(Beyond Pesticides, November 20 2024) The perpetual use of pesticide coated seeds and tillage changed the composition of various beetle, spider, and other epigeal arthropod communities on New Hampshire farmland, according to a recent study published in Agriculture, Ecosystems, and Environment. Researchers fell short of finding conclusive results about the multi-variable impacts of both practices on biodiversity but raise notable issues on the impact of treated seeds. This research builds on the existing peer-reviewed scientific literature that highlights the threats of toxic pesticides and pesticide-coated seeds. Environmental and public health advocates are in agreement with organic and agroecological farmers who reject chemical-intensive land management practices. “At the root of the cascading crises of public health collapse, biodiversity loss, and the climate crisis is a reliance on petrochemical-based toxic products, rather than public policy and investments that strengthen consumer and institutional trust of nature-based, organic systems,” says Max Sano, organic program associate at Beyond Pesticides. “This is consistent with various interactions I have had with advocates across New England who are demanding action to stymie the impending biodiversity collapse enabled by government inaction.” Background and Methodology This study was coauthored and led by environmental researchers at the Department of Natural Resources […]

(Beyond Pesticides, October 30, 2024) STARTS TODAY at 2 PM EDT—NATIONAL FORUM: IMPERATIVES FOR A SUSTAINABLE FUTURE. Beyond Pesticides has filed suit against The Scotts Miracle-Gro Company and GreenTechnologies, LLC for allegedly misleading consumers on the hazardous nature of their fertilizer products, which contain sewage sludge (often referred to as biosolids) contaminated with per- and polyfluoroalkyl substances (PFAS). The group filed two cases, Beyond Pesticides v. Miracle-Gro Co. and Beyond Pesticides v. GreenTechnologies, LLC, in D.C. Superior Court on October 25, 2024. The complaint alleges that, as part of their marketing, these companies tell consumers that their fertilizers are “eco-friendly” and “sustainable,” when, in fact, the products contain hazardous substances. The complaint cites test results showing PFAS residues in the companies’ fertilizers and numerous scientific studies on the adverse effects of PFAS to public health, wildlife, and pollinators.   PFAS, known as “forever chemicals” due to their ability to persist in the environment, are endocrine disruptors linked to developmental issues, cancers, metabolic, cardiovascular and reproductive harm, damage to the liver, kidneys, and the respiratory system, as well increased chances of disease infection and severity. The chemicals’ immunotoxic effects threaten human health.  Beyond Pesticides alleges that consumers are, thus, misled by advertising in which Scotts Miracle-Gro […]

Beyond Pesticides (October 17, 2024) On September 30, 2024, the U.S. Environmental Protection Agency (EPA) opened a public comment period about production of specific per- and polyfluoroalkyl substances (PFAS, also known as ‘forever chemicals’)—including perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), and perfluorodecanoic acid (PFDA). EPA is collecting information on the fluorination process of high-density polyethylene (HDPE) and other plastic containers to inform possible regulatory action under the Toxic Substances Control Act (TSCA). The deadline for submitting comments is November 29, 2024. PFOA and twelve other PFAS compounds are created during the fluorination of HDPE plastic containers by Inhance Technologies, LLC, the only U.S. company manufacturing containers using this fluorination technique (see here). Studies by EPA, independent researchers, and the company itself demonstrate that PFAS leaches from container walls into contents, exposing millions to these toxic chemicals without their knowledge. EPA notes, “Long-chain PFAS like PFOA, PFNA, and PFDA build up in our bodies and the environment over time. Even small amounts can significantly contribute to people’s long-term exposure and health risk for cancers, impacts to the liver and heart, and immune and developmental damage to infants and children.” The adverse effects of PFAS exposure are linked to serious health issues, […]

(Beyond Pesticides, September 19, 2024) An article published in the journal Science of the Total Environment finds that the European Union’s (EU) risk assessment process, required for registration, fails to accurately or reliably predict pesticide exposure rates, sometimes by several orders of magnitude. Pesticide registration in the EU leverages the Agricultural Operator Exposure Model (AOEM)—a predictive model developed in 2014 to estimate expected non-dietary pesticide exposure levels for operators [pest control operators in the U.S.] based on a very limited set of data generated by the pesticide industry. Models that predict real-world exposure and underestimate field data raise critical questions about the efficacy of risk assessment reviews that determine product labels and allowed level of harm. By comparing the dermal exposure measured during a field study conducted in a nonagricultural area with the corresponding values estimated by AOEM, researchers in France add to the body of scientific literature indicating that the fossil fuel and petrochemical pesticide industry data cannot be relied upon as a benchmark to ensure public health and safety. The study describes the difficulty and complexity of calculating the ability of protective equipment to provide protection. According to the authors, “[AOEM] underestimated hand exposure by 42 times and […]

(Beyond Pesticides, September 18, 2024) A literature review in Trends in Analytical Chemistry analyzes scientific articles from the last ten years from around the globe that identify more than 300 pesticides in bee pollen. Bee pollen, often used as an edible dietary supplement, is not regulated for pesticide residues, which sparks concern for human exposure due to contamination with pesticides, heavy metals, metalloids, and mycotoxins. “Bee pollen is a food supplement that is receiving increasing attention for its nutraceutical and therapeutic properties. However, several uncertainties on the safety of this beekeeping product still exist. The present work addressed this issue through the critical evaluation of 61 studies, published over the 2014–2024 period,” the Spanish authors state. Bee pollen is produced by honey bees. After they forage on flowers and gather pollen on their hind legs (in pollen baskets or corbiculae) to transport back to the hive, it is moistened with nectar and salivary secretions to create bee pollen in the form of pellets. While the composition of bee pollen can vary between geographical locations with different flowers, the studies reviewed all utilize mass spectrometry to pinpoint pesticides, as well as mycotoxins (created by naturally occurring mold spores), that threaten human […]

(Beyond Pesticides, August 2, 2024) In a recent study published in Science, a team from the University of Massachusetts and Yale University provides quantitative insight into the significant effects of a recent U.S. Supreme Court decision on the nation’s water quality. This research highlights the essential role of ephemeral streams—water sources that flow temporarily after rainfall—in transporting pollutants, including pesticides, sediments, and nutrients from land to larger water bodies.  This comprehensive study underscores the devastating risk to U.S. water quality, stemming from the May 2023 U.S. Supreme Court decision, Sackett v. Environmental Protection Agency (EPA), which dramatically limits the agency’s ability to protect ephemeral streams as well as critical wetland ecosystems under the Clean Water Act (CWA).  As a May 2024 report by Clean Water for All Coalition notes, “The [Sackett] decision has endangered the drinking water sources of at least 117 million Americans by stripping protections from over half of the nation’s wetlands, as well as up to nearly 5 million miles of rain-dependent and seasonal streams that feed into rivers, lakes, and estuaries.” At a time when an immediate response to the climate crisis and chemical pollution is more urgent than ever, the U.S. Supreme Court’s judicial decisions are seen […]

(Beyond Pesticides, July 26, 2024) Beyond Pesticides released the latest issue of Pesticides and You this week, a compendium of scientific research on pesticide threats to human and environmental health. The issue is a breathtaking warning from the science community that environmental, health, and labor laws are not protecting the public. Beyond Pesticides says in its introduction that a shift away from toxic pesticide use is urgently needed. Included in this issue are scientific reviews of research reported by Beyond Pesticides in 2023, providing a critique of the independent peer-reviewed literature with a shocking range of adverse effects, including cancer, neurotoxicity, brain effects, reproductive impacts, diabetes and obesity, chronic kidney and liver disease, Parkinson’s, respiratory illness and asthma, learning and behavioral abnormalities, and more, as well as disproportionate harm to people of color. In addition, the science documents pesticides’ catastrophic harm to the ecosystems that sustain life. In total, these dramatic findings call for an end to the use of toxic pesticides, incompatible with respect for living organisms and, to environmental, health, and labor advocates, unconscionable given the availability of viable, cost-effective organic practices. This issue adds to the body of knowledge from two previous issues of Pesticides and You (Transformative Change: […]

(Beyond Pesticides, July 24, 2024) The Center for Food Safety—joined by environmental, farm, and grassroots organizations including Beyond Pesticides—submitted a groundbreaking petition yesterday to the U.S. Environmental Protection Agency (EPA), urging immediate action to address the presence of per- and polyfluoroalkyl substances (PFAS) in pesticides and pesticide containers. Numerous studies have shown that the broad use of PFAS chemicals, and the resulting environmental contamination, has devastating impacts on public health, wildlife, and pollinators. Despite acknowledging PFAS as an urgent public health and environmental issue, EPA has upheld hundreds of registrations of pesticide ingredients that fall into the PFAS category. Furthermore, EPA has allowed the ongoing use of fluorinated pesticide storage containers, despite the agency itself finding that these containers leach PFAS chemicals into pesticide products.   PFAS, known as “forever chemicals” due to their ability to persist in the environment, are endocrine disruptors, which are linked to developmental issues, cancers, and organ damage. Crops can uptake PFAS from soil, resulting in dietary exposure for both the public and wildlife, while PFAS ingredients in pesticides can also leach into groundwater, contributing to widespread PFAS drinking water contamination. In recent years, EPA has acknowledged this critical issue and committed to addressing PFAS contamination outside […]

(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, May 1, 2024) According to a new analysis by Consumer Reports, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. A review of seven years of PDP data show that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day, according to Consumer Reports analysis. Consumer Reports contend that U.S. Environmental Protection (EPA) pesticide residue tolerances are too lenient. To better evaluate potential health risks associated with various foods, Consumer Reports applied stricter residue limits than the EPA tolerances (see here for CR’s analytical methodology). Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a function of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. The Consumer Reports results fly in the face of the rosy outlook reported by the USDA in its 2022 […]

(Beyond Pesticides, April 26, 2024) Researchers build on existing research when assessing the relationship between long-term exposure to organophosphorus pesticides—widely used in food production and homes and gardens—and the human gut microbiome. In a new study published in Environmental Health, an interdisciplinary research team from University of California, Los Angeles determined, “that exposure to [organophosphorus pesticides] is associated with changes in the abundance of several bacterial groups and differential functional capacity in metabolic pathways supported by the human gut microbiome.” The study draws upon data from a “Parkinson’s, Environment and Gene study (PEG)” in which 190 participants were asked to submit fecal samples and answer interview questions. “[The study] was initially designed to investigate the etiology of Parkinson’s disease (PD) and participants were recruited in two study waves [‘over the full 10-year exposure window’]: 2001–2007 and 2012–2017. At baseline, [Parkinson’s disease] patients were diagnosed within the past 5 years and randomly selected community controls were also recruited,” the research team shares in their Methodology section. “Since 2017, we invited previous study participants who could be contacted to enroll in a pilot study of the gut microbiome. In addition, we invited a household or community member of [Parkinson’s] patients to participate.” […]

(Beyond Pesticides, April 23, 2024) The Office of Inspector General for the U.S. Environmental Protection Agency (EPA) released a report last week finding that the agency has failed to establish “institutional controls” at the American Creosote Works Superfund Site in Pensacola, Florida, leading to continuous groundwater and soil contamination that “leav[es] the public at risk of exposure.” The 1980 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) established the Superfund program, codified under 42 U.S.C. Chapter 103, to clean up contaminated sites with tax money from polluting industries. The OIG made eight recommendations for the regional EPA administrator and one for the assistant administrator “for Land and Emergency Management to improve the institutional controls at American Creosote Works Superfund Site.” There are three main determinations found in the results section of the OIG report: first, the institutional controls to prevent potential exposure were either “insufficient or unimplemented;” second, the EPA missed its mark in communicating associated risks to the public in areas surrounding this Superfund site; and third, the full administrative record for this site was not available at the time of inspection. This report builds on what advocates argue is the sustained legacy of EPA inaction and failure to […]

(Beyond Pesticides, April 17, 2024) With headlines drawing public attention to the contamination of drinking water after years of federal government neglect, the U.S. Environmental Protection Agency (EPA) announced on April 10 new standards to reduce public exposure to PFAS, or per- and polyfluoroalkyl substances, commonly referred to as “forever chemicals” because of their persistence. EPA has finalized a National Primary Drinking Water Regulation (NPDWR) for six PFAS, including PFOA and PFOS, which EPA has recognized have no safe level of exposure, regulating new chemicals for the first time since the 1996 amendments to the Safe Drinking Water Act (SDWA). PFAS persistence and bioaccumulation in humans, wildlife, and the environment is due to the strength of a resulting fluorine–carbon atom bond. PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply—among other resources—is ubiquitous worldwide. PFAS is used in everyday products, including cookware, clothes, carpets, as an anti-sticking and anti-stain agent, in plastics, machinery, and as a pesticide. The action was welcomed by environmentalists and public health advocates as an important step but left many concerned that any level of exposure to these chemicals is unacceptable and critical of EPA’s ongoing failure to act despite years […]

(Beyond Pesticides, April 10, 2024) Researchers in a 2024 Chemosphere study find synergistic relationships in certain chemical mixtures, particularly heptachlor and triallate and trifluralin and lindane at lower concentrations, respectively. “Investigators should consider additional binary data for acute toxicity and potential chronic health impacts on these mixture…which showed synergism at low levels,” the researchers conclude. “According to a Centers for Disease Control (CDC) assessment, more than 50 pesticides are detected in blood or urine samples from the US population,” Researchers point to a cause for concern. The findings come as no surprise to advocates who have urged an assessment of the potential synergistic impacts of pesticide mixtures in the regulation of pesticides. Researchers “used the exposure data from a complex operating site with legacy pesticide pollution to evaluate if Inhalation of pesticide mixtures released from such contaminated sites could pose a risk to human health, The component-based risk assessment approaches that rely on additivity can predict the actual risk of pesticides in a mixture, and The legacy organochlorine pesticides banned many years ago interact with registered and supposedly safe herbicides in a mixture.” The study site is “a pesticide packaging and handling facility” contaminated with the following pesticides (“historical and […]

(Beyond Pesticides, March 28, 2024) Last week, Maine Central reported the first application was filed for Maine’s first-in-the nation PFAS (per- and polyfluoroalkyl substances) Fund. This $70 million federal-state Fund to Address PFAS Contamination (PFAS Fund) provides compensation for commercial farmers whose health, business, and land have been impacted by PFAS contamination. A critical component of this fund enables the state to purchase contaminated farmland at fair market, pre-contamination value, which in the state of Maine hovers at approximately $3,729 per acre when including estimated market value of land and buildings, according to newly released data in the 2022 Census of Agriculture. “Maine became the first state to ban sludge recycling and approve a 2030 ban on PFAS in nonessential products,” according to reporting by Maine Central. The state of Maine has exhibited extraordinary leadership in prioritizing public health, ecosystems, and the environment, setting an example for addressing a widespread contamination problem at the local, state, and national level. However, advocates in Maine are raising warnings after the Maine Department of Environmental Protection, according to reporting by Portland Press Herald, proposed “a compromise plan to regulate the sale of products containing forever chemicals [which] would exempt some federally regulated industries […]

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

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

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

(Beyond Pesticides, March 12, 2024) A study released in Science of the Total Environment unpacks the threat of emerging chemicals of concern (CECs), including toxic pesticides, in the groundwater of Tunisia. Researchers highlight that the impact of pesticide drift and leaching into groundwater reserves is not siloed to the Middle East and North Africa (MENA) region, but a key concern for most industrialized countries, including the United States. Authors of this study build on literature of CECs already conducted in the region that have broader implications for the spillover effects of pesticide regulation in broader contexts. This descriptive study and accompanying Environmental Risk Assessment (ERA) demonstrate the urgency of Beyond Pesticides’ mission to ban toxic petrochemical pesticides by 2032 because of the pervasiveness of toxic residues, be it pesticides, antibiotics, or other substances, from groundwater systems to human bodies. The researchers performed the tests in thirteen wells in the Grombalia shallow aquifer, an area of northeast Tunisia that feeds into the Wadi El Bay watershed, which is defined as a “high population density [with] intensive agricultural activity [in ‘one of the most polluted areas in Tunisia’].” The researchers gathered data “during two seasons and were analyzed with two high resolution […]

(Beyond Pesticides, December 21, 2023) A new study published in Environmental Toxicology and Pharmacology adds to prior research indicating glyphosate promotes the occurrence of nonalcoholic fatty liver disease (NAFLD) through diet by causing liver inflammation and oxidative stress. More importantly, the predisposition for NAFLD occurred at levels within toxicological limits, which are doses of glyphosate classified as causing no adverse effects or No Observed Adverse Effect Level (NOAEL). NAFLD is a condition that causes swelling of the liver and can eventually lead to cirrhosis, cancer, or liver failure. This study highlights the Westernized diet (WD), comprised of foods enriched in saturated fats, cholesterol, and simple carbohydrates (e.g., fructose, glucose, and sucrose), plays a role in the nearly 40 percent increased risk of NAFLD. Although glyphosate disrupts gut microbes and induces liver inflammation, oxidative stress, and fatty acid levels that promote NAFLD, the combination of WD and glyphosate reduces the threshold risk for NAFLD development. NAFLD is a growing worldwide epidemic, becoming the most prevalent form of liver disease and impacting at least 25 percent of the globe. Therefore, studies like this shed light on how diet and chemical exposure can work synergistically (together) to exacerbate disease risk. The study evaluates whether choric […]

Upcoming EPA Review of Nitrates in Waterways Raises Health and Environmental Questions About Synthetic Nitrogen Fertilizer Use. In  a quiet reversal of a 2018 Trump administration decision, EPA is resuming an evaluation of the health impacts of nitrate in water, reflecting the long-standing and mounting evidence of synthetic nitrogen’s adverse effects on human health and the environment, particularly in vulnerable communities.

(Beyond Pesticides, November 9, 2023) Two-hundred-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields—according to data evaluated by Environmental Working Group—are threatened by potential Farm Bill amendments now under consideration. Legislative language, if adopted, would take away (preempt) the authority of states and local jurisdictions to protect children and restrict agricultural pesticides used near schools. Pesticide drift is a widespread problem throughout the U.S. that has attracted national attention in recent years because of crop damage caused by the weed killer dicamba in numerous midwestern states. In the face of the U.S. Environmental Protection Agency’s (EPA) failure to mitigate drift hazards, states enact limits on when and how pesticides can be used, establish buffer zones around application sites, and in some cases, ban uses. In 2018, Arkansas banned dicamba use from mid-April through the end of October (and survived a Monsanto challenge to the ban. For a historical perspective on the drift issue, see Getting the Drift on Pesticide Trespass. Children, in particular, face unique risks from pesticide and toxic chemical exposures. Due to their smaller body size, they absorb a higher relative amount of pesticides through the food they consume and the air they breathe. Additionally, children’s developing […]

(Beyond Pesticides, October 31, 2023) With cooler weather setting in and people heading indoors and closing windows, the issue of COVID-19 transmission escalates, as do concerns about toxic chemicals filling the indoor ambient air. As a recent segment of 60 Minutes (October 29, 2023) stresses, COVID-19 spreads elevated public concern and understanding about the importance of ventilation, filtration, and air exchange to indoor air quality. Unfortunately, the concerns about indoor air are not limited to COVID-19 as volatile organic compounds (VOCs) invade most spaces where people live and work. These invisible toxic substances can be found in common household products, furniture, mattresses, and more, including pesticides in and around the house. Recognizing the risks associated with VOCs and the potentially hazardous off-gassing process is crucial for protecting public health.  VOCs are a group of chemicals that can easily vaporize into the air at room temperature. These compounds are found in many everyday items, including furniture, cleaning products, pesticides, cosmetics, and even air fresheners. Some household products, particularly pesticides, can introduce their own set of risks in addition to the risks they pose due to their VOC content. VOCs can range from harmless to harmful, and their presence can have a […]