(Beyond Pesticides, November 16, 2015) Bayer CropScience, the manufacturer of neonicotinoid pesticides that are linked to severe decline in pollinator populations, is expected to pay fines to multiple countries in Europe for wine grape damages associated with another of its pesticides. Citing “atypical symptoms” resulting from the use of a relatively new fungicide, Bayer initially sent out a warning to wine growers to cease use of their product. Now, Bayer is collecting data and assessing how much it will offer to wine growers for the damages its product has caused. European grape growers, including vineyards in Austria, France, Germany, Italy, Luxembourg and Switzerland, have reported deformed leaves and lower yields after using Moon Privilege, also known as Luna Privilege in some markets, from the German company’s CropScience unit. In Switzerland, losses are estimated at 80 million Swiss francs ($83.73 million), as reported by marketing group Swiss Wine to Reuters. Swiss Wine’s general secretary estimates harvest losses totaling 6.65 million kilos (14 million pounds) of grapes in 2015, or about  4.85 percent of 2014’s crop. It is also estimated that wine makers have lost approximately six million bottles of wine, with  Pinot Noir grapes and Chasselas, a white wine grape, hardest […]

(Beyond Pesticides, October 21, 2015) Last week, Responsible Industry for a Sound Environment (RISE), an umbrella group representing pesticide manufacturers, celebrated its 25th year anniversary, touting its efforts to roll back critical protections from pesticide use in the U.S. The group emphasizes its role in quashing local government’s right to restrict pesticide use within its jurisdiction  after the Supreme Court, in Wisconsin Public Intervenor v. Ralph Mortier (1991), upheld local  authority under federal pesticide law. RISE, formed out of the National Agricultural Chemicals Association to fight government regulation at the federal, state, and local level, launched with a  plan to defeat those opposing pesticide use in favor of sustainable practices, including concerned mothers, progressive businesses, and local and national health and environmental advocates. The platform  RISE articulates  showcases its plans to influence regulators and consumers to allow the widespread and less restricted use of pesticides. In the 1990’s, RISE joined with another industry group, the American Legislative Exchange Council (ALEC), to seek the adoption in state legislatures across the country pesticide preemption laws, which were adopted in over 40  states. These laws prevent local governments from adopting  their own restrictions governing pesticide use  on private property. At one point, the […]

(Beyond Pesticides, October 19, 2015) Monsanto, the major producer of Roundup (glyphosate), has found itself in hot water recently, as personal injury lawsuits pile up over the link between glyphosate exposure and non-Hodgkin’s Lymphoma (NHL). Personal injury law firms around the U.S. have found a multitude of plaintiffs and are preparing for what could be a “mass tort” action against Monsanto for knowingly misinforming the public and farmworkers about the dangers of the chemical. The latest lawsuit was filed October 14 in Delaware Superior Court by three law firms representing three plaintiffs. One plaintiff in the Delaware lawsuit, Joselin Barrera, 24, a child of migrant farmworkers, relates  her non-Hodgkin lymphoma (NHL) to glyphosate exposure. Elias de la Garza, a former migrant farm worker and landscaper diagnosed with NHL, has a similar claim. These follow other lawsuits filed last month in New York and California that  accuse Monsanto of knowing that glyphosate was hazardous to human health. Monsanto “led a prolonged campaign of misinformation to convince government agencies, farmers and the general population that Roundup was safe,” the lawsuit states. Glyphosate is touted as a “low toxicity” chemical and “safer” than other chemicals by the Environmental Protection Agency (EPA) and industry […]

(Beyond Pesticides, September 24, 2015) Seven years after an explosion that killed two factory workers in Institute, West Virginia, Bayer CropScience is facing federal fines. Bayer is the manufacturer of neonicotinoid pesticides that are linked to severe decline in pollinator populations. On Monday, the U.S. Department of Justice (DOJ) and U.S. Environmental Protection Agency (EPA) announced a $5.6 million settlement with Bayer to resolve the 2008 violation of federal chemical  accident prevention laws. As a result, Bayer must commit to spending $4.23 million to improve emergency preparedness and institute response  measures to protect the Kanawha River, pay a $975,000 penalty, and spend approximately $452,000 to implement a series of reforms to improve safety at chemical storage facilities across the United States. On August 28, 2008, a pesticide waste tank exploded inside the Bayer plant, instantly killing one worker and sending another to the hospital where he would eventually die. Although Bayer officials assure the public that the explosion was secure and released no chemicals, residents living near the plant complained of air pollution exposure and related illnesses. The tank contained waste products from thiodicarb, including methyl isobutyl ketone (MIBK), hexane, methomyl, and dimethyl disulfide, all of which are acutely toxic […]

(Beyond Pesticides, August 27, 2015) Last week, Philip J. Landrigan, M.D., and Charles Benbrook, Ph.D., released a perspective article, GMOs, Herbicides, and Public Health, in the New England Journal of Medicine  that outlines  the hazards associated with food residues of  elevated pesticide use in the production  of genetically engineered (GE) crops. While mainstream media continuously misses the central issue  in the GE debate by asserting that these crops are merely an extension of selective breeding and effect a reduction in pesticide use, the authors  focus on  the significance of the actual increase in herbicide use and weed resistance in herbicide-tolerant crops. Drs. Landrigan and Benbrook offer two main recommendations in their article: the U.S. Environmental Protection Agency (EPA) should delay implementation of its decision to permit the use of Enlist Duo (the 2,4-D herbicide used with  Monsanto-engineered GE herbicide-tolerant  crop), and  the U.S. Food and Drug Administration (FDA) should  require labeling of GE foods and couple it with adequately funded, long-term postmarketing surveillance. Dr. Landrigan, Dean for Global Health at Mount Sinai School of Medicine, is an epidemiologist and pediatrician and one of the world’s leading advocates of children’s and environmental health. Dr. Benbrook is a research professor at the […]

(Beyond Pesticides, July 31, 2015) New information has surfaced regarding the role of agrochemical giants Bayer and Syngenta in the United Kingdom (UK)’s recent decision to temporarily allow the use of neonicotinoid seed treatment on oilseed rape crop. A record of the meeting, involving the UK government’s expert committee on pesticides (ECP) and industry representatives, had previously been suppressed. The newly released record of the meeting shows that Bayer and Syngenta were the only external representatives asked to answer the ECP’s questions. The emergency use, which has been granted for 120 days, allows growers to use Bayer’s Modesto (clothianidin) and Syngenta’s Cruiser OSR (thiamethoxam). The active ingredients of these products belong to a class of toxic chemicals known as neonicotinoids  (neonics), which have been  linked  to pollinator decline. These pesticides are associated with  decreased learning,  foraging  and navigational ability in bees, as well as increased vulnerability to pathogens and parasites as a result of suppressed bee immune systems. Used widely in agriculture as seed treatment for various crops, foraging bees, in the absence of their native habitat, are exposed to fields of poison where even pollen and nectar are contaminated. In addition to toxicity to bees, neonicotinoids have been shown […]

(Beyond Pesticides, July 30, 2015) Despite concerns for human and environmental contamination, the U.S. Department of Agriculture (USDA) adds 2,4-D-tolerant cotton, a genetically engineered (GE) crop, to the list of unregulated GE crops, joining 2,4-D resistant corn and soybeans. Last week, the Animal and Plant Health Inspection Service (APHIS) division of USDA released its decision on Dow AgroSciences’ petition to deregulate the 2,4-D resistant GE cotton. The decision was signed off by Michael J. Firko, the Deputy Administrator of Biotechnology Regulatory Services. In September of last year, Deputy Firko also signed the determination paperwork that deregulated GE corn and soybean. The deregulation essentially releases the GE organism from the regulatory requirements of 7 CFR part 340 or the plant pest provisions of the Plant Protection Act. Dow’s GE cotton, part of the Enlist Weed Control System, is resistant to 2,4-D choline, glufosinate, and glyphosate. Growers in the cotton industry have been vying for the GE cotton to enter the market in order to combat herbicide-resistant weeds due to the broad scale use of Monsanto’s RoundUp (glyphosate), which continues to fail across the agricultural industry due to weed resistance. Glyphosate is a phosphanoglycine herbicide that inhibits an enzyme essential to plant […]

(Beyond Pesticides, July 29 2015) The  Safe and Accurate Food Labeling Act of 2015,  H.R. 1599, often referred to as the “DARK” Act or Denying Americans the Right to Know what is in their food, passed the U.S.  House of Representatives last week by a vote of 275-150. Backed largely by House Republicans, the DARK Act makes it harder for the Food and Drug Administration (FDA) to require mandatory national labeling of genetically engineered (GE) organisms and strengthens current policies that allow companies to voluntarily label foods containing GE products, an option they rarely choose to do. The bill also continues to allow misleading “natural” claims for food that contain GE ingredients. Most concerning, however, is the prohibition  that H.R. 1599 would place  on states’ authority to require labeling of GE ingredients in food products, instituting federal  preemption of state and local authority. While the bill was being debated on the floor, co-sponsors Representatives Mike Pompeo (R-KS) and G.K. Butterfield (D-NC) repeatedly cited a lack of scientific evidence that GEs were dangerous to support the passage of the bill, ignoring arguments from the opposition that people should be able to know what is in their food, regardless of whether it […]

(Beyond Pesticides, July 24, 2015) An emergency application was approved by the UK Department for Environment, Food, and Rural Affairs (DEFRA) on Wednesday that allows  farmers to use neonicotinoid seed treatment on 5 percent of oilseed rape crop (known as canola in the U.S.) this summer to control a flea beetle infestation. The emergency use, which has been granted for 120 days, allows growers to use Bayer CropScience’s Modesto (clothianidin) and Syngenta’s Cruiser OSR (thiamethoxam). The active ingredients of these products belong to a class of toxic chemicals knowns as neonicotinoids, which have been linked to pollinator decline. The request was the second one for the National Farmers Union (NFU) after the first request for a nationwide lifting of the two-year moratorium on neonicotinoid use was rejected. The NFU said it was “frustrated” at having to put in an application for a smaller area. There have been numerous attempts to shroud the application process in secrecy. DEFRA told its expert committee on pesticides (ECP) to halt its  normal practice of publishing the minutes  of meetings at which the neonicotinoid applications were discussed, in order to avoid “provoking representations from different interest groups.” Additionally, according to the Guardian, the UK government […]

(Beyond Pesticides, July 20, 2015) In response to  the recent cancer classification of glyphosate (Roundup)  by the International Agency for Research on Cancer (IARC), the specialized cancer agency of the World Health Organization,  an industry-based  assessment has reached the opposite conclusion based on classified industry reports has concluded that Monsanto’s glyphosate is not carcinogenic.   According to The Guardian, the assessment by the German Federal Institute for Risk Assessments (BfR) is based almost solely on industry science and classified industry reports. Three scientists on Germany’s scientific panel on pesticides work for the pesticide industry. Monsanto objected earlier this year, when IARC announced in a preliminary report that glyphosate is a probable human carcinogen based on laboratory animal studies. BfR and IARC’s findings have been released during a pivotal time, as a decision on whether to extend the license for glyphosate’s use in Europe is currently pending, and these studies are sure to be incorporated into the decision making process. According to The Guardian, the European Food Safety Authority (EFSA) is delaying the release of its  opinion on glyphosate to take the full IARC report into account. The Guardian reports that BfR’s research relied heavily on unpublished reports provided by the […]

(Beyond Pesticides, July 16, 2015) The latest former U.S. Environmental Protection Agency (EPA) official to take advantage of the revolving door between EPA and the pesticide industry is Nader Elkassabany, PhD, former branch chief of the Risk Assessment and Science Support Branch in the Antimicrobial Division in the Office of Pesticide Programs. CropLife America announced last week that it has hired Dr. Elkassabany to serve as senior director of environmental policy, responsible for the pesticide trade group’s regulatory strategies on environmental policy. He will also help manage the company’s Environmental Risk Assessment Committee and its working groups. In a statement, CropLife America President and CEO Jay Vroom considers his expertise invaluable. This is no surprise, given that Dr. Elkassabany brings with him 15 years of experience working in  the registration and re-registration of pesticide active ingredients in the Office of Pesticide Programs (OPP) at EPA. This will undoubtedly be beneficial for the trade association, which represents major agricultural chemical manufactures like Bayer CropScience, Dow AgroSciences, and DuPont Crop Protection. According to a statement from CropLife, Dr. Elkassabany received three EPA Bronze Medals for Commendable Service. He left EPA in 2012 to work for another big name in consumer pesticides,  S.C. […]

(Beyond Pesticides, July 14, 2015) Last November, a worker at a DuPont chemical plant in La Porte, Texas was overcome when a supply line released more than 20,000 lbs. of methyl mercaptan, a toxic chemical precursor for pesticides produced at the plant. Three co-workers rushed to attempt a rescue, but all four were fatally asphyxiated by the toxic gas, according to an investigation from the U.S. Occupational Health and Safety Administration (OSHA). Now, after a lengthy investigation, OSHA is placing DuPont on the Severe Violator Enforcement Program,  which focuses agency resources on inspecting employers who have “demonstrated indifference to their OSHA [Occupational Safety and Health Act] obligations by willful, repeated, or failure-to-abate violations.” Earlier this year, OSHA’s initial investigation into the La Porte plant incident resulted in eleven citations, a $99,000 fine, and a long list of safety upgrades required to be taken by the company. “Four people lost their lives and their families lost loved ones because DuPont did not have proper safety procedures in place,” said Assistant Secretary of Labor for Occupational Safety and Health David Michaels, PhD, MPH. “Had the company assessed the dangers involved, or trained their employees on what to do if the ventilation system […]

(Beyond Pesticides, July 7, 2015) In a sleight of hand,  the U.S. Environmental Protection Agency (EPA) announced plans last week to cancel all remaining agricultural uses of the hazardous insecticide chlorpyrifos by April 2016, and then left the door open for negotiations with the chemical’s manufacturer, Dow AgroSciences, to adopt  risk mitigation measures that would avoid a ban. Environmental groups are reacting to EPA’s announcement with guarded optimism, encouraging the agency to move forward with its planned cancellation of a highly toxic chemical that has remained on the market for far long. In June 2000, EPA announced a negotiated voluntary cancellation  with Dow that removed residential uses of chlorpyrifos (Dursban) from the market because of the neurotoxic effects to children, but allowed most agricultural uses to continue. As early as January of this year, EPA released a revised human health risk assessment for chlorpyrifos, finding that the chemical poses risk to farmworkers, and the drinking water of small watersheds. The assessment was, in part, in response to a petition submitted by Natural Resources Defense Council (NRDC) and Pesticide Action Network (PAN) in 2007, which called on the agency to ban all uses of the insecticide. Since the the 2000 cancellation, […]

(Beyond Pesticides, July 2, 2015) A report released this week by Friends of the Earth exposes the exorbitant amount of money food and agrochemical companies have spent over the past several years to defend industrial agriculture, sway public opinion, and influence elected officials. The report shines light on the both the tactics these companies use and the lengths to which they are willing to go to defuse public concern about the risks of chemical-intensive industrial agriculture and to undermine the reputation of organic food. Hundreds of millions of dollars were spent from 2009-2013 on communication efforts to spin the media and drive consumer behavior, often using front groups that appear in the media to be independent sources, but are in fact funded by the interests of the industrial food sector. This report is an important link in shaping public conversation about food and influencing consumers to think twice about where the information they’re being fed is coming from, and who might be paying for it. When explaining the motivation behind writing the report, Anna Lappé, one of the co-authors and a national bestselling author and founder of the Real Food Media Project, states that, “The food industry is using a […]

(Beyond Pesticides, June 25, 2015) The U.S Environmental Protection Agency (EPA) announced Tuesday that it will analyze the effects of two of the most commonly used pesticides in the United States, glyphosate and atrazine, along with atrazine chemical-cousins propazine and simazine, for their impacts on 1,500 endangered plants and animals. The announcement marks an agreement between EPA and Center for Biological Diversity (CBD) on a proposed settlement amending a 2010 court order that  established a schedule to complete effects determinations for 75 chemicals on 11 species in the San Francisco (SF) Bay Area. According to EPA, 59 of the 75 pesticides have been evaluated and subject to  effects determinations, however for the remaining 16 pesticides, EPA and CBD agreed that it would be more efficient and environmentally significant to complete nationwide effects determinations, rather than limit their focus to the SF bay area listed species. The agency has committed to completing the assessments by June 2020. The initial lawsuit was filed by CBD in May 2007 against EPA for violating the Endangered Species Act by registering and allowing the use of scores of toxic pesticides in habitats for 11 San Francisco Bay Area endangered species without determining whether the chemicals […]

(Beyond Pesticides, June 23, 2015) After years of denial and obstruction, Air Force and Air Force Reserve veterans now have the chance to receive compensation for their exposure to the highly toxic herbicide Agent Orange on contaminated aircraft used after the Vietnam War. Affected veteran’s health issues stem from their time spent on UC-123 transport planes, which during the war were outfitted with spray equipment in the American military’s attempt to eliminate forest cover for Vietcong fighters. After the war, these aircraft were returned to use in the United States for basic transport operations such as cargo shipping and medical evacuation missions. However, these planes never underwent any form of decontamination or testing before being repurposed. Though the Agent Orange Act of 1991 stipulated medical care and disability coverage for sick veterans who  served in the Vietnam War and were exposed to Agent Orange, those who flew in contaminated post-war planes were deemed ineligible. Prior to this recent announcement from the Department of Veteran’s affairs, government officials asserted that the “dried residues” of Agent Orange were not likely to pose a health threat to aircraft crew. However, a study published by the National Academy of Sciences Institute of Medicine in […]

(Beyond Pesticides, June 16, 2015) France’s Ecology Minister Segolene Royal announced Sunday a  call to  stop  the sale of the popular Monsanto herbicide Roundup (glyphosate) from garden centers. The announcement comes just a couple of  months after the active ingredient, glyphosate, was classified in March as “probably carcinogenic to humans” by the United Nation’s International Agency for Research on Cancer (IARC). “France must be on the offensive with regards to the banning of pesticides,” Royal said on French television. “I have asked garden centers to stop putting Monsanto’s Roundup on sale” in self-service aisles, she added. The announcement comes after a request by French consumer association CLCV (Consumption, Housing and Environment – Consommation, Logement et Cadre de vie)  to French and European officials to stop selling glyphosate-based products to amateur gardeners. Royal also announced last week that from January 2018 onwards, phytosanitary products —used to control plant diseases— would only be available to amateur gardeners “through an intermediary or a certified vendor.” Glyphosate is touted as a “low toxicity” chemical and “safer” than other chemicals by EPA and industry and is widely used in food production and on lawns, gardens, parks, and children’s playing fields. However, IARC’s new classification of […]

(Beyond Pesticides, May 27, 2015) As summer approaches, local stores continue to set the pace for protecting pollinator populations from the harms of neonicotinoid pesticide use. In southern Maine, Kittery Ace Hardware joins Eldredge Lumber and Hardware in its efforts to actively seek alternatives to  pesticides that contain  neonicotinoids and other toxic pesticides by consciously stocking their shelves with organic compatible products as opposed to lawn and garden products that contain toxic chemicals. This shift by local stores like Eldredge and Kittery highlights the role retailers can play in responding to community concerns over dangerous pesticide use, and indicates their desire to be part of the solution when it comes to protecting pollinators. Local stores’ increasing  attention to local concerns over a common problem is  juxtaposed with  big box hardware stores’ response to neonicotinoid concerns that respond to public pressure with vague language, drawn out or nonexistent timelines, and failure to take a stance on overwhelming scientific evidence that neonicotinoids cause harm to pollinator populations. As more national retailers respond to public pressure to ban neonicotinoid-containing products, it becomes clear that local, small-scale efforts to stock shelves with alternative products offer a better and more concrete approach to stopping neonicotinoid […]

(Beyond Pesticides, May 14, 2015) For the first time on record, summer losses of managed honey bee colonies have exceeded winter losses, according to preliminary results of the annual survey released yesterday by the Bee Informed Partnership, the U.S. Department of Agriculture (USDA) and the Apiary Inspectors of America. This is the second highest annual loss recorded to date: beekeepers lost a total of 42.1 percent of the number of colonies managed over the last year (total annual loss, between April 2014 and April 2015), which is up from 34.2 percent for the previous year. On the same day that this survey was released, the  U.S.  House Agriculture Subcommittee on Horticulture, Biotechnology and Research held a hearing on pollinator health, but failed to advance policy solutions that would protect pollinators from the unnecessary use of pesticides. “What we’re seeing with this bee problem is just a loud signal that there’s some bad things happening with our agro-ecosystems,” Keith Delaplane, PhD at the University of Georgia and one of the co-authors of the study told Phys.Org. “We just happen to notice it with the honeybee because they are so easy to count.” About two-thirds of the beekeepers responding to the survey […]

(Beyond Pesticides, May 12, 2015) Last week Kaua’i County Councilmember Gary Hooser returned from agrichemical giant Syngenta’s shareholder meeting in Basel, Switzerland, where he addressed the company and its stakeholders on  the corporation’s lawsuit against the  small Hawaiian island of Kaua’i. The Councilmember indicates that, although the company is unlikely to meet his request to drop its lawsuit against Ordinance 960, which generally creates buffer zones prohibiting pesticide use around schools, hospitals, and parks, the trip overall was a success. “Our main purpose was one of education and information, to tell our story in the home city of Syngenta, and we were greeted with open arms and really managed to get the word out,” Mr. Hooser said to The Garden Isle on Monday. VIDEO: See Councilmember Hooser’s speech to Syngenta: Part 1 | Part 2 (Note: Credit and thanks to Kauai activist Fern Rosenstiel for filming this video despite attempts by Syngenta to suppress her ability to do so.) In a related matter, it  was announced earlier this week that  a federal court awarded over $500,000 to 15 Kaua’i residents who launched a  lawsuit (separate from the one above) against another agrichemical company on the island, DuPont Pioneer. Residents won […]

(Beyond Pesticides, April 21, 2015) Last week, Health Canada opened public comments on its reevaluation decision for glyphosate, the active ingredient in Monsanto’s Roundup herbicide. The agency chose to continue allowance of the herbicide, but include some changes to the label of glyphosate-containing products. The decision comes shortly after the International Agency for Research on Cancer determined that the chemical is a human carcinogen based on laboratory animal test data,  and a recent study revealed that glyphosate accelerates antibiotic resistance. Health Canada’s label changes include the following: A requirement for a statement indicating to apply only when the potential for drift to residential or populated areas is minimal. This includes houses, cottages, schools and recreational areas A restricted entry interval (REI) of 12 hours for agricultural uses to better protect agricultural workers; New environmental hazard statements to inform users that, at high enough doses, it can be toxic to non-target species; Recommended spray buffer zones to protect non-target terrestrial and aquatic habitats from unintended exposure; and, Precautionary statements to reduce the potential for run off of glyphosate to adjacent aquatic habitats, particularly when heavy rain is forecasted. This includes a recommendation to keep a strip of vegetation between the treatment […]

(Beyond Pesticides, April 13, 2015) Last week home and garden retailer Lowe’s announced its commitment to phasing out the sale of products containing neonicotinoid (neonic) pesticides within 48 months. The announcement is encouraging for consumers and environmental groups, as it comes after nearly two years of direct action urging the retailer to remove bee-toxic insecticides from store shelves. A 2014 report released by Friends of the Earth, Beyond Pesticides and allies found that over half of garden plant samples purchased at major retailers like Lowe’s and Home Depot contained neonic pesticides, which when applied makes the entire plant poisonous to bees and other wild pollinators. Neonics have been consistently implicated in the decline of honey bees and other wild pollinators. Lowe’s commitment to phasing out neonics is being combined with a promise by the company to include greater organic product selection in its stores, encourage growers to use biological control programs, and educate employees and consumers through brochures, fact sheets, and product labels. Lowe’s now joins BJ’s Wholesale Club, Home Depot, and a number of plant nurseries in committing to transition away from the use of bee-toxic pesticides. The elimination of neonicotinoid pesticides on store shelves and in plants promoted […]

(Beyond Pesticides, April 7, 2015) Scientists working with the United States Department of Agriculture (USDA) don’t have adequate protections from pressure and retaliation when researching issues that threaten the interests of powerful agrichemical corporations like Monsanto, according to Public Employees for Environmental Responsibility (PEER), which filed a petition for rule-making with the agency last month. PEER’s petition seeks to strengthen USDA’s Scientific Integrity Policy, and urges the agency to adopt best practices used in other federal agencies in order to prevent political suppression or alteration of studies. USDA adopted a new integrity policy in 2013 in response to a 2009 memorandum issued by President Obama with the goal of “ensuring the highest level of integrity in all aspects of the executive branch’s involvement with scientific and technological processes.” PEER alleges that USDA’s policy falls far short of this aim, even containing language which actively encourages the agency to suppress scientific work for political purposes. USDA’s current policy reads, “scientists should refrain from making statements that could be construed as being judgments of or recommendations on USDA or any other federal government policy, either intentionally or inadvertently.” PEER explains that USDA management regularly uses this provision as reason for suppressing technical […]