(Beyond Pesticides, December 21, 2010) Despite the urging of over 100 groups, including the British Medical Association, for an overhaul of its pesticide regulations, the UK Department for the Environment, Food, and Rural Affairs (DEFRA) ruled last week that little action is required. The government was responding to the need to adapt to the European Union (EU) Directive on the Sustainable Use of Pesticides and Regulation on Plant Protection Product Authorizations. The directives, which will take effect at the end of 2011, are aimed at ensuring that EU member states are working to reduce pesticide usage and are taking adequate precautions when chemicals are used, however, they provide little incentive for governments to change their regulatory stance. Accordingly, DEFRA has deemed existing laws and regulations adequate in addressing the dangers posed by pesticide usage. There are a number of provisions in these directives that encourage member states to address pesticide usage, requiring such measures as implementing strict guidelines surrounding the sale and inspection of pesticides and application equipment, requiring governments to inform the public about the risks associated with pesticides, limiting or completely eliminating aerial spraying of pesticides, ensuring drinking water supplies and aquatic ecosystems are protected from runoff, and […]

(Beyond Pesticides, December 15, 2010) Every year, more than 10,000 kids are poisoned by rodenticides (pesticides made to kill rodents) and virtually all of the calls to U.S. poison control centers concern children under six. New rules and restrictions set by the U.S. Environmental Protection Agency (EPA) will go into effect next June in an attempt to prevent incidents involving children, but do not go far enough to protect children or wildlife. EPA has known for a generation that children have easy access to these super-toxic rat poisons. Every year, more than 10,000 kids are getting a hold of them, with Black and Hispanic children living below the poverty line being disproportionately affected. Records show that the EPA is aware that children have been getting into these poisons in significant numbers, according to data since 1983. Between 2004 and 2008, U.S. poison control centers continued to receive 10,000 to 14,000 calls about the rat killers annually. EPA has estimated that these incidents reported to poison control centers probably account for only about one-fourth of all exposures. On average, about 3,700 of these cases are treated by medical professionals each year, according to reports of the American Association of Poison Control […]

(Beyond Pesticides, December 10, 2010) Announcing a 60-day public comment period, the U.S. Environmental Protection Agency (EPA) yesterday published in the Federal Register a petition filed by 82 public health and environmental groups, led by Beyond Pesticides and Food and Water Watch, to ban the controversial antimicrobial/antibacterial pesticide triclosan, found in products from clothing to soaps, for non-medical use. The Federal Register notice (Petition for a Ban on Triclosan, 75 FR 76461, December 8, 2010) invites the public to comment until February 7, 2011 on the need to ban triclosan under numerous federal statutes. The petition, filed on January 14, 2010, identifies pervasive and widespread use of triclosan and a failure of EPA to: (i) address the impacts posed by triclosan’s degradation products on human health and the environment, (ii) conduct separate assessment for triclosan residues in contaminated drinking water and food, and (iii) evaluate concerns related to antibacterial resistance and endocrine disruption. The petition cites violations of numerous environmental statutes, including laws on pesticide registration, the Clean Water Act, Safe Drinking Water Act, and Endangered Species Act. It also documents that triclosan is no more effective than regular soap and water in removing germs and therefore creates an unnecessary […]

(Beyond Pesticides, December 9, 2010) Beekeepers and environmentalists called on the U.S. Environmental Protection Agency (EPA) December 8, to remove a pesticide linked to Colony Collapse Disorder (CCD), citing a leaked EPA memo that discloses a critically flawed scientific support study. The November 2nd memo identifies a core study underpinning the registration of the insecticide clothianidin as unsound after EPA quietly re-evaluated the pesticide just as it was getting ready to allow a further expansion of its use. Clothianidin (product name “Poncho”) has been widely used as a seed treatment on many of the country’s major crops for eight growing seasons under a “conditional registration” granted while EPA waited for Bayer Crop Science, the pesticide’s maker, to conduct a field study assessing the insecticide’s threat to bee colony health. Bayer’s field study was the contingency on which clothianidin’s conditional registration was granted in 2003. As such, the groups are calling for an immediate stop-use order on the pesticide while the science is redone, and redesigned in partnership with practicing beekeepers. They claim that the initial field study guidelines, which the Bayer study failed to satisfy, were insufficiently rigorous to test whether or not clothianidin contributes to CCD in a real-world […]

(Beyond Pesticides, December 3, 2010) Ignoring the assessments of top U.S. scientists and its own Scientific Review Committee, the California Department of Pesticide Regulation (DPR) announced its approval on December 1, 2010 for use of methyl iodide, a potent carcinogen and water contaminant, as a fumigant in the state’s strawberry fields, nut orchards, and flower farms. The news comes one day after press events in eight California cities urging DPR to deny its approval, and after Washington State decided to not allow use of the chemical.”¨ Methyl iodide poses great risk to farmworkers and those who live near fields where it will be applied as well as to air and waterways, should it escape into the surrounding environment. It is on California’s official list of known carcinogenic chemicals and has been linked to serious risks in reproductive and neurological health. A coalition of farmworker, farm, public health and environmental groups is calling on the administration of governor-elect Jerry Brown to work with his agency staff to undo this approval, and deny the use of methyl iodide in California. Specifically, the groups call on Brown to: ”¢ Follow the recommendation of John Froines, PhD, Chair of the Scientific Review Committee, to […]

(Beyond Pesticides, November 18, 2010) Yesterday, the U.S. Environmental Protection Agency (EPA) announced that it has identified a list of 134 chemicals that will be screened for their potential to disrupt the endocrine system, along with a draft of the policies and procedures that the agency will follow for testing. Endocrine disruptors are chemicals that that interfere with the hormones produced or secreted by the human or animal endocrine system, which regulates development, metabolism, growth, and reproduction. These man-made chemicals are used in everyday materials but appearing in increasing levels throughout the environment. For years, scientists have noted strange anomalies in fish and wildlife in locations where endocrine disrupting chemicals (EDCs) are found. A recent study found that an astounding 100 percent of small mouth bass in certain sites of the Potomac River basin have exhibited both male and female organs, a characteristic linked to EDCs. According to a 2009 study by the U.S. Geologic Survey, the occurrence of “intersex” fish is now found to be nationwide. EPA is currently proceeding with endocrine disruptor screening on three fronts: 1) Developing and validating Tier 2 tests; 2) Selecting chemicals for screening and testing; and 3) Implementing the policies and procedures the […]

(Beyond Pesticides, October 14, 2010) Over 13,000 organizations and individuals -consumers, parents, health advocates, farmworkers and others- from across the U.S. sent a letter to the Environmental Protection Agency (EPA) yesterday calling for a ban on the insecticide chlorpyrifos and a phase out of other organophosphate (OP) pesticides. Chlorpyrifos was phased out for residential use under a 2000 agreement between EPA and Dow Agrosciences, but continues to expose farmworkers and consumers through its use in agriculture. Also on October 13, the Endocrine Disruption Exchange (TEDX), led by renowned scientist Theo Colborn, PhD, announced the addition of chlorpyrifos to its online database, Critical Windows of Development, spotlighting research that links prenatal, low dose chlorpyrifos exposure to altered health outcomes in the brain and other organs. “Human studies have now linked prenatal exposure to chlorpyrifos with mental and developmental delays emphasizing even more the urgency to remove the product from the market,” said Dr. Colborn, President of TEDX and a signatory on the letter. “Chlorpyrifos illustrates the urgent need to be cautious, prevent further exposure and protect our children from the time they are conceived onward.” Beyond Pesticides calls EPA’s 2000 chlorpyrifos settlement with Dow a classic failure of the risk assessment […]

(Beyond Pesticides, October 4, 2010) The Nebraska Farm Bureau and its champion, Sen. Ben Nelson (D-Neb), have recently expressed concern over a series of actions and proposals by the U.S. Environmental Protection Agency (EPA) concerning agriculture. Arguing that EPA is “overreaching” and is “out of control” by introducing new regulations that create “more paperwork” for its farmers, Sen. Nelson and advocates for chemical-intensive agriculture dismiss the EPA’s mandate to protect public and environmental health. Sen. Nelson recently brought up his concerns at a Senate hearing with EPA Administrator Lisa Jackson. Nebraska Farm Bureau is asking the state’s congressional delegation to work with their colleagues to halt EPA’s “non-stop regulatory assault on the state’s farmers and ranchers and their counterparts nationwide.” In addressing Administrator Jackson, Sen. Nelson said he agreed with a number of Nebraska producers who have told him that agriculture’s perspective is not being considered in EPA’s decision making, saying that, “EPA is overreaching with proposed regulations for carbon emissions, atrazine, dust standards, applying clean water rules on pesticide use and greenhouse gas reporting for livestock operations.” “Many in the agricultural community are rightly concerned about EPA’s actions because the agency’s rules typically are implemented in a top-down fashion […]

(Beyond Pesticides, September 20, 2010) California-based discount retailer 99 Cents Only Stores Inc. has been fined over $400,000 for selling three household products containing unregistered or mislabeled pesticides. It is the largest contested penalty ever handed down by EPA. According to EPA, the retailer continued to sell the products even after being notified that they were violating regulations. EPA found 99 Cents Only Stores were selling products in violation of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) during a routine inspection in 2004. Subsequent inspections up until 2008 found additional problems resulting in a total of 166 separate violations. Originally. EPA handed down a $1 million fine. 99 Cents Only Stores Inc decided to contest the penalty. These types of fines are rarely contested. In the end, EPA Administrative Law Judge Susan Biro ruled the company would pay a fine of $409,490, declaring the retailer’s management had a “culture of indifference.” Of the 166 violations committed by 99 Cents Only stores Inc., 164 were related to a household cleaner and sanitizer imported from Mexico called Bref Limpieza y Disinfeccion Total con Densicloro which translates into “Bref Complete Cleaning and Disinfection with Densicloro.” The product had pesticidal claims on the […]

(Beyond Pesticides, September 15, 2010) On September 1, the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) unveiled “Enable the Label,” an online discussion forum established to facilitate the exchange of information and ideas related to the labeling of pesticides. EPA will facilitate a monthly discussion focusing on one or two chapters of the Label Review Manual, an educational tool for understanding the pesticide labeling process. Beyond Pesticides has criticized EPA’s pesticide labeling program in the past for not providing full disclosure on potential health and environmental effects, ingredients and breakdown products, data gaps and other missing information. Each month several questions will be posed for discussion and the public is welcome to post thoughts and ideas on the topics and provide feedback on any other subject covered in that month’s chapter. According to EPA, the goal is to improve the clarity and usefulness of the Label Review Manual for its users – primarily people who draft, review, or enforce labels in the field. Pesticide manufacturers and their representatives, State pesticide regulators, and pesticide users are expected to be interested in participating in EPA’s new “Enable the Label” online discussion forum. The Label Review Manual is a tool […]

(Beyond Pesticides, September 2, 2010) Beyond Pesticides, along with dozens of environmental and public health groups from across the country, sent a letter to members of the U.S. Senate Committee on Agriculture, Nutrition, and Forestry, urging the withdrawal of S. 3735, a bill that would strip the Clean Water Act of protections from pesticides. The bill, introduced by Senators Blanche Lincoln (D-AR) and Saxby Chambliss (R-GA), the Senate Agricultural Committee’s Chair and Ranking Member, seeks to nullify regulations that require pesticide applicators apply for National Pollutant Discharge Elimination System (NPDES) permits under CWA before applying pesticides on or near surface waters. The groups say Congress should be supporting the Environmental Protection Agency (EPA) in fulfilling its task, rather than undermining laws that protect public health and the environment. Senators Lincoln and Chambliss argue that because pesticides are registered under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) additional regulation is unnecessary and the legislation will reduce the burden on farmers, foresters and ranchers. In their August 30th letter, the groups say, “CWA complements and does not duplicate the pesticide registration reviews conducted by EPA under FIFRA, which sets a general national standard that does not take into account conditions and […]

(Beyond Pesticides, August 31, 2010) As the Environmental Protection Agency (EPA) continues its review of the popular herbicide atrazine, a new study shows that male rats prenatally exposed to low doses of the gender-bending chemical are more likely to develop prostate inflammation and to go through puberty later than non-exposed animals. The research adds to a growing body of literature on atrazine, an herbicide used in agriculture, especially in corn and sugar cane production, and on golf courses and residential lawns. Atrazine and its byproducts are known to be relatively persistent in the environment, potentially finding their way into water supplies. It has been linked to a myriad of health problems in humans including disruption of hormone activity, birth defects, and cancer. The research, “Effects of prenatal exposure to a low dose atrazine metabolite mixture on pubertal timing and prostate development of male Long-Evans rats,” which is available online and will be featured on the cover of Reproductive Toxicology (Vol. 30, # 4), found that the incidence of prostate inflammation went from 48 percent in the control group to 81 percent in the male offspring who were exposed to a mixture of atrazine and its breakdown products prenatally. The severity […]

(Beyond Pesticides, August 20, 2010) Behind closed doors this past Monday, the U.S. Environmental Protection Agency (EPA) and Bayer CropScience reached an agreement on a set of measures to gradually reduce and ultimately ban fully the use of the insecticde aldicarb in the U.S. This decision arrives on the heels of a revised risk assessment in which EPA found that babies and children under the age of five can ingest levels of the insecticide through food and drinking water at levels that exceed limits that the agency finds safe, and 25 years after 2,000 people fell ill after eating watermelons that were tainted with the pesticide. Though Beyond Pesticides applauds any decision to remove toxic chemicals from the environment, the problem with this cancellation, as with virtually all voluntary cancellations, is that the chemical can be legally used for years —eight years in this case — leaving open the opportunity for continued human and environmental exposure and harm. The decision was reached after EPA completed a revised risk assessment indicating that the pesticide does not meet the agency’s food safety standards. EPA scrutinized recent food consumption data from USDA to complete the risk assessment, which considered the percent of the […]

(Beyond Pesticides, August 10, 2010) Senator Blanche Lincoln (D-AR), Chair of the Senate Committee on Agriculture, Nutrition, and Forestry, and Ranking Member Saxby Chambliss (R-GA) introduced legislation on August 6, 2010 that would strip the public of the protection provided by the Clean Water Act (CWA) from the toxic hazards of pesticides applied to or near U.S. waterways. If successful, the bill, S. 3735, would nullify regulations that require pesticide applicators apply for National Pollutant Discharge Elimination System (NPDES) permits under CWA before applying pesticides on or near surface waters. Beyond Pesticides encourages its members to contact their Senators and let them know how they feel about S. 3735. Senators Lincoln and Chambliss say that because pesticides are registered under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) additional regulation is unnecessary and the legislation will reduce the burden on farmers, foresters and ranchers. Environmentalists argue that CWA is more protective, and pesticides should be regulated under both statues to improve protections for human health and the environment. CWA uses a health-based standard known as maximum contamination levels to protect waterways and requires permits when chemicals are directly deposited into rivers, lakes and streams, while FIFRA uses a highly subjective […]

(Beyond Pesticides, July 22, 2010) In a press release submitted last week, the Monsanto Company, Inc. announced that it has taken a vital step towards commercializing a new soybean product that is tolerant to the neurotoxic pesticide dicamba by completing its regulatory submission to the U.S. Department of Agriculture (USDA) for dicamba-tolerant soybeans. Monsanto expects to complete regulatory submission to the USDA and key global markets in the coming months. The dicamba tolerance trait is expected to also be stacked with the glyphosate-resistant, or “Roundup Ready” soybean trait upon commercialization. While Monsanto claims that this is a “highly effective and economical weed control package,” it is likely to be similar to Roundup (glyphosate) Ready crops, just another way to sell more pesticide product. Monsanto is banking on the idea that mixing dicamba with glyphosate will help manage the hard-to-control broadleaf weeds in chemical-intensive farming systems, targeting both pre-plant and post-emergence weed control in an effort to reduce resistance. In a report published last year, analysts found that genetically engineered (GE) crops have been responsible for an increase of 383 million pounds of herbicide use in the U.S. over the first 13 years of commercial use of GE crops (1996-2008). The […]

(Beyond Pesticides, July 14, 2010) The U.S. Environmental Protection Agency (EPA) announced that Monsanto Company Inc. has agreed to pay a $2.5 million penalty to resolve misbranding violations related to the sale and distribution of cotton seed products containing genetically engineered (GE) pesticides. This is the largest civil administrative penalty settlement ever received under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). “This agreement shows that when a company violates the law by distributing misbranded pesticides, EPA will take action,” said Cynthia Giles, assistant administrator for EPA’s Office of Enforcement and Compliance Assurance. “The regulated community should understand that we take these violations seriously, and the public will accept nothing less than compliance.” “People who manufacture and distribute pesticide products must follow the federal registration requirements,” said Steve Owens, assistant administrator for EPA’s Office of Chemical Safety and Pollution Prevention. “These requirements are critical to preventing the development and spread of insect resistance.” Monsanto Bollgard and Bollgard II cotton seed products contain genetically engineered pesticides known as plant incorporated protectants (PIPs), which are registered as a pesticidal product under FIFRA. As a condition of the registrations, EPA included planting restrictions on Bollgard and Bollgard II, which contain the PIP Bacillus […]

(Beyond Pesticides, July 13, 2010) Beyond Pesticides is urging the public to send comments by July 19, 2010 to the Environmental Protection Agency (EPA) on its recently issued draft “general permit” under the Clean Water Act (CWA) that will govern aquatic pesticides and certain pesticide spraying over or near surface waters, including mosquito spraying and spraying over forest canopies and near irrigation ditches. Environmental groups believe the pesticide industry is lobbying to make this permit as weak as possible. Beyond Pesticides encourages individuals to send comments to EPA supporting strong, meaningful regulation of pesticide applications in order to fully protect public health and the environment. See talking points and instructions for sending comments below. Background EPA announced the public availability of a draft National Pollutant Discharge Elimination System (NPDES) General Permit, posted here, for certain pesticide use patterns, also known as the Pesticides General Permit (PGP) on June 2, 2010. The action stems from a 2009 court decision in the case of the National Cotton Council et al. v. EPA, in which the 6th circuit court of appeals ruled that pesticide discharges into water are pollutants and require permitting under the CWA. This ruling overturned the Bush administration policy that […]

(Beyond Pesticides, June 30, 2010) The U.S. Environmental Protection Agency (EPA) approval process for thousands of antimicrobial products is woefully inadequate, according Public Employees for Environmental Responsibility (PEER). Despite a growing body of scientific evidence about the side-effects of these products, EPA rubberstamps registrations without duly considering an array of potential public health and environmental impacts. Antimicrobials are now a billion dollar business with more than 5,000 such products currently registered with EPA. Initially designed for hospitals and clinics, antimicrobial pesticides are today found in products ranging from household cleaners to mattresses and bedding, cosmetics, toys, toothpaste and even chopsticks. Antibacterial products are being marketed to the health conscious without firm evidence of real benefits and amid growing concern about downstream consequences. One prime example of this is the antibacterial pesticide triclosan that is formulated into hundreds of personal care products, toys and textiles. Studies show that triclosan is an endocrine disruptor, accumulates in human fatty tissue and can influence the onset of bacterial resistance. Beyond Pesticides, Food and Water Watch and several other groups petitioned FDA in 2009 and EPA in January 2010, calling for the ban of triclosan citing the possibility of bacterial resistance to antibacterial substances and […]

(Beyond Pesticides, June 10, 2010) After years of pressure from environmental and international groups concerned about the chemical’s health effects, the U.S. Environmental Protection Agencey (EPA) announced that it is taking action to end all uses of the insecticide endosulfan in the United States. EPA has decided that new data presented to the agency in response to its 2002 reregistration eligibility decision (RED) have shown that risks faced by workers are greater than previously known. EPA also has found that there are risks above the agency’s level of concern to aquatic and terrestrial wildlife, as well as to birds and mammals that consume aquatic prey which have ingested endosulfan. Farmworkers can be exposed to endosulfan through inhalation and contact with the skin. An organochlorine insecticide first registered in the 1950s, endosulfan is used on a variety of vegetables, fruits, cotton, and on ornatmental shrubs, trees and vines. It poses unacceptable neurological and reproductive risks to farmworkers and wildlife and can persist in the environment. According to the EPA, crops with the highest use in 2006 — 2008 included tomato, cucurbit, potato, apple, and cotton. The use of endosulfan decreased overall from 2001 to 2008. A restricted use pesticide, endosulfan may […]

(Beyond Pesticides, June 7, 2010) With thousands of violations cited, the pest control company and applicator responsible for the deaths of two young children are only fined several tens of thousands of dollars, a mere slap on the hand. The Utah Department of Agriculture and Food’s (UDAF) Division of Plant Industry has finally filed multiple charges of violations against Bugman Pest and Lawn, Inc. of Bountiful, Utah, and employee Cole Nocks associated with the February 5, 2010 application of the pesticide Fumitoxin (active ingredient: aluminum phosphide) at the residence of Nathan and Brenda Toone of Layton, Utah that lead to the death of their two daughters ages 15-months and 4 years. In addition to the Layton incident, investigators discovered additional violations of the Utah Pesticide Control Act by the company and other employees. The UDAF seeks to revoke Mr. Nocks’s applicator license and has issued him a $27,000 fine, while Bugman Pest and Lawn, Inc. is fined $32,000. Under law, the UDAF is only allowed to file civil penalties. Investigators determined that on February 5, 2010 applicator Cole Nocks operated in a faulty, careless or negligent manner by misapplying the highly toxic and restricted use pesticide, Fumitoxin. Mr. Nocks’s improper […]

(Beyond Pesticides, June 4, 2010) The U.S. Environmental Protection Agency (EPA) proposed new permit requirements for the discharge of pesticides into US waterways. EPA announced the public availability of a draft National Pollutant Discharge Elimination System (NPDES) General Permit for certain pesticide use patterns, also known as the Pesticides General Permit (PGP). The agency is accepting public comments until July 19, 2010. This action stems from a 2009 court decision in the case of the National Cotton Council et al. v. EPA, in which the 6th circuit court of appeals ruled that pesticide discharges into water are pollutants and require permitting under the Clean Water Act (CWA). This ruling overturned the Bush administration policy that exempted pesticides from regulation under the CWA, and instead applied the less stringent standards of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). CWA uses a kind of health-based standard known as maximum contamination levels to protect waterways and requires permits when chemicals are directly deposited into rivers, lakes and streams, while FIFRA uses a highly subjective risk assessment that does not consider safer alternatives. EPA will issue permits in territories, Indian Country Lands, 6 states and the District of Columbia where the Agency is […]

(Beyond Pesticides, June 3, 2010) City lawmakers in Albany, New York want to strengthen an 11-year-old ban on the use of some pesticides on city land after the revelation last week that one such banned chemical was sprayed near a local playground earlier this month. Albany’s Parks and Recreation Commissioner John D’Antonio said last Friday he was unaware of the ban, passed by the council in 1998, until he began researching a recent citizen complaint. The city is now rethinking its use of pesticides and exploring why the ban on city use of pesticides dubbed most toxic by the federal government was not more widely known. The law also required departments using less toxic pesticides to annually report plans to phase them out to the Common Council. TruGreen, a city contractor, used Trupower 3 Selective Herbicide, which is a mixture of 2,4-D, mecoprop-p and dicamba, and is listed in Toxicity Category 1 (most toxic) by the Environmental Protection Agency (EPA) — causing potentially irreversible eye damage, but is also toxic if ingested and can be irritating to the skin. The herbicide has been banned from city land, except in rare circumstances, since 1999. Under the same ordinance, all city agencies […]

(Beyond Pesticides, May 4, 2010) On April 30, 2010, despite significant cancer and reproductive health risk, especially to farmworkers and people living near agricultural fields, the California Department of Pesticide Regulation (DPR) proposed the use of a new and highly toxic pesticide, methyl iodide, for widespread agricultural use in California. The U.S. Environmental Protection Agency (EPA) registered methyl iodide in 2007 as a replacement for the ozone-depleting pesticide, methyl bromide. Environmental and public health advocates believe that blocking methyl iodide registration in California will prevent its use elsewhere, since the state will account for the vast majority usage and profitability nationwide. Public comments may be sent to [email protected]. If registered, methyl iodide will be used primarily to fumigate and sterilize the California’s strawberry fields, although the pesticide will also be used in nurseries and nut tree production. DPR’s proposal does not require neighbor notification before use of this extremely toxic chemical. As evidenced by California’s thriving organic industry, alternatives to fumigants exist and are in use in California. In a hearing on February 8, 2010, before the California Senate Committee on Food and Agriculture, two panels of California growers and researchers discussed a number of safe and effective alternatives to […]