(Beyond Pesticides, February 10, 2023) The U.S. Environmental Protection Agency (EPA) announced, on February 1, new measures to protect 28 endangered salmon species (including steelhead trout) from the use of four pesticides that threaten them and their critical habitats. Those compounds comprise three herbicides — metolachlor, bromoxynil, and prometryn, and one soil fumigant, 1,3-Dichloropropene. The protections, aimed at salmon populations in Washington, Oregon, and California, are meant to reduce impacts from pesticide runoff and spray drift, and to minimize potential “take.” (Under the Endangered Species Act (ESA), “take” means, essentially, the unintentional harming or killing of an individual of a protected species — in this case, harm or death from exposures to these toxic pesticide compounds.) Beyond Pesticides and other advocates have for years warned that multiple pesticides are threats to Northwest salmon and other species at risk. This EPA announcement is the second of two, recently, that offer slight redress to the agency’s historical failures to act (see more below). Indeed, advocates have engaged in multiple litigation efforts over the years to try to force EPA to take action; EarthJustice in 2001 noted some early instances. As Chemical and Engineering News says pointedly, “Environmental groups, which have been suing […]

(Beyond Pesticides, June 28, 2022) There is a strong connection between pesticide use and cancer rates in the Western United States, finds research recently published by scientists at University of Idaho and Northern Arizona University. Two studies (here and here) published in the peer-reviewed journal GeoHealth used geospatial data and publicly available pesticide databases to uncover the relationship between chemical heavy agricultural practices and cancer in both adults and children. As the rate of chronic diseases like cancer continue to increase in the United States, and more and more studies find these diseases to be pesticide-induced, it is imperative for the public to put increased pressure on regulators and lawmakers to enact meaningful measures that eliminate pesticide use and the hazards these chemicals pose. Of the two studies conducted by the research team, the first study modeled the connection between pesticide use and cancer incidence for adults and children in 11 western states (Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming), while the second study focuses on childhood cancer rates in Idaho’s 44 counties. Both studies utilized databases established by public entities, including U.S. Geological Survey (USGS) Pesticide National Synthesis Project database, EPA Pesticide Industry […]

(Beyond Pesticides, July 16, 2021) Recently published research reviews the 2013 Wilsonville, Oregon mass bumblebee die-off from application of the neonicotinoid dinotefuran on 55 linden trees in a big-box-store parking lot. In that single event, the research paper (published in Environmental Entomology) estimates between 45,830 and 107,470 bumblebees from some 289–596 colonies were killed. Reporting on the new study, by Entomology Today, quotes primary conclusions of the co-authors: “Our study underscores the lethal impact of the neonicotinoid pesticide dinotefuran on pollinating insect populations,” and, “It is likely that the vast majority of mass pesticide kills of beneficial insects across other environments go unnoticed and unreported.” As Beyond Pesticides has chronicled, the U.S. and the world are undergoing a pollinator crisis, caused in significant part by agricultural pesticides. Dinotefuran, the neonicotinoid (neonic) that killed those Oregon bumblebees, is used against fleas, thrips, tree-boring caterpillars, emerald ash borers, hemlock woolly adelgids, and in the Oregon case, aphids. Entomology Today (ET) notes that the timing of this particular application could not have been worse: it happened on a warm day when the linden trees were in full flower and the bees out in force. Ironically, it occurred during Nation Pollinator Week. ET pens a […]

(Beyond Pesticides, July 7, 2021) Organic food consumption among children is associated with higher scores on tests measuring fluid intelligence and working memory, research published in the journal Environmental Pollution finds. The study, conducted by Spanish researchers based at the Barcelona Institute for Global Health, took an exposome approach to environmental exposures, looking at a totality of all environmental hazards that children encounter, rather than investigating individual lifestyle factors one by one. As study co-author Jordi Júlvez, PhD, notes, “healthy diets, including organic diets, are richer than fast food diets in nutrients necessary for the brain, such as fatty acids, vitamins and antioxidants, which together may enhance cognitive function in childhood.” Researchers began their study by selecting mother-child pairs enrolled in the Human Early-Life Exposome (HELIX) Project, a pan-European study with projects in multiple European countries. Nearly 1,300 healthy children aged 6-11 were included in the study, as researchers already had pregnancy data and urine samples stored on the participants. To determine other environmental exposures, home addresses were evaluated for their level of pollution and proximity to natural spaces, and children and their mothers were given tests that included a questionnaire on lifestyle factors, including parents smoking and alcohol use, […]

(Beyond Pesticides, March 11, 2021) A Portland State University (PSU) study finds that pesticides from the forestry industry threaten clams, mussels, oysters (bivalves) along the Oregon state coast. Bivalves are excellent indicator species, signaling environmental contamination through their sedimentary, filter-feeding diet. However, continuous pesticide inputs—from various forestry management regimes—into watersheds along Oregon’s coastal zone endanger these species in downstream rivers and estuaries (river mouths). Although research demonstrates many forestry practices (e.g.., road building, planting, clearcutting, thinning) have cumulative effects on the ecosystem, there is a lack of studies addressing the overall impact of multiple chemical mixtures and application on watersheds and subsequent aquatic transport. Like agriculture, conventional forest management across the U.S. depends on the use of toxic pesticides to control pest populations. However, pesticide residues from application drift, runoff, and contamination continuously jeopardize the health and fitness of various non-target species, including humans. Marine ecosystem pollution is difficult to track and measure, and forestry pesticide regulations can invoke variations in water quality requirements through discrepancies in buffer zones and application concentrations. Therefore, studies like this can help guide future forest management practices to reduce the number of chemicals entering aquatic ecosystems. Researchers in the study note, “These findings highlight the need to […]

(Beyond Pesticides, October 4, 2019) A Circuit Court judge in Lincoln County, Oregon has overturned a hard-won ban on aerial spraying of pesticides, citing preemption of state law over any local ordinance. In her late-September decision, Judge Sheryl Bachart wrote that Oregon’s Pesticide Control Act “expressly and conclusively displaces any local ordinance regarding pesticide use. The intention of the legislature is apparent and unambiguous.” She noted in her opinion that the Oregon Revised Statutes (the codified laws of the state of Oregon), Chapter 634.057 “prohibits local governments from making any ordinance, rule or regulation governing pesticide sale or use.” Voters in the county approved the subject ban on the aerial spraying of pesticides (Measure 21-177) in 2017, the initiative having been spurred by the work of Lincoln County Community Rights (LCCR), a grassroots organization that “seeks to educate and empower people to exercise their right of local community self-government in matters that pertain to their fundamental rights, their natural environment, their quality of life, their health and their safety.” In its advocacy for the initiative, the group cited both the harm done by aerial pesticide spraying to people and ecosystems, and the injustice of laws — often drafted by corporations for approval […]

(Beyond Pesticides, May 16, 2019)  Use of the tree-killing herbicide aminocyclopyrachlor (ACP) is now restricted in Oregon, according to rulemaking finalized last week by the state’s department of agriculture (ODA). While an important step in the right direction, many environmentalists are perplexed by the state’s decision not to proceed with a ban on all uses of the inherently toxic chemical, which has killed thousands of old-growth pine trees along state scenic highways. Over five thousand comments from Oregonians and concerned individuals across the country urged ODA to scrap its convoluted proposed rule and simply eliminate the chemical from state commerce. While advocates will continue to urge ODA to completely eliminate ACP use, the current restrictions did not come without a fight. Public meetings were attended by representatives from the chemical’s manufacturer, Bayer. The company strongly opposed any restrictions on its product, and acted to delay the original implementation date for ODA’s rule. Oregon had intended to finalize the rule in late March. “We were pretty much set to file the final paperwork,” said Oregon pesticide program manager Rose Kachadoorian to The Bulletin. But through the work of its corporate lawyers, Bayer was able to track down an arcane Oregon law that […]

(Beyond Pesticides, February 11, 2019) Aminocyclopyrachlor (ACP) is a tree-killing pesticide masquerading as a broadleaf herbicide. The Oregon Department of Agriculture (ODA) has the opportunity to lead the country in banning this inherently dangerous chemical. According to ODA, nearly 1,500 dead or dying trees have been reported along Oregon’s iconic Interstate 20, home to old growth ponderosa pines. Many of these 150- to 300-year old trees are now dead from ACP exposure. ODA indicated that “because [ACP] is a relatively new herbicide it is unknown how many trees stressed from past applications of [ACP] will die in the future.” Even at tiny levels, ACP run-off and drift kills trees. Tell Oregon’s Department of Agriculture to lead the country in completely banning its use. In 2014, DuPont chemical company settled a nearly $2 million lawsuit with the U.S. Environmental Protection Agency (EPA) after the herbicide (under the brand name Imprelis®) was found to kill trees at golf courses, homeowners associations, businesses, and private residences. Despite this history, regulators left ACP on the market. Its use was banned on lawns and turfgrass, but allowed for roadside rights-of-way. A couple years ago, Bayer purchased the rights to ACP from DuPont and continues to market […]

(Beyond Pesticides, July 19, 2018) A variety of bentgrass, genetically engineered by Scotts Miracle-Gro and Monsanto to tolerate the glyphosate herbicide Roundup, escaped from an experimental field planting in Eastern Oregon 15 years ago, and continues to plague area farmers. Bentgrass is prized by those who maintain golf course greens because of its fine texture and habit of spreading in even, horizontal mats. But the genetically engineered (GE) version has become a giant annoyance for farmers and other growers who battle its spread through the irrigation systems of Malheur County in eastern Oregon. The escape of this GE version of Agrostis stolonifera is especially alarming in Oregon, the grass seed capital of the world. The GE grass showed up after crossing the Snake River from where it had been planted in seed fields in Idaho, despite the fact that the USDA had not approved its release into the seed market. By 2010, farmers and others found it spreading in mats across most of the irrigation canals and ditches that snake across Malheur County. It is now found in Jefferson County, Oregon, and Canyon County, Idaho, as well. The growth habit of the perennial grass is what greenskeepers love, but its persistent […]

(Beyond Pesticides, October 25, 2017) Oregon is the most recent site of an effort by a locality to establish more-protective pesticide regulations than are provided by the state. Voters in Lincoln County, on the north-central Oregon Coast, approved a ballot measure earlier this year that established a ban on aerial spraying of pesticides in the county. Immediately, county landowners Rex Capri and Wakefield Farms, LLC, both of whom use aerial spraying on their properties, filed a legal challenge to the ordinance created through that vote. The issue is whether the state of Oregon has the legal authority to stop its local political subdivisions from adopting more rigorous than those enacted by the state. When the state of Maine considered legislation to preempt its local jurisdictions (take away their authority to act) this summer, Beyond Pesticides wrote, “The democratic process is foundational to the culture of Maine and the country. LD 1505 betrays the democratic process. Maine communities want to be able to adopt standards that exceed or are more stringent than state standards as a matter of public health and environmental protection, or quality of life. Why would a town or city want to do use its local authority to adopt […]

(Beyond Pesticides, October 4, 2016) Last week, the  Oregon Liquor Control Commission (OLCC) approved 26 licences for 26 recreational marijuana retailers as well as modified state rules regarding state licensure testing requirements and packaging limitations. According to a OLCC press release, some of the marijuana retailers began operating on October 1st, fulfilling the OLCC’s promise to Oregon’s citizens that recreational marijuana stores would be open for business in fall 2016. OAR 845-025-5700 previously required that all batches be tested for pesticides. Under the new Oregon Administrative Rules (OAR) Temporary Pesticide Rules (“Limited Batch Testing”) OAR 845-025-5700, effective September 30, 2016 until March 1, 2017, the OLCC requires a minimum of 33.3% of batches per harvest lot of cannabis to be tested. According to OAR 333-007-0010, if the OLCC finds that there is not enough laboratory capacity for pesticide testing, the Commission may permit randomly chosen samples from batches of usable marijuana to be tested for pesticides by a licensed lab, rather than requiring every batch of usable marijuana from a harvest lot to be tested. If any part of those samples fails pesticide testing, every 10-pound lot is required to be tested. If the samples that are tested all passed, […]

(Beyond Pesticides July 25, 2016) The Oregon Department of Agriculture (ODA) last week issued 12 notices of statewide detainment and stop sale and removal orders for horticultural pesticide products that contain active ingredients not listed on the label. The orders call for the product manufacturers to immediately cease all sales, offers of sale, or other distribution in Oregon. This is the latest effort by a state with a legalized marijuana market to try to  curb the use of illegal pesticides in cannabis production, a practice that poses potential health threats to consumers, creating a regulatory challenge for state officials in states that have legalized marijuana for medicinal and or recreational purposes. Because the U.S. government classifies cannabis as a narcotic, the U.S. Environmental Protection (EPA) does not register pesticide products for use in its production, leaving consumers exposed to hazardous pesticides through inhalation, ingestion, and dermal absorption without any evaluation of potential health effects. The products in question are commonly used in horticulture and hydroponics, including cannabis production. The 12 notices cover 14 products sold in Oregon that were also identified by the Washington State Department of Agriculture (WSDA) in late June as containing undeclared pesticide active ingredients. In an […]

(Beyond Pesticides, April 25, 2016) Last week, the City Council of Milwaukie, Oregon passed a resolution that halts the use of bee-toxic neonicotinoid insecticides on city government and public property,  joining the growing number of local governments protecting pollinators.  Neonicotinoids  (neonics) have been widely cited in the demise of both managed and wild bee and pollinator populations.  The resolution specifically  restricts city government agencies from purchasing plants and seeds that have been treated with neonicotinoids and other systemic insecticides and urges public and private landscapers and homeowners to plant bee-friendly habitats.  Clackamas County will join with the Mayor’s office and City Council of Milwaukie to adopt an Integrated Pest Management Plan that mirrors the resolution. In addition to these stipulations, the City of Milwaukie is using this resolution to: urge all businesses, homeowners, and homeowner’s associations operating within the City ensure no plants, seeds, or products containing neonicotinoids are purchased, sold, or used within the City; and to clearly and accurately label any plants or materials that have been treated with a neonicotinoid or neonicotinoid-like insecticide; require that commercial pest service providers performing services on behalf of the City provide landscape services that encourage pollinator populations and support pollinator services; […]

(Beyond Pesticides, January 28, 2016) Last week, Oregon Representative Paul Holyey introduced legislation that would protect traditional crops against contamination from their genetically engineered counterparts. As it stands, local governments are preempted (disallowed) from taking actions that protect traditional farmers from contamination by genetically engineered (GE) crops. With the help of advocates representing family farms and food safety, The Transgenic Contamination Prevention Bill (HB 4122) will  repeal sections of Senate-passed  Bill 863,  which  preempts local governments, and restore the  right of local jurisdictions to regulate the planting of GE  seed. The law, Bill 863, dubbed  Oregon’s Monsanto Protection Act by environmentalists, farmers and consumers, was passed in 2013 and signed into law by then-Governor John Kitzhaber. The new language in HB 4122 seeks to correct the chemical company-driven legislation of the former bill and restore protection for traditional and organic farmers. In May, 2014, the voters of Jackson and Josephine Counties, Oregon, passed a ballot initiative, Genetically Modified Organism Ban, Measure 15-119, which sparked the backlash in the state legislature. A federal court decision upheld the ballot initiatives, and the county  laws were  grandfathered in, or allowed to stay in effect. Center for Food Safety’s attorney, George Kimbrell, expressed support […]

(Beyond Pesticides January 22, 2016) Last week, the Oregon Department of Agriculture (ODA) released a list of pesticide products available for use on marijuana cultivated within the state. The list, which contains 257 pesticide products, aligns with similar product lists published by Washington State and Colorado, and raises the same concerns over the allowance of products that violate the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and have not been subject to health evaluations of public exposure to the pesticides used. Those concerns were on full display last week in Colorado, when the Colorado Department of Agriculture (CDA) held a public meeting to discuss amendments to its Pesticide Applicators’ Act that would allow growers to use pesticides that violate FIFRA. Additionally, in an attempt to address consumers’ concerns over the issue of unregulated pesticides in marijuana, two lawmakers in Colorado introduced a bill that would establish a program for certifying marijuana as “pesticide free” within the state. Oregon Releases List of Approved Pesticides for Cannabis Growers Like Colorado and Washington, the Oregon list construes broad label language to allow the use of pesticide products that have not been specifically tested for use on marijuana, despite the fact that the Environmental […]

(Beyond Pesticides, December 17, 2015) On September 25, Applebee Aviation’s license to spray pesticides commercially was suspended for one year, after an employee complained of chemical exposure and violated worker protection rights. After Applebee Aviation’s one-year suspension was issued, it  continued to operate and illegally sprayed at least 16 sites, according to reports.  Two of those sites were public parks, 71 acres in total, overseen by the Oregon Department of Forestry (ODF). A series of back-and-forth communications between the Oregon Department of Agriculture and Applebee Aviation has resulted in a restraining order, $180,000 in fines, a five-year license revocation, and over 800 acres of state and private land illegally sprayed. According to recent investigations, ODF knew about the license revocation before Applebee Aviation illegally sprayed state forests. In April 2015, Applebee Aviation employee Darryl Ivy, a truck driver, spent 17 days on a spray crew in Oregon timber country. During that time, he and his crew were routinely exposed to aerial sprays. Mr. Ivy took shelter in his truck while a “milky chemical mixture” rained overhead and stained his vehicle. In the emergency room, Mr. Ivy’s urine showed elevated levels of the herbicide atrazine, a known endocrine disruptor. He suffered […]

(Beyond Pesticides December 9, 2015) Last week, the Oregon Health Authority (OHA) signaled its willingness to address a gap in the regulation  of pesticides in  marijuana production caused by a lag in the start date of the state’s revised testing program. After new regulations were adopted  last month to increase the amount of pesticide residue testing on cannabis required by the state, concerns were raised about the delayed  June 2016 start date. The  committee that advises OHA on medical marijuana pressured the agency to expedite the rules. While a final decision is pending, the    stop-gap testing rules would target the most commonly used pesticides in marijuana production and go into effect as early as January. Advocates are urging states to ban registered pesticides, since they are not labeled for use on marijuana and not evaluated for exposure associated with inhalation, ingestion, and dermal absorption, as well as potential environmental contamination. 70,000-plus medical marijuana users, as well as recreational users, within the state will be affected by the regulations. In November, the state of Oregon updated its rules governing pesticide use to require the mandatory testing of nearly  60 pesticide compounds  that are of particular concern. Under the new rules, […]

(Beyond Pesticides, October 2, 2015) Twelve worker safety violations are categorized as “serious” and result in thousands of dollars in fines. Highly toxic pesticides should not be sprayed on workers, but that is what Oregon-based company Applebee Aviation did to a number of its employees, according to the Oregon Department of Agriculture. On September 30, the Department, which is responsible for regulating state and federal pesticide laws, issued a citation revoking the Applebee’s operating license in the state of Oregon and levying a fine of $1,100. The same day, Oregon Occupational Safety and Health Division (OR-OSHA) cited Applebee Aviation for 12 serious violations of worker safety and protection laws and fined the company $8,850. The crackdown came after Darryl Ivy, who worked as an Applebee Aviation hazardous materials truck driver, became a whistle blower and reported  on dangerous and unsafe practices he witnessed during numerous aerial spray operations. Ivy recorded videos of the illegal activities on his cell phone before he went to an emergency room for treatment of illness due to pesticide exposure. “I had sores and rashes, was spitting up blood and felt very sick after three weeks on the job,” said Mr. Ivy. “I’ve worked in a […]

(Beyond Pesticides, July 29 2015) The  Safe and Accurate Food Labeling Act of 2015,  H.R. 1599, often referred to as the “DARK” Act or Denying Americans the Right to Know what is in their food, passed the U.S.  House of Representatives last week by a vote of 275-150. Backed largely by House Republicans, the DARK Act makes it harder for the Food and Drug Administration (FDA) to require mandatory national labeling of genetically engineered (GE) organisms and strengthens current policies that allow companies to voluntarily label foods containing GE products, an option they rarely choose to do. The bill also continues to allow misleading “natural” claims for food that contain GE ingredients. Most concerning, however, is the prohibition  that H.R. 1599 would place  on states’ authority to require labeling of GE ingredients in food products, instituting federal  preemption of state and local authority. While the bill was being debated on the floor, co-sponsors Representatives Mike Pompeo (R-KS) and G.K. Butterfield (D-NC) repeatedly cited a lack of scientific evidence that GEs were dangerous to support the passage of the bill, ignoring arguments from the opposition that people should be able to know what is in their food, regardless of whether it […]

(Beyond Pesticides, June 2, 2015) A federal judge released a ruling Friday rejecting a request by two alfalfa farms to overturn the ban on GE crops in Jackson County, Oregon. In his decision, U.S. Magistrate Judge Mark Clarke found the ban on GE crops is not preempted by the state’s Right to Farm Act, thereby allowing the ordinance to become effective on June 5. The ordinance, which bans the cultivation, production and distribution of GE crops within the county passed overwhelmingly last May with 66 percent support. This decision is an important victory for farmers of organic and non-genetically engineered crops, who constantly struggle with the threat of GE contamination. “We have always felt this was a strong case,” explained Tom Buchele, attorney with Earthrise Law Center, “but it was very encouraging to get such a strong and well-written opinion that affirms what we have argued since the beginning: communities have the ability under the Right to Farm Act to protect traditional agricultural crops from contamination from GMOs.” Magistrate Judge Clarke rejected the legal challenge by two GE alfalfa growers, Schulz Family Farms and James and Marilyn Frink, who claimed that the Jackson County GE crop ban violated Oregon’s Right […]

(Beyond Pesticides, April 6, 2015) Last week, the city council of Portland, Oregon voted unanimously to ban the use of neonicotinoid insecticides on city-owned property because these pesticides are persistent in the environment, harmful to pollinators, and have been involved in acute bee kills in other areas of the state. Neonicotinoids affect the central nervous system of insects, resulting in paralysis and eventual death. These pesticides have consistently been implicated as a key issue in pollinator declines, not only through immediate bee deaths, but also through sublethal exposure that causes  changes in bee reproduction, navigation, and foraging. The science has become increasingly clear that pesticides, either working individually or synergistically, play a critical role in the ongoing decline of honey bees.   Pesticide exposure can impair both detoxification mechanisms and immune responses, rendering bees more susceptible to viruses, parasites, and other diseases, and leading to devastating bee losses. Portland’s ordinance was spurred in part by the 2013 deaths of tens of thousands of bees as a result of the improper use of the neonicotinoids. Last month state officials banned  four   of the bee-killing insecticides, including   imidacloprid, clothianidin, thiamethoxam and dinotefuran from  use on  Linden  trees. In addition to […]

(Beyond Pesticides, March 6, 2015) Last Friday, Oregon enacted a new rule which bans the use of four types of bee-killing insecticides, including  imidacloprid, clothianidin, thiamethoxam and dinotefuran, regardless of application method on linden trees and other Tilia species. The four insecticides that are now illegal to spray on Tilia trees are all in the neonicotinoid chemical class which are implicated in pollinator decline, and represents a step forward in protecting bees. However, Tilia trees are not the only route of exposure that bees and other pollinators have to neonics, which are currently applied to fields across the U.S. as seed treatment. The rule comes at the request of the Oregon Department of Agriculture (ODA) following several bee-kill incidents in Oregon since June 2013, when more than 50,000 bumblebees were killed after dinotefuran was sprayed on trees in a shopping mall parking lot in Wilsonville, Oregon. After the incident in Wilsonville, ODA initially placed restrictions on two of the chemicals, dinotefuran and imidacloprid on Tilia trees, and the state launched a task force to look at protections for pollinators. The group came out with a range of recommendations including increased outreach and education about bees and support for bee habitat […]

(Beyond Pesticides, February 12, 2015) Oregon Senator Michael Dembrow (D-Portland) and Representative Ann Liniger (D-Lake Oswego) introduced a bill on Tuesday targeting the loosely regulated aerial pesticide spraying practices of the Oregon timber industry. The bill will establish residential, school, drinking water, and fish habitat buffers zones, require timely notification of spraying and controlled burns for nearby residents, increase record keeping requirements, establish protected areas where pesticide spraying is prohibited, and grant investigative and enforcement authority to the Oregon Health Authority in cases of human pesticide exposure. Development of the bill grew out of a series of incidents across Oregon involving residential pesticide exposure and poisoning from aerial spraying of forest lands. The main incident, which spurred state-wide outrage and investigations into the pesticide regulation and enforcement practices of the Oregon Department of Agriculture (ODA), involved Curry County residents who complained of pesticide exposure after witnessing aerial spraying near their homes. After pressure from local residents, investigative reporters, and environmental groups, ODA was ordered to publicly disclose pesticide records. It was found that the pesticides being sprayed were 2,4-D and triclopyr  ””information that conflicted with previous statements and reports and adding to the trend of opaque and lackluster ODA enforcement […]