(Beyond Pesticides, June 4, 2019) A class-action lawsuit is accusing Starbucks stores in New York of misusing a highly toxic, carcinogenic pesticide near food, putting the health of customers and employees at risk.  “Stores throughout Manhattan have for many years been permeated with a toxic pesticide called Dichlorvos [DDVP], which is highly poisonous and completely unfit for use in proximity to food, beverages and people,” the suit reads. According to the lawsuit, Hot Shot brand No Pest Strips were placed in food areas in violation of labels that prohibit the pesticide’s use in “the food/feed areas of food/feed processing or food/feed manufacturing or food/feed service establishments.” A pest control operator found the illegally placed products on a number of separate occasions, hidden under bagels or in pastry display cases, during a five year period from 2013 to 2018. This was not at only one location, but appeared to be a common occurrence at nearly every one of the 100+ stores serviced by the pest control operator. The case brings to light a number of issues with the use of synthetic pesticides. The unsanitary conditions permitted to persist within Starbucks stores, per the pictures provided in the suit (see page 14), […]

(Beyond Pesticides, May 24, 2019) University of California (UC) President Janet Napolitano announced, on May 15, a temporary ban on the use of glyphosate on all of UC’s 10 campuses. Set to begin on June 1, the ban will affect the more than 200,000 students in the UC system, and countless other staff, faculty, and visitors to the campuses. In announcing the ban, the university cited “concerns about possible human health and ecological hazards, as well potential legal and reputational risks associated with this category of herbicides.” (There are exceptions to the temporary suspension, such as uses for “agricultural operations, fuel-loaded management programs to reduce wildfire risk, native habitat preservation or restoration activities and research that requires glyphosate-based herbicides.”) The UC ban is the latest in a snowball-turning-avalanche of actions and decisions on glyphosate — the active ingredient in the Monsanto (now owned by Bayer AG) products Roundup and Ranger, and in many other herbicides. The suspension of glyphosate use at UC comes in large part as a result of the campaign, Herbicide-Free UC — which began as Herbicide-Free Cal, founded by student-athletes Mackenzie Feldman and Bridget Gustafson. The students became active on pesticides issues when they discovered that herbicides were […]

(Beyond Pesticides, May 20, 2019) The bans of chlorpyrifos in three important agricultural states show the support for a ban of the chemical nationwide. Hawai’i banned chlorpyrifos a year ago with a unanimous vote of the legislature. New York and California banned it this month. States have been pursuing bans since the Environmental Protection Agency rescinded its proposed ban in 2017. Tell Your Governor to Ban Neurotoxic Pesticides and Support Organic; Send Thanks to Your Governor in Hawai’i, New York, and California Like other organophosphate pesticides, chlorpyrifos has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children. A widely used pesticide, agriculture companies annually spray six million pounds on crops like citrus, apples, and cherries.  In the same family as Sarin gas, the substance was initially developed prior to World War II as a chemical weapon. It can overstimulate the nervous system to cause nausea, dizziness, and confusion. With very high exposures (accidents or spills), it can cause respiratory paralysis and even death. When applying the chemical to fields, workers must wear protective garments such as respirators. Workers are then blocked from entering the fields from 24 hours up to 5 days after application due to the chemical exposure risk. A group of leading toxics […]

(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, May, 7, 2019) Last week, the New York State legislature voted to phase out and eventually ban the use of the neurotoxic insecticide chlorpyrifos. The vote, 44-18 in the state Senate and 94-50 in the Assembly, is still awaiting the Governor’s signature, who is expected to sign the measure. As evidence of harm continues to accumulate, scientists have called for a ban, and a legal case works its way through the courts, pressure is mounting on the U.S. Environmental Protection Agency (EPA) to once and for all remove this harmful pesticide from use. New York’s legislation sets implementation dates that leapfrog a similar law banning chlorpyrifos that passed in Hawai’i last year. Although Hawai’i’s law takes effect beginning in July of this year, the state may provide temporary use permits for the chemical until December 2022. New York also phases in restrictions, first prohibiting aerial applications beginning January 2020, then prohibiting all use except on apple trees starting January 2021. The chemical will be completely banned for use in New York in December 2021. Chlorpyrifos is a highly toxic insecticide that has been linked to damaging and often irreversible health outcomes, particularly for pregnant mothers and their children, […]

(Beyond Pesticides, May 3, 2019) A Maryland Court of Special Appeals yesterday ruled that Montgomery County, Maryland has the right to restrict pesticides, under a 2015 landmark law, on all lawns and landscaped property in its jurisdiction more stringently than the state. This decision reverses a lower Circuit Court decision and upholds local democratic decision making in the face of a challenge by the industry groups representing lawn care companies and chemical manufacturers. Nine organizations, including Beyond Pesticides, filed an Amicus brief in support of the county law. The chemical industry has fought for nearly three decades to suppress the right of local governments in the U.S. to protect public health and safety with pesticide law, having successfully lobbied 43 states to preempt their local political subdivisions’ authority. Seven states uphold local authority, including the state of Maryland, which has affirmed in its legislature the rights of localities by rejecting preemption legislation on numerous occasions. According to Jay Feldman, executive director of Beyond Pesticides, “This is an important win for the local organic land management movement sweeping the country, as local elected officials embrace practices that protect the health of people and the environment.” The attorneys for the county expect that industry groups […]

(Beyond Pesticides, April 16, 2019) Help stop another attack on local authority in Maine – a bellwether state that has upheld local pesticide restrictions and leads the nation. Maine has led the nation in supporting the local democratic process as communities across the state have adopted pesticide use standards on public and private property that are more restrictive than state laws. This will be the third attack on local authority in recent years – each time beaten back with public opposition. This time preemption language has been introduced as a clause in the innocuous sounding bill LD 1518, An Act to Establish a Fund for Portions of the Operations and Outreach Activities of the University of Maine Cooperative Extension Diagnostic and Research Laboratory and To Increase Statewide Enforcement of Pesticide Use. The language was introduced by Rep. Stephen Stanley (D), who ran unopposed in the 2018 Democratic primary. The bill’s language establishes barriers to local decision making, giving sole authority to the state to determine the acceptability of local pesticide restrictions.  As drafted, the bill would force municipalities to submit a request to ban a substance to a statewide board, which would make the decision as to whether the community could block […]

(Beyond Pesticides, March 14, 2019) A study, supported by the USDA’s National Institute of Food and Agriculture, finds that state pesticide preemption laws “compromise public health and economic well-being” by preventing localities from enacting pesticide use restrictions on private property that are more restrictive than their state’s regulations. In the words of the authors, “By eliminating the ability of local governments to enact ordinances to safeguard inhabitants from health risks posed by pesticides, state preemption laws denigrate public health protections.” The study, Anti-community state pesticide preemption laws prevent local governments from protecting people from harm, published in the International Journal of Agricultural Sustainability, reviews scientific and historical evidence of the failure of state and federal pesticide laws to protect localities from pesticide poisoning, and highlights the inability of localities to compensate for that failure under present laws. Communities seeking to protect their residents would typically issue community-wide restrictions to ensure protection of shared community resources, including air, land, and waterways, from pesticide drift, runoff, and other nontarget effects —as is the case with other community decisions on recycling, smoking, and zoning. The study’s authors document how industry influence led to the adoption of state laws that undermine the ability of localities […]

(Beyond Pesticides, March 6, 2019) After a brief hiatus, Florida Fish and Wildlife Conservation Commission (FWC) is continuing use of aquatic herbicides, including glyphosate, for invasive species management. Public pressure and feedback caused FWC to take a temporary pause from spraying while the commission collected public comment  through public hearings and emails from late January through February. FWC ultimately decided to resume spraying invasive species, and points to its improved integrated management system as reducing overall herbicide use. Glyphosate, one of the 17 aquatic herbicides that FWC uses regularly has sparked opposition from environmentalists and the general public due to its wide usage and known adverse effects. According to FWC data, 12,263 pounds of glyphosate-based herbicides were used on Florida’s Lake Okeechobee in 2017. About 175,000 people have signed North Palm Beach photographer and wildlife advocate Jim Abernathy’s petition titled “Stop The State-Sanctioned Poisoning of Our Lakes and Rivers!”. The petition decries the use of glyphosate to kill invasive aquatic plants and warns of subsequent nutrient pollution caused by decay. An excess of nutrients (e.g. nitrogen and phosphorus) in water bodies contribute to algal blooms. Eutrophication can eventually result in oxygen depletion and thereby decrease biodiversity. FWC denies that the […]

(Beyond Pesticides, February 22, 2019) A bill introduced in the New York State Assembly and the Senate this month will break the century-long legal exclusion of agricultural workers from common labor protections. Among other protections, the Farmworker Fair Labor Practices Act will give New York farmworkers the right to collective bargaining, making employer intimidation and retaliation against organizing workers illegal. Citing farmworkers’ exposure to toxic chemicals among other occupational risks, former dairy farmworker and worker organizer Crispin Hernandez states, “The legislation would do a lot to end the pervasive climate of fear, intimidation and retaliation that exists on farms today. It would also make farmworkers’ lives safer.” The National Farm Worker Ministry notes that, “A union contract allows workers to report problems on the job without fear of getting fired.” In the case of farmworkers, problems on the job include exposures to toxic pesticides that workers, if organized, could freely report and collectively negotiate to remove from use to ensure their safety. The bill, introduced to the Assembly by Queens Assemblymember Cathy Nolan and to the Senate by freshman Senator Jessica Ramos (D), will amend the New York State Labor Relations Act (NYSLRA) by removing farmworkers from the list of […]

(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, February 7, 2019) A new study, released in Environmental Science and Policy, systematically reviews all state-level pollinator protection acts passed since 2000 and makes a somewhat dim diagnosis: as a rule, state policies fall far below the mark for protecting invaluable ecosystem services and ensuring long-term, sustainable food production. Authors judge the legislation against a set of pollinator protection policy benchmarks established in 2016 by a group of scientists from the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES). Citing the ten policy recommendations laid out by IPBES experts, researchers point to the failure of all enacted state policies to address three main target areas – (1) to improve genetically modified crop risk assessment, (2) to incentivize farmers to make the switch from agrochemical dependence to sustainable benefits from ecosystem services, and, critically, (3) to support diversified farming systems. Beyond Pesticides notes one additional missed target: (4) funding for research on organic, diversified, and ecologically intensified farming. The study includes a total of 109 state laws passed from 2000 to 2017, which authors tracked down by searching usa.gov and state legislative websites and by submitting requests to state librarians. To uncover common themes and patterns among these […]

(Beyond Pesticides, February 1, 2019) Prior to a pesticide ban taking effect in Montgomery County Maryland Parks, the Department of Parks announced in mid-December 2018 that it would discontinue the use of glyphosate-based herbicides through March 2019. The agency has used these hazardous herbicides as part of its IPM (Integrated Pest Management) program for weed management. Montgomery Parks indicates it will release further information on the use of glyphosate in mid-March. In November last year, Montgomery County Council member Tom Hucker wrote to the head of Parks, supported by a community-wide petition, urging that glyphosate be banned immediately, pending implementation of the county ban. He cited the finding of the International Agency for Research on Cancer’s (World Health Organization) finding that the chemical probably causes cancer in humans and the $289 million jury verdict last year that the chemical caused a school groundskeeper’s non Hodgkin lymphoma. In 2016, Montgomery Parks instituted a pesticide reduction program in compliance with Montgomery County, Maryland’s 2015 adoption of County Code 33B, which aimed to regulate use of pesticides on county-owned property, including parks, and on private property. In 2017, a Montgomery Circuit Court overturned the portion of the law pertaining to a ban on private […]

(Beyond Pesticides, January 22, 2019) Earlier this month, U.S. Representative Nydia Velásquez (D-NY) introduced The Ban Toxic Pesticides Act, H.R.230 which bans the insecticide chlorpyrifos from commerce. Chlorpyrifos is a toxic chemical that has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children. As a result of a revised human health risk assessment, the Environmental Protection Agency (EPA) developed a regulation to ban chlorpyrifos in 2016. Under the Trump Administration, the EPA has taken steps to reverse the regulation. “It’s unconscionable for EPA to turn a blind eye as children and workers are exposed to this poison,” Velázquez said.  “If the EPA won’t do its job when it comes to chlorpyrifos, then Congress needs to act – and do so quickly.” Ask your U.S. Representative to Co-Sponsor H.R. 230 to Stop the Use of the Toxic Insecticide Chlorpyrifos, which Is Damaging Children’s Brains.  Chlorypyrifos is a widely used pesticide. Agriculture companies annually spray 6 million pounds of the substance on crops like citrus, apples, and cherries.  In the same family as Sarin gas, the substance was initially developed prior to World War II as a chemical weapon. It can overstimulate the nervous system to cause […]

(Beyond Pesticides, January 10, 2019) The Trump administration is opening the floodgates to allow widespread use of antibiotics in citrus (grapefruits, oranges and tangerines) production, expanding on an emergency use decision it made in 2017. The public has an opportunity to comment on the widespread use of streptomycin by January 19, 2019. You can comment on the federal government’s public comment page (regulations.gov) by leaving a comment opposing any additional use of antibiotics in food production during a national and international crisis of deadly disease resistance to antibiotics. You can copy Beyond Pesticides’ prepared comment below and add your own concerns. Strikingly, the decision allows for up to 480,000 acres of citrus trees in Florida to be treated with more than 650,000 pounds of streptomycin per year, and 23,000 citrus acres in California will likely be treated annually. The two approved antibacterial chemicals to be used as a pesticide in citrus production are streptomycin and oxytetracycline. These uses were permitted by the U.S. Environmental Protection Agency (EPA) under an emergency exemption in May, 2017, allowing residues of antibiotics in Florida orange juice, for the antibiotics streptomycin and oxytetracycline –allowing their use for a bacterial disease, citrus greening (Candidatus Liberibacter asiaticus (CLas) bacterium that causes Huanglongbing), […]

(Beyond Pesticides, January 3, 2019) Bee-toxic pesticides banned for consumer use by the state of Maryland are still being sold in hardware and garden stores, according to reports from beekeeper and consumer watchdog groups. In 2016, Maryland passed the Pollinator Protection Act, which limited the use of neonicotinoids, insecticides implicated in the global decline of pollinator populations, to only certified applicators. According to spot checks by the Maryland Pesticide Education Network (MPEN) and the Central Maryland Beekeepers Association (CMBA), state enforcement agencies still have a ways to go to ensure retailers are complying with the law. From May to October 2018, six volunteers visited 30 Maryland stores along the Baltimore-Washington corridor to see whether they are complying with the law by removing bee-toxic neonicotinoids from retail consumer sale. Eleven of the 30 stores were not in compliance, ranging from local home and garden stores to national big-box chains. “I’ve taken bottles off the shelf and taken them up to an employee or a manager, and said, ‘You really need to stop selling this stuff — it’s illegal,’” said Steve McDaniel, a master beekeeper in Carroll County to the Bay Journal. The state, for its part, indicates that staffing problems at […]

(Beyond Pesticides, December 21, 2019) A study at the University of Maine (UMaine) finds that adding blackberry leaf litter in stormwater catch basins creates an “ecological trap,” enticing mosquito females to lay eggs in sites unsuitable for larvae survival. Employing this new and incredibly viable “attract-and-kill’ tool for mosquito control shows potential for preventing the breeding of mosquitoes that may carry insect-borne diseases, especially in urban environments. Stormwater catch basins regularly accumulate leaf litter, which serve as habitat for the mosquito species Culex pipiens (Cx. Pipiens) that may carry West Nile virus. Previous University of Maine research discovered decomposing leaf litter from Amur honeysuckle (Lonicera maackii) and common blackberry (Rubus allegheniensis) produces chemical compounds that attracts and stimulates Cx. Pipiens female to oviposit, or lay eggs. Investigating the attractiveness and lethality of varying catch basin conditions to mosquitoes, researchers hypothesized that blackberry leaf litter could be shown to be lethal to developing mosquito larvae, and, therefore, act as a natural ecological trap for Cx. Pipiens. Five varying treatments were applied to a total 50 catch basins. Treatments included (1) all debris dredged weekly throughout the duration of the study, (2) no change to debris naturally occurring in catch basins, (3) […]

(Beyond Pesticides, December 14, 2018) The richness, diversity, and abundance of wild bumblebees in Vermont has plummeted over the last century, according to an analysis from researchers at the University of Vermont and Vermont Center for Ecostudies (VCE). This research adds fresh evidence to the growing realization that mankind is witnessing and contributing to, as the New York Times recently labeled, a worldwide insect apocalypse. “We’re losing bumblebees even before we fully understand their benefits to our economy and well-being, or how they fit into ecosystems,” said Kent McFarland, study coauthor and conservation biologist at VCE in a press release. Researchers conducted surveys with the help of 53 trained citizen scientists. Alongside the researchers, these individuals surveyed bumblebee populations through a combination of photos of wild bees and net collections. In total, over 81% of the state’s municipalities were included in the survey, representing all of Vermont pollinator’s biophysical regions. These data, consisting of over 10,000 bee encounters, were then compared to a database of almost 2,000 historical public and private insect collections amassed by researchers. With the first records beginning at 1915, scientists are able to compose a century-long assessment of pollinator populations in Vermont. “These collections are priceless,” […]

(Beyond Pesticides, December 11, 2018) Meltwater and runoff from Alaskan glaciers contain detectable levels of organochlorine pesticides that bioconcentrate in fish and put individuals at risk, according to a new study from researchers at the University of Maine (UMaine). DDT, lindane, and other organochlorines have been detected throughout the world, even in natural areas thought to be untouched, and pristine. As UMaine scientists show, the atmospheric transport and ubiquitous deposition of these pesticides continues to pose risks to U.S. residents long after regulations banned their use. Although most of the highly toxic class of organochlorine pesticides like DDT were banned in the early 1970s, some chemicals retained certain uses. Lindane, for example, had its pest management uses phased out gradually until 2007, but is still allowed today as a scabies and lice shampoo. While use of these pesticides has declined in the U.S., much of the developing world, including many Asian countries, such as China, India, and North Korea, still report use. This results in atmospheric transport of the pesticides, and relevant to the UMaine research, increases the likelihood that the chemicals will eventually be deposited onto Alaskan glaciers through snow or rain. The UMaine research team investigated the amount of […]

(Beyond Pesticides, December 4, 2018) In mid-November, the state whose agricultural operations used more than 900,000 pounds of chlorpyrifos in 2016 (down from two million pounds in 2005) moved to establish some temporary restrictions on its use. Regulators at the California Department of Pesticide Regulation (CDPR) issued interim restrictions on the compound while the agency works on a formal regulatory process to list chlorpyrifos as a “toxic air contaminant” and develop permanent restrictions on its use. A neurological toxicant, chlorpyrifos damages the brains of young children: impacts of exposure, even at very low levels, include decreased cognitive function, lowered IQ, attention deficit disorder, and developmental and learning delays. It was slated to be banned for food uses by the U.S. Environmental Protection Agency (EPA) last year, but the decision was reversed by the Trump administration. The interim measures in California include: banning aerial application of chlorpyrifos; ending its use on many crops — except for those determined to be “critical” by virtue of there being few, if any, alternatives (as determined by the University of California Cooperative Extension and listed on DPR’s website); establishing a quarter-mile buffer zone for 24 hours after any application of the pesticide; and requiring a 24/7/365, 150-foot […]

(Beyond Pesticides, November 27, 2018) The U.S. Environmental Protection Agency (EPA) ignored the input of an expert weed scientist on the controversial herbicide dicamba, bending to Bayer’s Monsanto and the pesticide industry, according to emails obtained by the Arkansas Democrat and Chronicle (ADC) through a Freedom of Information Act request. The scandal centers on the recent re-approval of the pesticide, a highly volatile and drift-prone herbicide that has become a serious problem for many farmers and state regulators. As top-level EPA officials continue to work with industry to subvert their own agency’s scientific findings, more and more consumers are moving to organic products in order avoid the pesticide risks government regulators ask consumers to accept. Emails ADC received indicate that Jason Norsworthy, PhD, a weed scientist with the University of Arkansas, worked closely with Bayer’s Monsanto in conducting field trials this past summer, but found high volatility and drift of the company’s new dicamba-based herbicide XtendiMax. The product was developed in the face of widespread resistance to glyphosate-based herbicides in genetically engineered (GE) farm fields. However, recent accounts from farmers in the south and midwest indicate that, not only is the switch to dicamba unhelpful  in eliminating drift and reversing escalating weed resistance, its […]

(Beyond Pesticides, November 8, 2018) Two months after publishing its first series of tests, part two of an Environmental Working Group (EWG) study finds residues of Roundup’s active ingredient, glyphosate, in all General Mills’ Cheerios and PepsiCo’s Quaker Oats products sampled. Health advocates are expressing concern about the consequences of chronic glyphosate exposure, and say U.S. federal agencies must limit the herbicide’s use on oat-based breakfast foods regularly marketed to children. In addition, organic itself is under threat, as chemical-intensive management practices undermine the future of the growing organic movement. In this second round of testing, EWG scientists purchased products around San Francisco and Washington DC. 28 samples of conventional and 16 samples of organic oat products were collected. Approximately 300 grams of each General Mills and PepsiCo product were packaged and shipped to Anresco Laboratories, in San Francisco. Detected glyphosate residues were compared to EWG’s own health benchmark of 160 parts per billion (ppb). This benchmark is based on risks of lifetime exposure and what EWG scientists consider allowable and protective of children’s health with an adequate margin of safety.  EWG’s results detected glyphosate residues in all 28 samples of conventionally grown oat products. The vast majority (all but two) […]

(Beyond Pesticides, October 22, 2018) The California Department of Pesticide Regulation (DPR) is accepting comments on its proposal to classify chlorpyrifos as a toxic air pollutant. The classification would require DPR to develop control measures that adequately protect public health. What happens in California affects all of us because products of California agriculture are available all over the country –and the world. In addition, policies set by the state of California are often examples for other states and the federal government. Tell California Department of Pesticide Regulation to ban chlorpyrifos. California’s Office of Environmental Health Hazard Assessment (OEHHA) states: Under the Toxic Air Contaminant Identification and Control Act (AB 1807, Chapter 1047, Statutes of 1983) and its implementing regulations (Title 3, California Code of Regulations, Section 6864), one of the criteria for identifying a pesticide as a TAC is if its concentration in the air exceeds one-tenth of the level that has been determined to be adequately protective of human health. The draft TAC document shows that bystanders can be exposed to modeled air concentrations of chlorpyrifos that exceed one-tenth the protective level, and thus meet the criteria for TAC identification. OEHHA’s findings below serve to reinforce this overall conclusion, and […]