(Beyond Pesticides, October 29, 2019) The U.S. Environmental Protection Agency is proposing changes to the way farmworkers and bystanders are protected from toxic pesticide applications, per an announcement published on the agency’s website last week. Billed as “improvements” that will “reduce regulatory burdens for farmers,” the actions would instead significantly shrink Application Exclusion Zones (AEZs), buffer areas where individuals are not supposed to enter during a pesticide application. Health and justice advocates say the move will put farmworkers at risk. “Although the proposal is framed as a narrow revision, it would in fact eliminate, reduce or weaken various AEZ provisions,” said Farmworker Justice attorney Iris Figueroa to Politico. “These changes threaten to increase exposure to toxic pesticide drift for farmworkers and their families.” EPA’s proposal, announced in a press release featuring the heads of industry associations like the American Farm Bureau, would do the following: Make AEZs applicable only to a farm owners’ property. Under the current rules, pesticide handlers were required to keep individuals out of an area where pesticides were applied both on and off site. Exempt on-farm family members from all aspects of the AEZ. EPA says this will allow farmers and their family “to decide whether […]

(Beyond Pesticides, October 18, 2019) The U.S. Environmental Protection Agency (EPA) issued a directive in September, under Administrator Andrew Wheeler, that changes its pesticide approval process and aims to reduce (mammalian) animal testing significantly by 2035. The agency also announced awards totaling $4.25 million to four universities for development of alternative methods to evaluate chemicals, including pesticides. The move will likely be seen both as an advancement of animal rights, and as a setback for the kinds of testing that can have important implications for human health. Resolution of this issue could be found in a shift away from chemical agriculture and to organic and regenerative practices, which eschew toxic chemicals and synthetic fertilizers, and obviate need for them. The directive affects not only the agency’s own research, but also, as the memo says, EPA will “come as close as possible to excluding from its approval process any reliance on mammal studies conducted after January 1, 2035, including those performed by third parties.” The schools receiving EPA funds to work on alternative testing are Johns Hopkins University, Vanderbilt University and Vanderbilt’s Medical Center, Oregon State University, and the University of California-Riverside. President of the International Science Consortium for People for the […]

(Beyond Pesticides, October 17, 2019) The U.S. Environmental Protection Agency (EPA) is downplaying the connection between exposure to the herbicide paraquat and the development of Parkinson’s disease, per registration review documents released by the agency this week. Although unsurprising given the current administration’s track record of defending some of the most heinous chemicals still on the market, the review nonetheless marks a low point for scientific integrity within EPA’s Office of Pesticide Programs, according to advocates. Health and environmental advocates have already discounted EPA’s industry-biased review, and are instead pushing hard for Congressional action – namely HR 3817, the Protect Against Paraquat Act, introduced by Congresswoman Nydia Velazquez (D-NY). Under federal law, pesticides are required to undergo reevaluation every 15 years. Paraquat is a potent restricted use herbicide, not available to be applied by residential users, but permitted for use on multiple agriculture crops. Over the last decade, independent peer-reviewed scientific studies have repeatedly found strong associations between paraquat to the development of Parkinson’s disease. Many of these studies have been covered in Beyond Pesticides’ Daily News or are recorded in the Pesticide-Induced Diseases Database. In response to this growing body of literature, EPA conducted an epidemiological evaluation of published […]

(Beyond Pesticides, September 27, 2019) The U.S. Fish and Wildlife Service (USFWS) will be required to protect the habitat of the endangered rusty patched bumblebee, per a settlement with the Natural Resources Defense Council (NRDC) reached earlier this week. The bee was listed under the Endangered Species Act (ESA) in 2017, but USFWS has yet to designate the “critical habitat” for the bee where improved protections must be made to ensure its recovery. With the decline of both wild and managed pollinators throughout the U.S., action on this issue by federal agencies is sorely needed. According to NRDC, the settlement will require FWS to propose critical habitat by July 31, 2020, unless it makes a finding that habitat protections are not prudent. The Service must then finalize any habitat protections by July 31, 2021. Under ESA, FWS is required to designate the critical habitat of a listed species within one year of its listing if not included within its listing announcement. Thus, by drawing out this process, FWS is flouting this important action that will lead to real on-the-ground protections. “The U.S. Fish and Wildlife Service has violated federal law—again—by not designating critical habitat for the rusty patched bumble bee,” […]

(Beyond Pesticides, September 11, 2019) Germany is the latest entity to take action on getting glyphosate-based pesticides out of the marketplace. Chancellor Angela Merkel has announced that, beginning in 2020, the country will phase out herbicides that contain glyphosate by the end of 2023. The phase-out will occur through a series of scheduled reductions in amounts allowed for use, with a goal of a 75% reduction over the next four years. The announcement comes after “nation-wide protests and demands from [Merkel’s] junior coalition partner, the Social Democrats, for more decisive action on environmental issues.” This action stands in telling contrast to the U.S. Environmental Protection Agency’s (EPA’s) repeated failures to protect people, ecosystems, and our food supply, from this toxic compound. The German government also plans to oppose any European Union (EU) request for renewal of licensing of these herbicides, according to the environment ministry. Bayer AG, maker of glyphosate-based herbicides and owner of original manufacturer Monsanto, has pushed back, saying that the government is “getting ahead of itself” by banning glyphosate-based herbicides prior to any decision by the relevant EU authority, and that EU laws disallow unilateral decisions by member states. (Pesticide licensing decisions lie with EU governance in Brussels, […]

(Beyond Pesticides, September 4, 2019) Sixteen organizations representing health, environmental, farmer, and farmworker communities joined together yesterday to call on EPA to remove glyphosate from the marketplace. The groups cite a combination of high-profile lawsuits, environmental impacts, increasing reports of weed resistance, and growing public concern over the health effects of glyphosate in their comments on EPA’s interim reregistration review decision for the chemical. The comments warn that EPA is at risk of damaging the public’s trust in the agency’s review process for toxic pesticides. “EPA’s myopic review and response to the dangers posed by glyphosate does a disservice to American farmers, farmworkers, and commercial landscapers wishing to use least-toxic products that do not put them at risk of health impacts, and consumers aiming to make the safest choice in regards to what to feed their family and how to manage their yards,” the comments read. The document likewise replies to EPA’s attacks against the World Health Organization’s International Agency for Research on Cancer (IARC), which determined glyphosate to be a probable carcinogen based on sufficient evidence of carcinogenicity in experimental organisms. EPA has indicated that its process for evaluating glyphosate, “…is more transparent than IARC’s process” and that IARC’s […]

(Beyond Pesticides, August 30, 2019) The indictment of organophosphate pesticides gained more traction with the publication, in the Proceedings of the National Academy of Sciences, of a new research study out of the University of California, Berkeley. The research, among the first to use advanced brain imaging to assess cortical activation, shows altered brain activity, during tasks that call on executive function, in teenagers from California’s Salinas Valley (the site of significant organophosphate use) whose mothers were exposed prenatally. The UC Berkeley study underscores the slow-motion calamity of the Trump administration Environmental Protection Agency’s (EPA’s) failure to ban the use of this class of pesticides, and of chlorpyrifos in particular, which compounds carry extreme risks for children. The effects of this prenatal exposure continue to unfold during children’s critical developmental periods. Researchers used fNIRS (functional near-infrared spectroscopy) imaging to monitor blood flow in the brains of the teens, 15–17, born and raised in the Salinas Valley. They used data from the California Pesticide Use Reporting program (which documents locations and times of pesticide spraying) to estimate the subjects’ mothers’ proximity to organophosphate (OP) applications during pregnancy. The subject adolescents — estimated to have relatively high levels of prenatal exposure to organophosphates — […]

(Beyond Pesticides, August 27, 2019) The U.S. Environmental Protection Agency (EPA) is the subject to a new legal challenge from environmental groups after approving the use an insecticide shown to be highly toxic to bees and other pollinators.  The lawsuit, filed in the 9th Circuit Court of Appeals by the Center for Biological Diversity and Center for Food Safety, aims to stop the use of sulfoxaflor on more than 200 million acres of crops. As EPA under the Trump administration has become increasingly emboldened to fight for industry priorities, concerned organizations and people are responding by supporting legal challenges and working to pass policies that truly protect wildlife and the environment. According to EPA’s ecological risk assessment for sulfoxaflor, the chemical is “very highly toxic” to bees. A study published last year in the journal Nature found significant concerns with the chemical’s ability to harm already declining pollinator populations. “There is an urgent need to pre-emptively evaluate the potential sub-lethal effects of sulfoximine-based pesticides on pollinators, because such effects are rarely detected by standard ecotoxicological assessments, but can have major impacts at larger ecological scales,” the authors wrote. EPA had already run in to legal problems associated with its registration […]

(Beyond Pesticides, August 23, 2019) The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) recently released a report criticizing EPA’s oversight of states’ Managed Pollinator Protection Plans (MP3s). OIG conducted an audit, on which the report is based, to evaluate agency performance in overseeing MP3s, voluntary plans adopted at the state level with the goal to “reduce pesticide exposure to pollinators (generally, honey bees managed and contracted out to growers for pollination services) through timely communication and coordination among key stakeholders.” The report’s findings include the following: EPA has no means to evaluate the national impact of MP3s. The agency has not developed a strategy to use data from a planned fall 2019 survey (see more below on the AAPCO/SFIREG/EPA survey) to evaluate either the national impact of MP3s or the agency’s support of state MP3 implementation efforts. EPA focuses primarily on acute risks (those that occur during a single exposure to a specific pesticide), and gives insufficient attention to chronic exposures to pesticides and to native pollinator protection activities. The history of the MP3 program starts in 2014, when President Obama issued a memo establishing a Pollinator Health Task Force (PHTF), directing federal agencies […]

(Beyond Pesticides, August 22, 2019) In early August, experts from European Union (EU) member states and staff members of the European Food Safety Authority (EFSA) announced their conclusion that chlorpyrifos fails to meet criteria for renewed approval for use, potentially moving the EU a step closer to an outright ban. This ends the green light that chlorpyrifos (and its structurally close cousin, chlorpyrifos-methyl) have enjoyed at the EU level since 2006. That permitting is set to expire in January of 2020, although eight member states — Germany, Ireland, Finland, Denmark, Sweden, Latvia, Lithuania, and Slovenia — had already either banned or never authorized chlorpyrifos use in their countries. In the U.S., states are picking up the slack on efforts against chlorpyrifos use as, in the tenure of the current administration, the Environmental Protection Agency (EPA) has chosen to protect industry rather than human health and the environment. The step EFSA took was unusual in that the agency does not typically publish findings before ongoing peer reviews are completed. EUObserver.com reports that EFSA’s public statement was triggered by a July 2019 EU request for information “on the available outcomes of the human health assessment in the context of the pesticides peer […]

(Beyond Pesticides, August 15, 2019) An article in the journal Plos One, “An assessment of acute insecticide toxicity loading (AITL) of chemical pesticides used on agricultural land in the United States,” shows that recent shifts in insecticide use—from organophosphates and carbamates to synthetic pyrethroids and neonicotinoids—have made a large contribution to the ongoing insect apocalypse. This shift to insecticides that target insects based on both selective toxicity and delivery method occurs within a context of shrinking habitat and biodiversity. The study, by Michael DiBartolomeis, PhD, Susan Kegley, PhD, Pierre Mineau, PhD, Rosemarie Radford, and Kendra Klein, PhD, presents a measure of acute insecticide toxicity loading that incorporates acute toxicity, quantity used, and the rate at which the insecticide degrades. Goulson et al. applied a similar measure in Great Britain that did not incorporate the rate of degradation. Both studies use the median lethal dose (LD50) to honey bees as a measure of acute toxicity and calculate the potential number of bee deaths based on the number of lethal doses of various insecticides applied in the field. In both cases, researchers used toxicity estimates for honey bees because they are widely available. Other insects may be more or less sensitive. The […]

(Beyond Pesticides, August 13, 2019) The U.S. Environmental Protection Agency (EPA) is refusing to approve product labels that disclose that the herbicide glyphosate may cause cancer, according to a press release published last week. The move comes after the state of California listed glyphosate on its Prop 65 list of chemicals known to cause cancer, birth defects or other reproductive harm. Health advocates are condemning the decision as the latest in a long string of EPA actions aimed at benefiting industry at the expense of consumer and public health. Many are concerned that the incessant stream of industry-friendly decisions is eroding public trust in the agency and its ability to act as an independent regulator. While a state judge gave the Prop 65 warning labels the go-ahead, a prior ruling from U.S. District Court Judge William Shubb in Sacramento placed a preliminary injunction on the California requirement that remains in place today. The state added glyphosate to its Prop 65 list after the International Agency for Research on Cancer (IARC) designated the chemical as a group 2A carcinogen.  Under Prop 65, California regulators are required to provide “clear and reasonable” warning labels when any one of four requirements in the […]

(Beyond Pesticides, August 12, 2019) Once again, the Environmental Protection Agency (EPA) has rejected the evidence provided by independent scientists and sided with the pesticide industry promoting its products; this time, removing a safety for factor for children on some of the most widely used insecticides, synthetic pyrethroids. When EPA cannot do its job, it is time for Congress to step in. Tell Congress: To Protect Children, EPA Must Consider the Independent Peer-Reviewed Science, Not Bend to Industry Lobbying. In a move that challenges the preponderance of independent peer-reviewed scientific findings on children’s health, EPA recently stripped away protections that limit children’s exposure to class of chemicals associated with childhood cancer, autism other learning disorders, and asthma. The result of the agency’s actions will be a dramatic increase in the use of synthetic pyrethroids, insecticides found in indoor and outdoor bug sprays, bug bombs, and often used on conventionally grown fruits and vegetables. EPA, under the leadership of former fossil fuel lobbyist Andrew Wheeler, is embracing the positions of the pesticide industry while ignoring independent science and health and environmental groups. In 2017, the agrichemical industry trade group, Croplife America, submitted comments to EPA during its review of synthetic pyrethroids. The organization urged EPA to rely on a […]

(Beyond Pesticides, July 30, 2019) Earlier this month, the U.S. Environmental Protection Agency announced a decision to register new uses for the bee-toxic pesticide sulfoxaflor. The decision closely followed a USDA announcement halting the Honey Bee Colonies Survey, combining blows to already suffering beekeepers. According to the nonprofit Bee Informed, this past winter tallied the most colonies lost in a decade—an estimated 37% between October 1, 2018 and April 1, 2019. “Proposing to register sulfoxaflor for use on bee-attractive crops, in the midst of an ongoing pollinator crisis, is the height of irresponsibility,” said Drew Toher, community resource and policy director for Beyond Pesticides in an interview for Bloomberg Environment. “When all of the available data points to significant risks to pollinators from use of this chemical we must face the facts: EPA is working towards the protection of pesticide industry, not the environment,” he said. Sulfoxaflor is a systemic insecticide whose mode of action is the same as neonicotinoid pesticides. After application, the chemical is absorbed and distributed throughout the plant, including pollen and nectar. These insecticides are selective agonists of insects’ nicotinic acetylcholine receptors—they bind to the receptor and cause it to activate. The impact on foraging bees […]

(Beyond Pesticides, July 29, 2019) A research study, published in March in Scientific Reports, uncovers a pesticide effect on a sugar-metabolizing enzyme common to all cells that has broad health ramifications ignored by the U.S. Environmental Protection Agency’s (EPA) safety testing protocol. This finding raises a larger question regarding the need for EPA to test for the synergistic effects of pesticides, whereby pesticides and chemicals in combination have an even greater effect than they do by themselves. The research, by T. Tristan Brandhorst, PhD, Iain Kean, PhD, and others in the lab of Bruce Klein, PhD, of the University of Wisconsin–Madison and UW School ofMedicine and Public Health, specifically sheds light on the mode of action of the fungicide fludioxonil. Fludioxonil, a phenylpyrrole fungicide, was developed to treat seeds during storage, and has come to be used commonly on grains, vegetables, fruits, and ornamental plants during cultivation, and produce after harvest to extend “shelf life.” As reported by the American Association for the Advancement of Science publication, EurekAlert, “The ability of [the fungicide] fludioxonil to act on a sugar-metabolizing enzyme common to all cells, and to produce the damaging compound methylglyoxal, may mean that the pesticide has more potential to harm non-fungal cells than previously […]

(Beyond Pesticides, July 24, 2019) The U.S. District Court for the District of Hawai’i has found the state’s Agribusiness Development Corporation (ADC) guilty of violating the Clean Water Act. The case, brought by organizations including Surfrider Foundation, Pesticide Action Network North America, and others, represented by Earthjustice, accused ADC of dumping water contaminated with pesticides, including the cancer-causing herbicide glyphosate, into the Pacific Ocean off of West Kauai without a permit since 2015. Hawai’i bears the brunt of agribusiness wrongdoings, and Kauai in particular has faced past issues of pesticide injustice at the hands of the ADC. However, this new ruling marks a turn in past decisions that have favored agribusiness, as the judge found ADC violations. Advocates hope that this decision will highlight the need for government accountability, and increase transparency about what pesticides and chemicals are entering our oceans. The ADC system collects groundwater and storm water runoff through a series of canals, ditches, and pumps. The polluted water, full of toxic pesticides and chemicals, discharges into the Pacific Ocean along popular beaches that residents use for recreational activities, including surfing and fishing. The case brought against ADC accuses the department of dumping this water without a National […]

(Beyond Pesticides, July 5, 2019) This is a story about a chemical pesticide, a fungicide, in wide use for which the mode of action, i.e., the ability to cause harm, has not been fully understood. It is not a story unique to this pesticide. Rather, it is an important story to consider when deciding to use a pesticide or allowing a pesticide to be used. The question is whether the chemical could be broadly problematic beyond the target organisms, in this case fungi? In its coverage of a study published in March, the American Association for the Advancement of Science publication, EurekAlert, reported that, “The ability of [the fungicide] fludioxonil to act on a sugar-metabolizing enzyme common to all cells, and to produce the damaging compound methylglyoxal, may mean that the pesticide has more potential to harm non-fungal cells than previously thought. Although fludioxonil has been deemed safe for use, the authors . . . suggest that the effects of this widely used pesticide has upon animals be re-examined.” The research study, published in March in Scientific Reports and led by T. Tristan Brandhorst, PhD (in the lab of Dr. Bruce Klein at the University of Wisconsin–Madison and UW School of […]

(Beyond Pesticides, July 1, 2019) France made a decision in May to ban a widely-used fungicide because it damages the endocrine system. In contrast, there has been a stark failure to protect health in the U.S. Despite a Congressional mandate, EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. This is a tragedy. Ask your elected members of Congress to demand that EPA tests and acts on regulatory endocrine disruptors as required by law. In 1998, following a mandate in the Food Quality Protection Act (FQPA) of 1996, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 21 years, the Endocrine Disruptor Screening Program (EDSP) has made little progress in reviewing and regulating endocrine-disrupting pesticides.  As of 2019, the program has stalled entirely. To ensure appropriate follow-through, Congress gave EPA a timeline to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after […]

(Beyond Pesticides, June 24, 2019) During “Pollinator Week,” last week, the U.S. Environmental Protection Agency betrayed its responsibility to protect the environment and approved “emergency” uses of sulfoxaflor, a bee-toxic insecticide, in 11 states on millions of acres of crops that are attractive to bees. Sulfoxaflor is functionally identical to the neonicotinoid class of systemic pesticides, which are readily absorbed and translocated into the plant tissues, including its pollen and nectar. These insecticides are substantial contributors to the dramatic decline of pollinators and what is now recognized as a global insect apocalypse. Ask Your Elected Members of Congress to Tell EPA that Its Actions Are Unacceptable and Must Be Reversed In 2015, beekeepers sued to suspend the use of sulfoxaflor. A year later, in 2016, the chemical’s registration was amended with the specific exclusion of crops such as cotton and sorghum that attract bees, essentially acting as an aromatic draw to poison. However, EPA regularly utilizes the “emergency exemption” rule under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to circumvent these restrictions. The Center for Biological Diversity reports, “Ten of the 11 states have been granted the approvals for at least four consecutive years for the same ’emergency.’ Five have […]

(Beyond Pesticides, June 19, 2019) On June 17, 2019, the Environmental Protection Agency (EPA) once again approved “emergency” uses of sulfoxaflor, a bee-toxic insecticide, on millions of acres of crops that are attractive to bees. Sulfoxaflor is functionally identical to the neonicotinoid class of systemic pesticides, which are readily absorbed and translocated by the plant, including its pollen and nectar. These insecticides are substantial contributors to the dramatic decline of pollinators and what is now recognized as a global insect apocalypse. In 2015, beekeepers sued to suspend the use of sulfoxaflor. A year later, in 2016 the chemical’s registration was amended with the specific exclusion of crops such as cotton and sorghum that attract bees, essentially acting as an aromatic draw to poison. EPA regularly utilizes the “emergency exemption” rule under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to circumvent these restrictions. The Center for Biological Diversity reports, “Ten of the 11 states have been granted the approvals for at least four consecutive years for the same ‘emergency.’ Five have been given approvals for at least six consecutive years.” The EPA’s Office of Inspector General (OIG) has recognized the broad misuse of Section 18. A 2018 report from OIG notes […]

(Beyond Pesticides, June 13, 2019) The U.S. allows the use of 85 pesticides that have been banned or are being phased out in the European Union, China or Brazil, according to a peer-reviewed study published last week by the academic journal Environmental Health. In 2016, the U.S. used 322 million pounds of pesticides that are banned in the E.U., accounting for more than one-quarter of all agricultural pesticide use in this country, according to the study. U.S. applicators also used 40 million pounds of pesticides that are banned or being phased out in China and 26 million pounds of pesticides that are banned or being phased out in Brazil. “It’s appalling the U.S. lags so far behind these major agricultural powers in banning harmful pesticides,” said Nathan Donley, PhD, a senior scientist with the Center for Biological Diversity and author of the study. “The fact that we’re still using hundreds of millions of pounds of poisons other nations have wisely rejected as too risky spotlights our dangerously lax approach to phasing out hazardous pesticides.” The study compared the approval status of more than 500 pesticides used in outdoor applications in the world’s four largest agricultural economies: the United States, European Union, China and Brazil. Report […]

(Beyond Pesticides, June 6, 2019) Pesticide use eliminates pest predators and permits mosquito populations to flourish, according to research conducted in Costa Rica by scientists at Utah State University. The new study, “Adaptation to agricultural pesticides may allow mosquitoes to avoid predators and colonize novel ecosystems,” highlights the dangers of human intervention through broad scale pesticide applications, and the urgent need to consider ecosystem-wide impacts before allowing chemicals to be placed on the market. As lead study author Edd Hammill, PhD, told National Geographic, the investigation got its start after he observed higher numbers of mosquitoes in orange groves he was visiting, when compared to other, non-agricultural areas. “We felt like we were getting a lot more mosquito bites in plantations than in pristine areas and started to wonder why,” noted Dr. Hammill. The study focuses first on the role that bromeliads, a tropical flowering plant that grows on tree branches, play in affecting mosquito populations. Mosquitoes use the water that these plants catch in between their leaves to lay eggs. Many other species are found to lay eggs within the leaves, including the top-level predator in this system, the damselfly. Dr. Hammill’s team looked at community composition within bromeliad […]

(Beyond Pesticides, May 28, 2019) In yet another attack by the Trump administration on science, public health, and children and families, as well as another wink and nod to industries whose products harm, the U.S. Environmental Protection Agency (EPA) and the National Institute of Environmental Health Sciences (NIEHS) are planning to end their support for research centers that do important scientific investigation related to children’s health. Tell Your Congressional Representatives to Insist on Funding for Children’s Environmental Health Centers. EPA has announced that it will no longer renew its grants to these centers. As of July, they will lose a huge portion of the funding that has allowed them to deploy hundreds of scientists — in genetics, toxicology, and neurodevelopment — on unusually comprehensive and longitudinal studies of what factors in children’s experiences and communities impact their health. The work of these centers has been critical in uncovering the relationships between children’s exposures to toxic chemicals, including pesticides, and diseases and health anomalies later on in their developing years. According to Tracey Woodruff, PhD, who runs the University of California, San Francisco Pregnancy Exposures to Environmental Chemicals Children’s Center: When EPA weighs the harms of a chemical against its benefits, ignorance “works out perfectly for industry. . . If EPA doesn’t […]