(Beyond Pesticides, February 8, 2017) As the controversy surrounding the Trump Administration and GOP Congress’s plan for the Environmental Protection Agency (EPA) continues to grow, a nonpartisan group of 447 former EPA employees united to write a strongly-worded letter urging the Senate to block Scott Pruitt’s confirmation as EPA Administrator. Citing EPA’s “fundamental obligation to act in the public’s interest based on current law and the best available science,” the group, whose members served under both Democratic and Republican presidents, calls into question Pruitt’s qualifications, given his longstanding record of opposing “longstanding tenets of U.S. environmental law.” This letter is just the latest in the constantly evolving debate over the need for environmental protection. In the past two weeks, the EPA has been under attack by the Trump Administration and Republican lawmakers who would continue to undermine the environmental protections required for clean water, clean air, and healthy natural resources. Myron Ebell, head of Trump’s EPA transition team, suggested last week that the agency’s already understaffed workforce be cut from about 15,000 employees to 5,000, with potentially more cuts to follow. Trump himself then issued an executive order proposing that for every new regulation promulgated, two must be repealed, an […]

(Beyond Pesticides, February 7, 2017) After years of legal battle, the Colorado Court of Appeals last week affirmed a ruling that Colorado rancher, James Hopper, must serve two days in jail and pay a $7,500 fine for spraying pesticides that drifted unto his neighbor’s farm in violation of a 2012 court order protecting his neighbors. In 2012, organic farmers Rosemary Bilchak and her husband Gordon MacAlpine, were granted a permanent injunction prohibiting pesticide applications within 150 feet of the property line in order to reduce pesticide drift. Last week’s decision bolsters a legal precedent that wafting pesticides can constitute a trespass against which adjacent landowners and people with health sensitivities are protected. The legal battle began in 2011 when Mr. Hopper obtained his Colorado pesticide applicator’s license and applied the adulticide Fyfanon, which contains the organophosphate insecticide malathion, to kill mosquitoes on his property. However, the pesticide drifted onto Ms. Bilchak and Mr. MacAlpine’s organic vegetable farm. In 2012, a District Court Judge ruled that they have a right not to have their property invaded by other people or things, and prohibited Mr. Hopper from fogging for mosquitoes within 150 feet of his neighbor’s property or allowing the pesticides to drift, […]

(Beyond Pesticides, February 6, 2017) California Department of Pesticide Regulation (CDPR) rules that allow greater use of the highly toxic fumigant Telone, while decreasing protections for the public, have been challenged in California court. On January 31, attorneys representing Juana Vasquez, a farmworker in Ventura County, along with Californians for Pesticide Reform (CPR) and Pesticide Action Network North America (PANNA), filed suit in the Superior Court of California against the California Department of Pesticide Regulation (CDPR). The suit claims that CDPR failed to follow required public procedures in developing new rules for 1,3-Dicholopropene (1,3-D), which is an active ingredient in the product Telone and has many documented health risks, including cancer and kidney and liver damage. In October 2016, CDPR released new rules that allow the continued use of Telone and decrease protections for public health by permitting increased usage. CDPR and many news outlets reported the rule change as a tightening of the restrictions, but in reality, the new rules increase the previous annual cap from 90,250 pounds to 136,000 pounds per township, a defined area of 6×6 miles. These new rules went into effect on January 1, 2017, allowing for 1,3-D’s continued use in strawberry fields, vineyards, almond […]

(Beyond Pesticides, February 2, 2017) A commonly used inert pesticide ingredient negatively affects the health of honey bees by making larvae more susceptible to a virus, according to a recently published study in the journal, Nature. One of the authors of the study, Julia Fine, PhD candidate, stated that the findings, “Mirror the symptoms observed in hives following almond pollination, when bees are exposed to organosilicone adjuvant residues in pollen, and viral pathogen prevalence is known to increase. In recent years, beekeepers have reported missing, dead and dying brood in their hives following almond pollination, and exposure to agrochemicals, like adjuvants, applied during bloom, has been suggested as a cause.” The study assessed honey bee larval development after exposure to a continuous low dose of Sylgard 309, a surfactant, in their diet. This organosilicone surfactant is commonly used on agricultural crops, including tree fruits, nuts, and grapes. Their results reveal that honey bee exposure to chemical surfactants such as Sylgard 309 led to higher levels of Black Queen Cell Virus and when the bee larvae were exposed to the surfactant and virus simultaneously, “the effect on their mortality was synergistic rather than additive.” This research comes at a time when […]

(Beyond Pesticides, February 1, 2017) Last week in North Miami, the City Council took a significant step that could reduce pesticide use in the community. The Council adopted an Integrated Pest Management (IPM) policy modeled after a plan developed by San Francisco in the mid-90’s. The plan does not ban pesticides and herbicides, but instead aims to reeducate citizens and county workers on least-toxic pest management strategies with the goal of eliminating toxic pesticide use on city property.  The IPM plan does not address pesticide use on private property, due to state preemption of local authority. With the passage of the North Miami’s resolution, city operatives will now be asked to give preference to available, safe and effective non-pesticide alternatives and cultural practices. As stated in the resolution’s Integrated Pesticide Management Program Guidelines, the goal of the policy is “to eliminate the application of all Toxicity Category I and Category II pesticide products by January 2018.” On top of eliminating certain pesticide categories, the resolution also calls for staff training and expert consultants, both of which have the potential to help ease the transition in pursuit of the 2018 goal, and priority will be given to efforts to reduce or eliminate pesticide use near […]

(Beyond Pesticides, January 31, 2017) A tentative ruling last week by Fresno County Superior Court Judge Kristi Culver Kapetan moves California closer to listing glyphosate (Roundup) as a carcinogen under the state’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Monsanto, a leading manufacturer of glyphosate under its Roundup brand, sued California to stop the listing, as it would require cancer warning labels be placed on its end-use product. The company indicates it will challenge the tentative ruling. California’s proposed to list glyphosate as a carcinogen after a 2015 determination of the International Agency for Research on Cancer, a United Nations body under the World Health Organization, that the chemical is a cancer-causing agent for humans based on laboratory studies. Monsanto refutes these claims, and since the determination has worked directly, and through proxy organizations, to discredit and attack IARC, as well as individual scientists that have participated in its decision-making process. Shortly after IARC’s Monograph on glyphosate, the German Federal Institute for Risk Assessment (BfR), a Monsanto-supported group, released a report dismissing glyphosate’s link to cancer. In October of last year, the U.S. House of Representatives’ Committee on Oversight and Government Reform, led by Rep. Jason Chaffetz […]

(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 25, 2017) A study conducted at the University of Buffalo recently revealed a connection between two common insecticides and an increased risk for certain metabolic diseases, including diabetes. Researchers found that by binding to and disrupting melatonin receptors that control numerous physiological functions, chemicals such as insecticides can affect melatonin levels, creating a higher risk for metabolic diseases to develop. The study, Carbamate Insecticides Target Human Melatonin Receptors, was published in Chemical Research in Toxicology and was funded by a grant from the National Institute of Environmental Health Sciences, which is part of the National Institutes of Health. The implicated chemicals in this research, carbaryl and carbofuran, are notoriously dangerous carbamate insecticides. Carbamates share structural characteristics and an ability to inhibit acetylcholinesterase (AChE), an enzyme important for the transmission of nerve impulses. When AChE is inhibited, acetylcholine accumulates leading to overstimulation of neurotransmitters, resulting in muscle weakness, confusion, and paralysis, among other symptoms. Carbaryl is said by EPA to be “one of the most widely applied insecticides in the U.S.,” since use began in 1959, with 10-15 million pounds used annually. It is a broad-spectrum insecticide used on a variety of crops, in forestry and on ornamentals, in […]

(Beyond Pesticides, January 24, 2017) An analysis conducted by scientists at the University of St. Andrews in Scotland is calling into question the conclusions reached in a study conducted by multinational chemical company Syngenta, which indicated that honey bees were not at risk from the widely used neonicotinoid insecticide thiamethoxam. The challenge to the Pilling et al 2013 study is important because while many experiments have been performed in the lab or semi-lab environment, this study was a field experiment developed to test pollinator exposure under normal agricultural conditions. The conclusions of such real-world experiments are weighed more heavily by regulators when making safety and use determinations. St. Andrews’ scientists focus in on the Pilling et al claim that because its study did not have high levels of replication, that it would have been misleading to perform formal statistical analysis. They respond that this would indeed be the case if Pilling et al had intended on finding statistical significance and concluded that there was no effect based on those tests. However, Syngenta’s scientists instead simply graphed average values over time based on their measurements (measurements such as number of bees in a hive, hive weight, number of brood, etc.), and compared […]

(Beyond Pesticides, January 23, 2017) Last week, the U.S. Environmental Protection Agency (EPA)  released its final Biological Evaluations of Three Chemicals’ Impacts on Endangered Species, which finds that chlorpyrifos and malathion likely have detrimental effect on 97 percent of all species listed and protected under the Endangered Species Act (ESA), while diazinon adversely affects 78 percent. According to EPA’s release on the subject, this is the “first-ever draft biological evaluations analyzing the nation-wide effects” of these registered chemicals on endangered species after decades of widespread use. The evaluations stem from a legal settlement with the Center for Biological Diversity (CBD) in which CBD sued EPA in April 2014 for its failure to comply with ESA, which requires the agency to carry out consultations with federal wildlife agencies while registering pesticides. According to Nathan Donley, Ph.D., a CBD senior scientist, “We’re now getting a much more complete picture of the risks that pesticides pose to wildlife at the brink of extinction, including birds, frogs, fish and plants. When it comes to pesticides, it’s always best to look before you leap, to understand the risks to people and wildlife before they’re put into use. The EPA is providing a reasonable assessment of those risks, many of which can be […]

(Beyond Pesticides, January 18, 2017) Despite science affirming its hazards, the U.S. Environmental Protection Agency (EPA) has expanded the registration of the toxic herbicide mixture, Enlist Duo, which contains 2,4-D and glyphosate, for use on genetically engineered (GE) cotton and extended its use on GE corn, soybean, and cotton from 15 to 34 states. This approval late last week comes at a time when widespread chemical use is threatening public health and the environment and weed resistance continues to grow, threatening farmers’ productivity and profitability. Over 600 public comments were submitted to EPA on this issue, with many comments vehemently opposing the current uses and the proposed expansion of uses. In its decision, EPA stated that Enlist Duo “meets the safety standard for the public, agricultural workers, and non-target plants and animal species.” However, as Beyond Pesticides stated in comments to the agency, EPA has not fully considered all the environmental costs, including the cost of tackling increased 2,4-D resistant weeds, crop and non-target damages from uncontrolled drift, as well as unanswered questions regarding synergistic chemical effects in non-plant species. Advocates predict weed resistance to Enlist Duo and have urged EPA to reject its continued use and incentive sustainable organic practices. Additionally, […]

(Beyond Pesticides, January 17, 2017) On January 12, 2017, the U.S. Environmental Protection Agency (EPA) released major risk assessment documents on  pollinator exposure to bee-toxic neonicotinoid insecticides finding no significant risks, despite the large and growing body of science identifying the pesticides’ hazards. In the documents, EPA identifies risks posed to bees by several neonicotinoid insecticides, but suggests that no restriction on uses are imminent. In another decision meant to protect bees from acutely toxic pesticides, the agency is scaling back its original proposal in deference chemical-intensive agricultural interests. EPA’s long awaited pollinator assessments for the neonicotinoids: clothianidin, thiamethoxam, and dinotefuran, much like the 2016 pollinator assessment release for imidacloprid, identifies risks to bees from the agricultural applications (foliar, soil and seed) of these chemicals, including from pesticide drift. Observed effects include decline in worker bees, and subsequent declines in brood and pollen stores in the colony. EPA‘s assessments continue to focus on honey bees, with cursory mention of wild, native bees. Once again, the assessments did not consider risks from exposures to contaminated water, guttation droplets, or soil, with EPA stating that, “The Agency lacks information to understand the relative importance of these other routes of exposures and/or to quantify potential risks […]

(Beyond Pesticides, January 13, 2016) Just prior to the U.S. Environmental Protection Agency (EPA) announcement on January 12 that several neonicotinoid insecticides “do not pose significant risks to bee colonies,” the preprint version of a new review of neonics identified the range of lethal and sublethal effects of the chemicals on non-target organisms.  The review, The Environmental Risks of Neonicotinoid Pesticides: a review of the evidence post-2013, authored by Dave Goulson, PhD, and Thomas James Wood, a PhD candidate, concludes that studies published since the 2013 European Food Safety (EFSA) published risk assessments show even greater risks. The EFSA assessment, which led to a moratorium on neonicotinoid uses, found that certain neonics on specific flowering crops pose a high risk to bees. With reference to the 2013 EFSA risk assessment conclusions as their baseline, the researchers summarize the difference in risk for certain categories, including: “Risk of exposure from and uptake of neonicotinoids in non-crop plants. Uptake of neonicotinoids by non-target plants was considered likely to be negligible, though a data gap was identified. Many studies have since been published demonstrating extensive uptake of neonicotinoids and their presence in the pollen, nectar and foliage of wild plants. Exposure from non-target plants clearly represents a Greater […]

(Beyond Pesticides, January 12, 2017) Yesterday marked a monumental event in the fight against pollinator declines, as the rusty patched bumblebee became the first bee species to officially be declared endangered by the U.S. Fish and Wildlife Service (FWS). According to FWS, endangered species designations are made when a species is “in danger of becoming extinct throughout all or a portion of their range.” Tom Melius, Service Midwest Regional Director for FWS, stated in a press release that, when it comes to this determination, “[FWS’s] top priority is to act quickly to prevent extinction of the rusty patched bumble bee. Listing the bee as endangered will help [the agency] mobilize partners and focus resources on finding ways right now to stop the decline.” Listed yesterday in the Federal Register, the ruling will go into effect February 10, 2017. This is a victory for environmental groups who have fought to protect the rusty patched bumble bee from widespread threats, such as habitat loss and pesticide use. According to FWS, the rusty patched bumble bee was once widespread across the United States and parts of Canada, but declined dramatically in the 1990s.  Since then, their populations have dwindled and their overall decline is estimated at 91 […]

(Beyond Pesticides, January 11, 2017) Ultra-low doses of glyphosate formulations fed to rats is linked to an increased likelihood of developing non-alcoholic fatty liver disease (NAFLD), according to a recently published study in the journal Nature. A lead author of the study, Michael Antoniou, PhD, stated that the findings are “very worrying as they demonstrate for the first time a causative link between an environmentally relevant level of Roundup consumption over the long-term and a serious disease.” The findings point to the growing need to eliminate the widespread use of this herbicide, as it has already been implicated in endocrine disruption, reproductive effects, and kidney and liver damage. The researchers analyzed female rat livers obtained from a previous 2-year study on Roundup toxicity using molecular profiling techniques. These rats were administered Roundup via drinking water at a concentration of 0.1 ppb, which is an allowable level within both the U.S. and the European Union. The molecular analyses conducted by researchers on the internal organs of the rats fed Roundup included testing of liver cell disturbances. Overall, ultra-low dose glyphosate-formulation exposure led to observations of biomarkers also seen in fatty liver disease. These findings have human health implications “since NAFLD is predicted to be the […]

(Beyond Pesticides, January 10, 2017) Exposure to neonicotinoid (neonic) insecticides leads to a decrease in pollination frequency and fewer social interactions in bumblebees, according to research published by scientists from Harvard University and University of California, Davis. The study, released last year but presented this week at the Society for Integrative and Comparative Biology’s annual meeting, underscores the need for regulators and policy makers to eliminate use of these chemicals, not only to protect honey bees, but also wild pollinators like the bumblebee. While worker bumblebees (Bombus impatiens) divide their tasks within the colony in a similar manner to honey bees, their nests appear quite different than their more structured cousins. “Bumblebee nests are not the organized, beautiful geometry of the honeybee,” said James Crall, PhD candidate in Harvard’s Department of Organismic and Evolutionary Biology. Instead, “They’re more a hodge-podge of food and larvae in a pile in the middle of the nest space.” For their study, researchers placed four bumblebee colonies in a mesh enclosed area, tagged each bee, and observed them foraging on tomato flowers grown in a pollinator-excluding greenhouse (to ensure bees had freshly-opened flowers for pollination each day). After observing normal behavior, bees within each colony […]

(Beyond Pesticides, January 9, 2017) After the U.S. Environmental Protection Agency (EPA) released its recent human health risk assessment for the organophosphate insecticide (OP) tetrachlorvinphos (TCVP) on December 21, 2016, the agency announced it was allowing the continued use of the neurotoxic chemical to which children are widely exposed through pets’ flea collars and other flea treatments. According to EPA, ” TCVP is used as a direct animal treatment to livestock (i.e., cattle, horses, poultry and swine) and their premises, in kennels, outdoors as a perimeter treatment, and as a flea treatment [including flea collars] on cats and dogs.” In its announcement on January 4, 2017, EPA states, “We advise consumers to take certain precautions when handling TCVP products in residential areas. These precautions are listed on TCVP product labels, including: not allowing children to play with TCVP pet collar products, keeping TCVP spray and powder products out of reach of children, and washing hands thoroughly with soap and water after handling.” Advocates have raised concerns related to similar decisions on flea collars in the past in which EPA has issued warnings to mitigate risks, despite its inability to ensure children’s safety. Children typically come into close contact with pets and their […]

(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, January 3, 2017)  A study published in December 2016 in Environmental Contamination and Toxicology, entitled The Effect of Atrazine on Louisiana Gulf Coast Estuarine Phytoplankton, finds that phytoplankton in estuaries in close proximity to agricultural operations are less productive than phytoplankton in an uncontaminated environment. The study examines three different estuaries of the Mississippi river in Louisiana and also evaluates microcosms with different concentrations of atrazine. Phytoplankton, incredibly important to estuary ecosystems and aquatic life, are an integral part of the aquatic food web and ultimately critical to the wild seafood market. As photosynthetic microorganisms, phytoplankton harness the sun’s energy for metabolism and create as a byproduct of photosynthesis dissolved oxygen, which oxygen-breathing sea life require. For the study, the researchers created microcosms, or large containers that are able to closely mimic ecosystems, so that they can observe the effects of independent variables. On average, phytoplankton in the microcosms are less productive at producing chlorophyll a in the presence of atrazine. The microcosm study design is important because it is difficult to separate and measure the effects of chemicals like atrazine in the environment, given the range of potential causes of phytoplankton decline. A variety of factors, like freshwater discharge rates, precipitation, […]

(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, December 23, 2016) The Environmental Agency (EPA) has finalized a proposal to ban 72 inert (or secret hazardous) ingredients from use in pesticide formulations following a long fight with environmentalists who, in 2006, asked that pesticide product labels disclose any of 371 inert ingredients that could be in products. While this finalization is a step in the right direction, ultimately the move is viewed by advocates as inadequate. The original petition, submitted by Northwest Coalition for Alternatives to Pesticides, along with Beyond Pesticides, Physicians for Social Responsibility, and nearly 20 other organizations, called on the agency to require disclosure of inerts. To put the announcement in perspective, EPA is acting on 72 inert ingredients that are no longer being used, such as turpentine oil, and nitrous oxide. An inert ingredient is defined as any ingredient that is “not active,” or specifically targeted to kill a pest. According to a 2000 report produced by the New York State Attorney General, The Secret Ingredients in Pesticides: Reducing the Risk, 72 percent of pesticide products available to consumers contain over 95 percent inert ingredients and fewer than 10 percent of pesticide products list any inert ingredients on their labels. The report also found […]

(Beyond Pesticides, December 22, 2016) Legislation passed Monday in the District of Columbia stops the use of toxic pesticides near schools, child-occupied facilities, waterbody-contingent property, and public property. The Pesticide Education and Control Amendment Act (PECCA) of 2016 (Bill B21-0580), passed unanimously by the District Council, strengthens previous law to protect children and residents living in Washington DC from unnecessary pesticide exposure. The law places the District at the forefront with other communities around the country that are phasing out the use of toxic pesticides in building and land management. The legislation, sponsored by Councilmember Mary Cheh, clarifies certain provisions of the original PECCA passed in 2012, which had not been implemented by the Department of Energy and Environment (DOEE) in accordance with the original spirit and intent of the law. The new law clarifies the department responsibility to prohibit all pesticide use near schools and waterbody-contingent properties, except a defined list of material allowed in organic land management. The law is intended to effect a transition to sustainable and cost-effective insect and weed management practices in the District. Jay Feldman, Executive Director of Beyond Pesticides, said: “This law protects vulnerable populations, like children, from the dangers of unnecessary toxic […]

(Beyond Pesticides, December 21, 2016) A California Department of Pesticide Regulation (DPR) report of all pesticide related illnesses in the state in 2014 identifies 1,685 cases “potentially involving health effects from pesticide exposure,” combining exposures from agricultural and non-agricultural use. Of the 798 cases associated with non-agricultural use, 18% of them (146 cases) involved exposure in children under 18 years old. The exposure rates are alarming, and only strengthen efforts by local activists in counties like Tulare to protect children from pesticide exposure. According to the report, Tulare County has the highest number of reported illnesses related to pesticide exposure at 78, followed by Santa Cruz County with 67. The report, Summary of Results from the California Pesticide Illness Surveillance Program 2014, provides a summary of illnesses identified by the Pesticide Illness Surveillance Program (PISP), a program under DPR. Of the 1,685 cases potentially involving health effects from pesticide exposure reported, DPR epidemiologists determined that 1,073 of those cases were “at least possibly associated” with pesticide exposure, representing a 5% decrease from 2013. However, even though the number of associated cases decreased in 2014, PISP did see a 14% rise in the number of associated episodes, defined as “an event in which a single source […]