(Beyond Pesticides, June 21, 2010) Pesticide experiments using people as test subjects will have stricter federal rules to follow under a new agreement reached on June 17, 2010 between the U.S. Environmental Protection Agency (EPA) and public health groups, farm worker advocates and environmental organizations. “People should never have been used as lab rats for testing pesticides,” said Natural Resources Defense Council (NRDC) senior attorney Michael Wall. “Under today’s settlement, EPA will propose far stronger safeguards to prevent unethical and unscientific pesticide research on humans.” In 2006, a coalition of health and environmental advocates and farmworker protection groups led by NRDC filed a lawsuit against EPA, claiming EPA’s recent rule violated a law Congress passed in 2005 requiring strict ethical and scientific protections for pesticide testing on humans. EPA’s 2006 rule lifted a ban on human testing put in place by Congress. It also allows experiments in which people are intentionally dosed with pesticides to assess the chemicals’ toxicity and allows EPA to use such experiment to set allowable exposure standards. In such experiments, people have been paid to eat or drink pesticides, to enter pesticide vapor “chambers,” and to have pesticides sprayed into their eyes or rubbed onto their […]

(Beyond Pesticides, June 2, 2010) After decades-long litigation over the use of the toxic pesticide dibromochloropropane, or DBCP, in the 1970’s which has been linked to sterility and has since been banned, Dole Food Co. is proposing new settlements for farm workers claiming they were injured by exposure to the pesticide. A request has been filed by lawyers for Dole in the Los Angeles Superior Court asking that nearly 1,500 Honduran farm workers who are suing Dole be allowed to drop out of those suits and settle their claims out of court under an existing program arranged by the company and Honduran government officials. This could potentially end years of legal action inexpensively for Dole while providing compensation to workers quickly, however some people view this plan as a way for the company to back out of its responsibilities to former plantation workers. The pesticide DBCP was used by workers from Nicaragua, Costa Rica, Guatemala, Honduras, and Panama to kill worm infestations in the trees’ roots. In the U.S., DBCP was used as a soil fumigant and nematocide on over 40 different crops until 1977. According to the U.S. Environmental Protection Agency (EPA), DBCP causes male reproductive problems, including low […]

(Beyond Pesticides, April 30, 2010) The U.S. Supreme Court heard oral arguments on Tuesday in a case that prohibited Monsanto from selling genetically engineered (GE) alfalfa seed. A decision on the case of Monsanto Co. v. Geertson Seed Farms, the first time the Supreme Court has heard a case involving a genetically engineered crop, is expected in late June. The Center for Food Safety filed suit in 2006 on behalf of a coalition of organic farmers and environmental groups including Beyond Pesticides, arguing that the USDA violated the National Environmental Protection Act (NEPA) when it approved deregulation of GE alfalfa without an environmental impact statement (EIS). Roundup Ready Alfalfa is genetically engineered to resist the herbicide Glyphosate, sold by Monsanto under the trade name Roundup. Alfalfa is a bee pollinated crop used primarily for forage. The potential for cross pollination between GE and non-GE varieties of alfalfa is much higher than in other crops such as corn, because of the way Alfalfa is pollinated. In 2007, U.S. District Judge Charles Breyer ordered a moratorium on GE alfalfa until the USDA completed an EIS. The USDA released a draft EIS in December of 2009 again calling for deregulation of the crop. […]

(Beyond Pesticides, March 2, 2010) A lawsuit filed March 1, 2010 in federal court against the U.S. Fish and Wildlife Service seeks to compel the Service to uproot genetically engineered (GE) crops from its Bombay Hook National Wildlife Refuge in Delaware. As many as 80 other national wildlife refuges across the country now growing GE crops are vulnerable to similar suits. Filed in the U.S. District Court for Delaware by the Widener Environmental and Natural Resources Law Clinic on behalf of Delaware Audubon Society, Public Employees for Environmental Responsibility (PEER) and the Center for Food Safety, the federal suit charges that the Fish & Wildlife Service had illegally entered into Cooperative Farming Agreements with private parties, allowing hundreds of acres to be plowed over without the environmental review required by the National Environmental Policy Act (NEPA). In March 2009, the same groups won a similar lawsuit against GE plantings on Prime Hook National Wildlife Refuge. Ironically, Prime Hook has now been administratively incorporated into Bombay Hook, meaning that the same refuge management that is overseeing execution of the Prime Hook verdict is violating its tenets on Bombay Hook. In August 2009, several environmental groups led by the Center for Food […]

(Beyond Pesticides, February 26, 2010) The U.S. Supreme Court refused Monday to review a U.S.Circuit Court decision in National Cotton Council (NCC) v. Environmental Protection Agency (EPA), upholding EPA’s authority to subject pesticide use to a permitting process under the Clean Water Act (CWA). In January of 2009, the 6th Circuit Court of Appeals upheld the ruling that commercial application of certain pesticides must be regulated under the Clean Water Act. EPA is now working to create a permitting system that complies with the ruling under the National Pollutant Discharge Elimination System (NPDES). This is one of three high profile cases the Supreme Court refused to hear involving industry challenges to government regulations. In the case of the Texas Water Development Board v. the Department of Interior, local government intended to build a reservoir in an area designated by the U.S. Fish and Wildlife Service (FWS) as a wildlife refuge. The U.S. 5th Circuit Court of Appeals found that the FWS did not violate the National Environmental Policy Act when it created the refuge, and so a reservoir cannot be constructed in that area. In the case of Rose Acre Farms Inc. v. the United States, an egg producer sued […]

(Beyond Pesticides, February 8, 2010) The Center for Biological Diversity filed a notice of intent to sue the Environmental Protection Agency (EPA) last week. The lawsuit argues that EPA violated the Endangered Species Act when it approved 394 pesticides known to be harmful to humans and wildlife, without consulting with wildlife regulatory agencies as to the pesticides’ effects on endangered species. By registering pesticides known to harm migratory birds the EPA has also violated the Migratory Bird Treaty Act, according to the suit. The pesticides named in the suit pose a danger not only to wildlife, but to human health as well. Some of the pesticides named include 2,4-D the most commonly used pesticide in the nonagricultural sector, atrazine, triclosan, and pyrethrins. Jeff Miller, conservation advocate at the Center for Biological Diversity, said, “It’s time for the Environmental Protection Agency to finally reform pesticide use to protect both wildlife and people…Many endangered species most affected by toxic pesticides are already struggling to cope with habitat loss and rapid climate changes. For too long this agency’s oversight has been abysmal, allowing the pesticide industry to unleash a virtual plague of toxic chemicals into our environment.” The suit names 887 threatened and […]

(Beyond Pesticides, January 25, 2010) For the first time, a case involving a genetically engineered crop will be heard by the U.S. Supreme Court. The case, Monsanto v. Geerston Seed Farms, is the most recent development in an ongoing battle to stop the use of genetically modified alfalfa seed. The seed is modified to be resistant to the herbicide glyphosate, sold by Monsanto under the brand name Roundup. In 2006 the Center for Food Safety (CFS) and several other farming and environmental groups, including Beyond Pesticides, filed suit on behalf of Geerston Seed Farms. The suit led to a U.S. District Court ruling that the U.S. Department of Agriculture (USDA) violated the National Environmental Protection Act (NEPA) by approving the sale of GE alfalfa without requiring an environmental impact statement (EIS). Monstanto was forced to stop selling the seed until a comprehensive EIS is prepared. This was the first ever moratorium in the U.S. on a genetically engineered, or modified, crop. The USDA completed its first draft of the EIS in December 2009. Brushing aside the concerns of organic alfalfa growers, consumers, and environmentalists, USDA argues for non-regulated status of GE alfalfa. According to this document, the economic gains of […]

(Beyond Pesticides, January 20, 2010) The Organic Consumers Association (OCA), along with certified organic personal care brands Dr. Bronner’s Magic Soaps, Intelligent Nutrients, and Organic Essence, last week filed a complaint with the U.S. Department of Agriculture (USDA) National Organic Program (NOP), seeking action to stop some personal care manufacturers from, according to the petitioners, mislabeling their products as “organic.” The petitioners are requesting an investigation into what it believes is widespread and blatantly deceptive labeling practices of leading “organic” personal care brands, in violation of USDA NOP regulations. The complaint, filed collectively on behalf of 50 million consumers of organic products, argues that products such as liquid soaps, body washes, facial cleansers, shampoos, conditioners, moisturizing lotions, lip balms, make-up and other cosmetic products produced by 12 different corporations have been advertised, labeled and marketed as “organic” or “organics” when, in fact, the petitioners say the products are not “organic” as understood by reasonable consumers. “Unfortunately, the hands-off regulatory approach by the USDA’s National Organic Program during the Bush years failed to protect consumers from deceptive labeling in the personal care marketplace,” said Ronnie Cummins, executive director of the Organic Consumers Association. While the USDA enforces strict standards for the […]

(Beyond Pesticides, January 15, 2010) Yesterday, environmental and health groups petitioned the Environmental Protection Agency (EPA) to ban the use of the widely used antimicrobial pesticide triclosan, which is linked to endocrine disruption, cancer and antibiotic resistance and found in 75% of people tested in government biomonitoring studies. Over 75 groups, lead by Beyond Pesticides and Food and Water Watch, say EPA must act to stop the use of a chemical now commonly found in soaps, toothpaste, deordorants, cosmetics, clothing, and plastic, with a nearly $1 billion market and growing. In their petition, the groups cite numerous statutes under which they believe the government must act to stop non-medical uses of triclosan, including laws regulating pesticide registration, use and residues, clean and safe drinking water, and endangered species. “Given its widespread environmental contamination and public health risk, EPA has a responsibility to ban household triclosan use in a marketplace where safer alternatives are available to manage bacteria,” said Jay Feldman, executive director of Beyond Pesticides. “Scientific studies indicate that widespread use of triclosan causes a number of serious health and environmental problems,” said Wenonah Hauter, executive director of Food & Water Watch. “EPA needs to ban its use in non-medical […]

(Beyond Pesticides, September 28, 2009) In a case brought by Center for Food Safety (CFS) and Earthjustice representing a coalition of farmers and consumers, a federal court ruled September 23, 2009 that the Bush Administration’s approval of genetically engineered (GE) “RoundUp Ready” sugar beets was unlawful. In this case, Center for Food Safety v. Vilsack, No. C 08-00484 JSW (N.D. Cal. 2009), the court ordered the U.S. epartment of Agriculture (USDA) to conduct a rigorous assessment of the environmental and economic impacts of the crop on farmers and the environment. The decision follows on the heels of a June 2009 decision from the Ninth Circuit Court of Appeals affirming the illegality of the USDA’s approval of Monsanto’s genetically engineered alfalfa. The federal district court for the Northern District of California ruled that the USDA’s Animal and Plant Health Inspection Service (APHIS) violated the National Environmental Policy Act (NEPA) when it failed to prepare an Environmental Impact Statement (EIS) before deregulating sugar beets that have been genetically engineered (GE) to be resistant to glyphosate herbicide, marketed by Monsanto as Roundup. Plaintiffs CFS, Organic Seed Alliance, Sierra Club, and High Mowing Seeds, represented by Earthjustice and CFS, filed suit against APHIS in […]

(Beyond Pesticides, September 24, 2009) The U.S. Environmental Protection Agency (EPA) has just announced that it filed suit against San Leandro based VF Corporation for the sale and distribution of unregistered pesticides through its retail company, The North Face. An AgION silver treated footbed, which the company claims has antimicrobial properties, is featured in over 70 styles of shoes by the company. These claims, according to the EPA, are in violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The company could face up to $1 million in fines. While these products do not purport to usie nano-sized silver materials, the claims that are made for these products are suspiciously similar to those made by manufacturers for other nano-based antimicrobial products. These claims include: inhibiting the growth of disease-causing bacteria; preventing bacterial and fungal growth; and the continuous release of antimicrobial agents. Because of the lack of regulation, nanotechnology products are not always easy to recognize in the marketplace, and even the best lists do not include everything. Consumer products that include nano-based technologies, however continue to grow. EPA has taken a few regulatory actions against other manufacturers whose products made similar claims as this case, including action against […]

(Beyond Pesticides, September 21, 2009) In a federal lawsuit filed in San Francisco earlier this month, the environmental watchdog group Ecological Rights Foundation (ERF) claims that dioxin is being discharged from Pacific Gas and Electric Company’s (PG&E) utility poles into the San Francisco Bay, violating both the Clean Water Act and the Resource Conservation and Recovery Act. Dioxin is a contaminant in the wood preservative pesticide pentachlorophenol (penta), the chemical used to treat more than one million PG&E utility poles in Northern California. Dioxin is a known human carcinogen. It also causes birth defects at extremely low levels. The ERF suit asks the court to stop PG&E from discharging dioxin from its utility poles, a move that could eventually lead to wide scale replacement of the ubiquitous penta-treated wood poles. “These are the common, I guess you could say ‘classic,’ brown wood poles you see holding up wires on practically every street,” says ERF attorney Bill Verick. Pentachlorophenol (penta) is a chlorinated aromatic hydrocarbon, closely related to other chlorophenols, hexachlorobenzene, polychlorinated dibenzo-p-dioxins and furans, all of which are found in commercial grade penta, along with secret “inert” ingredients. It was 1978 when EPA began its review of wood preservatives, including […]

(Beyond Pesticides, August 13, 2009) The Alaska Department of Environmental Conservation is currently reviewing a request by the Alaska Railroad for permission to use the herbicide glyphosate along a 90 mile stretch of its track between Seward and Indian. The herbicide is set to be applied on Railroad operating property (rail yards, spurs, sidings, etc) and along the mainline and branch line right-of way for four feet out from both sides of the track in the summer of 2010. Despite the fact that previous requests have been met with opposition, the railroad states that its vegetation problem has gotten too out of hand for “so-called ”˜alternative methods.’” They also state that the Federal Railroad Administration, the railroad’s federal regulatory agency, will impose fines and operational restrictions such as reducing speeds or emergency closures of some sections of track if they aren’t cleared of the overgrown vegetation. Current methods of weed management utilized by the railroad are mechanized rail-based brushcutters, off-rail hydroaxing, wayside manual cutting. The extents to which these methods are used are unknown, however, and the railroad states that these are effective””but only within limited ranges. Beyond Pesticides has an entire factsheet on least toxic control of weeds which […]

(Beyond Pesticides, July 10, 2009) The Center for Biological Diversity notified the U.S. Environmental Protection Agency (EPA) earlier this week of its intent to file suit against the agency for failing to consider impacts to the polar bear and its Arctic habitat from toxic contamination resulting from pesticide use in the U.S. Pesticides registered by EPA for use in the U.S. are known to be transported to the Arctic via various atmospheric, oceanic, and biotic pathways. Such pesticides are biomagnified with each step higher in the food web, reaching some of their greatest concentrations in polar bears, the apex predators of the Arctic. A body of literature demonstrates the far-reaching effects of commonly used pesticides that are suspected endocrine disruptors and persistent organic pollutants, such as atrazine, 2,4-D, lindane, endosulfan, and permethrin, on global ecosystems. These pesticides, among others, and related contaminants have been linked to suppressed immune function, endocrine disruption, abnormalities in reproductive organs, hermaphroditism, and increased cub mortality in polar bears. Human subsistence hunters in the Arctic, who share the top spot on the food web with the polar bear, also face increased risks from exposure to these contaminants. “The poisoning of the Arctic is a silent crisis […]

(Beyond Pesticides, July 6, 2009) Last week, the U.S. Environmental Protection Agency (EPA) proposed to formally evaluate the harmful effects of 74 pesticides on 11 endangered and threatened species in the San Francisco Bay Area over the next five years, and to impose interim restrictions on use of these pesticides in and adjacent to endangered species habitats. The proposal stems from a settlement agreement with the Center for Biological Diversity, which sued EPA in 2007 for violating the Endangered Species Act by registering and allowing the use of toxic pesticides in Bay Area endangered species habitats without determining whether the chemicals jeopardize those species’ existence. “Tens of millions of pounds of toxic and poisonous chemicals, known to be deadly to endangered species and harmful to human health, including proven carcinogens and endocrine disruptors, are applied in the Bay Area each year, and many of those find their way through runoff or drift into our soil, creeks and rivers, San Francisco Bay, and sensitive wildlife habitats,” said Jeff Miller, conservation advocate with the Center. “The toxic stew of pesticides in the Bay-Delta has played a major role in the collapse of native fish populations, and pesticides are a leading cause of […]

(Beyond Pesticides, June 29, 2009) Last week the United States Court of Appeals for the Ninth Circuit re-affirmed its previous decision upholding a nationwide ban on the planting of genetically-engineered (GE) Roundup Ready alfalfa pending a full Environmental Impact Statement (EIS). The Court determined that the planting of genetically modified alfalfa can result in potentially irreversible harm to organic and conventional varieties of crops, damage to the environment, and economic harm to farmers. Although the suit was brought against the United States Department of Agriculture (USDA), Monsanto Company and Forage Genetics entered into the suit as Defendant-Intervenors. In September 2008 the Ninth Circuit affirmed the lower court’s ruling, but the Intervenors continued to press the appeal alone, requesting the appellate court to rehear the case. Last weeks decision denied that request and re-affirmed the earlier decision in full. “This ruling affirms a major victory for consumers, ranchers, organic farmers, and most conventional farmers across the country,” said Andrew Kimbrell, Executive Director of the Center for Food Safety. “Roundup Ready Alfalfa represents a very real threat to farmers’ livelihoods and the environment; the court rightly dismissed Monsanto’s claims that their bottom line should come before the rights of the public and […]

(Beyond Pesticides, April 13, 2009) Rebuffing the Department of Agriculture, the Justice Department announced that it will not seek rehearing of a recent significant environmental decision that enables improved protection from pesticides under the Clean Water Act. In a letter dated March 6, 2009, Agriculture Secretary Vilsack had asked EPA Administrator Jackson to request reversal of the 6th Circuit’s decision (The National Cotton Council et al. v. EPA) in January that invalidated a Bush EPA rule exempting pesticide spraying around waterways from the Clean Water Act regulations. “This decision means that EPA recognizes its responsibility to move forward with implementing the Clean Water Act, instead of trying to circumvent this bedrock public protection statute as was attempted by the Bush EPA,” stated Charlie Tebbutt of the Western Environmental Law Center, who argued the case for the environmental plaintiffs. “We now look forward to working with EPA and the states to bring about meaningful changes in site specific uses of pesticides to protect our nation’s waters,” continued Mr. Tebbutt. In this same announcement, EPA stated that it will seek to continue the Bush rule for two years, despite the court ruling it illegal. “This part of the EPA’s decision is troubling,” […]

(Beyond Pesticides, March 27, 2009) A federal court has ordered the U.S. Fish & Wildlife Service to stop planting genetically engineered (GE) crops on its Prime Hook National Wildlife Refuge in Delaware. While the ruling is limited to Prime Hook, the lawsuit may serve as a model for similar litigation at more than 80 other national wildlife refuges now growing GE crops across the country. Filed in April 2006 by the Widener Environmental and Natural Resources Law Clinic on behalf of Delaware Audubon Society, Public Employees for Environmental Responsibility (PEER) and the Center for Food Safety, the federal suit charges that the Fish and Wildlife Service (FWS) illegally entered into Cooperative Farming Agreements with private parties, allowing hundreds of acres to be plowed over without required environmental review and contrary to FWS’ own policy prohibiting GE crops. “It is unfortunate that we had to file suit against the Service to get it to comply with its own policies,” commented Nicholas DiPasquale, Conservation Chair for Delaware Audubon. “It is clear that this Refuge Manager had abdicated control over farming operations at Prime Hook just as it is also clear that farming practices have been extremely destructive to the forested uplands at […]

(Beyond Pesticides, February 25, 2009) After three years of legal battle, the North Carolina Pesticide Board on February 19, 2009 fined Florida-based Ag-Mart Produce Inc. a substantially lower fine of $3,000 than the originally proposed $185,000, after deciding that it can only prove six of about 200 worker safety accusations that had been levied against the company. This comes less than a month after the unprecedented ruling against Ag-Mart in New Jersey, where the company was ordered to pay penalties of more than $931,000 for misusing pesticides and jeopardizing the health and safety of workers in its New Jersey farm fields and packing houses. The Florida-based company, described as one of the biggest pesticide offenders, has been accused of routinely exposing hundreds of workers to toxic chemicals. Investigators in North Carolina, Florida and New Jersey, the three states where the international company grows its tomatoes, scrutinized the company’s records and charged it with ignoring laws intended to keep workers safe from toxic pesticide residue. The investigators alleged workers were sent into the fields too soon after dangerous chemicals had been sprayed. The case started three years ago when some workers gave birth to babies with severe birth defects. One mother […]

(Beyond Pesticides, December 22, 2008) The U.S. EPA has filed an administrative complaint, seeking a maximum penalty of only $4,550, against a pest control company that sprayed pesticides in a couple’s home, causing the wife to die shortly thereafter. It has been more than three years since the incident took place in Florence, Oregon. Swanson’s Pest Management of Eugene, Oregon sent an employee to a home on June 29, 2005 to apply Conquer Residential Insecticide Concentrate, active ingredient esfenvalerate, and ULD BP-100 Contact Insecticide, active ingredient pyrethrin. The couple returned to their home two and a half hours later and immediately fell to the ground due to the fumes. Paramedics were called in and they too experienced respiratory distress or became ill when they entered the treated home. According to The Oregonian, Florence Kolbeck was 76 years old and died of cardiac arrest as a result of the exposure. Her husband, Fred, was hospitalized for respiratory distress. The complaint was filed following a review of Swanson’s use of the two pesticides, finding that the company failed to properly ventilate the home prior to the occupants re-entering, and improperly applied Conquer as a “space spray” at nearly three times the allowable […]

(Beyond Pesticides, November 26, 2008) On November 10, two Alaskan environmental groups sued the United States Fish and Wildlife Service (FWS) for failing to conduct a proper assessment of the environmental consequences of using herbicides to kill non-native species in Kodiak National Wildlife Refuge and the Alaska Maritime National Wildlife Refuge. The groups, Alaska Survival and Alaska Community Action on Toxics, allege that FWS sprayed hundreds of gallons of herbicide in the Kodiak National Wildlife Refuge and the Alaska Maritime National Wildlife Refuge over the past several years. In the complaint to the U.S. District Court of Alaska, the groups say FWS violated the National Environmental Policy Act (NEPA) by failing to conduct adequate investigations on the environmental impacts of pesticide use and by failing to inform the public of the practice. The lawsuit states, “(Fish and Wildlife) failed to consider the potential harm to aquatic organisms, fish, birds, insects and other non-target species, as well as the potential for adverse effects to humans visiting the area,” and that the “defendants failed to consider the effect of herbicide use on the commercial salmon fishing industry and on subsistence users.” Under NEPA, all federal agencies are required to conduct an Environmental […]

(Beyond Pesticides, November 19, 2008) In what is described as a great victory for environmental campaigner Georgina Downs, a British high court ruled last week that there was “solid evidence” that rural residents had suffered harm from crop spraying with toxic chemicals. The landmark ruling ordered the Government to reconsider how to protect the health of countryside communities. This victory comes after a long-running legal battle over the use of pesticides in rural communities. Ms. Downs, who lives on the edge of farmland, launched her campaign in 2001 and documented that she was first exposed to pesticide spraying in the early 1980s at the age of 11 and has since suffered from ill health, flu-like symptoms, sore throat, blistering and other problems. She created a DVD portraying collected evidence from other rural residents reporting health problems including cancer, Parkinson’s disease and asthma believed to be linked to crop spraying. Ms. Downs said the government had failed to address the concerns of people living in the countryside. She added that these people “are repeatedly exposed to mixtures of pesticides and other chemicals throughout every year, and in many cases, like mine, for decades.” She also noted that people were not given […]

(Beyond Pesticides, October 1, 2008) Last week, a jury awarded $1 million in compensation to an organic farm in Santa Cruz, California, whose herbs were contaminated by pesticides. The jury found that organophosphate pesticides, used on vegetables on neighboring farms, drifted onto the organic farm, leaving the herbs in violation of organic standards. The organic farm, Jacobs Farm Del Cabo, filed a lawsuit against the pesticide application company Western Farm Service, Inc. in May 2007. The suit sought an order to stop Western Farm Service from spraying pesticides that contaminate crops at Wilder Ranch State Park, where Jacobs Farm leases 120 acres. Compensation for losses, in the sum of $1 million, which resulted from pesticide contamination, was also sought. The court ruled that pesticide applications by Western Farm Service resulted in trespass of the pesticides onto Jacobs Farm and were legally determined to be a nuisance depriving Jacobs Farm of the right to use and enjoy the land, caused by negligence on the part of Western Farm Services. The jury found that Jacobs Farm was damaged in the sum of $1 million and Judge Robert Atack ordered judgment in that amount against Western Farm Service. The organophosphates, chlorpyrifos, diazinon, and […]