(Beyond Pesticides, July 1, 2021) Yellow fever mosquitoes (Aedes aegypti) are evolving resistance to the pyrethroid insecticide permethrin, according to a study published by Colorado State University, highlighting the need to adopt ecologically-based mosquito management. Widespread, intensive use of the pesticide in mosquito control has allowed genetic mutations to persist among these mosquito populations, causing subsequent resistance to permethrin. Pyrethroids are one of the few remaining classes of insecticides available to control yellow fever mosquitos, and resistance threatens the ability to prevent disease outbreaks with chemical-intensive methods. Yellow fever mosquitoes are a vector for numerous untreatable diseases in humans, including dengue, chikungunya fever, and Zika viruses. Hence, this study highlights the significance of addressing pest resistance to pesticide control, particularly to mitigate disease exposure and effects. The researchers note, “This knowledge can help scientists understand how mosquitoes have evolved resistance and when a population can no longer be controlled with permethrin. This understanding will be necessary to develop tools to support future insecticide management strategies.” Researchers sequenced the genome of resistant and knockdown (either recovered or dead) mosquitoes after permethrin exposure using a bottle bioassay. The aim was to identify genomic variants/biomarkers associated with specific resistance mechanisms. Two common pyrethroid resistance mechanisms occur among […]

(Beyond Pesticides, March 19, 2021) As reported by VTDigger, Vermont’s Endangered Species Committee recently took action to uphold the state’s endangered species law. The committee announced that a mosquito control program in the Champlain Valley, which uses the toxic pesticides malathion and permethrin, is threatening five species of endangered bats — all of which are on Vermont’s list of threatened and endangered species. The committee voted unanimously to recommend to the state Secretary of the Agency of Natural Resources that the spraying program in the Brandon, Leicester, Salisbury, Goshen, Pittsford Insect Control District be allowed only via special permit. Learn about safer mosquito management and insect-borne diseases at Beyond Pesticides website pages. The bats inhabit the Insect Control District’s five towns, which are host to important feeding habitat for these creatures, as well as maternal roosting colonies where baby bats are born and raised during the months when the pesticides are typically sprayed. In addition, the nighttime spraying of these compounds along 190 miles of road in these communities hangs in the air for hours, putting nocturnally active bats — who fly through the toxic mist or consume insects contaminated with the chemicals — at risk. Mason Overstreet of Vermont […]

(Beyond Pesticides, March 17, 2021) Ultraviolet radiation (UV-C) applied at night can successfully kill powdery mildew in farm fields, providing a potential route to significantly reduce the use of toxic fungicides, new research published in the journal Plant Disease finds. “UV treatments applied once or twice weekly were as effective as the best available fungicides applied on similar schedules for control of strawberry powdery mildew,” study author Natalia Peres, PhD, of the University of Florida said. “It’s not a one-time fluke.” The results are encouraging, and have the potential of reducing fungal pressure through non-toxic means, but like all pest management tools should be used as part of a system the focuses first and foremost on fostering healthy soils and biodiversity.  Powdery mildew is a fungal pathogen that can infect a range of plants, from cucurbits to grapes, apples, onions, and cannabis. For the study, the primarily Florida-based researchers focused on the state’s $300 million strawberry industry. Powdery mildew is often facilitated by high humidity, and can be exacerbated when crops are grown in tunnels or other enclosed areas due to lack of airflow and poor ventilation. The fungus presents as a white powder on the surface of plant leaves, […]

(Beyond Pesticides, March 5, 2021) Pet owners will be alarmed to read the report, by USA Today, that a popular flea and tick collar — Seresto, developed by Bayer and sold by Elanco — has been linked to nearly 1,700 pet deaths, injuries to tens of thousands of animals, and harm to hundreds of people. At the time of publication, the U.S. Environmental Protection Agency (EPA), which regulates pesticides, had issued no informational alert to let the public know about these risks to pets — despite many hundreds of incident reports in its Office of Pesticide Programs Incident Report database. Beyond Pesticides and other advocates have warned of the toxicity of pet pesticide treatments, not only to the animals themselves, but also, to children and other household members. There are nontoxic ways to protect pets from fleas and other pests, and to protect human family members at the same time. Beyond Pesticides is calling on EPA to recognize, finally, that the label on flea collars is not adequately protective, as evidenced by the number of deaths and 75,000 incidents. “EPA has the authority to act now, and it should use its powers to protect the health and lives of pets,” […]

(Beyond Pesticides, March 3, 2021) Earlier this week, pesticide regulators in the commonwealth of Massachusetts voted to restrict outdoor consumer uses of neonicotinoid insecticides. The move is the result of sustained advocacy from broad coalition of individuals and organizations focused on protecting pollinators and ecosystem health. While advocates are pleased that the Pesticide Board Subcommittee made Massachusetts the first state in the country to restrict neonicotinoids through a regulatory process, they note this is only the first step in eliminating these hazardous insecticides. “This marks an incremental victory which took us 6 years to land, and it only happened because of immense, ongoing grassroots action and legislative allies who are willing to hold state regulators accountable,” said Martin Dagoberto, Policy Director of the Northeast Organic Farming Association, Mass. Chapter in a press release. “We still have a monumental endeavor ahead if we are to reduce toxins and rein in the toxic influence of the chemical lobby,” Mr. Dagoberto added. Advocates had been pushing the legislature to pass An Act to protect Massachusetts Pollinators, sponsored by pollinator champion Representative Carolyn Dykema, since 2014. Following several failures by state lawmakers to bring the bill over the finish line, efforts in 2019 resulted […]

(Beyond Pesticides, February 12, 2021) Being many decades down the path of chemical-intensive agriculture, growers and other land managers (and all the industries that influence them) have come largely to ignore the efficacy of healthy, functioning natural systems to maintain ecological equilibrium, i.e., not letting any one pest or disease proliferate. Recent research points to an example of such ecosystem efficacy. The study, by researchers in California and China, sought to evaluate whether increased population densities of fungi might be suppressing nematode populations in California production fields frequently planted with the cole crops (such as brussels sprouts and broccoli) they favor. The research finds that a diverse population of fungi in soils is highly likely to be effectively killing nematodes that threaten such crops. This is not the first time Beyond Pesticides has covered the potential of fungi as an effective control for agricultural pests. Thirty years ago, these nematodes were dealt with by application of soil fumigants and nematicides, because at sufficient population levels, the nematodes can destroy cole crops. During the following three decades, state-mandated monitoring showed that use of those chemical controls was diminishing and, by 2014, had been eliminated — even as yields rose. The co-authors […]

(Beyond Pesticides, December 8, 2020) Researchers at Oregon State University recently made a promising discovery that could significantly improve the ability for North American farmers and gardeners to manage invasive, crop damaging slugs. It isn’t a pesticide, but a nematode (Phasmarhabditis spp.), a microscopic animal whose phylum contains potentially millions of different species. Oregon State researchers think they’ve found the specific type of nematode that will parasitize and kill Deroceras reticulatum, also known as the grey garden slug. The research underscores the critical importance of funding and supporting research on biological controls and other non-toxic pest management approaches.   Researchers were keyed into the potential to use nematodes for slug biocontrol by a product that has been successfully used in Europe for over 25 years, known as Nemaslug. However, the product is not registered in the United States by the U.S. Environmental Protection Agency (EPA). “The thought process is that if it works in Europe and we find it here and it works here, it might be easier to get it registered by the EPA,” study coauthor Rory Mc Donnell, PhD, said. “If we can provide evidence it’s native, that makes a strong case for developing it as a bio-control. […]

(Beyond Pesticides, November 20, 2020) Many pet owners likely do not consider what is actually in the flea treatments they administer to their animals. That should change, and recent research demonstrates why. Scientists sampling rivers in England found extreme contamination with two neurotoxic pesticides commonly used in flea products for dogs and cats: fipronil and the neonicotinoid imidacloprid. In many instances, the concentrations in the waterways were far higher than accepted “safe” levels. Though these compounds are banned for agricultural uses in the United Kingdom (UK), risk assessment for them, as used on animals, has been minimal because of the assumption that the amounts used for veterinary treatments would mean far-less-significant environmental impact than might be expected with agricultural-scale use. This research out of the University of Sussex voids that assumption, and the researchers recommend “re-evaluation of the environmental risks posed by pet parasite products, and a reappraisal of the risk assessments that these products undergo prior to regulatory approval.”   Apart from being an active ingredient in flea treatments for pets, fipronil is used in insect baits, and in turf management and agriculture in the U.S. It is highly toxic to insects, including bees, to birds, and to aquatic invertebrates. […]

(Beyond Pesticides, September 16, 2020) Disease carrying mosquitoes are more likely to flourish in areas being altered by human activities, according to new research published by scientists at Oregon State University. With climate change facilitating the spread of mosquitoes into new regions throughout the world, it is critical to understand the drivers of mosquito-borne disease in order to establish effective mitigation measures. “People care a lot about what environment a lion needs to succeed in; we’ve researched that extensively. But people don’t do that with mosquitoes. We don’t understand them as a group of species and how their ecology differs between species,” said study co-author Brianna Beechler, PhD, a disease ecologist and assistant professor of research in Oregon State University’s Carlson College of Veterinary Medicine. Authors of the study note that most mosquito collection occurs opportunistically, with samples taken at known mosquito breeding sites. To better understand mosquito spatial ecology, scientists conducted paired sampling at locations inside and outside South Africa’s Kruger National Park, the largest nature preserve in the country. Each sample location inside the park was paired with another sample from a similar location (in terms of landscape and climatic conditions) in developing areas outside of the park. […]

(Beyond Pesticides, September 2, 2020) It’s being called the Monarch Massacre—hundreds of monarch butterflies found dead after the Vector Control Department of Cass County, North Dakota aerially sprayed the county for mosquito control. This incident occurred during a moment in history that is seeing monarchs at the edge of extinction, with the number of monarch butterflies overwintering in Mexico having declined 53% from last year, according to a count conducted by World Wildlife Fund (WWF) Mexico. This tragedy happened as the nation and the world are experiencing an insect apocalypse and severe biodiversity decline, threatening the web of life. (See Study Predicts Demise of Insects within Decades if Pesticide Dependence Continues.) While it is critical that steps be taken by communities nationwide to protect their local ecology, the incident generated a response from Cass County that claims that the insecticides used are “the lowest toxicity products on the market for mosquito control,” and points to the “monarch migration [that] is a sporadic event that unfortunately occurred during the latest adult mosquito control application.”  The County justifies the spraying because of nuisance mosquitoes and a finding in the “surrounding communities” of mosquitoes carrying West Nile virus (WNv). In its Facebook statement, the County […]

(Beyond Pesticides, August 4, 2020) Last month Massachusetts lawmakers finalized, and the Governor subsequently signed, emergency legislation S.2757, aimed at revamping the state’s approach to mosquito management. The final version of this mosquito reform bill continues to include certain problematic provisions, but nonetheless represents a significant shift from an initial proposal that would have allowed the blanket spraying of mosquito adulticides throughout the Commonwealth with little oversight, notification, or transparency. “Though many cooks had a hand in the process, the resulting final bill was strengthened by advocates,” said state Senator Jo Comerford, Chair of the state’s Joint Committee on Public Health, in an emailed statement to supporters. “I’m pleased that we were able to build in strong protections for both the environment and human health.” The original bill was filed by Massachusetts Governor Charlie Baker (R) under emergency legislative provisions, requiring state lawmakers to act within a set period of time. The Massachusetts Department of Public Health (DPH) had indicated that this year would bring higher risks of mosquito-borne disease, particularly Eastern Equine Encephalitis (EEE), for which outbreaks generally last two or three years. The state saw 12 human cases of EEE and four deaths from the disease in 2019; […]

(Beyond Pesticides, July 20, 2020) Does your community spray toxic pesticides for mosquitoes? In a well-intentioned but ill-informed attempt to prevent mosquito-borne illness such as West Nile virus, many communities spray insecticides (adulticides) designed to kill flying mosquitoes. If your community is one of these, then your public officials need to know that there is a better, more-effective, way to prevent mosquito breeding. Tell your public officials to stop spraying pesticides and adopt a mosquito management plan that protects public health and the environment. The problem with mosquito pesticides. Two classes of insecticides are favored by mosquito spray programs—organophosphates and synthetic pyrethroids. In order to better target flying mosquitoes, adulticides are generally applied as ultra-low-volume (ULV) formulations that will float in the air longer than usual.  Pesticides are toxic chemicals and can exacerbate respiratory illnesses like Covid-19.Organophosphates, which include malathion (Fyfanon), naled (Dibrom), and chlorpyrifos (Mosquitomist for public health uses only) are highly toxic pesticides that affect the central nervous, cardiovascular, and respiratory systems. Symptoms of poisoning in humans include numbness, tingling sensations, headache, dizziness, tremors, nausea, abdominal cramps, sweating, incoordination, blurred vision, difficulty breathing, slow heartbeat, loss of consciousness, incontinence, convulsions, and death. Some organophosphates have been linked to […]

(Beyond Pesticides, July 8, 2020) Efforts to control the transmission of malaria are encountering a big, though predictable, problem: the mosquitoes that transmit malaria are developing resistance to at least five of the insecticides that have been central to limiting transmission of the disease. A study released in late June reveals a dramatic increase in resistance to pyrethroid insecticides and DDT across sub-Saharan Africa. This signals the failure of a mainstay chemical approach to the spread of malarial mosquitoes; this same problem — resistance — is happening with chemical management of agricultural pests and weeds, and with antibiotics to treat human bacterial infections. This study underscores a point Beyond Pesticides has made repeatedly: resistance to pesticides (whether insecticides, herbicides, biocides, fungicides, or medical antibiotics) is nearly inevitable. The solution to containing the spread of malaria lies not in the use of more and different chemicals, but in nontoxic approaches that respect nature and ecological balance. Malaria is a sometimes deadly disease caused by female Anopheles mosquitoes infected with any of four varieties of the Plasmodium parasite. The disease kills roughly 400,000 people annually, with half that mortality in sub-Saharan Africa. The U.S. sees approximately 2,000 cases of malaria annually, primarily in […]

(Beyond Pesticides, June 5, 2020) Amidst the COVID-19 pandemic, Massachusetts is wrestling with solutions for mosquito-borne illnesses such as Eastern Equine Encephalitis (EEE) and West Nile Virus (WNV). A coalition consisting of national, state and local nonprofits, with the assistance of 75 legislators, won major amendments to emergency legislation sponsored by Governor Charles Baker, but the coalition seeks further refinements. As originally introduced, Gov. Baker’s bill (H.4650 – see original legislation and amended version) would have given state agencies overly broad authority to eradicate mosquitoes through unlimited pesticide applications, without local input or notification to communities and residents prior to aerial spraying.  It would have suspended all environmental safeguards whenever state officials determine that an elevated risk of arbovirus “may exist” in the future.  In response to input from 75 legislators, the Joint Committee on Public Health made significant improvements to the bill, including– Giving property owners 48-hour notification before a spray event; Providing public notice as to what chemical agents will be sprayed; and Sunset emergency powers within two years, and authorization of a comprehensive stakeholder-driven evaluation of how the Commonwealth deals with mosquito control. “We applaud lawmakers for significantly improving accountability and transparency, but more work is needed,” […]

(Beyond Pesticides, May 8, 2020) At the height of Covid-19 impacts in the Northeast U.S., Massachusetts Governor Charlie Baker (R) and Lieutenant Governor Karyn Polito (R) filed emergency legislation at the Boston State House that would, according to their April 16 press release, “help the Commonwealth more effectively combat diseases transmitted by mosquitoes, including arboviruses like Eastern Equine Encephalitis (EEE) and West Nile Virus (WNV), by authorizing a coordinated, proactive, statewide approach to mosquito control activities.” Protecting the public from such diseases is an important public health mission. However, the Governor’s bill, H.4650, represents an alarming “over-reach” that would give unitary authority to the State Reclamation and Mosquito Control Board (SRMCB) to conduct mosquito control activities, including ineffective and toxic spraying, with virtually no effective oversight or transparency. Beyond Pesticides opposes this bill, whose passage would enable use of pesticides that can have respiratory and immune impacts — increasing health risks for everyone, but especially for the many people already at higher risk from Covid-19, despite the availability of ecological management approaches that eliminate the need for toxic chemicals. H.4650, An Act to mitigate arbovirus in the Commonwealth — was promulgated in response to a Massachusetts Department of Public Health […]

(Beyond Pesticides, May 7, 2020) On April 22, 2020, the Ninth Circuit U.S. Court of Appeals granted the U.S. Environmental Protection Agency (EPA) 90 days to respond to Natural Resources Defense Council’s (NRDC) petition requesting cancellation of tetrachlorvinphos (TCVP), a toxic organophosphate pesticide in pet products. The order followed the Ninth Circuit’s decision to grant NRDC’s petition for a writ of mandamus (a court’s order requiring a lower court or public authority to perform its statutory duty) as EPA withheld action to fulfill NRDC’s judicial review of TCVP, for over a decade. A favorable ruling on NRDC’s mandamus petition can influence other petitioners that hope to coerce agency action, especially when public health is at risk. The court states, “Repeatedly, the EPA has kicked the can down the road and betrayed its prior assurances of timely action, even as it has acknowledged that the pesticide poses widespread, serious risks to the neurodevelopmental health of children.” NRDC petitioned EPA to cancel TCVP pesticide registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in April 2009, after studies indicated humans absorb TCVP through contact with pesticide-treated pet products. EPA failed to respond to the initial petition after five years, and NRDC filed a 2014 mandamus requiring […]

(Beyond Pesticides, January 14, 2020) Scientists have found a new method to reduce the sources of Lyme disease, but it is uncertain whether the finding will ultimately translate into fewer cases of human infections. Research published in the journal Experimental and Applied Acarology finds that incorporating Lyme vaccines into pelletized mouse food had the effect of reducing levels of Borrelia burgdorferi, the bacterium that causes Lyme disease, in both mice and ticks in a certain location. “So, the idea here is to vaccinate the mice,” study author Kirby Stafford, PhD told WBUR. “What we’ve done is incorporate a Lyme disease vaccine in an oral bait that would immunize them. That would prevent ticks feeding on those animals from becoming infected and then ultimately turn around and infect you.” To test their approach, researchers enrolled 32 homes in Redding, CT, an area where Lyme disease in endemic and several human cases are reported each year. Vaccine-incorporated mouse baiting stations were placed around 21 homes, while 11 acted as a control. Four times throughout the two year study period, mice and the ticks attached to them were trapped and tested for the disease. While there were no significant differences between the experimental […]

(Beyond Pesticides, January 7, 2020) It may seem peculiar at first sight, but painting zebra stripes on domestic cattle has the potential to significantly reduce the livestock industry’s use of toxic pesticides, according to research published last year by Japanese scientists at the Aichi Agricultural Research Center in Nagakute, Japan. Each year, farmers spend an estimated $1.6 billion on pesticides in the livestock industry, while biting flies cause over $2 billion of economic loss. This clever example of applied ecology could change those numbers with the added benefit of a safer environment.    While long considered a mystery, the science is now generally in agreement that zebras developed their stripes in order to confuse and ward off biting flies and the various ailments that can be passed on by the pests. While some cow breeds were developed with spotted patterns that may confer some fly deterrence, researchers used mono-colored Japanese Black cows to test their hypothesis. Six cows were separated into one of three groups: white and black stripes, black stripes, and an unpainted control. Stripes were painted with a water-based lacquer. The cows were observed starting 30 minutes after the paint was applied and allowed to air out. For […]

(Beyond Pesticides, September 24, 2019) In 2016, Canadians and Americans residing in Havana reported symptoms of headaches, dizziness, nausea. They described hearing strange buzzing and high-pitched sounds – some woke in the middle of the night fumbling for alarm clocks that were not going off. Media used the term “Havana syndrome” to describe the illness. Diplomats, scared by symptoms that seemed to only hit them in their hotel rooms or at home, speculated that a sonic weapon was being used against them. The Trump administration accused Cuban leaders of misconduct and removed all but essential employees. Later, some suspected that the diplomats could have experienced “mass hysteria.” A new Canadian study provides a more likely explanation to this mysterious illness that impacted diplomats in Havana: neurotoxic pesticide exposure. Researchers conducted testing on 14 individuals who had resided in Havana and a control group of 12 that had never lived there. Some of the experimental group had been recently exposed while others, tested 19 months after their return, were classified as “remotely exposed.” Tests included brain imaging and self-reported symptom questionnaires. They analyzed blood samples for routine biochemistry, kidney, liver, and metabolic functions. Individuals that showed symptoms of brain injury went […]

(Beyond Pesticides, July 10, 2019) The California Coastal Commission will host a public hearing today on a U.S. Fish and Wildlife Service (USFWS) proposal to drop 1.5 tons of the rodenticide brodifacoum, an extremely potent anticoagulant, on the Farallon Islands National Wildlife Refuge. The Los Angeles Times headline on July 7 read, “Biologists say it’s for the best.” At the least, it is important to highlight that all biologists have not come to a consensus and the topic is very much still under debate. The commission has already received over 700 emails regarding the drop, with 600 opposing it. Home to rare, endemic seabirds such as the ashy storm-petrel, the Farallon Islands certainly have a serious mouse problem – 59,000 rodents occupy the rocky islands. Mice compete with native species for resources and attract an average of six burrowing owls a year. Owls feast upon ashy storm-petrels when mouse populations drop during the winter, killing hundreds of petrels annually. The global population of the ashy storm-petrel is small (10,000 – 20,000), but it is not considered an endangered species. The Audubon Society in California, which supports the brodifacoum program, worked with experts who say the eradication of invasive mice is […]

(Beyond Pesticides, July 2, 2019) German cockroaches, the bane of many apartment-dwellers throughout the U.S., can rapidly develop cross-resistance to insecticides they have never been exposed to, according to researchers from Purdue University. “This is a previously unrealized challenge in cockroaches,” said Michael Scharf, PhD, whose findings were published in the journal Scientific Reports. “Cockroaches developing resistance to multiple classes of insecticides at once will make controlling these pests almost impossible with chemicals alone.” In the face of pesticide resistance, integrated measures that focus structural, mechanical, and cultural pest management practices must become standard practice for this notorious pest. Dr. Scharf and his colleagues began their study at two separate housing complexes in Indianapolis, IN and Danville, IL. Prior to the study, researchers pre-treated a subset of cockroaches in each building, and selected five insecticides out of 14 commercially available. These insecticides – abamectin, pyriproxyfen, thiamethoxam, lambda-cyhalothrin, and boric acid, were used because cockroaches had already developed significant resistance to others tested, mostly synthetic pyrethroids. Pre-treatment applications of synthetic pyrethroids revealed over 80% of cockroaches surviving. For the insecticides left with any level of efficacy, researchers established three separate treatment approaches, and stuck with it for six months, with one […]

(Beyond Pesticides, June 6, 2019) Pesticide use eliminates pest predators and permits mosquito populations to flourish, according to research conducted in Costa Rica by scientists at Utah State University. The new study, “Adaptation to agricultural pesticides may allow mosquitoes to avoid predators and colonize novel ecosystems,” highlights the dangers of human intervention through broad scale pesticide applications, and the urgent need to consider ecosystem-wide impacts before allowing chemicals to be placed on the market. As lead study author Edd Hammill, PhD, told National Geographic, the investigation got its start after he observed higher numbers of mosquitoes in orange groves he was visiting, when compared to other, non-agricultural areas. “We felt like we were getting a lot more mosquito bites in plantations than in pristine areas and started to wonder why,” noted Dr. Hammill. The study focuses first on the role that bromeliads, a tropical flowering plant that grows on tree branches, play in affecting mosquito populations. Mosquitoes use the water that these plants catch in between their leaves to lay eggs. Many other species are found to lay eggs within the leaves, including the top-level predator in this system, the damselfly. Dr. Hammill’s team looked at community composition within bromeliad […]

(Beyond Pesticides, January, 30, 2019) Bug bombs are completely ineffective at reducing German cockroach infestations, according to new research published in the journal BMC Public Health.  Not only are they ineffective, research indicates that these products are putting people at unnecessary risk. “In a cost-benefit analysis, you’re getting all costs and no benefits,” said Zachary DeVries, PhD, co-author of the study. “Bug bombs are not killing cockroaches; they’re putting pesticides in places where the cockroaches aren’t; they’re not putting pesticides in places where cockroaches are and they’re increasing pesticide levels in the home.” Scientists enrolled residents in 30 low-income apartments that had ongoing German cockroach infestations. Of the 30 homes, 20 were treated with a name-brand total release fogger (TRF), or bug bomb, and and 10 were treated only with gel baits. Baseline pesticide residue levels were recorded in all residences, and new data was collected after use of the bug bombs. Bug bombs were set off in each infested apartment’s kitchen, according to EPA label precautions. Residents waited 4-6 hours before ventilating and returning to their homes. In apartments receiving baiting gel treatments, the products were applied three times on an as-needed basis during the course of a month. […]