(Beyond Pesticides, August 28, 2024) The U.S. Environmental Protection Agency’s (EPA) pesticide labeling requirements fail to adequately communicate acute toxicity levels to the public, as evidenced in a recent study of consumers published last month in the journal Nature. After evaluating whether the current three “signal” words (CAUTION, WARNING, DANGER) on pesticide products adequately convey pesticide toxicity, the authors conclude that current labeling may result in “unintended adverse effects” because it does not “effectively communicate toxicity risks to consumers.” The signal words on pesticide labels, based on laboratory animal testing for determining lethal doses, are intended to protect users of the product from exposure that can kill through inhalation, skin absorption, and ingestion of the pesticide. However, the signal words do not warn about long-effects like cancer, neurological diseases, reproductive harm, as well as other adverse effects associated with pesticide exposure. (See Pesticide-Induced Diseases Database.)   The study tests two prototype labels to evaluate the effectiveness of visual elements in communicating toxicity information, citing research in cognitive psychology that indicates visual elements, like images and graphics, are more effective for conveying information than text alone. This is particularly crucial for pesticide labels, where complex toxicity details need to be communicated quickly […]

(Beyond Pesticides, July 25, 2024) On July 10, the Oregon Court of Appeals ruled that the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) does not preempt pesticide exposure victims’ state law claims against pesticide manufacturers, based on reporting from The New Lede. This decision builds on years of judicial precedent from the Supreme Court of the United States (SCOTUS) that protects individuals’ right to use failure-to-warn claims against producers of toxic pesticides, including Bayer-Monsanto. The importance of judicial review is critical to protecting the public against public health impacts of toxic pesticide use in the context of last month’s SCOTUS decision ending Chevron Doctrine, and with it the end of deferring to federal regulatory agencies on ambiguities in statutory mandates. A growing coalition of environmental and public health advocates, organic farmers, trial attorneys, farmworkers, and physicians are united in pushing back against a concerted effort by industry and its allies to attack victims’ ability to sue under “failure-to-warn” through the Farm Bill, state legislatures, and the proposed federal budget for Fiscal Year 2025. Oregon Court of Appeals In 2022, a local trial court in Oregon ruled in favor of Monsanto on a lawsuit initiated by Jackson County residents Larry and […]

(Beyond Pesticides, Feb 22, 2024) The Idaho Senate failed to pass SB 1245 last week which would have provided legal protection to pesticide manufacturers from “failure-to-warn” liability. This legal framework has been pivotal not only for plaintiffs, who are typically users of a toxic product, seeking redress from exposure to glyphosate-based herbicide products such as Roundup, but can also potentially extend to any toxic pesticide products. Similar bills have recently been introduced in the Iowa, Florida, and Missouri state legislatures as petrochemical pesticide industry actors such as Bayer face billions of dollars in legal settlements from victims of pesticide injury. While the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) registration process permits the labeling of products with pesticidal claims based on compliance with testing requirements, the state legislation would establish EPA-authorized pesticide labels as definitive evidence that cannot be challenged in a court of law. The Idaho legislation, SB 1245, was introduced in January in the state Senate by Senator Mark Harris, who represents Soda Springs County, which has North America’s largest elemental phosphorus mine (phosphorus is a critical ingredient in developing glyphosate). Proponents of SB 1245 argue, “[This bill] protect[s] companies that produce safe pesticides critical to agriculture in […]

(Beyond Pesticides, December 19, 2023) Last week, farmworker organizations and Beyond Pesticides, represented by the Center for Food Safety, filed a petition with the U.S. Environmental Protection Agency (EPA) urging that the weed killer glyphosate be removed from the market. The petition cites 200 studies, which represent a fraction of the independent scientific literature on the hazards of glyphosate and formulation ingredients of glyphosate products. This action follows previous litigation in 2022 in which a federal court of appeals struck down EPA’s human health assessment, finding that the agency wrongfully dismissed glyphosate’s cancer risk. The farmworker groups petitioning include Farmworker Association of Florida, Organización en California de Lideres Campesinas, Alianza Nacional de Campesinas, and the Rural Coalition.   Meanwhile, verdicts against glyphosate’s manufacturer, Bayer, continue to pile up with a December jury verdict in Pennsylvania awarding $3.5 million and a November jury in Missouri ordering $1.56 billion to be paid to four plaintiffs. All link their cancer to use of the Roundup. Bayer has lost almost all of the cases filed against it for compensation and punitive damages associated with plaintiffs’ charge that its product (previously manufactured by Monsanto) caused them harm.  The petition summarizes its purpose and justification as […]

(Beyond Pesticides, February 22, 2018) Online retailer Amazon will pay $1.2 million in penalties to settle violations to U.S. regulations for selling illegal and misbranded pesticides in its online store. Under the terms of the settlement, Amazon will monitor and remove illegal pesticide products from its website. These products, mostly imported, were not registered for use and sale in the U.S. and can pose hazards to unsuspecting consumers. As part of an agreement with the U.S. Environmental Protection Agency (EPA) Amazon has agreed to pay $1.2 million in administrative penalties for nearly 4,000 violations of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) by allowing third-party distributors to sell imported pesticide products on Amazon even though the products were not registered in the U.S. While agreeing to the settlement, Amazon neither admitted nor denied the specific facts alleged by the EPA. “This agreement will dramatically reduce the online sale of illegal pesticides, which pose serious threats to public health in communities across America,” EPA Region 10 Administrator Chris Hladick said in a news statement. The most concerning illegal products being sold are insecticide chalk products imported from Chinese manufacturers (3 pcs Cockroaches Bugs Ants Roach Kills chalk; Miraculous Insecticide Chalk; […]

(Beyond Pesticides, June 22, 2017) On Tuesday, a lawsuit was filed in a Wisconsin federal court against Monsanto, the manufacturer of Roundup brand herbicides, and Scotts Miracle-Gro Company, a marketer of Roundup brand products. The complaint, filed by six consumers from states around the country, focuses on the promotion, marketing, and sale of Roundup brand products, rather than physical injury from the pesticide products. The lawsuit alleges that the Monsanto and Scotts label, advertise, and promote their Roundup products with the “false statement that Roundup’s active ingredient, glyphosate, targets an enzyme that is not found ‘in people or pets.’” Plaintiffs assert that this is a false and deceptive claim, as this enzyme is found in the gut bacteria of people and pets and glyphosate can disrupt the health and functioning of their immune system. This suit follows on the heels of and mirrors the lawsuit filed by Beyond Pesticides and Organic Consumers Association in April 2017 against Monsanto for misleading the public by labeling the weedkiller Roundup as “target[ing] an enzyme found in plants but not in people or pets.” Monsanto aggressively markets Roundup as safe for humans and animals, despite newer studies indicating that glyphosate may be carcinogenic and affect […]

(Beyond Pesticides, May 24, 2017) A Hawai’i woman is suing her former employer, DuPont Pioneer, stating that the company retaliated against her for bringing up concerns over pesticide safety. Shanbnell Grilho, who worked for DuPont Pioneer on Oahu’s North Shore, alleges the company required her to apply hazardous herbicides without the proper training or protection, and ultimately fired her after fabricating allegations against her. This lawsuit is the latest claim against multinational pesticide companies operating in Hawai’i, which have been at the center of local and state-level disputes over their use of toxic pesticides where Hawai’i residents live, work, and play. In her complaint, Ms. Grilho indicates that she began working at DuPont Pioneer as a temporary employee, during which time she was awarded a raise and named DuPont Pioneer employee of the month. At the time she did not have to apply pesticides. However soon after her award, she was hired as a full time employee and required to work with Roundup, Liberty, and Honcho herbicides, which contain the active ingredients glyphosate, glufosinate, and glyphosate, respectively.  “DuPont Pioneer required plaintiff to apply herbicides and biocides while wearing a backpack sprayer, driving an ATV while applying herbicides with a backpack […]

(Beyond Pesticides, May 18, 2017) A pesticide reduction plan proposed by investors in the Dr. Pepper Snapple Group (DPS) lacks a positive vision that could accomplish the investors’ goals. The shareholder proposal at DPS, which makes Mott’s, 7UP, Snapple, and Canada Dry, was filed by the Green Century Equity Fund, a company that offers environmentally and socially responsible mutual funds, seeks to pressure DPS to reduce toxic pesticide use in its supply chain. According to their press release, the shareholder proposal suggests that DPS “use quantitative metrics to track the amount of pesticides avoided, publish goals to reduce pesticide use or toxicity, and/or provide incentives to growers to minimize the use of pesticides.” However, the shareholder group could better achieve its goals by asking that DPS use certified organic ingredients. Beyond Pesticides has long sought a broad-scale marketplace transition that does not simply reduce or minimize pesticide use, but prohibits the application of toxic synthetic pesticides by law and promotes the widespread transition of conventional farmland to organic production, which is protective of health and the environment. Certified organic production, with its requirement of a detailed organic system plan and methods to foster and improve soil health, achieves the elimination […]

(Beyond Pesticides, January 27, 2016) Last week, farmers, environmentalists, and conservation groups filed a federal lawsuit that challenges the U.S. Environmental Protection Agency’s (EPA) approval of a new formulation of the toxic herbicide dicamba. The new formulation is called Xtendimax with Vapor Grip Technology, which is claimed to have lower volatility. The petitioners claim that EPA violated its duties under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) in issuing a conditional registration, and that it did not adhere to duties under the Endangered Species Act that require EPA to consult with the U.S. Fish and Wildlife Service to ensure registration would not harm any listed species. The organizations involved in the lawsuit are National Family Farm Coalition, Pesticide Action Network North America, Center for Food Safety, and Center for Biological Diversity, represented by legal counsel from Earthjustice and Center for Food Safety. Dicamba has caused a lot of controversy in the past. In August 2016, farmers in Missouri, Arkansas, and Tennessee confronted widespread crop damage and braced for lower yields as a result of agrichemical giant Monsanto’s botched roll-out of GE soybean and cotton crops. The company, whose current line of glyphosate-tolerant crops are failing to control weeds throughout […]

(Beyond Pesticides, January 4, 2017) The New Year saw its first pesticide-related tragedy yesterday when four children, ranging in age from 7-17, died from a toxic pesticide treatment on their house in Amarillo, Texas. The pesticide at issue, aluminum phosphide, was illegally applied under a mobile home where at least ten people were living. The chemical, classified by the U.S. Environmental Protection Agency (EPA) as a restricted use pesticide (RUP), is restricted for use by certified applicators (and those under their supervision) and it is a violation to use it within 100 feet of residential structures. CNN reports that a family member used water to try and wash away the pesticide after it was applied, and the combination of water and aluminum phosphide increased the release of toxic phosphine gas. The incident demonstrates the deficiency of managing risks of highly toxic chemicals by labeling them “restricted use.” It has been Beyond Pesticides’ position that chemicals with aluminum phosphide’s level of toxicity should not be available on the market, even with restrictions. In making regulatory determinations on pesticide allowances, advocates have urged EPA to calculate the reality of misuse and accidents, instead of assuming 100% compliance with product label instructions. With this approach, the agency would […]

(Beyond Pesticides, December 24, 2016) Beyond Pesticides thanks our members and supporters for being a part of a critical movement to advance sustainable and organic land and building management in 2016. As our Daily News takes a holiday break, returning Tuesday, January 3, 2017, we hope you will join us in reflecting on the progress made this year, and the critical challenges that lie ahead. The road ahead We are entering a period in our nation’s history with many serious concerns about the protection of public health and the environment. We have heard the President-elect’s rhetoric about the overreach of the Environmental Protection Agency (EPA), the burden of regulatory compliance, and the need to dismantle environmental programs. The nominee for EPA Administrator is on record as challenging science and the value of environmental protection. In contrast, we have learned over the last several decades that protection of the environment contributes to a productive economy and healthier people. Beyond Pesticides’ databases track the scientific literature on pesticide hazards and alternatives, which clearly document the value of healthy ecosystems in providing ecosystem services that translate to reduced costs for farmers and land managers. Whether we’re talking about bees and other pollinators or predator insects, […]

(Beyond Pesticides, November 8, 2016) A report published last month from the U.S. Centers for Disease Control and Prevention (CDC) finds that over 2,600 cases of acute pesticide poisoning occurred among workers in 12 states between 2007 and 2011. The report, published by CDC’s National Institute for Occupational Safety and Health (NIOSH), highlights the hazards conventional pesticides pose to both farm and non-farm workers who apply these inherently toxic chemicals. Results of this study underscore the importance of calls from public health and farmworker advocacy groups for improving the protection of workers who grow and harvest the food that makes its way to American’s dinner plates. The results also support a wholesale transition away from toxic chemicals in favor of organic and sustainable alternatives. CDC’s report, collected from 12 farming states (including California, Florida, Iowa, Louisiana, Michigan, Nebraska, North Carolina, New Mexico, New York, Oregon, Texas, and Washington), focuses on acute pesticide poisonings. The data gathered comes from NIOSH’s Sentinel Event Notification System for Occupational Risks (SENSOR) program, a project that has tracked pesticide-related illness in the U.S. since 1987. The report finds that pesticide poisoning incidents among agricultural workers are 37 times those of nonagricultural workers. Proportionally, acute poisoning […]

(Beyond Pesticides, September 27, 2016)  Multinational pesticide manufacturer Syngenta Crop Protection was handed a  $1.2 million fine last week for multiple violations of federal pesticide law, according a settlement reached with the U.S. Environmental Protection Agency (EPA). EPA charged Syngenta with three major violations of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA), including: (1) Failure to have repackaging agreement and/or maintain records on registered pesticides; (2) Distributing misbranded pesticides, and; (3) Failure to maintain data submitted for pesticide registration. However, under the consent agreement reached with EPA, the company neither admits nor denies the allegations. The settlement comes at a time of increased scrutiny of Syngenta, as the company is in the process of reregistering the herbicide atrazine, and Chinese National Chemical Corporation (ChemChina) continues its attempts to complete a $43 billion merger. While the plan appears to have cleared U.S. regulatory hurdles, European lawmakers have yet to sign off on the deal. “The repackaging, sale and distribution of unregistered and misbranded pesticides is illegal and puts people and the environment at risk. Users rely on accurate, up-to-date information about ingredients, directions for use, hazards and safety precautions,” said Anne Heard, Acting Regional Administrator for the Southeast in an […]

(Beyond Pesticides, September 21, 2016) The U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs released last week  its Glyphosate Issue Paper in which the agency is proposing to classify glyphosate as “not likely to be carcinogenic to humans at doses relevant for human health risk assessment.” Glyphosate, the controversial active ingredient in Roundup, was classified in 2015 by the World Health Organization (WHO) as a “probable carcinogen” and numerous studies have associated the chemical with cancer and other human health issues. However, EPA’s proposed a classification that is contrary, not only to WHO’s, but also a position  it had previously held. The issue paper was released in preparation for the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Scientific Advisory Panel (SAP) meeting, October 18-21, which convenes to review EPA’s evaluation of the carcinogenic potential of glyphosate. Glyphosate, produced by Monsanto, is one of the most popular weedkillers in the U.S., and the active ingredient in Roundup. Glyphosate is often promoted by industry as a “low toxicity” chemical and “safer” than other chemicals, yet has been shown to have  detrimental impacts  on humans and the environment. Given its widespread use on residential and agricultural sites, its toxicity is of increasing […]

(Beyond Pesticides September 12, 2016) On Thursday, September 8, a federal judge in the U.S. District Court for the Northern District of California rejected the U.S. Department of Agriculture’s (USDA) motion to dismiss a federal lawsuit (Case No. 15-cv-01590-HSG) that challenges changes to the rules that review the potential hazards and need for allowed synthetic and prohibited natural substances used in certified  organic food production. Finding that plaintiffs had established both proper jurisdiction and a viable claim, this ruling allows the case to move forward on its merit. The court will now  be able to review the substantive importance of formal notice and public comment regarding  the rules for organic food production, which were changed dramatically by USDA in 2013. Plaintiffs in this case, recognized  by the court as “approximately a dozen advocacy and industry groups representing organic farmers, retailers, and consumers,” filed a complaint last April asking the court to require USDA to reconsider its decision on the rule change and reinstitute the agency’s customary public hearing and comment process. Specifically at issue in the lawsuit is a rule that implements the organic law’s “sunset provision,” which since its origins has been interpreted, under a common reading of the […]

(Beyond Pesticides, August 31, 2016) Last week, a Denver marijuana company went through its first inspection for the Colorado-based Organic Cannabis Association’s (OCA) new “pesticide-free” certification. This voluntary certification program was developed by OCA following an indefinite postponement of the Pesticide-Free Marijuana Bill, HB 16-1079 by the Colorado Senate and the failure of  the Colorado Department of Agriculture (CDA) to implement meaningful regulations to protect  users within the state from pesticides that are not regulated  for use in cannabis production by the U.S. Environmental Protection Agency (EPA) and the states. While the certification program is characterized as “pesticide-free,” it is focused on residues on the finished product, allowing the use of pesticides that do not appear on the narrow list of those restricted by the state of Colorado. The certification is a a step in the right direction for consumers who wish to protect themselves from unwanted pesticides in their cannabis products, however it is important to note that it  does not equate to a USDA organic inspection, as marijuana remains illegal at the federal level and is unable to qualify for certification under the USDA National Organic Program (NOP). While discussing his inspiration for developing such a program, OCA […]

(Beyond Pesticides, August 26, 2016) Virgin Islands Superior Court Judge, Harold Willocks denied a request made by Terminix to stop a subpoena for Terminix documents in the methyl bromide poisoning case  issued  by Attorney General Claude Earl Walker, according to The Virgin Islands Consortium. The paper reported that the subpoena ordered the pest control company to provide documents and information relating to an ongoing investigation by the Department of Justice (DOJ). This follows two settlement agreements made by Terminix; one to pay $10 million to DOJ and the Environmental Protection Agency (EPA) for violating the Federal Insecticide, Fungicide and Rodenticide Act, and another to pay $87 million to the Esmond family, poisoned by the misuse of a neurotoxic pesticide fumigant, methyl bromide, when they vacationed in the Virgin Islands in the spring of 2015. According to the Virgin Islands Consortium, DOJ launched  another investigation into Terminix after the Esmonds were poisoned to determine if there had been a violation of the Criminally Influenced and Corrupt Organizations Act (CICO). Attorney General Walker issued the original subpoena on April 28, requesting that Terminix surrender all information related to the purchase, use and import of methyl bromide obtained within the past three years. […]

(Beyond Pesticides, August 23, 2016) “Fundamentally anti-consumer,” said U.S. Senator Richard Blumenthal (D-CT) of the new genetic engineered (GE) labeling bill signed into law by President Obama late last month. Senator Blumenthal’s frustration with the new legislation and its preemption of state-level laws such as Vermont and Connecticut’s led the Senator to announce he will be introducing a bill next session to repeal the divisive law. After years of state-level ballot initiatives in California, Oregon, Washington State, and Colorado, which were defeated after the chemical industry poured millions of dollars into ad buys that played on consumer fears of higher prices at the check-out line, Maine and Connecticut took a stand for consumer’s right to know. While their legislation required trigger clauses to go into effect, Vermont’s was passed shortly after without such a clause, and withstood a legal challenge from the multinational food and chemical industry. Vermont’s law propelled industry to move its efforts to Congress, and the state’s legislation actually went into effect on July 1, 2016, as industry was still working to garner the necessary votes for its new DARK deal.   Pushed forward by Senators Debbie Stabenow (D-MI) and Pat Roberts (R-KS), the new law has […]

(Beyond Pesticides July 25, 2016) The Oregon Department of Agriculture (ODA) last week issued 12 notices of statewide detainment and stop sale and removal orders for horticultural pesticide products that contain active ingredients not listed on the label. The orders call for the product manufacturers to immediately cease all sales, offers of sale, or other distribution in Oregon. This is the latest effort by a state with a legalized marijuana market to try to  curb the use of illegal pesticides in cannabis production, a practice that poses potential health threats to consumers, creating a regulatory challenge for state officials in states that have legalized marijuana for medicinal and or recreational purposes. Because the U.S. government classifies cannabis as a narcotic, the U.S. Environmental Protection (EPA) does not register pesticide products for use in its production, leaving consumers exposed to hazardous pesticides through inhalation, ingestion, and dermal absorption without any evaluation of potential health effects. The products in question are commonly used in horticulture and hydroponics, including cannabis production. The 12 notices cover 14 products sold in Oregon that were also identified by the Washington State Department of Agriculture (WSDA) in late June as containing undeclared pesticide active ingredients. In an […]

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

(Beyond Pesticides, March 12, 2015) Marijuana may be legal in your state for medicinal and recreational use, but are toxic pesticides used in its production? A study released today of the 23 states and the District of Columbia that have legalized marijuana finds a patchwork of state laws and evolving policy that define allowed pesticide use and management practices in cannabis production. This variety of state law is occurring in the absence of federal registration of pesticide use for cannabis production because of its classification as a narcotic under federal law. The investigation, Pesticide Use in Marijuana Production: Safety Issues and Sustainable Options, evaluates the state laws governing pesticide use in cannabis production where it is legalized. “The use of pesticides in the cultivation of cannabis has health implications for those growing the crop, and for users who are exposed to toxic residues through inhalation, ingestion, and absorption through the skin,” said Jay Feldman, executive director of Beyond Pesticides. “The good news is that five states and DC have adopted rules that require marijuana to be grown with practices that prevent the use of pesticides. State officials have an opportunity to restrict all pesticide use at the front end of […]

(Beyond Pesticides, March 10, 2015) U.S. Senator Charles E. Schumer (D-NY) yesterday called on the U.S. Environmental Protection Agency (EPA) yesterday to immediately investigate the specific use of pentachlorophenol  (penta or PCP), a toxic wood preservative, to treat  utility poles throughout Long Island and urged  Public Service Electric and Gas (PSEG) Long Island to immediately suspend further use of this chemical until a  federal review  is complete. PSEG has been installing new, chemically-treated utility poles throughout the Towns of North Hempstead and East Hampton. In his press  release, Senator Schumer expresses  serious concern about penta’s  health risks to utility workers, adults and children and its ability to  move  into water over the long-term as the chemical leaches from the poles. The Senator also notes that a private firm has conducted a study based on a very limited sample size that does not consider long-term risks as the pole decomposes and further leaches toward groundwater. EPA, which is responsible for evaluating penta’s health and environmental risk, has noted public health concerns related to the chemical when ingested or inhaled, including  neurological, respiratory, kidney and immune system effects. On Long Island, 95,000 of PSEG’s 324,000 utility poles have been treated with penta. […]

(Beyond Pesticides, February 25, 2015) The biotechnology industry behind genetically engineered (GE) foods have for years touted that their technology is safe, dismissing any attempts to challenge their science or regulate their material. However, 300 scientists, physicians and scholars assert there is no scientific consensus on the safety of GE foods and find that claims of safety are an “artificial construct that has been falsely perpetuated” through various forums and media. The statement, published in the journal Environmental Sciences Europe and entitled, “No scientific consensus on GMO safety,” cites a concerted effort by GE seed developers and some scientists, commentators and journalists to construct the claim that there is a “scientific consensus” on GE safety, and that debate on the topic is “over.” According to the 13-page statement, 300 independent scientists and researchers felt compelled to develop a document that offered a balanced account of the current state of dissent in this field, based on published evidence in the scientific literature, for both the interested public and the wider science community. They find that a claim of safety “”¦is misleading and misrepresents or outright ignores the currently available scientific evidence and the broad diversity of scientific opinions among scientists on […]