken them so long to come up with a draft to propose, and the fact that they are being kind of tight-lipped about it and that even the very minimal detail about the proposal that was in the 2010 document disappeared from the 2012 […]

(Beyond Pesticides, January 8, 2013) Neurologists at the University of California, Los Angeles (UCLA) have published their latest research linking pesticide exposure to Parkinson’s disease. Appearing in the online edition of PNAS, the UCLA scientists’ work details the series of events that can occur after individuals are exposed to the pesticide benomyl, which was phased out in 2001. Researchers believe their findings on the series of events the pesticide sets in motion could be applicable even to Parkinson’s patients who have not been exposed to benomyl. According to scientists, exposure to benomyl prevents the enzyme aldehyde dehydrogenase (ALDH) from keeping in check a naturally occurring toxin in the brain called 3,4-Dihydroxyphenylacetaldehyde (DOPAL). Without ALDH regulating DOPAL, the toxin accumulates, damages neurons, and increases an individual’s risk of developing Parkinson’s disease. Researchers postulate that this process may be occurring in people with Parkinson’s who were never exposed to pesticides. The findings of this research provide insight into possible treatments to slow the disease, such as developing new drugs to protect ALDH activity. Although the exact cause of Parkinson’s is still unknown, until this research scientists were focusing in on the protein a-synuclein as a pathway to the disease. The protein, present […]

(Beyond Pesticides, January 4, 2013) On December 31, 2012, the U.S. Environmental Protection Agency (EPA) proposed to clarify its labeling requirement for disclosure of all active and inert ingredients in “minimum risk pesticide products,” exempt from registration under Section 25 (b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The rule (77 FR 250) reorganizes the list of eligible active and inert ingredients by adding identifiers that will clarify for the public, and more importantly for federal and state inspectors, which ingredients are permitted in minimum risk pesticide products. The modification would require labels to use common chemical names in the list of ingredients as well as the contact information for the manufacturer. The lack of clarity on minimum risk pesticide product labels in the past has made it difficult for enforcement officials who must use their own judgment on the applicability of vague descriptors such as cedar leaf oil and cedar wood oil, which are exempt under the current listing of “Cedar Oil” under CFR Section 152.25. While EPA has attempted to improve labeling clarity of minimum risk pesticide products by updating its website, stakeholders have found the measure insufficient. Regulatory Background Currently, EPA is empowered under FIFRA […]

(Beyond Pesticides, December 19, 2012) The Congressional Research Service (CRS) issued its overview report, Bee Health: The Role of Pesticides, in response to a congressional request for more information on the connection between declines in bee populations, colony collapse disorder (CCD) and pesticides, particularly neonicotinoids. The 23-page report, dated December 11, 2012, summarizes the range of scientific studies and regulatory activities without offering a critique of what bee health advocates have identified as serious deficiencies in the regulatory review process and compliance with the pesticide registration law. The review gives equal standing to independent and industry science. The CRS report identifies a range of issues regarding: 1. Changes to managed and wild bee populations (indicating limited information); 2. Factors that are documented to impact bee health, including pesticides, pests and diseases, diet and nutrition, genetics, habitat loss, and beekeeper issues, highlighting that there are multiple exposure pathways that may work synergistically; 3. Scientific research on the role of pesticides; and, 4. Current research and regulatory activity regarding neonicotinoids, a neurotoxic insecticide impacting bees. The report reviews the ‘state of play’ on the issue of bee declines and finds that there are reported to be many factors that contribute to the […]