(Beyond Pesticides, March 28, 2022) Last Chance This Spring To Tell the NOSB To Uphold Organic Integrity. Comments are due 11:59 pm EDT April 1 (No Fooling!) The National Organic Standards Board (NOSB) is receiving written comments from the public through April 1. April 1 is also the deadline for registering for the upcoming public comment webinar on April 19 and 21, which precedes the online meeting April 26-28—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov. As always, there are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong (KOS) and the Spring 2022 issues page, where you can find Beyond Pesticides’ comments on all issues facing the NOSB at this meeting. In the spirit of “continuous improvement,” we urge you to submit comments (please feel free to use our comments on the KOS page or use language below) that contribute to an increasingly improved organic production system. Here are some high priority issues for us: The NOSB must insist that the National Organic Program (NOP), which is part of the U.S. Department of Agriculture (USDA) follow through with NOSB recommendations. […]

(Beyond Pesticides, March 14, 2022) The National Organic Standards Board (NOSB) is receiving written comments from the public through April 1. This precedes the upcoming public hearing on April 19 and 21—concerning how organic food is produced. Written comments must be submitted through Regulations.gov. For details on the all the issues of importance to organic integrity, please see Beyond Pesticides’ Keeping Organic Strong webpage. The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2022 issues page. Here are some high priority issues for us: Cetylpyridinium chloride (CPC) is a quaternary ammonium compound (quat or QAC) that is being petitioned for […]

(Beyond Pesticides, March 7, 2022) Contrary to the demands of consumers for hormone-free organic dairy products and the requirements of the Organic Foods Production Act (OFPA), the U.S. Department of Agriculture (USDA) will allow continued use of the synthetic hormone oxytocin in organic dairy production. The National Organic Standards Board (NOSB) voted unanimously in 2017 to reject the use of the synthetic hormone oxytocin in livestock production. Since administration of oxytocin has been linked to a range of serious health problems and early onset puberty, autism, and psychiatric disorders, it is important to avoid residues in food that may cause a hormone imbalance in food consumers. Tell USDA Secretary Vilsack to reverse the decision to allow oxytocin in organic dairy. Tell Congress that greater oversight is needed to ensure that USDA upholds the Organic Foods Production Act.  Substances on the National List are reconsidered every five years to determine whether they still meet criteria in OFPA—that is, that their use is (1) not harmful to human health or the environment, (2) necessary for organic production, and (3) consistent with organic practices. In the case of oxytocin, a hormone involved in the milk “let-down” reflex, there is longstanding concern that misuse […]

(Beyond Pesticides, January 31, 2022) Public concern is now heightened as Florida manatees are facing extremely severe threats—so severe that wildlife officials have resorted to feeding them cabbage and lettuce in an attempt to keep their rapidly dwindling populations alive. Protecting manatees will require a multi-faceted approach, including upgrading their status to endangered and protecting their watery habitat from toxic threats. Tell the U.S. Fish and Wildlife Service to upgrade the Florida manatee to endangered and require protection from chemical pollution. Tell your Congressional Representative and Senators to support H.R. 4946. Tell Florida’s Governor DeSantis to protect manatees. Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years old, weigh up to 1,200 lbs, and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants. In 2017, the U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating that over 1,000 manatees died in just the […]

(Beyond Pesticides, January 24, 2022) The advisory board of health experts who counseled President Biden during his transition have now called for an entirely new domestic pandemic strategy geared to the “new normal” of living with the virus indefinitely. While this new strategy addresses important issues like “reimagining public health” and disparities in vulnerability to COVID, it misses out on an important one—reducing vulnerability to disease by eliminating exposure to toxic chemicals, especially those that threaten the immune, nervous, and respiratory systems. Tell the President, EPA, and Congress to address the ongoing threat of Covid-19 by eliminating toxic pesticide use that elevates overall, and disproportionately for people of color, the public’s vulnerability to the virus. The strategic initiative is organized by Ezekiel J. Emanuel, MD, PhD, an oncologist, medical ethicist, and University of Pennsylvania professor who advised former President Barack Obama. The group published a collection of opinion articles in the Journal of the American Medical Association (JAMA). In those articles, the group advises President Biden to give up on an eradication goal, accept that COVID-19 is here to stay—that is, that it is becoming endemic—and adopt a goal of living with it. These articles explore what that means. The […]

(Beyond Pesticides, January 10, 2022) The U.S. Department of Agriculture (USDA) is now undermining full public disclosure of genetically engineered ingredients in our food, both through misrepresentation in labeling and through a definition that allows a large percentage of ingredients to go undisclosed. The National Bioengineered Food Disclosure Act, dubbed the Deny Americans the Right to Know (DARK) Act by food safety advocates, establishes a national GMO (genetically modified organisms or genetically engineered GE) food labeling requirement that has led to deceptive messaging, preempts states from adopting stronger label language and standards, and excludes a large portion of the population without special cell phone technology (because information is accessed the QR codes on products). However, USDA regulations go further—creating loopholes and barriers to transparency that prohibit the use of the widely-known terms “GMO” and “GE” and prohibit retailers from providing more information to consumers. Tell USDA Secretary Tom Vilsack to require USDA agencies to honestly disclose genetically engineered ingredients and carry out the goals of the Executive Memorandum, Modernizing Regulatory Review. Urge your U.S. Senators and Representative to ask Agriculture Committees to hold oversight hearings to ensure that USDA holds to those goals.    USDA is huge—encompassing 29 agencies and offices, with […]

(Beyond Pesticides, January 3, 2022) Environmentalists and public health advocates are calling for an aggressive program of policy change in 2022—change they say is critical to addressing existential crises of public health threats, biodiversity collapse, and severe climate disruption that is not being taken seriously by policy makers. On November 23, 2021, Senator Cory Booker introduced legislation to eliminate many of the current problems with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which regulates the registration and use of pesticides in the U.S. It corrects some of the worst mistakes in registering pesticides and removes some of the worst loopholes in the law. However, in order to prevent future pesticide problems, we need reform that goes deeper. Urge your Senators to co-sponsor legislation to reform the toxic core of federal pesticide law. Specifically, the bill, the Protect America’s Children from Toxic Pesticides Act of 2021 (PACTPA), would provide some desperately-needed improvements to FIFRA to better protect people and the environment, including: Bans some of the most damaging pesticides scientifically known to cause significant harm to people and the environment: Organophosphate insecticides, which are designed to target the neurological system and have been linked to neurodevelopmental damage in children; Neonicotinoid insecticides, which […]

(Beyond Pesticides, December 13, 2021) If you plan to give socks, sweatshirts, or other items of clothing as holiday gifts, you need to be aware that many such items are treated with toxic chemicals. Such treated items may be labeled as “odor free” and may contain nanosilver, triclosan (banned in soaps, but allowed in textile and household products), or other (undisclosed) chemicals hiding behind brand names such as Microban® or FreshIQ. Since it is not always possible to determine which chemical may be used in these textiles, the best option is to buy clothing that is organic or made locally.  The Environmental Protection Agency (EPA) exempts treated articles from registration requirements under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Although the chemicals themselves may be registered antimicrobial pesticides, the treated products in which they are found—and which expose the public to them—are not considered pesticides. Besides clothing treated with antimicrobials to control odors, EPA also allows seeds, wood, paints, cutting boards, sponges, mops, and even toothbrushes to be treated with antimicrobial pesticides under the exemption—as long as claims made for the treatment only pertain to protecting the treated article. For example, sock manufacturers may claim that the treated socks […]

(Beyond Pesticides, November 29, 2021) The U.S. Fish and Wildlife Service (FWS) is reviving its proposal to aerially apply (by helicopter) the toxic rodenticide brodifacoum to kill house mice on the Farallon Islands National Wildlife Refuge off the Northern California coast. Globally significant wildlife populations inhabit the Farallones, including hundreds of thousands of seabirds and thousands of seals and sea lions. According to FWS, these include: thirteen species seabird species that nest on the islands including Leach’s Storm-petrel, Ashy Storm-petrel, Fork-tailed Storm-petrel, Double-crested Cormorant, Brandt’s Cormorant, Pelagic Cormorant, Black Oystercatcher, Western Gull, Common Murre, Pigeon Guillemot, Cassin’s Auklet, Rhinocerous Auklet, and Tufted Puffin; pinnipeds including Northern fur seals, Steller sea lions, California sea lions, harbor seals, and northern elephant seals that breed or haul-out onto Farallon Refuge; and endemic species including white sharks, hoary bats, and arboreal salamanders. Tell the California Coastal Commission to deny the proposed aerial dispersal of the highly toxic rodenticide brodifacoum on the Farallon Islands. Brodifacoum is a “second generation anticoagulant rodenticide” (SGAR) that is highly toxic to birds, mammals, and fish. It also poses a secondary poisoning risk to predators. The California Department of Pesticide Regulation quotes the FWS: “Secondary exposure to SGARs is particularly […]

(Beyond Pesticides, November 15, 2021) A recent hearing in the U.S. Senate Agriculture Subcommittee on Food and Nutrition, Specialty Crops, Organics, and Research, subcommittee chair Senator Cory Booker stressed the failures of the U.S. Department of Agriculture’s (USDA) food and nutrition programs, saying, “Our food system is not a “free market,” we are picking winners and losers, and it’s consumers, family farmers, and food workers who are losing.” Tell USDA’s Food and Nutrition Service to require organic school lunches. Experts at the hearing pointed out impacts of poor nutrition choices that are driven by USDA’s policies. Associate professor Angela Odoms-Young, PhD of Cornell University said, “People of color overall, and Black populations specifically, face higher rates of diet-related chronic conditions and have poorer dietary intakes as compared to whites. We did not get here by chance but through policy.” Childhood obesity is a serious problem in the U.S., leading to a host of health problems in childhood and later in life. Juvenile obesity is highest in Hispanic, African American, and lower income groups, which provides an opportunity for USDA’s school lunch program to have a positive impact. At the hearing, Donald Warne, MD, MPH of the University of North Dakota medical […]

(Beyond Pesticides, November 8, 2021) California state agencies, led by the California Natural Resources Agency (CNRA), released a draft Natural and Working Lands Climate Smart Strategy to guide and accelerate near- and long-term climate action across key California landscapes. All states need such strategies, and to be effective, they must be backed by ambitious targets focused on reduction of pesticides and support for organic agriculture. Tell your state legislators and governor to adopt a Natural and Working Lands Climate Smart Strategy that supports organic agriculture and land management. (CALIFORNIA RESIDENTS: Please use this form.) A Natural and Working Lands Climate Smart Strategy will identify our natural and working lands as a critical yet currently underutilized sector in the fight against climate change. These lands can sequester and store carbon emissions, limit future carbon emissions into the atmosphere, protect people and nature from the impacts of climate change, and build resilience to future climate risks. Climate smart management of our natural and working lands also improves public health and safety, secures our food and water supplies, and increases equity. The strategy should define the state’s natural and working landscapes; describe how these lands can deliver on climate change goals; highlight priority nature-based climate […]

(Beyond Pesticides, November 1, 2021) Join with 37 environmental and health groups, farm organizations, and beekeeper councils, who have delivered a letter to the Environmental Protection Agency (EPA) leaders seeking major reforms in the Office of Pesticide Programs (OPP). They provided a comprehensive list of OPP’s major failures as the lead federal office for pesticide regulation and management, including: Allowing chlorpyrifos to stay registered for more than 14 years after health experts and affected farmworkers petitioned for its removal based on its known neurological danger, Allowing unlimited use of Roundup (glyphosate) long after it was shown to contribute to deadly non-Hodgkin’s lymphoma in heavy users and it devastated the treasured monarch butterfly, now driven to near extinction in North America, Approving hundreds of neonicotinoid systemic insecticides, now the most widespread insecticide in the country where they are decimating honey and native bees and other key pollinators and beneficial species; and Registering dicamba in a highly volatile herbicide, a shocking blunder later overruled by a federal court ruling that stated OPP “not only substantially understated the risks …. It also entirely failed to acknowledge other risks, including those it was statutorily required to consider.” Take action: Tell EPA and Congress that the […]

(Beyond Pesticides, October 18, 2021) The most recent science on pesticides raises serious health and environmental effects associated with pesticide use for lawn and landscape management. While the data is often not assembled in one place, updated factsheets bring together the science on the 40 commonly used pesticides used for conventional landscape management. Governors have the authority to stop the use of these hazardous materials that are used on parks and playgrounds, either by executive order or through their work with their state legislature, and transition land management to organic practices. Tell your governor to stop hazardous pesticide use on state lands and transition to organic land management. The new factsheets document with scientific citations a wide range of diseases and ecological effects linked to pesticides. The underlying analysis supporting the adverse health and environmental effects identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases. What do the factsheets disclose? Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects… 26 are possible and/or known carcinogens 24 have the potential to disrupt the endocrine (hormonal) system 29 are linked to reproductive effects and sexual dysfunction 21 […]

(Beyond Pesticides, October 4, 2021) Recent findings of high levels of toxic pesticides in products permitted to be used as “minimum risk pesticides” (terminology used for essentially nontoxic) point to the need for greater oversight of these products and more severe penalties for violations. Pesticides classified as minimum risk are allowed under Section 25(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) [40 CFR 152.25(f)] to be used without going through EPA’s pesticide registration process. These products are limited to a specific list of ingredients, and all ingredients, including “inert” ingredients, are required to be listed on the label.  Minimum risk pesticides are used by organic growers, municipalities, and others who are not permitted to use, or choose to avoid, toxic chemicals.  Tell EPA and Congress to protect the integrity of minimum risk pesticides. Organic growers can lose their organic certification if they apply materials that are prohibited, which include the toxic ingredients glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl, found by the state of California in dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Contamination of these products came to light in late July, when the California Department of Food and […]

(Beyond Pesticides, September 27, 2021) The National Organic Standards Board (NOSB) is receiving written comments from the public through September 30. This precedes the upcoming public comment webinar on October 13-14 and online meeting October 19-21—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov. As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong (KOS) and the Fall 2021 issues page. In the spirit of “continuous improvement,” we urge you to submit comments (please feel free to use our comments on the KOS page) that contribute to an increasingly improved organic production system. The Organic Foods Production Act (OFPA) requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. Among the issues up for consideration at this meeting is a material that the National Organic Program (NOP) has taken off the NOSB’s sunset agenda for several years—sodium nitrate. There are also issues affecting organic integrity that need to be addressed—systemic fraud and plastic—as well as decisions about other materials that are described on the […]

(Beyond Pesticides, August 23, 2021) “Biopesticides”—widely regarded as an alternative to chemical pesticides and hence given a special status in regulation—need a better definition. “Biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term can be misleading and mixes contradictory approaches. It is troublesome when we continue to look for product replacements or substitutions for agricultural practices that are clearly ineffective, and in the process avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions. The U.S. Environmental Protection Agency (EPA) uses the following definition for “biopesticides”: Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals); Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient; Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce. Tell EPA it’s time to redefine “biopesticide.” It is deceptive and misleading. The definition should not include genetically modified organisms or synthetic analogs of naturally occurring […]

(Beyond Pesticides, August 16, 2021) The failure of the U.S. Environmental Protection Agency (EPA) to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine-disrupting chemicals must end. The Office of the Inspector General (OIG) for EPA has issued a damning report on the agency’s progress in protecting the population from potentially damaging endocrine disruption impacts of exposures to synthetic chemical pesticides (and other chemicals of concern) that shows the situation to be even worse than previously reported. The OIG’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” As a result, according to the OIG, “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.” Tell EPA that pesticide use cannot continue without findings of no endocrine disruption. Over recent decades, evidence has mounted showing that many pesticides interfere with hormones—and are therefore endocrine-disrupting chemicals (EDCs). In 1996, the promise of screening pesticides for endocrine disruption generated support from environmentalists and public health advocates for the Food Quality Protection Act […]

(Beyond Pesticides, August 9, 2021) What’s going on at the Environmental Protection Agency (EPA)? Last month, Bayer/Monsanto announced it would voluntarily cancel “residential lawn and garden” uses of glyphosate products, “exclusively to manage litigation risk and not because of any safety concerns.” EPA has done virtually nothing to restrict glyphosate/Roundup since the World Health Organization/International Agency for Research on Cancer in 2015 classified the chemical as probably carcinogenic. It is now expected, as with other voluntary cancellations, that EPA will make no health or environmental findings that could affect other uses (e.g., agricultural) of glyphosate, but will accept the action by Bayer/Monsanto. The company refers to its action as “risk mitigation”—that’s risk to the company’s profitability, economic viability, and shareholder investment, not public health or environmental protection. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing. The Biden administration began with high hopes for the environment. Combating climate change is a priority. On his first day in office, President Biden issued an executive memorandum, Modernizing Regulatory Review, that appears to establish a new framework supporting healthy people and ecosystems, as it […]

(Beyond Pesticides, August 2, 2021) One reason to eat organic food is to join with a crucial national and global campaign to eliminate toxic, petroleum-based pesticides and fertilizers and protect ecosystems in the urgent fight to curtail the climate crisis and biodiversity decline—in addition to local and immediate health and environmental benefits. Despite an important and timely vote by the National Organic Standards Board (NOSB) in 2018 to protect native ecosystems as a critical tool in sequestering carbon and improving environmental resiliency, and despite the Biden Adminstration’s stated commitment to fighting the climate crisis, the U.S. Department of Agriculture and its National Organic Program (NOP) have not acted to put this recommendation in force. As our understanding of the connection between protecting intact ecosystems and combating climate change has grown, the urgency to implement this recommendation cannot be overstated. We must act now! Sign the petition to tell the National Organic Program (NOP) to take action to finalize the National Organic Standards Board (NOSB) recommended rulemaking that will protect Native Ecosystems and thereby preserve the integrity of the organic seal, help reverse the biodiversity crisis, and reduce global climate change. Sign by September 20, 2021. The Organic Foods Production Act […]

(Beyond Pesticides, July 12, 2021) During Pollinator Week 2021 in June, U.S. Representatives Earl Blumenauer (D-OR) and Jim McGovern (D-MA) reintroduced the Saving America’s Pollinators Act (SAPA) to reverse ongoing declines in wild and managed pollinators. New data released in June for 2020-21 documents the second highest honey bee losses in 15 years. SAPA uses the latest scientific research and perspectives to ensure that pollinators are protected. The bill suspends the use of neonicotinoid (neonic) insecticides and other pesticides harmful to bees and other pollinators until an independent board of experts determines that they are safe to use, based on a strong scientific assessment. Ask your elected representative in Congress to support pollinators by cosponsoring Saving America’s Pollinators Act (SAPA). If they are already a cosponsor, use this occasion to thank them for their leadership on this critical issue. “Without our world’s pollinators, the world would be a very different place. These bees, butterflies, hummingbirds, and other creatures are essential elements of our food system. Losing them means we risk losing the very food we put on our table,” said Rep. Blumenauer. “We must use every tool at our disposal to provide pollinators with much-needed relief from bee-toxic pesticides and monitor […]

(Beyond Pesticides, July 6, 2021) ACT NOW: Public Comment Period Ends July 12, 11:59pm (eastern). A new proposed rule on the “origin of livestock” is intended to undo nearly two decades of regulatory failure by the USDA. Organic dairy producers have suffered economic harm and many organic milk consumers have been drinking substandard milk, while the National Organic Program (NOP) failed to promulgate a Final Rule on the issue of transitioning non-organically certified dairy bovine animals to organic production. The public comment period on this rule closes on July 12, 2021 at 11:59pm (eastern). We all have a stake in growing the organic marketplace by supporting the transition from conventional chemical-intensive practices to clearly defined sustainable and regenerative practices that support family farmers and a production system that confronts the climate crisis, biodiversity decline, and rising public health threats. We do this by supporting transition and then continually improving standards to ensure a robust and healthful organic sector. The issues challenging organic dairy production are a part of the continuous efforts of Beyond Pesticides to ensure organic integrity, while growing the organic market. Tell NOP to adopt an origin of livestock rule that protects dairy farmers and consumers.  When the […]

(Beyond Pesticides, June 28, 2021) The endocrine disrupting herbicide propazine (in the triazine family of frog-deforming endocrine disruptors) is set for cancellation by the U.S. Environmental Protection Agency (EPA). The move would eliminate use of the hazardous herbicide by the end of 2022. However, all pesticides in the triazine class, including atrazine and simazine, have similar properties and should be eliminated from use. Tell EPA to finish the job by banning all triazines. In November 2020, Beyond Pesticides and allied environmental groups launched a lawsuit against EPA for its intent to reregister the triazine family of chemicals. The agency’s interim approval of the herbicides, conducted under the Trump administration, eliminates important safeguards for children’s health and a monitoring programs intended to protect groundwater from contamination. As is typical with EPA, the agency merely proposed minor label changes in attempts to mitigate risks identified in its registration review. According to a release from EPA, it made the decision not out of concerns relating to human health and environmental protection, but in order to provide “regulatory certainty” for farmers and local officials. In March 2021, the Biden administration requested a stay on the atrazine lawsuit brought by environmental groups, as it indicated […]

(Beyond Pesticides, June 7, 2021) Beyond Pesticides and Friends of the Earth (FOE) collaborated to analyze herbicide products at two of the most popular home and garden retailers, Home Depot and Lowe’s. This new Commercial Herbicide Analysis highlights the adverse health and environmental effects of widely available toxic pesticides while encouraging retailers to expand on—and consumers to use—safer, least/nontoxic pesticide approaches. Tell Home Depot and Lowe’s to remove toxic herbicides from their shelves and replace them with products that promote least-toxic practices. According to Akayla Bracey, Beyond Pesticides’ science and regulatory manager and lead researcher on the review, “People generally aren’t aware that the pesticides widely available in garden retailers like Home Depot and Lowe’s are a threat to health and the environment, and that there are safer approaches that are available and used in organic land management.”  When it comes to weeds, gardeners need good tools that enable them to control them with minimal effort and damage to their plants. Although gardeners differ in their preference for style of garden hoe, all must be sharp to operate efficiently, so files for sharpening should be located near the hoes, and customer service representatives should be prepared to demonstrate their use.  […]