(Beyond Pesticides, January 23, 2008) Agribusiness giants Dow AgroSciences and Monsanto have successfully persuaded the state of Minnesota to reconsider their water-quality limit for the chemical, acetochlor. Scientists representing the industry presented their own studies to the Minnesota Pollution Control Agency (MPCA) and explained that the state’s original draft limit for acetochlor was too strict. Despite three years of research conducted by the state, scientists from Dow and Monsanto presented officials at the MCPA with six published studies- one of them in Chinese- which they claimed were overlooked by the state when determining the standard for acetochlor in waterways. As a result, the MPCA has decided to allow 3.6 parts per billion of acetochlor in rivers, more than twice the concentration of the 1.7 parts per billion previously proposed. As a result, three of five streams classified as ”˜impaired’ by acetochlor, including a popular trout stream in southeastern Minnesota, can no longer be considered polluted. Some environmental advocacy groups question whether the MPCA gave favorable treatment to the pesticide makers, claiming that other research that suggest that the chemical can cause ecological damage have not been seriously considered. “It looks like there’s a double standard, that industry can come in […]

(Beyond Pesticides, January 11, 2008) Talks between the Environmental Protection Agency (EPA) and Dow Chemical Company ended unsuccessfully when EPA determined that Dow’s offers were not comprehensive enough. Negotiations had centered around study and interim cleanup measures in the Saginaw and Tittabawassee rivers, wetlands, and Saginaw Bay. Dow agreed in July to clean up dioxin contamination downstream of its Midland, Michigan facility, but this time Dow spokesman John C. Musser said, “They were asking us to go beyond what we thought was reasonable, and we could not with our earlier offers resolve that dispute.” EPA plans to return to negotiations, but the latest round was not progressing successfully. “Key issues that are paramount for protecting human health and the environment remain unsolved,” said Ralph Dollhopf, associate director for the Superfund Division of EPA’s Region 5 Office in Chicago. “EPA simply will not accept any deal that is not comprehensive.” EPA spokeswoman Anne Rowan added, “We’re not walking away from cleaning up the river system. We walked away from negotiations that we thought were not fruitful.” The state Department of Environmental Quality (DEQ) has worked with Dow to ensure completion of the required cleanup, and these latest developments seem par for […]

(Beyond Pesticides, January 10, 2007) EPA decided at the end of 2007 to extend the deadline for public comments on its controversial proposal to allow pesticide product labels with third-party endorsements and cause-marketing claims. The new due date is March 27, 2008. The agency extended the public comment period for another 90 days in response to requests from Beyond Pesticides and others. In extending the comment, Debra Edwards, Director, Office of Pesticide Programs, said, “The Agency is particularly interested in assuring that its State partners in pesticide regulations, as well as organizations such as yours, have adequate opportunity for comments.” See letter.The issue of cause-marketing on pesticide labels came up last year when Clorox petitioned EPA to allow it to display the Red Cross logo on some of its products, including pine-sol and bleach products. In letters to all the state pesticide regulatory agencies in March, 2007, Beyond Pesticides urged the states to deny the label changes approved by EPA, saying: The inherent danger is that misleading the public about pesticides can result in harm to consumers who either do not, unfortunately, take the time to read pesticide labels or who cannot read or comprehend labels (e.g. non-English speaking citizens, […]

(Beyond Pesticides, January 3, 2008) The US Department of Agriculture (USDA) has struck an arrangement with agribusiness giant Monsanto Co. that gives farmers in four states a break on federal crop insurance premiums if they plant a majority of Monsanto-brand seed corn this spring. Farmers in Illinois, Indiana, Iowa and Minnesota need to plant 75-80% of their crops with Monsanto’s (and only Monsanto’s) GM seeds to receive the “premium rate discount”. The arrangement has raised some eyebrows, particularly among organic farm groups that argue the government agency should not be promoting corn that promotes herbicide use; the Monsanto brands are resistant to Roundup (main ingredient, glyphosate) and contain chemicals that kill insects and other plants. Monsanto’s deal is legal, according to USDA officials, who point out that such arrangements were encouraged in a 2000 crop insurance passed by Congress. The idea is to give farmers a break on their insurance premiums if they use corn seeds that are higher yield and show resistance to insects and other threats. USDA officials said they are aware of the appearance of favoritism toward one of the nation’s largest agricultural companies. “We knew it would look that way,” said Shirley Pugh, a spokeswoman for […]

(Beyond Pesticides, December 21, 2007) EPA is proposing a major overhaul of pesticide labels that will allow cause-related marketing (advertising) directly on products, a reversal of a long-standing policy that prohibited such representations. Beyond Pesticides urges the public to submit comments opposing such labeling and to support a request that EPA extend the deadline for comments (now set at December 31, 2007) to allow between 30 and 60 additional days for public comment on this proposed change. The change in law has serious safety implications, according to Beyond Pesticides, because the use of symbols, such as the Red Cross, implies that poisonous products are safe. On February 7, 2007, numerous groups petitioned EPA to rescind and deny the pesticide product label for the Clorox Company, which allows the display of the Red Cross symbol and language on pesticide products. The groups signing the petition included Beyond Pesticides, Pesticide Action Network North America, Center for Environmental Health, American Bird Conservancy, Pesticide Education Project, Strategic Counsel on Corporate Accountability, Environmental Health Fund, The Endocrine Disruption Exchange, Northwest Coalition for Alternatives to Pesticides, Natural Resources Defense Council, Maryland Pesticide Network and Washington Toxics Coalition. Current label laws, defined by the Federal Insecticide, Fungicide, […]

(Beyond Pesticides, November 30, 2007) Seven years ago, the introduction of genetically modified (GM) sugar beets, along with other crops like potatoes and rice, was shelved at fears that consumers would not support their use. Sugar beets, which produce about half of the United States sugar (almost all of which is used domestically), are used in foods like candy, cereal, and baking products. The failure of the GM beet’s initial introduction was based on unwillingness from companies like Hershey and Kellogg to provoke consumer protests. Now, the marketplace seems to have changed enough that such big sugar-buying companies are less hesitant to buy Monsanto’s “Roundup Ready” beet (which are tolerant of Roundup’s main ingredient, glyphosate). According to Kellogg spokeswoman Kris Charles, her company “would not have any issues” buying them because “most consumers are not concerned about biotech.” “Basically, we have not run into resistance,” said American Crystal Sugar president David Berg of the switch. “We really think that consumer attitudes have come to accept food from biotechnology.” Most other companies, including Hershey and Mars, are refusing to comment on the subject, which has kept these developments quiet until recently. Despite the corporate perception of public opinion on GM crops, […]

(Beyond Pesticides, November 20, 2007) According to the Pennsylvania Department of Agriculture, as of January 1, 2008, dairy products with labels such as “growth-hormone free” will be illegal in the state. The Pittsburgh Post-Gazette reported that Pennsylvania Secretary of Agriculture Dennis Wolff announced the decision last month after convening a 22-member Food Labeling Advisory Committee to look into false or misleading claims in “absence labeling.”The ruling covers all dairy products sold in the state, forcing some out-of-state manufacturers, in effect, to make Pennsylvania-only packaging. So far, the state Department of Agriculture has notified 19 companies that their labels must change. Of the three principal types of labeling affected by the ruling, getting rid of “growth-hormone free” milk labels has proven most controversial.The PA Department of Agriculture explained its decision in a statement on its website, “[S]ome milk labels contain statements such as ”˜hormone-free,’ but all milk contains hormones. Some labels also claim the absence of synthetic hormones, but there is no scientific test that can determine the truth of this claim.” Organic labeling, Mr. Wolff said, involves a certification process that includes surprise audits, so the department does not currently intend to interfere with it. Some food safety advocates believe […]

(Beyond Pesticides, November 8, 2007) In a landmark decision, a California jury on November 5, 2007 awarded $3.3 million to Nicaraguan farmworkers sterilized by pesticides made by Dow Chemical and used at Dole’s banana plantations. The lawsuit accused Dole and Standard Fruit Co., now a part of Dole, of negligence and fraudulent concealment while using the pesticide 1,2-Dibromo-3-Chloropropane (DBCP) to kill rootworms on banana plants. Until 1977, DBCP was used in the United States as a soil fumigant and nematocide on over 40 different crops. From 1977 to 1979, EPA suspended registration for all DBCP-containing products except for use on pineapples in Hawaii. In 1985, EPA issued an intent to cancel all registrations for DBCP, including use on pineapples. Subsequently, the use of existing stocks of DBCP was prohibited. In Nicaragua, DBCP was legal from 1973 until 1993.EPA’s website states the following: Acute (short-term) exposure to DBCP in humans results in moderate depression of the central nervous system (CNS) and pulmonary congestion from inhalation, and gastrointestinal distress and pulmonary edema from oral exposure. Chronic (long-term) exposure to DBCP in humans causes male reproductive effects, such as decreased sperm counts. Testicular effects and decreased sperm counts were observed in animals chronically […]

(Beyond Pesticides, October 26, 2007) Aurora Organic Dairy, found earlier this year by the United States Department of Agriculture (USDA) to be in “willful” violation of organic standards, is once again the subject of claims made by the Cornucopia Institute. In its findings, USDA had announced that Aurora “labeled and represented milk as organically produced, when such milk was not produced and handled in accordance with the National Organic Program [NOP] regulations.” As a result of this report, Cornucopia, whose research and original complaint initiated USDA’s investigation, has brought class action suits in Denver, St. Louis, and federal courts, which allege “consumer fraud, negligence, and unjust enrichment concerning the sale of organic milk by the company. “The basis of Cornucopia’s suit centers around milk sold before USDA’s organic certifier, Quality Assurance International (QAI), filed a notice of the violations found. Cornucopia’s Mark Kastel argued that the milk sold in the more than three years prior to QAI’s findings hurt smaller players in the organic industry, as well as consumers. “Aurora’s actions have injured the reputation of more than 1,500 legitimate organic dairy farmers who are faithfully following federal organic rules and regulations,” he said. “We cannot allow these families to […]

(Beyond Pesticides, October, 10 2007) One of the largest chemical companies in the world, BASF Corporation, announced in a press release October 9, 2007 that it will get serious in its campaign against the use of illegal pesticides. The sale and distribution of unregistered or counterfeit pesticidal products is clearly prohibited under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), resulting in harm to public health and the environment. Several companies have recently been fined by the EPA for selling and distributing unregistered or mislabeled pesticide products (See Daily News Blogs: “EPA Fines Clorox Over Export Labels” and “Target Settles with EPA on Labeling Violations”). BASF sees the problem as adversely affecting its bottom line. BASF Agricultural Products spends over 300 million euros in research and development, especially in the field of crop protection, to develop and launch new products. As a result, the company is on a state of alert to prevent activities which deliberately infringe its existing patents or which are illegal, including product counterfeiting and the sale and distribution of unregistered pesticides. The agricultural products division of BASF said that its worldwide fight against illegal pesticides would involve taking legal action for patent infringement, illegal imports of […]

(Beyond Pesticides, 2nd October 2007) Target Corp. has been fined over $40,000 by the U.S. Environmental Protection Agency (EPA) for violating pesticide-labeling rules under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). As part of the penalty, EPA (Region 5) filed a consent agreement and final order with Target to halt the distribution and sale of the products in violation. According to EPA, Target sold and distributed products from its stores and website that made pesticidal claims on their labels. Some product’s properties also made comparisons to other registered products sold by competitors. An inspector cited the company for violation in April and Target is now removing pesticidal claims from the products.The products identified were: Antimicrobial Toilet Seats, Home Ultimate Mattress Pads, Home Ultimate Pillows- which made “germ-killing” claims and Cleaner With Bleach, which compared its disinfectant properties with a competitor. Under FIFRA (Section 2(u)), any substance or product intended for “preventing, destroying, repelling, or mitigating any pest,” which includes germs and bacteria, is defined as a pesticide and must be registered with EPA prior to sale and distribution. EPA considers disinfectants, antimicrobial and antibacterial products to be pesticides. This settlement is one of several recent EPA crackdowns concerning the […]

(Beyond Pesticides, September 19, 2007) In Vietnam, attempts continue to be made to protect villages from the ongoing threat of Agent Orange, used by American forces to deforest the jungle canopy in the Vietnam War over 30 years ago, according to the New York Times. Reforestation and fencing are being carried out to prevent local animals and residents from being exposed to soil contaminated with 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD), a potent dioxin contaminant of Agent Orange. Phung Tuu Boi, forester and director of the Center for Assistance in Nature Conservation and Community Development in Hanoi, is attempting to reforest thousands of hectares in central Vietnam. However, his main concern is the dioxin that taints the soil and the local residents most at risk since they live off the land. “The local people are poor and uneducated, and they don’t understand. Children come here to play and they collect insects and other things to eat,” said Mr. Boi. TCDD is the most dangerous form of dioxin and the levels found in soil samples from Central Vietnam are more than 200 times the “acceptable” level set by the US EPA. Efforts to educate the residents about the dangers of dioxin are difficult since most […]

(Beyond Pesticides, September 17, 2007) Mediterranean fruit flies were discovered last week in Dixon, California, and federal, state, and county agencies rushed to respond with traps, biopesticide treatment, and sterile mates to prevent the insect from infesting local agriculture. A total of eight Medflies have been found so far, and the three-pronged attack started with an effort to monitor the presence of the Medfly. California Department of Food and Agriculture (CDFA) employees have placed 1,700 fruit fly-targeted detection traps in an 81-square-mile grid. Next, residents within 200 meters of the original finding had their yards treated with the organic compound Naturalyte, the active ingredient of which is spinosad, a naturally occurring extract from bacteria. The pesticide, made by Dow, is approved for use on organic crops, yet the vast majority of its ingredients (so-called “inerts”) are not disclosed. As another biological control, more than 3 million sterile male flies were released last Friday in a 12-square-mile area around Dixon. The sterile males will be deployed on a weekly basis to mate with wild females, helping to eradicate the Medfly population. This is the first Medfly case in Solano County, according to county agriculture officials. Agriculture Commissioner Jerry Howard said that […]

(Beyond Pesticides, September 7, 2007) The United States Department of Agriculture and Aurora Organic Dairy have reached an agreement stemming from complaints brought by the Cornucopia Institute. While Aurora called USDA’s decision a “dismissal”, the department did find that the dairy did not provide enough pasture for its milking cows and that not all cows could be proven to have been raised organically. As part of its agreement with USDA’s Agricultural Marketing Service (AMS), Aurora will thin its herd at its Platteville, Colorado dairy from 2,200 to 1,250 and increase its organic pasture from 325 acres to 400. Rather than alter operations at another Colorado facility, Aurora has agreed not to renew its organic certification there. USDA will also monitor the company more closely, and violations during its one-year probationary period could threaten Aurora’s organic certification. “The organic industry is booming, and the National Organic Program is a high priority for USDA,” said Bruce I. Knight, under secretary for marketing and regulatory programs, “and through this consent agreement consumers can be assured that milk labeled as organic in the supermarket is indeed organic.” Cornucopia was particularly critical of the positive spin put on the settlement in USDA’s decision and Aurora’s […]

(Beyond Pesticides, August 24, 2007) The Wisconsin Natural Resources Defense Board recently passed stricter limits on allowable groundwater levels of alachlor-ESA, the breakdown product of the herbicide alachlor, cutting in half the standard to 20 parts per billion (ppb). The reduction from the previous standard of 40 ppb was prompted by the state Department of Natural Resources (DNR), which has tried to pass a similar measure in recent years, only to be blocked by the Republican-controlled Senate. Officials hope that a Democratic majority will ensure adoption of the new standard. The board voted 7-0 in favor of lowering the allowable groundwater level of alachlor-ESA, after DNR cited studies showing the chemical causes blood problems in rats. Department of Agriculture, Trade & Consumer Protection (DATCP) tests in 2001 showed alachlor-ESA in 28 percent of private wells tested, in spite of its declining use (on less than a quarter of the state’s 100,000 acres of corn). A similar proposal was rejected by the board in 2005, when DNR refused to agree to the Joint Committee for Review of Administrative Rules’ request to allow Monsanto, manufacturer of alachlor, to fund a separate study in addition to the state’s data. Monsanto, as expected, issued […]

(Beyond Pesticides, August 21, 2007) Last week, The Cornucopia Institute announced that Aurora Organic Dairy, one of the largest organic dairies in the United States, could soon lose its organic certification. Based on a private investigation as well as United States Department of Agriculture (USDA) documents, Cornucopia claims the industry giant does not comply with organic regulations regarding pasture grazing and cattle procurement. Aurora has 12,000 milking cows on five farms in Colorado and Texas. The company claims that the cows have access to 5,700 acres of organic pasture land across those farms, and that all cows graze for at least 120 days per year. Among the brands Aurora supplies organic dairy products for are Target, Wal-Mart, Costco, Safeway, Wild Oats, Trader Joes, and other grocery chains. According to Cornucopia’s senior farm policy analyst Mark Kastel, “After personally inspecting some of Aurora’s dairies in Texas and Colorado, we found 98 percent of their cattle in feedlots instead of grazing on pasture as the law requires.” While USDA’s investigation is ongoing, Cornucopia expects to hear of other missteps. “Our sources tell us that the USDA’s investigators found many other violations when conducting their probe of Aurora,” said Mr. Kastel. Cornucopia’s original […]

(Beyond Pesticides, August 16, 2007) The Environmental Protection Agency’s (EPA) recent decision not to go through with a Special Review of 2,4-D’s carcinogenic properties is being touted by industry as the final word that the toxic chemical “has been found to have no human carcinogenic effects,” despite significant evidence to the contrary. The Special Review has been cancelled after an industry task force poured millions of dollars into industry funded research and a public relations campaign. The pesticide 2,4-D, or 2,4-Dichlorophenoxyacetic acid, was first slated by EPA for Special Review in 1986. A few years later in a unique move, several large pesticides companies with a common interest in keeping 2,4-D on the market formed the Industry Task Force II on 2,4-D Research Data. Since then, the task force reports it has funded nearly $30 million in new research on the chemical. Industry funded research is often biased and influential in the regulatory process. The results are reported to EPA, which provides a large portion of the data the agency relies on in order to make decisions under an inadequate risk assessment review process. The task force is currently comprised of the major pesticide producers Dow AgroSciences (U.S.), Nufarm Ltd. […]

(Beyond Pesticides, July 20, 2007) Dow Chemical Company has reached agreement with the Environmental Protection Agency (EPA) to begin cleanup of dioxin contamination downstream of its Midland, Michigan facility immediately. The teratogenic (i.e. ability to cause developmental malformations) and mutagenic compounds are not only byproducts of manufacturing processes but are contained in one of Dow’s most used herbicides. Last November, Dow identified dioxin hot spots along the Tittabawassee River, but corrective action “has taken too long” according to an EPA press release. “EPA has documented that dioxin contamination in soil poses risks to human health and the environment.” Dioxins are a family of chemicals that have been linked to cancer, weakened immune systems and reproductive problems. Terry Miller, a member of Lone Tree Council, an environmental group, told the Saginaw News that EPA’s decision confirmed his suspicions that Dow was “dragging their feet” in the cleanup efforts. “There’s been a lot of print suggesting the state has been too hard on the company when it appeared that Dow was being too slow,” he said. “The federal government would seem to support that contention.” Michelle Hurd-Riddick, a spokeswoman for the Lone Tree Council, was quoted by the Saginaw News saying that […]

(Beyond Pesticides, July 12, 2007) More than 5,000 agricultural workers from Central America have filed lawsuits in the United States, claiming that a pesticide used on banana trees has rendered them sterile. The pesticide, dibromochloropropane (DBCP), was used by workers from Nicaragua, Costa Rica, Guatemala, Honduras, and Panama to kill worm infestations in the trees’ roots. According to the U.S. Environmental Protection Agency, DBCP, which was largely phased out on U.S. crops by 1979, causes male reproductive problems, including low sperm count, and is a “probable human carcinogen.” The first of the five lawsuits, originally filed in 2004, which began jury selection two days ago, accuses Dole Fresh Fruit Co. and Standard Fruit Co. of “negligence and fraudulent concealment while using the pesticide.” In addition, it argues that Dow Chemical Corp. and Amvac Chemical Corp., which manufacture DBCP, “actively suppressed information about DBCP’s reproductive toxicity.” The suit filed by attorney Duane Miller states that Dow and Amvac were aware of the health risks of DBCP in the 1950s. “Defendants, however, continued to market, sell, and use pesticide products containing a DBCP outside of the United States, including Nicaragua,” it says. In addition, Miller claims the pesticide seeped into the water […]

(Beyond Pesticides, June 11, 2007) Scientists from the University of Nebraska-Lincoln (UNL) have discovered a gene that enables crops to tolerate being sprayed with dicamba. Citing previous experience with glyphosate resistant crops, environmentalists are concerned that this will increase use of a toxic herbicide while negatively impacting health and the environment. This new gene expands the range of genetically engineered (GE) crops available to farmers. The most popular are currently marketed as “Roundup Ready,” or tolerant of glyphosate, by Monsanto Company The discovery is being touted as a way to provide another option in areas where weeds have built up a resistance to glyphosate. Indeed, biochemist Don Weeks, who headed the UNL team, said, “Importantly, we think that this technology will help to extend the lifetime of the Roundup Ready technology. Some Roundup-resistant weeds have emerged in recent years, but working dicamba products into a weed-control strategy with Roundup could help counter that trend and lead to more complete weed control.” In fact, the dicamba-ready technology could appear in fields as part of a “stacked” seed, which is tolerant to both glyphosate and dicamba. Said Mr. Weeks, “It is highly likely that [Monsanto] would stack our gene with the Roundup […]

(Beyond Pesticides, May 14, 2007) Wisconsin consumer fraud investigators have released the findings of a three month long look into claims that Wal-Mart has been mislabeling conventional products as organic. The state’s numerous findings of improper labeling confirmed a complaint placed by the Cornucopia Institute in January. The Wisconsin Department of Agriculture, Trade and Consumer Protection, in a letter to Wal-Mart Stores, Inc., advised the company that “use of the term ”˜Wal-Mart Organics’ in combination with references to a specific non-organic product may be considered to be a misrepresentation and therefore a violation” of Wisconsin state statutes. While the report did not take action beyond extending a warning to Wal-Mart, the Cornucopia Institute was pleased with the investigation’s outcome. “This finding is a victory for consumers who care about the integrity of organic food and farming,” said Mark Kastel, co-director of the Institute. “Wal-Mart cannot be allowed to sell organic food ”˜on the cheap’ because they lack the commitment to recruit qualified management or are unwilling to properly train their store personnel. Such practices place ethical retailers, their suppliers, and organic farmers at a competitive disadvantage.” While Wisconsin has completed their investigation, the United States Department of Agriculture (USDA) has […]

(Beyond Pesticides, May 7, 2007) Beyond Pesticides is encouraging its members, activists and others in the Midwest to join Students for Bhopal and Amnesty International in a protest at the Dow Chemical Company Annual General Meeting (shareholder meeting) on Thursday, May 10, 2007, in Midland, Michigan. The purpose of the protest is to send a message to Dow that corporate irresponsibility will not be tolerated. The protesters will demand that Dow: 1) Clean up toxic wastes and contaminated groundwater left by the 1984 Bhopal disaster; 2) Face trial and ensure that Union Carbide (now owned by Dow) and CEO Warren Anderson present themselves in the Indian Courts; 3) Cooperate with authorities assessing the long-term health consequences of the explosion; and, 4) Make public information about the toxicity of reaction products released during the leak. See details on the Bhopal disaster below. Beyond Pesticides is part of an international campaign working to expose and hold Dow Chemical accountable for its wrong doings. Aside from its liabilities in Bhopal, Vietnam and around the world, Dow AgroSciences, a division of Dow Chemical, produces many of the most hazardous pesticides on the market, which contaminate our bodies and the environment through a variety of […]

(Beyond Pesticides, May 2, 2007) A recent study completed by the Center for Public Integrity finds that industry, including pesticide companies, spent over $12 million on trips for U.S. Environmental Protection Agency (EPA) employees between October 1997 and March 2006. During that time, EPA officials took more than 10,000 privately sponsored trips totaling more than 40,000 days ”” a total of 110 years ”” away from their offices. While some of those trips were legitimate fact-finding missions paid for by companies, local governments, nonprofit organizations, universities and international environmental groups, many were funded by those with a financial stake in EPA decision-making, including groups and companies that receive EPA contracts and grants, groups lobbying the federal government and companies with ties to federally recognized toxic waste sites, according to disclosure documents. Although EPA’s authority is limited to the U.S., more than $6.6 million was spent on trips to other countries. Agency employees took more than $1 million in trips to France, Germany and Italy during the study period. East Asia was also a common destination – more than $1.4 million was spent on trips to China, Japan, Taiwan and Thailand. “While EPA is a domestic agency, it has international responsibilities,” […]