(Beyond Pesticides, October 11, 2016) Last week, in a calculated attack on the International Agency for Research on Cancer’s (IARC), the U.S. House of Representatives’ Committee on Oversight and Government Reform summoned the National Institutes of Health (NIH) to answer questions about taxpayer contributions to the World Health Organization’s (WHO) cancer agency. From reports, it is easy to gather that the committee has problems with IARC scientists’ findings that glyphosate, among other things, is a probable  carcinogen. Led by Chairman Jason Chaffetz (R-UT), the hearing is  clearly aimed at  undermining IARC’s March 2015 listing of glyphosate as a probable carcinogen based on sufficient evidence of carcinogenicity  found in laboratory studies. Set to take place in private, limiting any opportunity for public oversight, the hearing will consist of NIH officials answering questions on the scientific processes and public funding from politically-charged committee investigators. If Rep. Chaffetz is persuasive in this rouse against science, he stands to put in jeopardy  a significant amount funding for IARC provided by NIH, a devastating outcome for individuals who value the importance of IARC’s work in the scientific community. Glyphosate, which is produced and sold as RoundupTM  by Monsanto, has been touted by industry and EPA […]

(Beyond Pesticides, October 3, 2016) On Friday, the California Department of Pesticide Regulation (CDPR) released a rule titled, Pesticide Use Near Schoolsites, that proposes limited restrictions for certain agricultural pesticide applications near schools and child day care facilities. CDPR, whose proposal  has been criticized by advocates as not adequately protective of workers and communities, is accepting public comments on the proposal until November 17, 2016. The  proposed rule, effective October 1, 2017, will require farmers to notify public schools and child day care facilities when “certain pesticide applications made for the production of an agricultural commodity near a school site are planned in the coming year and also a few days prior to the applications.” For pesticides applied via aircraft, airblast sprayer, sprinkler chemigation, and fumigation, there must be a minimum ¼  mile buffer around the school or child day care facility. While the move by CDPR is a step in the right direction, it is not rigorous enough and does not adequately protect the most vulnerable populations from pesticide exposure, according to advocates. The rule does not include private K-12 schools or family day care homes, a move that according to CDPR documents is due to the potential for […]

(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 26, 2016) Last week, the Center for Environmental Health (CEH) filed a lawsuit against Dow Agrosciences LLC, also known as Dow Chemical, charging  that the “chemical manufacturing giant” fails to warn communities across California about the dangers associated with wide use of the chemical Telone. A trade name for the chemical 1,3-Dicholoropropene, or 1,3-D, Telone is a known carcinogen and is the third most heavily used pesticide in the state. The case focuses on the air pollution caused by the pesticide, as it has been found to linger in the air for multiple days after application, disproportionately impacting the rural communities, often with large minority populations, that live in the immediate vicinity. The case was filed in the State of California Alameda County Superior Court, and Dow has yet to comment or release a statement addressing the allegations against the company. Routinely applied to strawberry fields, almond orchards, vineyards, and an array of other crops, 1,3-D is a restricted use soil  fumigant, used to kill nematodes, insects, and weeds that has strong links  to cancer and other serious health issues. The use of the chemical in the production of strawberries came into prominence with the forced reduction […]

(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 16, 2016) Tell EPA to ban all uses of atrazine in the United States! Atrazine, widely used on food and feed crops, golf courses, and residential lawns, is a potent endocrine disruptor that is  strongly associated with birth defects, cancer, sex reversal and hermaphroditism in many different animals. The European Union and other countries have banned atrazine, however EPA continues to put U.S. citizens and the environment in harm’s way, allowing nonstop use of this toxic chemical. Sign Beyond Pesticides’ petition to ban atrazine by October 5, 2016. Atrazine is the second-most widely used pesticide in the U.S., with over 73 million pounds applied each year. Atrazine has washed into surface water and leached into groundwater, spurring community water utilities  across the U.S. to file class-action lawsuits to remove the pesticide from drinking water supplies. Even at levels established as “safe” or acceptable by EPA drinking water standards, atrazine is linked to endocrine-disrupting effects. EPA is not adequately assessing the effects of atrazine by using high dose testing models, which are not appropriate for hormonally-active substances  that  often show effects at minute doses. Studies by Tyrone Hayes, Ph.D., University of California, Berkeley,  and others have shown that […]

(Beyond Pesticides,  September 6, 2016) “The Food and Drug Administration (FDA) decision today to remove the antibacterial triclosan, found in liquid soaps (toothpaste use will remain), is a long time coming,” Jay Feldman, Executive Director of Beyond Pesticides, said today. He continued: “The agency’s failure to regulate triclosan for near two decades, as the law requires, put millions of people and the environment at unnecessary risk to toxic effects and elevated risk to other bacterial diseases. Now, FDA should remove it from toothpaste and EPA should immediately ban it from common household products from plastics to textiles.” Many companies had decided under consumer pressure to remove triclosan from its liquid soap products years ahead of the FDA decision today. FDA’s announcement today indicates that soaps containing the antibacterial ingredient triclosan do not have substantiated germ-killing health benefits. Beyond Pesticides raised concerns about the health effects of triclosan in 2004 in its piece The Ubiquitous Triclosan, and petitioned the agency to ban the chemical in 2005. In 2015, triclosan was banned in the European Union. For nearly two decades, scientific studies have disputed the need for the chemical and linked its widespread use to health and environmental effects and the development […]

(Beyond Pesticides, September 2, 2016) Last Sunday, beekeepers in Dorchester County, South Carolina emerged from their homes to find their yards and  farms, once full of busy buzzing, littered with the honey bees. The cause was no mystery — a massive bee-kill had occurred due to aerial spraying of Naled, a highly toxic  insecticide used primarily to control adult mosquitoes. The county announced plans to spray two days before the incident, when four travel-related cases of Zika virus were confirmed in the area by the state Department of Health and Environmental Control. The spraying occurred between 6:30 and 8:30am. Naled is an organophosphate insecticide with the highest acute toxicity of any mosquitocide. According to the Environmental Protection Agency (EPA), Naled can cause cholinesterase (an enzyme necessary to the transmission of nerve impulses) inhibition in humans, meaning that it can overstimulate the nervous system causing nausea, dizziness, confusion, and, at very high exposures (e.g., accidents or major spills), respiratory paralysis and death. Naled is highly toxic to honey bees. In Dorchester County, beekeepers say that the spray announcements did not come soon enough. Flowertown Bee Farm and Supply lost more than 2.3 million insects from 46 hives, according to co-owner Juanita […]

(Beyond Pesticides, August 30, 2016) Last week, Minnesota Governor Mark Dayton issued an executive order aimed at reversing pollinator decline in the state by limiting the use of toxic, systemic neonicotinoid (neonics) pesticides. The order tasks state agencies with a range of pollinator protective activities, and follows the completion of a Special Registration Review of Neonicotinoid Pesticides conducted by the Minnesota Department of Agriculture. Given that a change in administration could lead to a rescinding of an executive order, it is critical that advocates continue to pressure for concrete legislative changes that institutionalize bee protective practices. “Bees and other pollinators play a critical role in supporting both our environment, and our economy,” said Governor Dayton. “This order directs state government to take immediate action to alleviate the known  risks that pollinators face. It also will create a new task force to study the issues impacting pollinators and recommend long-term solutions.” The executive order directs the Department of Agriculture to immediately initiate steps requiring neonics only be applied when there is “an imminent threat of significant crop loss.” This move applies  to sprays, drenches, or granular applications of neonics, however, and not seed coatings, which will require separate legislative action to […]

(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 14, 2016) According to recent reports, the illegal misuse of pesticides in Dubai has left ten people dead within the last year. The culprit? Domestic use of a pesticide containing highly toxic aluminum phosphide sold on the black market, touted as a way to fight bed bugs for low-income families that may not have the education level or means to research and pursue other options. While the government acknowledges a significant problem given the common occurrence of these  deaths, those in positions of power are admittedly at a loss when it comes to finding a solution, with some calling for a crack down on those selling the pesticides illegally, and others wanting to punish those that buy and use it. Regardless of the actions, elected officials decide to pursue, embracing organic pest management systems, as well as a robust education campaign, will be critical in curbing these deaths. Given the availability of greener, safer alternatives, Beyond Pesticides opposes any registration or allowance of phosphide fumigants and other highly toxic chemicals that can be easily misused. Phosphide fumigants, including aluminum phosphide, are known to be acutely toxic when ingested or inhaled. Symptoms of mild to moderate acute exposure […]

(Beyond Pesticides, August 8, 2016) Last week, the Environmental Protection Agency (EPA) received a  letter  from Earthjustice requesting that the agency notify the Hawaii State Department of Agriculture (HDOA) of its chronic failure to meet statutory duties for pesticides regulation and enforcement under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and, if timely corrections are not made, to rescind HDOA’s primary enforcement authority completely. Earthjustice has asked EPA to immediately notify HDOA that it has failed to carry out its responsibilities, and, pursuant to FIFRA, to give the agency 90 days to correct its overwhelming shortcomings. If the problems, which include failure to enforce pesticide use violations and a large backlog of pesticide complaints and investigations dating back to as early as 2008, are not corrected and addressed within 90 days, Earthjustice requests that EPA revoke HDOA’s primary enforcement authority indefinitely.  In the event that HDOA’s authority to regulate is stripped, EPA would then take over the responsibility for enforcing pesticide use violations occurring within the state. Under FIFRA,  the federal statutory authority for  pesticide approval and use, EPA may  delegate to  a state primary responsibility for enforcing pesticide use violations if thestate has adequate pesticide laws and adequate […]

(Beyond Pesticides, August 3, 2016) Home pest control giant Terminix reached a tentative settlement agreement this week of $87 million with  the  Esmond family for the severe poisoning of the mother, father and two teenage children with the highly neurotoxic pesticide fumigant  methyl bromide.  The company treated  a neighboring unit  to  their vacation residence  last spring  at a  condo resort complex in St. John, U.S. Virgin Islands. This amount is in addition to $3 million already paid to the family to cover the insurance deductible, and an undisclosed amount that the company’s insurance carriers have agreed to pay pursuant to their general liability insurance policies, according to an earnings report filed by the Terminix’s parent company, ServiceMaster Global Holdings, Inc. of Memphis, Tennessee. Stephen Esmond became paralyzed after the March 2015 incident, while his two sons spent weeks in critical condition. The mother,  Theresa Devine is still recovering. Beyond Pesticides’ executive director, Jay Feldman, spoke to CBS Evening News August 2 on the poisoning. Watch news piece  here.   Methyl bromide is a restricted use pesticide and is not registered for residential use, according to the U.S. Environmental Protection Agency’s (EPA) 2013 Methyl Bromide Preliminary Workplan. It was taken off […]

(Beyond Pesticides, July 29, 2016)  A study released earlier this week finds lower IQ (intelligence quotient) in children born to mothers who during their pregnancy were living in close proximity to chemical-intensive agricultural lands where organophosphate pesticides were used. This study adds to the body of scientific literature that links prenatal exposure to organophosphate pesticides with lower IQ’s in children. Organophosphate pesticides, a relatively older generation of highly neurotoxic pesticides still widely used on farms in California, have been associated with a  broad range of diseases  in both children and adults.  This  latest study  supports health and environmental advocates’ call to eliminate these toxic pesticides in agriculture and move toward safer, sustainable, and organic management practices. The study, titled  Prenatal Residential Proximity to Agricultural Pesticide Use and IQ in 7-Year-Old Children, looks at 283 women and children from the agricultural Salinas Valley who are enrolled in the long-term Center for the Health of Mothers and Children in Salinas (CHAMACOS) study. Specifically, researchers looked at pregnant women living within one kilometer of agricultural fields where organophosphate pesticides were used. They found that at age 7, the children of those women had declines of approximately two IQ points and three verbal reasoning […]

(Beyond Pesticides, July 26, 2016)  Health Canada’s Pest Management Regulatory Agency (PMRA) announced this week it will cancel certain  formulations  of boric acid-based pesticides. The announcement reflects the latest science showing that certain products, such as those in dust formulations or open baits, put residents at inhalation and ingestion exposure risk, respectively, to the naturally occurring element  boron and borate compounds. PRMA’s decision  is part of the Health Canada’s registration review of boric acid, which, like that of the U.S. Environmental Protection Agency (EPA), is conducted every 15 years. PRMA is cancelling the following uses of boric acid and similar compounds All domestic dust formulation products All domestic granular formulation products Domestic solution formulation products, with the exception of enclosed bait stations and spot treatment with gel formulations For other uses, PRMA has amended label requirements to better protect handlers and users of the pesticide. For example, the agency will update label directions to specify that boron products can only be applied to areas inaccessible to children and pets. Jane Philpott, Minister of Health in Canada said in a press release, “even natural ingredients like boric acid can pose a risk to Canadians. That’s why Health Canada looks at all […]

(Beyond Pesticides, July 21, 2016) An investigative report released yesterday by Center for Biological Diversity (CBD) concludes  that, over the past six years, the U.S. Environmental Protection Agency (EPA) has approved nearly 100 pesticide products with chemical mixtures that elevate the formulations’  toxicity, but are not specifically evaluated  by the agency. CBD finds that these formulations add  more stress to already-jeopardized pollinators and rare plants. The report Toxic Concoctions: How the EPA Ignores the Dangers of Pesticide Cocktails, highlights a long-running blind spot within EPA’s pesticide evaluation program, which Beyond Pesticides has long sounded the alarm on: the risk associated with combining mixtures of different pesticide active ingredients, which independent science shows may be more toxic than a single active ingredient by itself, also known as pesticide synergism. The mixtures occur as a result of multiple ingredients in individual products or  because of exposure to multiple pesticide product residues in food, air, water, and land areas, such as lawns, playing fields, and parks. “It’s alarming to see just how common it’s been for the EPA to ignore how these chemical mixtures might endanger the health of our environment,” said Nathan Donley, Ph.D., a scientist with the CBD, and author of […]

(Beyond Pesticides, July 13, 2016) California’s Office of Environmental Health Hazard Assessment (OEHHA) has announced that atrazine, its chemical cousins,  propazine,  simazine,  and its break down triazine compounds des-ethyl atrazine (DEA),  des-isopropyl atrazine (DIA)  and  2,4-diamino-6-chloro-s-triazine (DACT)  would be added to the list of chemicals known to the state to cause reproductive toxicity for purposes of the state’s Proposition 65. The formal listing has been delayed and will not be effective until July 15, 2016 due to litigation from the manufacturer, Syngenta, which opposes the listing. In 2014 the state announced its Notice of Intent to list the triazines: atrazine, propazine, simazine and their breakdown products under Proposition 65 — the state’s law on toxic chemicals. The listing of these chemicals was initially to be effective on August 3, 2015. However, Syngenta, manufacturer of atrazine, challenged the listing decision, leading to a delay in the formal decision. Syngenta Crop Protection v OEHHA  (Sacramento Superior Court case#34-2014-800001868). Syngenta’s challenge was unsuccessful and now the official listing can move forward, in spite of Syngenta’s pending appeal. The six chemicals will now be known as reproductive toxicants in the state of California effective July 15, 2016. See listing notice. http://oehha.ca.gov/media/downloads/crnr/listingnoticetriazines070516.pdf Proposition 65, officially […]

(Beyond Pesticides, July 11, 2016) The Centers for Disease Control and Prevention (CDC) and the U.S. Environmental Protection Agency (EPA) announced last Wednesday, July 6 that Zika is spreading rapidly in Puerto Rico, and recommends aerial spraying of the toxic pesticide Naled for mosquito control, much to the dismay of many area farmers, activists and concerned citizens who feel that the decision was made without consultation or information provided to the local population. Aerial spraying of pesticides have long been used for mosquito control, but many experts believe that these methods fail to sufficiently manage mosquito populations, increase pesticide resistance, and kill other species that would have acted as a natural predator to mosquitoes. Many experts  agree that combating mosquito-borne diseases should include good surveillance and scientific understanding for controlling mosquito populations, including a focus on  eliminating or managing  breeding areas,  utilizing  biological controls, exclusion from indoor environments with screening, and repellents. An efficient mosquito management strategy emphasizes public awareness, prevention, and monitoring methods. However, if these methods are not used properly or in time, communities must determine if they should risk exposing vulnerable populations to potentially harmful diseases caused by mosquitoes or to chronic or deadly illnesses caused by […]

(Beyond Pesticides, July 8, 2016) Researchers at the University of Montana (UM) recently released a study that found a lack of government data and accountability on  the use of herbicides on public lands to kill invasive and non-native plants. The report raises serious questions about the widespread management practice, which the researchers say may be causing more harm than good. UM researchers, Cara Nelson, Ph.D. and Viktoria Wagner, Ph.D., along with two researchers from Canada, looked at government agencies and agricultural statistics companies in the U.S., Canada, and Mexico to find their data. The study found that the government agencies in Canada and Mexico kept no archived database of herbicide usage for invasive plant management. In the U.S., five out of seven agencies that were contacted by the researchers tracked herbicide usage, and only four of those agencies shared their data. These agencies include the Bureau of Indian Affairs, Bureau of Land Management, Fish and Wildlife Service, and National Park Service. The U.S. Forest Service, which oversees 193 million acres in the U.S., declined to share its data on herbicide use. The report found that even the agencies that did share their data did not consistently archive information on the […]

(Beyond Pesticides, July 7, 2016) Despite an outpouring of letters, calls and protests, in a key procedural vote yesterday, the Senate voted to deny Americans the right to know what is in in their food products, and to preempt states’ rights to create their own genetically engineered food labeling laws. In a cloture vote of 65-32, the highly-flawed genetically engineered (GE or GMO) labeling bill, S.B. 764, offered by Senators Debbie Stabenow (D-MI) and Pat Roberts (R-KY), also known as the Deny Americans the Right to Know (DARK) Act, passed through the Senate. This “compromise” bill allows producers to use QR codes and “smart labels” instead of clear, on-package labeling of food products that contain genetically modified organisms, which means that consumers will need to use a smart phone for the information. The bill also exempts major portions of current and future GE foods from being labeled, and, in an affront against democracy, preempts the genetically engineered food labeling laws in Vermont (which went into effect July 1), Connecticut, Maine and Alaska. “The American people have a right to know what they’re eating,” said Senator Bernie Sanders (I-VT), who vowed to put a hold on the bill if they didn’t […]

(Beyond Pesticides, July 6, 2016) Unable to come to a formal decision on glyphosate, the European Commission has issued a limited license extension for  glyphosate,  the pesticide in Monsanto’s flagship product Roundup. The decision also comes with some restrictions, including obligations for member states to minimize use on playgrounds, and a ban on formulations with the ingredient POEA. The  18-month interim license will allow glyphosate-containing products to remain on the market until the European Chemicals Agency rules  on glyphosate’s safety, an action  due by the end of 2017. According to the European Commission, “Despite repeated efforts from the Commission to address concerns expressed about the re-approval of glyphosate, Member States were not prepared to take responsibility for a decision  as no qualified majority was reached”¦” Debate has been raging in Europe about the continued use of glyphosate in light of the 2015 classification by the World Health Organization’s (WHO) International Agency for Research on Cancer (IARC) of glyphosate as a “probable human carcinogen.” However, confusion peaked when a few short months later the European Food Safety Authority (EFSA) published its report finding that glyphosate is  “unlikely to pose a carcinogenic hazard to humans.” However, EFSA’s report is  limited in that […]

(Beyond Pesticides, June 23, 2016) A truck full of dead bees made its final stop yesterday at a rally outside the headquarters of the U.S. Environmental Protection Agency (EPA), culminating a coast-to-coast tour to raise awareness about recent massive declines in pollinators. While the millions of dead bees stayed on the truck, advocates and beekeepers, including Beyond Pesticides, delivered over 4 million signatures urging an immediate ban on bee-killing pesticides. “In the five years since I started keeping bees, I’ve seen many hives killed by pesticides,” said James Cook, a Minnesota-based beekeeper who has been driving the truck across the country since last Monday. “If some fundamental things don’t change, it’s going to be really hard for beekeepers to adapt to the environment around us.” Bees pollinate most of the world’s most common crops, including summer favorites like peaches and watermelon. But over 40 percent of U.S. honeybee hives die each year, costing the farming and beekeeping industry more than $2 billion annually. The most significant culprit in the bee die-off is the widely-used class of pesticides called neonicotinoids, or neonics. Last spring EPA began a process to assess four types of neonics and their impacts on pollinators. In January […]

(Beyond Pesticides, June 21, 2016) New regulations issued by the European Commission (EU) last week to regulate endocrine disruptors in pesticide products are being criticized by public interest groups and scientists as undermining the precautionary legal standard governing pesticide use in Europe. Previous  investigations and reports  have uncovered  industry’s attempt to quash efforts to enact robust protections from these harmful chemicals, despite their likely contribution to billions of dollars in lost revenue due to health effects. EC’s new rules endorse the World Health Organization’s definition of endocrine disrupting chemicals (EDC). The WHO defines an endocrine disruptor as “an exogenous substance or mixture that alters function(s) of the endocrine system and consequently causes adverse health effects in an intact organism, or its progeny, or (sub)populations,” However, the proposed regulations go little beyond defining the term. “The WHO definition is not a criteria, it is just a definition,” said Andreas Kortenkamp, PhD to The Guardian. “In effect, the commission has decided to place the burden of deciding how to regulate endocrine-disrupting chemicals onto the assessors on a case-by-case basis.” Of concern is the level to which the rules reflect a hazard or risk-based criteria. While EC asserts that its rules will follow […]