(Beyond Pesticides, September 18, 2018) While climate change campaigners have long warned of increased pest pressure as a result of a warming planet, new research published in Science has begun to envisage the true extent of this expanding crisis for agriculture and crop yields. An Earth warmed by 2 degrees Celsius will see significant increases in insect metabolism and population growth, increasing global food scarcity. The study underlines the need to move towards more sustainable agricultural models that can better handle pests and other stressors brought about by climate change. Scientists focused their models on the three staple crops that comprise over 40% of calories consumed worldwide – rice, corn, and wheat. Pest impacts were considered for a variety of scenarios, including a world warmed by 2 °C from Earth’s current global mean surface temperature. The Paris Climate Accords aims to limit warming to 1.5 °C, but with uncertainty around the U.S. pulling out of the voluntary agreement, the model produced by researchers represents a very possible scenario. The results paint a grim picture for global food security and nutrition, with pest-related losses expected to increase by 19% for rice, 31% for corn, and 46% for wheat. The trajectory boarders […]

(Beyond Pesticides, September 17, 2018) The Fall 2018 NOSB meeting dates have been announced and public comments are due by October 4, 2018. Your comments and participation are critical to the integrity of the organic label. Written comments may be submitted through Regulations.gov  until 11:59 pm ET October 4, 2018. Reservations for in-person and webinar comments close at the same time. The proposals of the National Organic Standards Board (NOSB), as a part of its ongoing review of practices and materials, are published for public comment. On our Keeping Organic Strong page, Beyond Pesticides will be providing the public with a listing and analysis of the issues under consideration of the Board when it meets in Saint Paul, MN on October 24 – 26, 2018. You can view USDA’s announcement of the NOSB’s meeting and proposals here. Issues before the NOSB include materials allowed in organic production as well as some policy issues. Materials are either the subject of petitions or the subject of sunset review (concerning whether to be allowed for another 5 years). To be allowed, materials must have evidence summarized in the proposals that they meet the OFPA requirements of essentiality, no adverse effects on humans and the […]

(Beyond Pesticides, September 14, 2018) A lawsuit first filed nearly a decade ago over dioxin contamination released from the storage of chemical treated utility poles was settled this week in U.S. District Court in San Francisco. Judge Richard Seeborg signed the agreement between California utility company Pacific Gas & Electric (PG&E) and the Ecological Rights Foundation (ERF), which commits PG&E to identifying storage yards holding treated poles, and implementing technologies that reduce dioxin levels through the year 2026. The utility poles of concern were treated with the chemical pentachlorophenol, which is regulated as a pesticide by the U.S. Environmental Protection Agency (EPA), and is known to produce dioxin as a byproduct of its manufacture. “Dioxins are among the most toxic chemicals known to science,” noted ERF attorney Fredric Evenson to KPIX 5.  “This has been a hard-fought legal battle, but in the end PG&E now appears to understand that dioxin has no business in our bay, and will now take meaningful action to benefit San Francisco Bay’s wildlife and residents who eat locally caught seafood.” As part of the settlement, PG&E is not required to admit any wrongdoing. “Because environmental stewardship is a guiding principle at PG&E, we are pleased […]

(Beyond Pesticides, September 13, 2018) House proposal would wipe out communities’ power to restrict pesticides. In an effort to protect the rights of communities nationwide, over 60 local officials from across the country sent a letter to Congress today opposing a farm bill provision that takes away local governments’ authority to restrict hazardous pesticides. The signatories are urging the farm bill conference committee to reject a “poison pill” rider that will preempt local governments, making the entire legislation unacceptable. Section 9101 of the House version of the farm bill will institute federal preemption of local pesticide policies, a move that will overturn a decades-old Supreme Court decision and prevent communities from adopting protective laws that meet the needs of their residents or unique local environment. The letter urges the conference committee to reach an agreement on a final 2018 farm bill that does not include this rider. It was signed by over 60 local officials in 39 communities from 15 different states, ranging from North Miami, FL to South Euclid, OH, West Hollywood, CA and Maui, HI. The County Council of Montgomery County, MD, which passed a landmark policy on toxic pesticides, also sent a letter to the farm bill conference committee. […]

(Beyond Pesticides, September 11, 2018) A report released this summer by the nonprofit group The Cornucopia Institute helps consumers avoid ‘factory farmed’ dairy products in light of disturbing revelations uncovered in a 2017 Washington Post investigation of major organic brands. The report, The Industrialization of Organic Dairy, traces the broken promises of many major dairy companies and provides a scorecard enabling consumers to review brands for their overall sustainability and adherence to truly organic standards. “With the USDA’s failure to protect ethical industry participants and consumers from outright fraud, using our Organic Dairy Scorecard is a way for organic stakeholders to take the law into their own hands,” said Mark A. Kastel, codirector and senior farm policy analyst of Cornucopia, on the group’s website. “In every market and product category, consumers can vote in front of the dairy case to economically support authentic organic farmers while simultaneously protecting their families.” The Washington Post’s 2017 report found that Aurora Organic Dairy, a major milk supplier for big box retailers like Walmart and Safeway, is producing milk that was less nutrient dense compared to small-scale organic family farms. Information on nutritional deficits in this milk was preceded by an earlier 2014 Cornucopia […]

(Beyond Pesticides, September 10 2019) Does your community spray toxic pesticides for mosquitoes? In a well-intentioned but ill-informed attempt to prevent mosquito-borne illness such as West Nile virus, many communities spray insecticides (adulticides) designed to kill flying mosquitoes. If your community is one of these, then your public officials need to know that there is a better, more-effective, way to prevent mosquito breeding. Tell your public officials to stop spraying pesticides and adopt a mosquito management plan that protects public health and the environment. The problem with mosquito pesticides. Two classes of insecticides are favored by mosquito spray programs –organophosphates and synthetic pyrethroids. In order to better target flying mosquitoes, adulticides are generally applied as ultra-low-volume (ULV) formulations that will float in the air longer than usual. Organophosphates, which include malathion (Fyfanon), naled (Dibrom), and chlorpyrifos (Mosquitomist), are highly toxic pesticides that affect the central nervous, cardiovascular, and respiratory systems. Symptoms of poisoning in humans include: numbness, tingling sensations, headache, dizziness, tremors, nausea, abdominal cramps, sweating, incoordination, blurred vision, difficulty breathing, slow heartbeat, loss of consciousness, incontinence, convulsions, and death. Some organophosphates have been linked to birth defects and cancer. Breakdown times range from a few days to several months, depending […]

(Beyond Pesticides, September 7, 2018) As the marijuana industry gears up for exploding markets created by the increasing number of states that permit medical and/or recreational cannabis use, the quality of marijuana products is emerging as an important issue for patients and consumers. Beyond Pesticides identified this concern back in the winter of 2014–2015, and pointed to the importance of organic production practices for the emerging industry. As of July 1, California’s mandated testing of cannabis became effective, and initial results are in. New Frontier Data CEO Giadha Aguirre de Carcer is pointing to those results as a threat to the medicinal cannabis market. She notes that 84% of 2016 product batches tested were found to harbor pesticide residue; and that in the recent California round of assays, 20% failed established standards due to contamination from pesticides, bacteria, or processing chemicals, and in some cases, inaccurate labeling. Ms. de Carcer, speaking to attendees at the Benzinga Cannabis Capital Conference in Toronto recently, said that cannabis producers must reduce the pesticide contamination in their products, at the very least because of consumer concerns that will translate to the marketplace. At that conference, she said, “Those are troublesome figures. . . . When we […]

(Beyond Pesticides, September 6, 2018) Red swamp crayfish have long been associated with Louisiana and Gulf Coast bayous, but the species has found new homes throughout the world over the last 70 years, and evidence is showing that their introduction may alter ecosystems in ways that increase mosquito populations and human disease risk.  In late August, researchers at the University of California, Los Angeles and Pepperdine University published new evidence in the journal Conservation Biology associating non-native crayfish in California streams with declines in dragonflies that would otherwise eat local mosquito populations. As mosquito species and disease vectors shift in response to a changing climate, influxes of non-native species and their impacts on ecosystems add another layer of complexity to communities aiming to manage mosquitoes and other vector-borne diseases. Red swamp crayfish (Procambarus clarkii) are native to the U.S. Gulf Coast, but as a result of the aquarium pet trade, and their use as fish bait, have established opportunistic populations in wild ecosystems throughout the world – in every continent except Australia and Antarctica. In Southern California, researchers observed higher levels of mosquitoes in streams where the non-native crayfish have been found. To further understand the impact of this species […]

(Beyond Pesticides, September 5, 2018) Local Limits on Spraying Monsanto’s Toxic Weed Killer in Parks, Playgrounds, and Schoolyards. More than 50 city and county ordinances banning the use of the toxic weed killer glyphosate on local playgrounds, parks and schoolyards could be overturned by a provision championed by House Republicans in their version of the farm bill, a Beyond Pesticides and EWG analysis found. A four-page provision tucked away in the 748-page farm bill passed by the U.S. House of Representatives in June would likely preempt local governments from adopting their own pesticide regulations, including ordinances that prohibit the use of glyphosate, the active ingredient in Monsanto’s Roundup, in parks and playgrounds. Beyond Pesticides found that 58 local ordinances ban the use of glyphosate. Overall, 155 local ordinances that regulate the use of toxic chemicals in parks and playgrounds could be preempted by Sec. 9101 of the House’s farm bill. Glyphosate is classified by the state of California as a chemical known to cause cancer, and as a probable carcinogen by the World Health Organization. Earlier this month, a San Francisco jury ordered Monsanto to pay $289 million to a school groundskeeper who said years of working with Roundup caused his terminal cancer. […]

(Beyond Pesticides, September 4, 2018) Close on the heels of the recent landmark California decision against Monsanto, maker of the glyphosate-based pesticide Roundup, Vietnam has demanded that the company pay damages to the many victims of its Agent Orange herbicide and defoliant, which Monsanto supplied to the U.S. military during the Vietnam War. (Monsanto was not the only U.S. manufacturer of the compound; there were nine in total.) U.S. forces, in a program dubbed Operation Ranch Hand, used more than 13 million gallons of the compound in Vietnam — nearly one-third of the 20 million gallons of all herbicides used during the war in Laos, Cambodia, and Vietnam. In Vietnam alone, 4.5 million acres were impacted by Agent Orange. Nguyen Phuong Tra, a spokesperson for Vietnam’s foreign ministry, said, “The [U.S.] verdict serves as a legal precedent which refutes previous claims that the herbicides made by Monsanto and other chemical corporations in the U.S. and provided for the U.S. army in the war are harmless. . . . Vietnam has suffered tremendous consequences from the war, especially with regard to the lasting and devastating effects of toxic chemicals, including Agent Orange.” Around the world, the U.S. case may be sparking […]

(Beyond Pesticides, August 27, 2018) Beyond the visual and audial charms of some bird species, insect-eating birds play a significant role in controlling pests that can ruin crops or ravage forests. A meta-study by Martin Nyffeler, Ph.D. of the University of Basel in Switzerland finds that globally, birds annually consume 400-plus million metric tons of various insects, including moths, aphids, beetles, grasshoppers, crickets, and other arthropods (invertebrate organisms with exoskeletons, paired and jointed appendages, and segmented bodies, such as insects, crustaceans, and spiders). This research reviews 103 studies that examine the volume of insects consumed by various birds in seven of the world’s major biomes. In consuming such volumes of insects that can inflict damage on crops, trees, and other plants on which organisms may feed or otherwise depend, birds provide significant services to ecosystems, to denizens of habitats, and to human food system and economic interests; they also keep local ecosystems in balance. Threats to birds — and thus, to those ecosystem services — include those from pesticide use. Of the 10,700 known bird species distributed across the planet, more than 6,000 are primarily insectivorous. The study indicates that forest-dwelling birds consume the majority of insects (approximately 300 million metric […]

(Beyond Pesticides, August 24, 2018)  We must stop the adoption of a law that will prevent local communities from restricting pesticides. Request that Minority Leader Rep. Nancy Pelosi lead the effort to protect a basic principle of local democratic decision making, especially in light of inadequate federal environmental and health protections. As a member of the Farm Bill Conference Committee between the U.S. House of Representatives and the U.S. Senate, Rep. Pelosi can stop this provision, which was unanimously rejected by Democrats in the House and is not in the Senate Farm Bill. Tell Nancy Pelosi to stand up for democracy, public health, and environmental protection in the Farm Bill! In June, the U.S. House of Representatives passed H.R.2 (the Farm Bill) with a provision that prohibits local governments from restricting pesticide use on private property within their jurisdictions. Existing local laws in two states, Maine and Maryland, will be overturned with final passage of this law. In those 43 states that forbid local pesticide laws by state law, future reconsideration of such state prohibitions would be foreclosed —a squelching of local authority pushed by the chemical and pest management industries. The fight to defend the authority of local governments to […]

(Beyond Pesticides, August 23, 2018) Three nonprofit groups today jointly announced that they have resolved a consumer-protection action filed by the groups against General Mills on August 24, 2016, concerning General Mills’ labeling of its Nature Valley Granola Bars as “Made with 100% Natural Whole Grain Oats.” See a copy of the Complaint. The parties, which were represented by Brooklyn, N.Y- and Washington, D.C-based Richman Law Group, were able to resolve the claims without going to trial. At a time specified by the agreement, packaging for General Mills Nature Valley Granola bars will no longer bear the term “100% Natural Whole Grain Oats.” Beyond Pesticides is a national grassroots non-profit organization headquartered in the District of Columbia that works with allies in protecting public health and the environment to lead the transition to a world free of toxic pesticides. For more information, see www.beyondpesticides.org.  Moms Across America is 501(c)3 non profit and a national coalition of unstoppable moms raising awareness about GMOs and toxins in our food and environment. Their motto is “Empowered Moms, Healthy Kids.” Visit www.momsacrossamerica.org. The Organic Consumers Association (OCA) is an online and grassroots non-profit 501(c)3 public interest organization campaigning for health, justice, and sustainability. The Organic Consumers Fund is […]

(Beyond Pesticides, August 22, 2018) Mothers with high levels of DDT’s major metabolite, DDE, are more likely to have their children diagnosed with autism, according to a study published in The American Journal of Psychiatry this month. Though this study links autism to long-banned DDT, it raises significant concerns about legacy contamination from this chemical, which remains ubiquitous in the environment and in human bodies. With an increasing number of studies linking autism and other developmental disabilities to pesticides, the need to transition to safer, organic methods of farming is now more important than ever before. The study, Association of Maternal Insecticide Levels With Autism in Offspring From a National Birth Cohort, measured maternal serum levels of Finish women during early pregnancy whose children were born between 1987 and 2005. Specimens were analyzed for DDE as well as PCB contamination. Mothers with DDE at the highest 75% threshold reportedly had a 132% (1.32x odds ratio) increased risk of having a children diagnosed with autism after adjusting for confounders such as age and history of psychiatric disorders. Moms above the 75th percentile had their chances of a child’s autism diagnosis increase by 221% (2.21x odds ratio). The study found no connection […]

(Beyond Pesticides, August 21, 2018) Please comment by Thursday, August 23, midnight. The Trump Administration is proposing to weaken or repeal virtually all of the modest improvements to the Risk Management Plan (RMP) adopted in January 2017. While this proposal has broad implications for communities near pesticide manufacturing plants, according to Environmental Justice Health Alliance for Chemical Policy Reform, “EPA itself admits that the proposed rollback will disproportionately endanger communities of color and low-income communities. . .” “EPA concludes that there is evidence that risks from RMP facilities fall on minority and low-income populations, to a significantly greater degree than those risks affect other populations. Therefore, EPA believes that this action may have disproportionately high and adverse human health or environmental effects on minority populations, low-income populations and/or indigenous peoples, as specified in Executive Order 12898 [Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations].” (EPA, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, 83 FR 24881, 40 CFR Part 68 [EPA–HQ–OEM–2015–0725; FRL–9975–20– OLEM], RIN 2050–AG95.) Tell the Trump Administration to reject the proposal to rollback disaster prevention plans for chemical plant accidents (see suggested comment below) As has become more evident with the […]

(Beyond Pesticides, August 17) Please comment by the deadline of Monday, August 20, 2018, 11:59 pm EDT. The White House Council on Environmental Quality (CEQ) has announced plans to weaken one of our country’s bedrock environmental laws, the National Environmental Policy Act (NEPA). NEPA provides a foundation for environmental law in the U.S., and requires a precautionary approach that is stronger than other laws. NEPA requires the government to investigate and publish results concerning all alternatives –including a “no action” alternative of major federal actions. While the NEPA regulations can be improved, the current administration has been dismantling environmental protection programs. We do not believe that this is the time to open up NEPA regulations, given the importance of this program. Tell the Trump Administration to enforce current CEQ regulations –during this period when we are seeing serious degradation of the environment with the loss of species 100 to 1000 times the normal rate, tropical diseases advancing into temperate regions in step with global climate change, and elevated environmentally induced diseases, such as cancer, asthma, and autism. The American Bird Conservancy and other organizations are submitting detailed comments, which can be viewed here for more background. CEQ is accepting comments through Regulations.gov. […]

(Beyond Pesticides, August 16, 2018) The jury verdict last week awarding groundskeeper Dewayne “Lee” Johnson $289 million in compensatory and punitive damages because of the carcinogenic effect caused by the herbicide glyphosate/Roundup, which he used, brought to the forefront a long standing concern about inadequate regulation of hazardous pesticides and chemical industry corruption. In the case, the jury heard from numerous scientists and medical experts, including Christopher Portier, Ph.D., who has researched the toxicity and carcinogenicity of glyphosate. One of the challenges in the court case was overcoming the lack of regulatory action on glyphosate, despite the overwhelming science indicating its adverse effects, including its connection to non-Hodgkin lymphoma. Globally, food safety agencies have spent the past few years insisting that glyphosate is not carcinogenic. Health and environment advocates point to the 2015 International Agency for Research on Cancer (IARC) designation of glyphosate as a “probable carcinogen” as the knell to which regulators, pesticide users, and the public should pay attention. The jury listened and considered the scientific facts. Glyphosate has perhaps been the subject of more controversy than any other pesticide in recent memory. Advocates in the scientific and environmental realms note the multiple risks its use represents, while […]

(Beyond Pesticides, August 13, 2018) Tell USDA to Follow the EU in Classifying New Mutagenesis Techniques as GMO. The Court of Justice of the European Union has highlighted the fact that failing to classify mutagenesis (purposeful changes in DNA) as genetic engineering is a backdoor way of allowing GMOs (genetically modified organisms) without labeling them as such. The court issued an opinion on July 25, saying, “Organisms obtained by mutagenesis are GMOs [genetically engineered organisms] and are, in principle, subject to the obligations laid down by the GMO directive.” Although the opinion does not apply to techniques that “have been conventionally used in a number of applications and have a long safety record,” the court says that member states may subject even those organisms to the obligations of the GMO or other directives. The court finds that the risks of new mutagenesis techniques, may yield results –and risks— similar to those of transgenesis (introducing genes from other organisms), and should thus be regulated as genetically engineered organisms. Tell USDA to classify mutagenesis techniques as GMO. This issue is one on which the Agricultural Marketing Service (AMS) of the U.S. Department of Agriculture requested comment during an informal comment period that ended July […]

(Beyond Pesticides, August 12, 2018) In a stunning legal victory for a man who contracted non-Hodgkin lymphoma (NHL) after using the herbicide glyphosate (Roundup), groundskeeper Dewayne Johnson won a $289 million jury verdict against the chemical’s manufacturer, Monsanto. The jury on August 10, 2018 awarded the 46-year old Mr. Johnson $39 million in compensatory damages, and $250 million in punitive damages. The jury found that Monsanto acted with “malice or oppression.” “We applaud and thank Mr. Johnson, and his family and attorneys, for persevering in this litigation, which sets a critically important standard for protecting people’s right not be poisoned by pesticides in the marketplace,” said Jay Feldman, executive director of Beyond Pesticides. Mr. Feldman continued: “While we know that the jury verdict cannot restore Mr. Johnson’s health, we believe that the verdict is a clarion call to manufacturers that ignore the devastating impact that their products can have on unsuspecting workers, consumers, and families. We look forward to the day in the not-too-distant future when we recognize as a society that products like glyphosate (Roundup) are not necessary, and effective and affordable land and building management can be achieved without toxic chemicals. The case should also signal to all […]

(Beyond Pesticides, August 10, 2018) The U.S. Environmental Protection Agency (EPA) must ban a widely used organophosphate pesticide linked to brain damage in children, the 9th Circuit Court of Appeals ruled yesterday. The appellate court ordered EPA to finalize its proposed ban on chlorpyrifos, produced by DowDupont, based on undisputed findings that the pesticide is unsafe for public health, and particularly harmful to children and farmworkers. The ruling comes in a lawsuit brought by a coalition of labor and health organizations, represented by Earthjustice. In the absence of EPA action, states have started to stand up. In May, the state legislature in  Hawaii passed legislation, which took effect in May, to become the first state to ban the chemical. On July 30, the California Department of Pesticide Regulation (DPR) released its scientific assessment concluding that the organophosphate insecticide, chlorpyrifos, should be listed as a Toxic Air Contaminant (TAC) in the state based on evidence of its neurological effects and exposure risks of concern. Legislation is also pending in Congress to ban chlorpyrifos and similar pesticides nationwide. Chlorpyrifos is a dangerous nerve agent pesticide that can damage the developing brains of children. Prenatal and early life exposure to chlorpyrifos is linked to lower birth weight […]

(Beyond Pesticides, August 6, 2018)  Say “No” to Trump’s Supreme Court Pick. President Donald Trump’s nominee for Supreme Court Justice, Brett Kavanaugh, would be disastrous for workers, public health, and our environment. Judge Kavanaugh’s record shows he consistently puts the interests of big business and polluters over those of public health and the environment. Tell your Senators to vote NO on Judge Kavanaugh’s confirmation. As a circuit court judge, Kavanaugh gutted requirements for endangered species recovery and overturned efforts to protect critical habitat. He has opposed workers’ rights. He has consistently tried to undermine EPA safeguards to protect clean air and our climate. His decisions wrongfully delayed rules to protect the air we breathe — rules that the EPA estimated would prevent thousands of premature deaths. The Center for Biological Diversity says, “It’s not an exaggeration to state that Kavanaugh’s judicial philosophy will kill Americans and cause wildlife extinctions.” In short, if Kavanaugh is confirmed, special interests will be in the driver’s seat as the court strips away 40 years of environmental progress. Tell your Senators to vote NO on Judge Kavanaugh’s confirmation. Letter: President Trump’s nominee for Supreme Court Justice, Brett Kavanaugh, would be disastrous for workers, public health, and our environment. […]

(Beyond Pesticides, August 3, 2018) Documents made public in late July show that the U.S. Environmental Protection Agency (EPA) let Monsanto write its own rules after farmers and the public raised red flags over crop damage and contamination caused by its new line of dicamba herbicides. As part of the discovery process initiated by a lawsuit against EPA’s approval of its new dicamba product, called “XtendiMax with Vapor Grip Technology,” emails released (start at p. 147) show Monsanto line-editing regulations first proposed by EPA. This is only the latest in a long string of instances where EPA has worked hand in glove with the agrichemical industry it is charged with overseeing. When the new regulations were released, Beyond Pesticides’ noted broad criticism that the changes will not adequately address the damage caused by this new herbicide. The newest product in the agrichemical industry’s predictable trajectory toward increasingly toxic cropping systems, XtendiMax was developed to be sprayed on corn and soy genetically engineered to tolerate the herbicide. As its flagship Roundup Ready products have failed to control resistant weeds in farm fields throughout the U.S., Monsanto and others in the agrichemical industry continue to reach back towards older, more toxic pesticides […]

(Beyond Pesticides, August 2, 2018) Weed scientists from the University of Missouri (UM) have just published evidence of a water hemp population resistant to six different herbicides. The study is sending shock waves throughout the chemical-intensive agricultural community, particularly in light of the plant’s resistance to 2,4-D. In its reporting on the study, KTIC Rural Radio begged the question, “If we’re already seeing 2,4-D resistance now, what will happen when use of the herbicide becomes even more commonplace?” KTIC is referring to the impending commercialization of products like Enlist Duo, developed by DowDupont in an attempt to address widespread weed resistance to glyphosate. Enlist Duo is an herbicide containing both glyphosate and 2,4-D, and is intended to be sprayed only on crops genetically engineered (GE) to tolerate exposure to both chemicals. However, with growing reports like this, many farmers may begin to rethink their approach. In 2014, a farmer contacted UM indicating that water hemp was not responding to 2,4-D during a regular ‘burndown’ the farmer conducted before planting a new crop. (Chemical-intensive farmers will often use a synthetic herbicide to clear their field for new plantings.) The farmer had also used other herbicides, fomesafen and glyphosate, in this process […]