(Beyond Pesticides, March 29, 2021) New data on the hazards of neonicotinoid insecticides calls for urgent regulatory action. The same pesticides that are linked to the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Widely known for their nectar-fueled hovering flight powered by wings beating up to 80 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal. Tell EPA and Congress to save the hummingbirds by suspending use of neonicotinoid insecticides and supporting the transition to organic practices. While hovering, a hummingbird consumes calories faster than any other bird or mammal. That’s why the finding that exposure to the neonicotinoid insecticide imidacloprid slows metabolism up to 25% is so disturbing. Systemic pesticides like imidacloprid and other neonics are transported throughout the plant, including nectar. Findings on the danger neonicotinoids pose to hummingbirds decades after the chemicals were first permitted to be used in the environment, and by independent scientists, not regulatory agencies, is indicative of a regulatory approach that fails […]

(Beyond Pesticides, March 23, 2021) Earlier this month, the Arkansas State Plant Board (ASPB) voted to loosen regulations curtailing use of the highly drift-prone herbicide dicamba. With an 8-7 vote, ASPB eliminated measures advanced in 2016 that protect growers from dicamba drifting off of genetically engineered (GE) soybean fields. Farmer, health, and environmental advocates are encouraging groups and individuals to submit testimony in opposition to the changes should the state’s Governor continue the proposal to a 30-day comment period. Dicamba has been the subject of intense debate and scrutiny over the last several years—most prominently in Southern and Midwestern states where extensive cotton and soybean monocultures are grown. Due to rampant weed resistance to glyphosate herbicides in GE crop fields, Bayer/Monsanto developed new seeds capable of growing into plants that can withstand repeated sprayings of both glyphosate and dicamba. The company released these new seeds in the mid-2010s without waiting for the U.S. Environmental Protection Agency (EPA) to approve a corresponding herbicide formulation Bayer/Monsanto claimed would reduce drift problems. Farmers began using older, unapproved dicamba formulations, but ultimately even after receiving approval, new formulations proved too drift-prone and problematic to be used without incident. In response, ASPB instituted changes that […]

(Beyond Pesticides, March 15, 2021) A staff report produced for the Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform of the U.S. House of Representatives has documented substantial levels of the heavy metals arsenic, lead, cadmium, and mercury in infant foods. The researchers examined organic as well as nonorganic brands, finding contamination of both. They found that heavy metals were present in both crop-based ingredients and additives. However, many unknowns remain regarding the precise origin of the metals. Tell FDA and USDA to get heavy metals out of baby food! Two U.S. Senators (Amy Klobuchar, D-MN and Tammy Duckworth, D-IL) and two U.S. Representatives (Raja Krishnamoorthi, D-IL and Tony Cardenas, D-CA) have drafted legislation to strengthen regulations for infant food safety, but meanwhile want the Food and Drug Administration (FDA) to use existing authority to take immediate action. The National Organic Program should also take action to ensure that parents can depend on organic baby food to be the best possible. Heavy metals can have serious health impacts, especially on young children. As stated in the report, Children’s exposure to toxic heavy metals causes permanent decreases in IQ, diminished future economic productivity, and increased risk […]

(Beyond Pesticides, March 9, 2021) Last week, the Environmental Protection Agency (EPA) announced an interim decision to cancel of one of the most hazardous pesticides still used in the United States, pentachlorophenol (penta). Although long overdue, health advocates are hailing the agency’s action, taken due to significant risks to human health, the availability of alternatives, and the uncertain future of penta production. Many advocates hope that EPA’s announcement is the start of a pivot to science-based decision-making in the best interest of health and the environment, not the pockets of pesticide industry executives. Cancellation of this toxic chemical will bring  the U.S. into conformance with the Stockholm Convention, an international treaty to ban persistent organic pollutants (POPs) joined by over 150 countries that was never ratified by the U.S. “This has been a long time coming,” said Jay Feldman, executive director of Beyond Pesticides. “After decades of scientific reports, lawsuits, regulatory comments, and an international ban, we’re glad EPA finally acknowledged the intrinsic dangers posed by continuing penta’s registration. We urge the agency expedite its slow cancellation timeline so that we can finally eliminate this unnecessary pollutant.” Produced for its ability to preserve wood through pressure treatment, penta has been […]

(Beyond Pesticides, March 5, 2021) Pet owners will be alarmed to read the report, by USA Today, that a popular flea and tick collar — Seresto, developed by Bayer and sold by Elanco — has been linked to nearly 1,700 pet deaths, injuries to tens of thousands of animals, and harm to hundreds of people. At the time of publication, the U.S. Environmental Protection Agency (EPA), which regulates pesticides, had issued no informational alert to let the public know about these risks to pets — despite many hundreds of incident reports in its Office of Pesticide Programs Incident Report database. Beyond Pesticides and other advocates have warned of the toxicity of pet pesticide treatments, not only to the animals themselves, but also, to children and other household members. There are nontoxic ways to protect pets from fleas and other pests, and to protect human family members at the same time. Beyond Pesticides is calling on EPA to recognize, finally, that the label on flea collars is not adequately protective, as evidenced by the number of deaths and 75,000 incidents. “EPA has the authority to act now, and it should use its powers to protect the health and lives of pets,” […]

(Beyond Pesticides, March 3, 2021) Earlier this week, pesticide regulators in the commonwealth of Massachusetts voted to restrict outdoor consumer uses of neonicotinoid insecticides. The move is the result of sustained advocacy from broad coalition of individuals and organizations focused on protecting pollinators and ecosystem health. While advocates are pleased that the Pesticide Board Subcommittee made Massachusetts the first state in the country to restrict neonicotinoids through a regulatory process, they note this is only the first step in eliminating these hazardous insecticides. “This marks an incremental victory which took us 6 years to land, and it only happened because of immense, ongoing grassroots action and legislative allies who are willing to hold state regulators accountable,” said Martin Dagoberto, Policy Director of the Northeast Organic Farming Association, Mass. Chapter in a press release. “We still have a monumental endeavor ahead if we are to reduce toxins and rein in the toxic influence of the chemical lobby,” Mr. Dagoberto added. Advocates had been pushing the legislature to pass An Act to protect Massachusetts Pollinators, sponsored by pollinator champion Representative Carolyn Dykema, since 2014. Following several failures by state lawmakers to bring the bill over the finish line, efforts in 2019 resulted […]

(Beyond Pesticides, March 2, 2021) Populations of solitary ground nesting bees decline after exposure to neonicotinoid insecticides, according to a study published in Scientific Reports late last month. In addition to ground-nesting bees, neonicotinoids have been shown to harm butterflies, hummingbirds, songbirds, aquatic species and mammals, including humans. As independent science continues to look beyond the effects of these systemic chemicals on honey and bumblebees, advocates maintain that it has become increasingly clear that the high hazards presented by neonicotinoids necessitate their complete elimination. “Farmers need to protect their crops from pests, but they also absolutely need to protect pollinators from the unintended effects of pesticides,” said study coauthor Susan Willis Chan, PhD. “The data on this particular [neonicotinoid] product are so clear that there’s really no question about what has to happen. We have to find something else.” Researchers focused their effort investigating how various systemic pesticides effect the hoary squash bee (Eucera pruinosa), a ground nesting bee found throughout North America that feeds entirely on pollen from cucurbits (including squash, cucumber, pumpkin, gourds, etc). The hoary squash bee provides essential pollinator services for these crops throughout the U.S. and Canada. Neonicotinoids and other systemic insecticides are often applied […]

(Beyond Pesticides, February 23, 2021) The same pesticides implicated in the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Well known for their nectar-fueled hovering flight powered by wings beating over 50 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal. Scientists began their experiment by trapping 23 wild ruby-throated hummingbirds and housing them in an animal care facility. One group of birds acted as a control and received no pesticide exposure, while the rest were assigned either low, middle, or high exposure (1 part per million [ppm], 2ppm, and 2.5ppm, respectively) to the neonicotinoid imidacloprid. Scientists determined these amounts based upon probable nectar contamination in the real world. The pesticide was incorporated into the sugar solution provided to the birds over the course of three days. Within two hours of exposure to the pesticides, hummingbird metabolism dropped significantly. While the control group increased energy expenditure between 1% to 7%, the low exposed group displayed a 6% average decline, […]

(Beyond Pesticides, February 22, 2021) Congressional Rep. Joe Neguse, Rep. Alan Lowenthal and Chair of the Natural Resources Subcommittee on Water, Oceans and Wildlife Rep. Jared Huffman have reintroduced their resolution (H.Res. 69: Expressing the need for the Federal Government to establish a national biodiversity strategy for protecting biodiversity for current and future) to create a national biodiversity strategy. Everywhere we turn, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. Never was a holistic strategy on biodiversity more urgent. Tell your U.S. Representative to cosponsor Rep. Neguse’s National Biodiversity Strategy Resolution, H.Res. 69. The resolution calls for a natio. 69.nal commitment to addressing the biodiversity crisis by establishing a strategy to be developed through an interagency process announced by the president in an Executive Order. The strategy process will encourage agencies to identify and pursue a full range of actions within existing laws and policies and encourage consideration of new ones. It would also promote accountability and progress in addressing the biodiversity crisis through a new quadrennial assessment. “The decline of biodiversity presents a direct threat to the security, […]

(Beyond Pesticides, February 17, 2021) New details are emerging around the pressure campaign Mexican President Andrés Manuel López Obrador and his administration withstood as the country moved towards banning Bayer/Monsanto’s glyphosate (Roundup) herbicide. According to documents obtained by a Freedom of Information Act request and published in the Guardian, U.S. Trade Representative, the U.S. Environmental Protection Agency (EPA), and U.S. Department of Agriculture (USDA) worked in coordination with Bayer/Monsanto and the agrichemical industry umbrella group Croplife America to stop the Mexican government from embracing a precautionary approach to pesticide regulation. While the Trump administration and its collaborators were successful in a similar campaign against Thailand, there are no indications that Mexico will rescind its final decision to ban glyphosate, made at the end of last year. Health and environmental advocates want the Biden administration to not only halt the regular use of the United States’ immense global power on embarrassing flacking for the agrichemical industry, but reverse course, and embrace a truly precautionary approach. Croplife and the rest of the agrichemical industry are terrified of that outcome. In a letter to the U.S. Trade Representative, copying the heads of USDA and EPA, Croplife President Chris Novak wrote of Mexico’s decision, […]

(Beyond Pesticides, February 8, 2021) Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order, if effective, will  reverse the historical trend of status-quo regulatory reviews required by the White House Office of Management and Budget (OMB) that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers). Instead, the President’s EO, Modernizing Regulatory Review, sets the stage for the adoption of agency policy across government to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism). Key agencies that can have a systemic effect in meeting these existential challenges are the Environmental Protection Agency (EPA), Department of Interior (DOI), Department of Agriculture (USDA), and Department of Labor/Occupational Safety and Health Administration (DOL/OSHA). But the EO will remain words on a page unless we all across the country exercise our voice and advocate for the changes necessary to end […]

(Beyond Pesticides, February 5, 2021) The American public has witnessed, in the barely launched tenure of President Joe Biden, a surge of Executive Orders (EOs). Based on the first flurry of orders, much of the Biden “reset” appears gauged to beat back Trump policies that worsened an already inadequate regulatory system, and to reconfigure federal operations and regulations so as to address and solve the biggest threats (beyond COVID) the country faces. Among the high-profile EOs already issued are three that stand out. One recalibrates the operations of the OMB (Office of Management and Budget) to forward health, racial equity, and environmental stewardship. A second and third seek, respectively, to restore scientific integrity and elevate the role of science across the federal government, and to tackle comprehensively the climate crisis with a “whole of government” approach. Beyond Pesticides welcomes these early efforts, and maintains that vigilance and robust advocacy will be necessary to achieve needed paradigmatic change across federal agencies, which exist to protect and support the American people. EOs are tools the President can wield to manage directly some operations of the federal government. They are seen as muscular and immediate means through which to change course, particularly in […]

(Beyond Pesticides, February 2, 2021) The U.S. Environmental Protection Agency (EPA) will evaluate the effect of the neonicotinoid insecticide imidacloprid on endangered species, after an agreement was reached between the agency and the Natural Resources Defense Council (NRDC). Imidacloprid is one of the most commonly used insecticides in the world today and, like other neonicotinoids in its chemical class, has been linked to a range of adverse impacts on wildlife and their habitat. While the agreement to the assess effects on endangered species is important, advocates note that EPA should already have conducted this review, and further, that imidacloprid and other neonicotinoids should already be banned. NRDC’s successful lawsuit follows a separate legal challenge by the Center for Food Safety, Beyond Pesticides, beekeepers, and other environmental organizations which was settled in 2019. The judge in that case, focused on the neonicotinoids clothianidin and thiamethoxam, did not order EPA to consult with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) (which is required when registering a pesticide in order to mitigate risks to endangered species). Instead, she directed the parties, including the plaintiffs, defendant EPA, and intervenor Bayer CropScience (the manufacturer of neonicotinoids), to move forward […]

(Beyond Pesticides, February 1, 2021) The yearly winter monarch count along the California coast, overseen each year by the conservation group Xerces Society, was the lowest ever. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate that many on the planet today are, within their lifetimes, likely to experience a world where western monarchs are extinct. Tell the U.S. Fish and Wildlife Service to list monarch butterflies on the list of threatened and endangered species. Tell the Environmental Protection Agency to eliminate pollinator poisons. Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count. In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, that number fell to 1.2 million. Five years ago, counts were at roughly 300,000. By 2019, numbers crashed below 30,000. This year’s count saw no monarchs at well-known overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park, saw only a few hundred. “These sites normally host thousands of butterflies, and their absence this year was heartbreaking for volunteers and visitors flocking to these locales hoping […]

(Beyond Pesticides, January 29, 2021) More oversight is needed to ensure farmworkers are protected from toxic pesticides, according to a report published this month by the U.S. Government Accountability Office (GAO) (the federal agency that provides auditing, evaluation, and investigative services for Congress). Revisions to the Worker Protection Standards (WPS) governing farmworker safety were updated by the Obama administration in 2015, but GAO identified a number of shortfalls in EPA’s administration of the changes. GAO focused its review on the implementation of the ‘designated representative’ provision, which grants farmworkers the ability to task an individual they designate to request information on toxic pesticides from their employers. Providing farmworkers with a designated representative allows for the access of pesticide application and hazard information, so that they may take proper precautions or seek medical care. A farmworker may use this provision when they are no longer near the farm they worked on, or if there are language barriers. Without this provision, the information farmworkers receive would be at the whim of employers, and past incidents show that lack of information can lead to hazardous, abusive conditions for workers. EPA officials, state officials, and stakeholders told GAO there was no evidence of such […]

(Beyond Pesticides. January 25, 2021) First registered in 1970 and voluntarily cancelled in 2010, aldicarb (Temik™) was being manufactured in Bhopal, India in 1984 when a leak of a precursor—methyl isocyanate (MIC)—spread over the city, ultimately killing more than 25,000 people and leaving more than 120,000 people who still suffer from severe health problems as a result of their exposure. In 1989, Union Carbide Corporation—the manufacturer of aldicarb at the time—paid $470 million (equivalent to $860 million in 2019) to settle litigation stemming from the disaster. Aldicarb has been allowed by the outgoing Trump EPA for use on oranges. >>Tell EPA to Reverse Approval of Highly Toxic Insecticide Aldicarb! No pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. The disaster in Bhopal was followed by others, including a leak in Institute, WV in 1985 that injured at least 135 people and a 2008 explosion in Institute, WV that killed two and injured at least eight. In use, it has been implicated in poisoning of workers and their children, poisoning deer and other game consuming contaminated seeds, and notably, poisoning food grown in soil treated with the chemical. The effects don’t stop there—aldicarb is also notorious for contaminating groundwater. […]

(Beyond Pesticides, January 22, 2021) After the past four devastating years, hopes and expectations of the Biden/Harris administration abound among the environmental and public health communities. The ears and eyes of many advocates, as well as those in the agricultural community, are attuned (among myriad candidates) to the fate of the pesticide aldicarb. Although Environmental Protection Agency (EPA) registration of this terribly toxic insecticide was cancelled in 2010, various limited-use reapprovals since then have meant that the compound has found its way to increasing levels of use. On January 12, as another parting shot of midnight rulemaking, Trump’s EPA approved expanded uses (see below). The $64,000 question is whether the new administration will use its authority under the Congressional Review Act — which enables Congress to pass a joint resolution (then signed by the President) to overturn a new federal agency rule and prevent its reissuance in the future — to get this pesticide retired for good. Beyond Pesticides urges President Biden’s EPA to do so. Notably, the Trump administration used the Congressional Review Act to destroy myriad environmental rules when it came into power. This permitting of expanded aldicarb uses fits the pattern. Environmental Health News notes that, as of early […]

(Beyond Pesticides, January 20, 2021) The U.S. Environmental Protection Agency has confirmed that PFAS (per and polyfluorinated alykyl substances) ‘forever chemicals’ are contaminating containers that store pesticide products, and subsequently the products themselves. The confirmation comes after preliminary testing from the watchdog group Public Employees for Environmental Responsibility (PEER) found PFAS in the widely used mosquito pesticide Anvil 10+10. In response EPA announced further investigation and said, “EPA understands the need to provide guidance to states, tribes, and other users as they prepare to purchase mosquito control products for 2021 and will provide more information as it continues its investigation. EPA will update the following webpage with information as it becomes available: https://www.epa.gov/pesticides/pfas-packaging.” “EPA’s discovery has opened a Pandora’s Box of health risks,” stated PEER Science Policy Director Kyla Bennett, PhD, whose testing of the insecticide first raised the alarms, according to the EPA statement.  “Shipping containers may be a significant source of PFAS exposure through the entire U.S. agricultural sector.” According to EPA, high-density polyethylene (HDPE) containers used to store and transport pesticides are commonly treated with fluoride in order to create a “chemical barrier” that will “prevent changes in chemical composition.” The fluorinated container is supposed to be more stable, […]

(Beyond Pesticides, January 13, 2021) An ethanol processing plant located in the small village of Mead, Nebraska has been using seeds coated in bee-toxic chemicals as part of its production process, according to reporting published in The Guardian earlier this week. The plant, owned by a company called AltEn, may be the only plant in the U.S. producing biofuels with toxic seeds. There is a reason for that, and Mead residents are experiencing the adverse effects of EPA not regulating treated seeds. The prevalence of the use of seed coatings in chemical agriculture has increased over the last several decades, as the pesticide industry works to increase product sales by exploiting a loophole in federal pesticide law. Under FIFRA (the Federal Insecticide Fungicide and Rodenticide Act), a clause known as the “treated article exemption” permits seeds to be coated with highly toxic pesticides without any requirement for the U.S. Environmental Protection Agency (EPA) to assess environmental or public health effects of their use. This allows hazardous pesticides (primarily insecticides and fungicides) to be used indiscriminately with no effective oversight. Research finds that over 150 million acres of farmland are planted with toxic seeds, including nearly four tons of bee-killing neonicotinoids […]

(Beyond Pesticides, January 12, 2021) New York State is set to prohibit on December 31, 2021 the use of glyphosate on all state property after Governor Andrew Cuomo signed bill S6502A/A732b late last year. The state legislature passed the legislation in July, 2020. The move is an important recognition by the nation’s fourth most populous state that the Environmental Protection Agency (EPA) is not adequately protecting people and the environment from hazardous pesticides (pesticide is an umbrella term that includes insecticides, herbicides, fungicides, etc). However, the law’s ability to improve these protections will depend significantly upon the management approach that replaces glyphosate use.  “A transition away from Roundup and other glyphosate-based pesticides must reject the use of regrettable substitutes, and embrace sound organic principles and practices,” said Jay Feldman, executive director of Beyond Pesticides. In pest and weed management, regrettable substitutions occur when one toxic chemical is banned or restricted, and another hazardous pesticide is simply used in its place. The substitution may have a different chemical formulation, mode of action, and set of health and environmental impacts, but nonetheless fills the same role as Roundup/glyphosate when it comes to weed management. When the answer to eliminating glyphosate is to […]

(Beyond Pesticides, January 11, 2021) Treatment of chemical companies as clients rather than regulated entities is not new at the Environmental Protection Agency (EPA), but corruption reached new highs during the Trump administration. With a new administration, it is time to end the rule of corporate deception at EPA. This goes beyond the use of the Congressional Review Act to reverse individual rules (adopted in the last six months) that defy scientific findings and compliance with environmental and public health standards. We can no longer rely on bad science and unscrupulous chemical manufacturers that put profits above concerns for the health of people and the environment. EPA must audit pesticide registrants for integrity to scientific process and set a moratorium on future pesticide registration until the agency can assure the public that their science is not corrupt, as it has been in the past. Tell President-elect Biden and Congress to clean up the corruption of science at EPA and set a moratorium on future pesticide registrations—until the agency can assure the public that the chemical manufacturers’ science supporting pesticide registrations is not corrupt. The Midwest Center for Investigative Reporting published a story in early December on yet another example of the […]

(Beyond Pesticides, January 8, 2021) In an eleventh-hour move, the Trump administration’s Environmental Protection Agency (EPA) announced on January 5 the finalization of its controversial, so-called “transparency” rule. The agency claims that the rule— dubbed “Strengthening Transparency in Pivotal Science Underlying Significant Regulatory Actions and Influential Scientific Information”—which mandates that researchers provide to EPA access to their raw data, will improve the credibility of its regulations because the public would be able to validate research that influences EPA regulations. In fact, as researchers and advocates recognize, this rule will significantly restrict the scientific research EPA uses in developing regulations to protect human health. This rule will mitigate against use of the best and broadest knowledge base in developing protections for the American people. In its article on the EPA announcement, The Washington Post explains that the rule would “actually restrict the EPA from using some of the most consequential research on human subjects because it often includes confidential medical records and other proprietary data that cannot be released because of privacy concerns.” Trevor Nace of Forbes magazine writes of the proposed rule: ‘It literally throws out fundamental and hallmark environmental studies the EPA paid scientists to conduct and [which it used to] build […]

(Beyond Pesticides, January 5, 2021) In the waning days of 2020, a federal court provided a hint of hope that farmworkers will retain basic buffer zone protections from toxic pesticides. The District Court for the Southern District of New York  issued in late December a temporary restraining order against the U.S. Environmental Protection Agency (EPA), prohibiting the agency from implementing industry-friendly rules that weaken application exclusion zones (AEZs) for farmworkers. The ruling, a result of a lawsuit brought by groups Farmworker Justice and Earthjustice, is likely to put the onus on the next administration to determine the fate of the rule. Application Exclusion Zones (AEZs) are buffer zones where individuals are not permitted to enter during a pesticide application, as doing so would put one at risk of dangerous exposure. EPA’s proposal,  pushed forward by Administrator Andrew Wheeler and finalized in October 2020, included a number of changes to the way AEZs would be managed. Chemical intensive farms would no longer be required to keep bystanders out of off-site spray areas, and pesticide applications could be restarted when an individual leaves an AEZ. Current rules require farms to keep individuals out of areas where pesticides are applied, both on and […]