(Beyond Pesticides, January 5, 2016) An administrative court judge has agreed to hear a case filed by a U.S. Department of Agriculture (USDA) pollinator researcher who says his  firing by the agency  was retaliation for his  cutting edge research  linking neonicotinoid insecticides to declinining monarch butterfly populations, which  has drawn  national attention and international recognition. Late last year, Judge Patricia M. Miller of the Merit Systems Protection Board denied USDA’s request to dismiss a claim filed  by Johnathan Lundgren, PhD, a USDA employee for eleven years with high accolades. In April of last year, Dr. Lundgren published a study in The Science of Nature (pdf) that shows that clothianidin, a neonicotinoid insecticide  often used to coat seeds, kills monarch butterfly larvae in the laboratory. On August 3, 2015, USDA imposed a 14-day suspension against Dr. Lundgren for submitting the study and for a paperwork error in his travel authorization for his invited presentation about his research to a panel of the National Academy of Sciences, as well as to a USDA stakeholder group, the Pennsylvania No-Till Alliance. The suspension was cut to 14 days from 30 after Dr. Lundgren filed an appeal. In October 2015, Dr. Lundgren, respresented by Public […]

(Beyond Pesticides, December 23, 2015) Native  bees are on the decline in some of the major agricultural regions in the United States, according to a new study. The study scientists produced the first national map of bee populations and identified numerous trouble areas. Since 2006, honey bees and other pollinators in the U.S. and throughout the world have experienced ongoing and rapid population declines. The continuation of this crisis threatens the stability of ecosystems, the economy, and food supply, as one in three bites of food are dependent on pollinator services. The study, titled Modeling the status, trends, and impacts of wild bee abundance in the United States  and published in the journal Proceedings of the Natural Academy of Science, for the first time aims to assess the status and trends of wild bees and their potential impacts on pollination services across the U.S. and found that between 2008 and 2013 bee abundance declined across 23% of the nation’s  land area. The decline is generally associated with conversion of natural habitats to row crops. The researchers also list pesticide use, climate change, and disease as other threats to wild bees. The researchers specifically cited 139 counties as especially worrisome, with […]

(Beyond Pesticides, December 15, 2015) Last week Montreal, the largest city in Canada’s Quebec province, announced plans for an all-out ban on the use of bee-toxic neonicotinoid pesticides. The new regulations represent the strongest move against this neurotoxic class of insecticides by any government entity to date. Environmental and health advocates are praising the ban as a sign that more and more localities in North America are finding these chemicals unnecessary to manage pest problems, and not worth the risk to pollinators and other wildlife. Montreal’s regulations provide for a complete ban, “without exception,” on the use of neonicotinoids outside of buildings on City land. Prior to the new rules, private citizens and businesses could obtain a temporary permit for the use of neonicotinoids in the  case  of an infestation, however, the permit will no longer be available and citizens will be encouraged to employ alternative practices or products. The ban will also apply to golf courses and properties in the City used for agricultural and horticultural purposes. “By adopting a regulation that prohibits the use of such pesticides in Montreal, our Administration places the health of its citizens, the quality of life of its neighborhoods and the preservation of […]

(Beyond Pesticides, December 4, 2015) Home Depot, the world’s largest home-improvement chain, has announced that it will no longer use  neonicotinoid (neonic) pesticides (which have emerged as the leading class of pesticides responsible for bee declines) in  80 percent of its flowering plants, and that it will complete its phase-out in plants by 2018. This follows the announcement made by Lowe’s earlier this year to phase out the sale of products containing neonicotinoid pesticides within 48 months. On its Eco Options gardening page, Home Depot says the following: “Our live goods suppliers have reduced the number of plants that they treat with neonicotinoids, so that now over 80% of our flowering plants are not treated HomeDepotWinBPwith neonicotinoids. We will continue this decrease unless,  1) it is required by state or federal regulation, or  2) undisputed science proves that the use of neonicotinoids on our live goods does not have a lethal or sub lethal effect on pollinators. Otherwise we will have a complete phase-out of neonicotinoid use on our live goods by the end of 2018.” “It’s important that retailers begin to make the switch toward safer products for bees, butterflies, and other beneficial insects,” said Jay Feldman, executive director […]

(Beyond Pesticides, December 3, 2015) Last month, the European Commission and member states approved the new pesticide flupyradifurone. The department, known as Directorate-General for Health and Food Safety, authorized the approval of the pesticide, which is an insecticide in  the chemical class  butenolides. Bayer Crop Sciences, the creator of flupyradifurone, touts the insecticide as a “safe” alternative to neonicotinoids (neonics), although both neonics and butenolides are systemic, persistent, and acutely toxic to adult honey bees. Already launched in the United States, Mexico, Nicaragua, Guatemala, Honduras, and the Dominican Republic, advocates are pointing to the hasty nature of flupyradifurone’s approval and the lack of scientific research supporting its use. Flupyradifurone, marketed as “Sivanto prime” in Europe, is approved for use in the EU on sucking pests that feed on fruits and vegetables as well as specialty crops such as hops.  It is also approved for use in seed coatings. The chemical is neurotoxic and can inhibit nicotinic acetylcholine receptors (nAChR) in the nervous system. Neonicotinoids, widely  criticized for their harmful effects on bees,  affect the nervous system in the same way. Matthias Haas, Ph.D., Global Project Manager at Bayer CropScience says, “It combines efficacy and convenience for the grower with excellent […]

(Beyond Pesticides, November 30, 2015) Last week, two studies were published that link neonicotinoid (neonic) insecticide exposure to detrimental effects in bees and butterflies. The first study, published in the international scientific journal Nature, found that bumblebees exposed to neonics suffered pollination services impairment that reduces their delivery to apple crops. The second study, published in the United Kingdom journal Peer J, used over 1,000 sites cataloged from 1984 to 2012 in the UK Butterfly Monitoring Scheme (UKBMS) database to point to the strong association between neonic use and butterfly population decline. These studies contribute to the mounting evidence that neonic insecticides are linked to pollinator decline. Neonics have increasingly been the subject of recent studies that highlight a causal relationship between neonic exposure  and harmful effects to pollinators, like foraging and reproductive complications. These effects are being identified by scientists all over the world, gradually negating industry criticism of study design. Andre Gilburn, PhD, and ecologist at the University of Stirling, led the butterfly study. He said, “Our study not only identifies a worrying link between the use of neonicotinoids and declines in butterflies, but also suggests that the strength of their impact on many species could be huge.” […]

(Beyond Pesticides, November 24, 2015) The Canadian province of Quebec has announced plans for a major overhaul of its pesticide laws in order to protect pollinators, public health and the wider environment. Canadian provinces, particularly Quebec and Ontario, have long led the way in crafting common sense pesticide legislation that responds to sound science on the dangers of these chemicals. The proposed reforms will focus on further restricting the most toxic pesticides allowed for use in both agriculture and residential pest control, including atrazine, chlorpyrifos, and the neonicotinoid class of insecticides, which are  widely implicated in pollinator declines. “Québec has made progress in recent years with respect to responsible pesticide management,” said the Quebec Minister of Sustainable Development, Environment and the Fight Against Climate Change. “However, the time is  right to intensify our efforts and become even more proficient at reducing the risks to health and the environment that are associated with pesticide use, particularly by supervising the use of highest-risk pesticides like neonicotinoids, which have a recognized major effect on bee mortality.” Quebec’s Pesticide Strategy 2015-2018  is structured  to incentivize farmers and home gardeners to choose lower risk pesticides through economic motivators such as levies, permits, and compensation fees. […]

(Beyond Pesticides, November 19, 2015) French scientists say that they have found the “missing link” between laboratory studies and field studies that assess the adverse effects of neonicotinoid (neonic) insecticides on bees. The study, published in Royal Society Journal Proceedings B, evaluates the effects of neonics on honey bees in field trials. After 15 years of research into the effects of neonicotinoids on bees, researchers had identified a gap between the results of toxicity assessments on individual bees in the laboratory and  impacts seen at the colony level in the field. The new two-year study made two discoveries: First, they found that field exposure to thiamethoxam combined with imidacloprid contamination is associated with a significant excess mortality in individual free-ranging bees.  Second, while colonies appeared to be able to compensate for the excess mortality and preserve population size and honey production, this was done at the expense of a change in brood laying patterns. Thus, this study provides an explanation for the “missing link” in the discrepancies between labs studies and field studies, where the former establishes harmful and fatal effects that had yet to be replicated in real-life conditions. Because the bees responded to the increased mortality with selective […]

(Beyond Pesticides, November 19, 2015) Thanksgiving offers an opportunity for family and friends to eat, drink and be thankful for the bounty of the organic harvest. Unfortunately, conventional Thanksgiving meals are more common, which include a host of pesticides, genetically engineered foods, and can affect  the health of consumers and agricultural workers alike. Read below to find out why now, more than ever, it’s important to go organic, and how you can combat the shortcomings of conventional agriculture with an organic Thanksgiving Day feast. Now, more than ever, it’s important to go organic. The most widely used weedkiller, glyphosate, has been classified as a probable carcinogen to humans, based on laboratory animal studies. Glyphosate, produced and sold as Roundup by Monsanto, is touted as a “low toxicity” chemical and “safer” than other chemicals by EPA and industry and is widely used in food production and on lawns, gardens, parks, and children’s playing fields. However, IARC’s recent classification of glyphosate as a Group 2A “probable” carcinogen finds that glyphosate is anything but safe. According to IARC, Group 2A means that the chemical is probably carcinogenic to humans based on sufficient evidence of carcinogenicity in experimental animals. The agency also notes that […]

(Beyond Pesticides, November 16, 2015) Bayer CropScience, the manufacturer of neonicotinoid pesticides that are linked to severe decline in pollinator populations, is expected to pay fines to multiple countries in Europe for wine grape damages associated with another of its pesticides. Citing “atypical symptoms” resulting from the use of a relatively new fungicide, Bayer initially sent out a warning to wine growers to cease use of their product. Now, Bayer is collecting data and assessing how much it will offer to wine growers for the damages its product has caused. European grape growers, including vineyards in Austria, France, Germany, Italy, Luxembourg and Switzerland, have reported deformed leaves and lower yields after using Moon Privilege, also known as Luna Privilege in some markets, from the German company’s CropScience unit. In Switzerland, losses are estimated at 80 million Swiss francs ($83.73 million), as reported by marketing group Swiss Wine to Reuters. Swiss Wine’s general secretary estimates harvest losses totaling 6.65 million kilos (14 million pounds) of grapes in 2015, or about  4.85 percent of 2014’s crop. It is also estimated that wine makers have lost approximately six million bottles of wine, with  Pinot Noir grapes and Chasselas, a white wine grape, hardest […]

(Beyond Pesticides, November 12, 2015) The U.S. Geological Survey (USGS) recently performed the first-ever study of pesticide residues on native bee populations and found that they are exposed to neonicotinoid insecticides, as well as other pesticides, at significant rates. This study digs deeper into a question  that was previously considered by a researcher who  studied chemical-intensive  apple orchards and linked a steep decline in wild or native bees to the application of pesticides. The USGS study  broadens understanding about the effects of toxic pesticides to native bee species, expanding field research that has principally focused on managed honey bee populations. The study tested for 122 different pesticides including bifenthrin, atrazine and chlorpyrifos, a chemical for which the U.S. Environmental Protection Agency (EPA) recently proposed to revoke all food tolerances in response to  a court-ordered deadline. According to study findings, 72% of bees tested positive for pesticide residues, raising concerns for the potential for unintended pesticides exposures where land uses overlap or are in proximity to one another.   Residues of pesticides found in bees in the study include  thiamethoxam, clothianidin, and imidacloprid, all of which are highly toxic neonicotinoids, a class of chemicals that have been linked to the global […]

(Beyond Pesticides, November 05, 2015) Research  at  the University of California, Davis finds  that hedgerows, a line of shrubs and trees that form a boundary at the edges of farm fields, improve a farm’s ecology and reduce the need for pesticides. Hedgerows serve many other beneficial functions; they can provide ornamental and aesthetic value, sequester carbon, and be a source of food, and more. There is also evidence that they can be an effective barrier against spray drift, reduce soil erosion, and act as habitat corridors for forest plants in agricultural landscapes.  Hedgerows support biodiversity in the face of habitat decline, given fence row to fence row cultivation practices in agriculture, manicured lawns and landscapes, urban sprawl, and the use of broad spectrum pesticides that threaten the diverse organisms that make up a healthy ecosystem. Rachael Long, M.S., a farm advisor for the UC Cooperative Extension, tells Capital Public Radio, “We have Christmas berries, and  elderberry — which has these beautiful blueberries that a lot of birds really like. We have redbud which has terrifically bright red flowers in the spring. And also ceanothus which is California lilac which has blue flowers in the spring.” She adds that birds and […]

(Beyond Pesticides, October 29, 2015) One of the top entomologists at the U.S. Department of Agriculture (USDA) filed a whistleblower complaint against a  federal agency, citing unprofessional retaliation following the publication of a study linking neonicotinoid insecticides to the decline of monarch butterflies. Jonathan Lundgren, Ph.D., Senior Research Entomologist and Lab Supervisor for the Agricultural Research Service (ARS) in South Dakota, is fighting suspension for publishing research deemed “sensitive” by his USDA superiors. According to Jeff Ruch, executive director of Public Employees for Environmental Responsibility (PEER), which is providing legal services to Dr. Lundgren, this case underscores why legal protections for government scientists are sorely needed. Until recently, Dr. Lundgren worked for USDA for eleven years with great success, and his cutting edge research has drawn national attention and international recognition. In April of this year, Dr. Lundgren published a study in The Science of Nature that shows that clothianidin, a neonicotinoid seed treatment, kills monarch butterfly larvae in the laboratory. On August 3, 2015, USDA imposed a 14-day suspension against Dr. Lundgren for submitting the Science of Nature study and for a paperwork error in his travel authorization for his invited presentation about his research to a panel of […]

(Beyond Pesticides, October 28, 2015) On the heels of a recent federal court decision that rejected the U.S. registration of sulfoxaflor, which cited inadequate and flawed review of the science on the chemical’s toxicity to bees, European beekeepers filed complaint that that asks the European Court of Justice to take the same action. The complaint  asks the court to cancel sulfoxaflor’s authorization. Sulfoxaflor is a neonicotinoid-like chemical that, like neonicotinoids, is highly toxic to bees. Three of the most widely used neonicotinoids are currently under a two-year European-wide moratorium which began December 2013, due to concerns about risks to bee populations. European beekeepers, Bee Life European Beekeeping Coordination, the Italian National Beekeeping Union (UNAAPI), and PAN Europe, filed the complaint which cites a published  negative opinion on Dow AgroScience’s sulfoxaflor by the European Food Safety Authority (EFSA). According to EFSA, the pesticide is categorized as ”˜highly toxic to bees’ and it identified crucial toxicity data gaps, which according to the beekeepers, makes a proper risk assessment for bees impossible. Despite these facts, the European Commission’s Directorate-General for Health and Food Safety (DG Sante) and the EU member states authorized sulfoxaflor in July 2015, completely bypassing the pesticide regulation, the complaint […]

(Beyond Pesticides, October 26, 2015) Last week, Pop Weaver, the second largest popcorn supplier in the country, released an official statement on its commitment to “removing 50 percent of its neonicotinoid usage in 2016, 75 percent in 2017, with a long-term commitment of further reducing usage by working with agricultural universities and those companies supplying neonicotinoids to the seed industry.” Widely-used neonicotinoids (neonics), which as systemic chemicals move through a plant’s vascular system and express poison through pollen, nectar, and guttation droplets, have been identified in multiple  peer-reviewed studies  and by beekeepers  as the major contributing factor in bee decline. This commitment is a response to a campaign led by Center for Food Safety (CFS), which asked citizens to sign a petition asking Pop Weaver, and other large popcorn suppliers, to protect bees and other pollinators by phasing out the use of neonicotinoid-coated corn seed. Over 37,000 people have signed their petition. Americans eat, on average, 17.3 billion quarts of popcorn each year; each American eats about 68 quarts. According to CFS, there are roughly 40 insecticides currently registered for use as an active chemical on popcorn, including 3 bee-toxic neonicotinoid chemicals: clothianidin, thiamethoxam, and imidacloprid. Between  79 and 100 […]

(Beyond Pesticides, October 22, 2015) With increasing consumer concern about genetically engineered (GE) food, yesterday  the U.S. Senate Committee on Agriculture, Nutrition, and Forestry held a hearing,  entitled Agriculture Biotechnology: a Look at Federal Regulation and Stakeholder Perspectives, that critics called lopsided. Most witnesses characterized GE food as safe or side-stepped the issue of safety, as government witnesses refused to distinguish GE from conventional food and opposed food labeling. “This is the first time in 10 years we’ve had a hearing on biotech. I guess we’re a little late, but we’re here,” said chair of the committee, Senator Pat Roberts (R-KS). The ranking  minority member of the committee, Senator  Debbie Stabenow (D-MI)  said,  “Biotechnology is proven to be safe, beneficial, and I believe will play a major role in helping to solve these dual global challenges of climate change and global food security,” Central to the hearing is the the issue of labeling food products containing GE crops. Senator Stabenow called for the adoption of legislation on GE food labeling, presumably with language that will preempt the authority of states to adopt more stringent labeling standards. Senator Stabenow said that she wants labeling that “doesn’t stigmatize biotechnology.” The GE food […]

(Beyond Pesticides, October 20, 2015) Exposure to neonicotinoid (neonic) pesticides results in profound negative impacts to the health of honey bee queens, according to an international team of researchers led by Geoff Williams, MD, PhD, at the University of Bern in Switzerland. While most studies to date have investigated how neonics effect the health of individual workers or overall colony fitness, Dr. William’s study, Neonicotinoid pesticides severely affect honey bee queens, is one of the first to focus on the health of honey bee queens. Neither the European Union nor U.S. Environmental Protection Agency (EPA) study the impacts of pesticides on queen health before allowing a pesticide to market. The results of this research are particularly concerning, given widespread anecdotal evidence from beekeepers across the globe that ”˜poor quality queens’ are playing a role in bee declines. To test the impacts of these chemicals on queen honey bees, scientists exposed a sample of 29 queens to field-realistic levels of the neonics  clothianidian and thiamethoxam (1 parts per billion and 4 ppb respectively), and compared them to a population of 28 control queens, which were not treated with neonics. Both groups experienced similar environmental circumstances in terms of food availability, rearing […]

(Beyond Pesticides, October 15, 2015) A new study, published in Environmental Science & Technology, has found that wildflowers bordering fields that are treated with neonicotinoids contain a higher concentration of the bee-toxic pesticides than the actual treated fields, pointing out an often overlooked avenue of exposure for bees. Widely-used neonicotinoids, which as systemic chemicals move through a plant’s vascular system and express poison through pollen, nectar, and guttation droplets, have been identified in multiple  peer-reviewed studies  and by beekeepers  as the major contributing factor in bee decline. The study, titled Neonicotinoid Residues in Wildflowers, A Potential Route of Chronic Exposure for Bees, discovered neonicotinoid insecticides in wildflowers, including Hogweed and Poppy pollen (up to 86ppb and 64ppb, respectively). The study’s authors  found higher concentrations of neonicotinoids in wild flowers in field margins than in Oilseed rape flowers in the adjacent neonicotinoid treated crop — on average 15ppb vs. 3ppb.   They also found that more than 97% of the neonicotinoids being brought into the hive by honey bees are from wildflowers, while only 3% are  from the crop. Researchers have found  that chronic exposure to neonicotinoids increases neuronal vulnerability to mitochondrial dysfunction in the bumblebee. In other words, these pesticides […]

(Beyond Pesticides, October 1, 2015) Now is your chance to show off both your green thumbs and your photography skills: if you use a sign to designate your yard, park, garden or other space as pesticide-free, we want to see it! We would love to see how you are using your signs, whether it is our honey bee, ladybug, or your own creative one. If you don’t already have a sign, we encourage you to put one up and use its presence to spark a conversation in your community about the use of pesticides. One yard at a time, we can transition towards a safer future without the hazards associated with unnecessary pesticide use. Your Work in the Spotlight! Send your best photo of your Pesticide-Free Zone to [email protected]! We will choose four grand prize photographs (Best overall, best sign featuring a child, best sign featuring wildlife, and best sign on an environmentally sensitive area), and 8 runners up to be featured in our 2016 Calendar! Staff picks and other select photos will also be highlighted on Beyond Pesticides’ Facebook and Twitter pages throughout the month of October. Each photo must include a Pesticide-Free Zone sign (it can be either […]

(Beyond Pesticides, September 25, 2015) Neonicotinoid-treated seeds do not reduce crop damage from pests, adding to a growing body of evidence questioning the benefits of using these bee-toxic insecticides, according to a study  published in the journal BioOne. Widely-used neonicotinoids (neonics), which as systemic chemicals move through a plant’s vascular system and express poison through pollen, nectar, and guttation droplets, have been identified in multiple  peer-reviewed studies and by beekeepers  as the major contributing factor in bee decline. The study,  titled Impact of Western Bean Cutworm (Lepidoptera: Noctuidae) Infestation and Insecticide Treatments on Damage and Marketable Yield of Michigan Dry Beans, examines the relationship between western bean cutworm infestation and damage in dry beans, and the use of seeds treated with the neonicotinoid thiamethoxam, as well as soil treated with aldicarb, another systemic insecticide. Researchers have concluded that neither thiamethoxam nor aldicarb reduced cutworm damage. In fact, plots treated with these insecticides had a higher percentage of defects due to feeding by pests when compared to untreated plots, which researchers believed is  attributable to factors such as fewer natural enemies. There have been additional reports and studies published over the past few years questioning the benefits of neonic use. In […]

(Beyond Pesticides, September 18, 2015) Glyphosate’s harmful effects continue to accumulate, this time with evidence pointing to toxic and sublethal effects on bees. According to a new study conducted by German and Argentinian researchers, honey bees exposed to low levels of glyphosate have a hard time returning home. Glyphosate, the  controversial and toxic active ingredient in Monsanto’s Roundup, is an herbicide widely used on genetically-engineered (GE) crops as well as on parks and golf courses, for control of weeds and grasses. Along with neonicotinoids, which have been linked to worldwide bee decline by a growing body of science, glyphosate is just another chemical in the toxic mixture that bees and other non-target organisms are constantly exposed to in the environment. In the study, titled “Effects of sublethal doses of glyphosate on honeybee navigation” and published in the Journal of Experimental Biology, researchers evaluate the effects of recommended concentrations of glyphosate used in agricultural settings on honey bee navigation and found that a single exposure to a concentration of glyphosate within this range delays the return of the foraging honey bee to the hive. Flight trajectories were also affected after successive exposure to the herbicide, suggesting that the spatial learning process […]

(Beyond Pesticides, September 16, 2015) In a letter posted to the federal docket, the U.S. Department of Agriculture (USDA) states that it is opposed to U.S. Environmental Protection Agency’s (EPA) recent proposal to restrict pesticides highly toxic to bees on sites where managed bees are present, saying the measure “has not established the need for such a prohibition.” In its position, USDA  cites economic impacts to farmers and lack of a cost/benefit analysis. USDA’s critique of EPA’s proposal contrasts with a decision handed down last week by a federal court that ruled EPA should not ignore risk concerns for bees and rejected the registration of a pesticide known to be highly toxic to bees, highlighting a lack of collaboration and understanding between federal agencies in advancing  pollinator protection. USDA communicated its challenge to EPA despite the growing body of science on the hazards of neonicotinoid insecticides and findings in Europe that their restriction does not undermine crop productivity. Last May,  EPA announced a new proposal  to temporarily prohibit foliar applications of pesticides that are acutely toxic to bees during plant bloom and when managed bees are on site and under contract. The proposal received a mixed response, with many from […]

(Beyond Pesticides, September 11, 2015) On Thursday, the Ninth Circuit Court of Appeals unequivocally rejected the U.S. Environmental Protection Agency’s (EPA) unconditional registration of the systemic and bee-toxic pesticide sulfoxaflor. The Court concluded that EPA violated federal law and its own regulations when it approved sulfoxaflor without reliable studies regarding the impact that the insecticide would have on honey bee colonies. The Court vacated EPA’s unconditional registration of the chemical, meaning that sulfoxaflor may no longer be used in the U.S. However, while the decision is good news for now, it still leaves the door open for sulfoxaflor’s future use once EPA obtains the necessary information regarding impacts to honey bees and re-approves the insecticide in accordance with law. The case is Pollinator Stewardship Council, American Honey Producers Association, National Honey Bee Advisory Board, American Beekeeping Federation, Thomas Smith, Bret Adee, Jeff Anderson v. U.S. EPA (9th Circuit U.S. Court of Appeals,  No. 13-7234). Dow AgroSciences (a Dow Chemical company)  joined  the case as an intervenor to support EPA. EPA initially proposed to conditionally register sulfoxaflor and requested additional studies to address gaps in the data regarding the pesticide’s effects on bees. A few months later, however, EPA unconditionally registered […]