(Beyond Pesticides, November 14, 2014) In the face of staggering declines of monarch butterflies, more than 40 leading scientists and 200 organizations and businesses this week urged the Secretary of the Department of the Interior, Sally Jewell, to protect these butterflies under the Endangered Species Act (ESA). These groups and scientists are supporting the formal petition to the U.S. Fish and Wildlife Service (FWS) submitted this summer, which seeks federal protection for monarch butterflies. Forty scientists from around the U.S. and Mexico signed on to a letter requesting protected status for the butterflies and for FWS to recognize the importance of continued research by scientists and citizen scientists in understanding and conserving the monarch butterfly and its habitat. The scientists also request FWS to streamline the permitting process, so that scientific and conservation research and citizen science activities are encouraged rather than deterred by a listing. In a separate letter, over 200 environmental groups and businesses called on FWS to take swift and effective action by granting the monarch butterfly protection as a threatened species under the ESA. Both letters come in support of a formal petition to FWS seeking federal protection for monarchs. The petition was filed in August […]

(Beyond Pesticides, November 12, 2014) The Oregon Department of Agriculture (ODA) has issued two civil penalties totaling $16,000 in connection with a pesticide application of imidacloprid, a chemical in the neonicotinoid class of insecticides connected to widespread bee decline, this summer that resulted in the death of nearly 1,000 bees at a Eugene apartment complex. Although ODA is taking actions to address pollinator protection, the frequent and continued occurrence of pesticide-related bee deaths indicates that current laws still fall woefully short of preventing these incidences. ODA’s Pesticide Program conducted an investigation that determined that Glass Tree Care and Spray Service, Inc. and its pesticide applicator violated Oregon’s pesticide control law through gross negligence. ODA is authorized to issue a civil penalty of up to $10,000 for violations that are the result of gross negligence, the maximum in this case issued to the company, a commercial pest control  operator based in Eugene. In addition, the applicator, James P. Mischkot, Jr., was issued a $6,000 civil penalty. When the incident in Eugene occurred, the trees were in full bloom and attracting pollinators.  In this case, ODA determined that the company and its applicator knew or should have known of this standard of […]

(Beyond Pesticides, November 3, 2014) A  state ban of neonicotinoid insecticides, which have become increasingly linked to the decline of honey bees and other pollinators worldwide, is under consideration  in Minnesota, making it the first state to move in this direction.  A revised version of an earlier review, “Scoping a Review of Neonicotinoid Use, Registration and Insect Pollinator Impacts in Minnesota,” published last  week, proposes a range of state action, including “restrictions on or cancellation of products,” The review  also calls for a “clarification of label provisions and enforcement designed to protect non-target organisms and the environment, targeted enforcement-related education, ”¦ suggesting research topics that would further the understanding of non-target impacts from neonicotinoids for policymakers, funding agencies, regulatory agencies, etc., and proposing other measures designed to minimize the impacts of pesticide use on human health and the environment.”  The earlier  review, issued in March, was heavily criticized for not including the option  of banning neonicotinoids. The state has already taken steps to address the  environmental crisis  linked to neonicotinoids. This year, Minnesota legislators passed a labeling law  that  will identify bee-friendly plants for  consumers. On a local level, Shorewood, MN became the first city in the state to pass […]

(Beyond Pesticides, October 21, 2014) Due in large part to the use of rodenticides in the cultivation of illegal marijuana grow operations, earlier this month the U.S. Fish and Wildlife Service (FWS) announced a proposal to list fishers, medium sized carnivores of the weasel family, as threatened under the Endangered Species Act. Fishers are the second species in the West that have been recognized by regulators as adversely affected  by illegal marijuana grow operations. Coho salmon have also been affected as a result of pesticide and fertilizer use, water withdrawals, and clear-cut logging that have silted, dried up, and polluted streams where the salmon run. Fishers, which are found throughout North America and have been part of the forests in Pacific states for thousands of years, have all but virtually disappeared in much of Washington, Oregon and California, according to FWS. Illegal marijuana grow operations have been a troubling source of wildlife deaths as growers often use “industrial-sized quantities of poison in forests to fend off rodents,” says Humboldt County District Supervisor Rex Bohn. A study published in PLOS One in 2012 found that 79% of fishers surrounding an illegal marijuana grow operation had been exposed to anticoagulant rodenticides. Fishers […]

(Beyond Pesticides, September 25, 2014) Last week, the Borough of Skagway, Alaska passed a comprehensive vegetative maintenance pesticide ordinance, joining a growing number of localities across the country in enacting restrictions that protect human health, wildlife, and the wider environment from the hazards associated with unnecessary pesticide use. Among a number of notable accomplishments, Skagway’s Ordinance 14-15 makes it the first municipality in Alaska to ban the use of bee-toxic neonicotinoids by government employees. However the new law goes further, prohibiting the sale and use of neonicotinoid-containing products on all public and private lands in the Borough of Skagway. The state of Alaska is one of seven states that affirms the right of a local jurisdiction  to restrict pesticide use throughout its jurisdiction by not adopting law that preempts localities. Skagway, Alaska’s Ordinance 14-15 also: Prohibits the sale and use of persistent herbicides (persistent according to the US Composting Council) on public and private property. Prohibits the use of restricted herbicides within 300 feet of any waterway. Creates a list of restricted pesticides (based in part upon the list of pesticides restricted in Takoma Park, Maryland). Although the ordinance establishes a waiver system by which restricted pesticides may be used, […]

(Beyond Pesticides, September 16, 2014) In light of President Obama’s Memorandum directing federal agencies to take action on pollinator declines, groups and members of Congress are calling on the U.S. Environmental Protection Agency (EPA) to take meaningful steps to save our bees. In a letter to EPA, U.S.Representatives Earl Blumenauer (D-OR) and John Conyers (D-MI) are urging the agency to follow the lead of the U.S. Fish and Wildlife Service (FWS) and revise pesticide regulations to protect pollinators from exposure to bee-toxic neonicointoids. >>Ask Your Representative to Join the Call: Urge Your Member of Congress to Sign-on to the Blumenauer-Conyers Letter to EPA! Pollinators, including honeybees, bumblebees, butterflies, and other insects, play a critical role in our agriculture systems. More than 70% of America’s food sources are pollinated by bees and the worldwide economic value of bee”pollinated crops is as high as $125 billion per year. Since 2006, however, beekeepers have lost more than 30% of their hives annually””a huge threat to the vitality of our farms. Pollinators are a critical driver of healthy, nutrient-dense foods. One in three bites of food depends on honey bees and other pollinators, and without them food prices are sure to rise and some […]

(Beyond Pesticides, September 12, 2014) A new U.S. Geological Survey (USGS) report finds that levels of pesticides continue to be a concern for aquatic life in many of the Nation’s rivers and streams in agricultural and urban areas. The study, which documents pesticide levels in U.S. waterways for two decades (1992-2011), finds pesticides and their breakdown products in U.S. streams more than 90 percent of the time. Known pesticide water contaminants, such as atrazine, metolachlor, and simazine, continue to be detected in streams more than 50 percent of the time, with fipronil being the pesticide most frequently found at levels of potential concern for aquatic organisms in urban streams. According to the USGS report, “An Overview Comparing Results from Two Decades of Monitoring for Pesticides in the Nation’s Streams and Rivers, 1992—2001 and 2002—2011,” featured in the journal, Environmental Science and Technology and part of the agency’s ongoing National Water-Quality Assessment Program, the proportion of streams with one or more pesticides that exceed an aquatic-life benchmark (or guideline) is similar between the two decades for streams and rivers draining agricultural and mixed-land use areas, but much greater during the 2002-2011 for streams draining urban areas. During both decades, one or […]

(Beyond Pesticides, September 5, 2014) A study published in a scientific journal finds that the U.S. Environmental Protection Agency (EPA) favors the chemical  industry when making determinations on pesticide safety. Under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA), EPA conducts  risk assessments to determine whether a new or existing chemical is eligible for registration or reregistration and therefore able to enter or remain on the market. The study’s conclusions raise serious concerns for both environmental and human health protection because of EPA’s practice of inviting bias and underestimating potential harm. The study, which will be in the October issue of BioScience, highlights the case of atrazine, an herbicide that has been linked to cancer, endocrine disruption, birth defects, and reproductive effects. In their study, Michelle Boone, Ph.D., of Miami University, and her colleagues find that most pesticide toxicity tests used in risk assessments are conducted by pesticide manufacturers themselves. The authors contend that this can result in conflicts of interest. Additionally, strict methodological criteria, such as the types of containers in which exposed specimens are raised, often mean that potentially relevant studies are barred from EPA’s assessment process. The agency reassessed atrazine  based on a sole, manufacturer-funded study, finding […]

(Beyond Pesticides, August 29, 2014) Environmentalists issued a legal petition to the U.S. Fish and Wildlife Service on Tuesday calling for the protection of the monarch butterfly as a threatened species under the  Endangered Species Act (ESA). Monarch butterflies, a striking and familiar symbol of beauty and nature in the U.S., have had their population decline by a staggering 90 percent in the past two decades alone, most likely due to a significant loss of habitat of more than 165 million acres – an area about the size of Texas -as well as nearly a third of their summer breeding grounds. Part of the decline of monarch butterflies  stems from the loss of milkweed, a native plant where the butterflies lay their eggs and is their main food source. Although little use to farmers, milkweed is an important plant to butterflies, wasps, and bees. A recent study attributed the disappearance of milkweed plants primarily to the use of genetically-engineered (GE) corn and soybean crops. The widespread adoption of GE agriculture and the ever-growing use of herbicides are contributing extensively to the loss of milkweed areas. Scientists also point to the prolific use of herbicides in the Midwest eliminating these plants, […]

(Beyond Pesticides, August 18, 2014) In a victory for environmental groups, conservationists, and fishing groups, the U.S. Environmental Protection Agency (EPA) finalized a settlement last Wednesday to restore no-spray buffer zones around waterways to protect imperiled salmon and steelhead from five toxic pesticides.   An initial agreement was reached in June, when it underwent public comment, and was ultimately filed August 13 without any substantive changes. The settlement follows litigation filed by Earthjustice, representing the Pacific Coast Federation of Fishermen’s Associations, the Northwest Coalition for Alternatives to Pesticides, and Defenders of Wildlife, back in 2010 that called for EPA adoption of reasonable fish protections from the insecticides. The buffers apply to salmon habitat throughout California, Oregon, and Washington to prohibit aerial spraying of broad-spectrum pesticides diazinon, chlorpyrifos, malathion, carbaryl, and methomyl within 300 feet of salmon habitat and prohibit ground-based applications within 60 feet. “Poisoning salmon rivers puts our people out of work while creating an unnecessary and expensive public health hazard,” said Glen Spain of the Pacific Coast Federation of Fishermen’s Associations, a West Coast commercial fishing industry trade association and co-plaintiff. “This agreement helps the coastal and inland communities that depend on salmon for their livelihoods and provides […]

(Beyond Pesticides, August 7, 2014) Residents of St. Louis, Michigan aren’t used to seeing large excavators and dump trucks haul piles of dirt from their front yards or entire blocks of big, neighborhood trees felled. What they are used to seeing are dead birds ””sometimes even spontaneous, mid-flight deaths of the birds”” and because of a toxic series of events, disasters, and delays spanning decades, the two sights are inextricably connected. As one St. Louis resident described to the Detroit Free Press, dozens of dead robins and blackbirds had been collected from her backyard in the 18 years she has lived there, with the most recent just a couple weeks ago. This experience and other similar stories from the area prompted researchers at Michigan State University (MSU) to start figuratively and literally digging. Matt Zwiernik, Ph.D., an environmental toxicologist at MSU, and volunteers collected 29 dead birds, including 22 robins, last year from a nine-block residential area in St. Louis. The scientific sampling was only a small portion of the dead birds they could have collected, Dr. Zwiernik explained to reporters at the Detroit Free Press, as time, distance, logistics, and access to property sometimes limited collection efforts. Nevertheless, it […]

(Beyond Pesticides, July 31, 2014) Scientific researchers on opposite sides of the globe are coming to the same startling conclusion concerning very different species: what was once abundant is no longer and slipping away at drastic rates. Common Declines In the Pacific Northwest, a partnership of government scientists and environmental organizations have taken to the water to collect data on populations of certain species of marine birds. Unlike most research that  focuses on threatened or endangered species, however, this census targets birds like marbled murrelets, common murres, and long-tailed ducks ””thought to be commonplace and abundant. Thoughts have changed. Population counts from 2014 show these “common” species are in decline, and in several cases, steep decline. For example, population counts for the common loon have decreased from 1978/1979 by 64 percent, scoters by 77 percent, long-tailed ducks by 94 percent and western grebes by a scary 99 percent. Other species in general decline include the marbled murrelet, common murre, and glaucous-winged gull. On a different continent, the International Union for the Conservation of Nature (IUCN) conducted a wide swath of international scientific research and advocacy efforts targeting environmental and species monitoring and conservation. And much like the Pacific Northwest, recent […]

(Beyond Pesticides, July 17, 2014) The U.S. Fish and Wildlife Service (FWS) issued an internal memorandum last week that  signals a significant shift in its pesticide-application policies for Pacific Region wildlife refuges: no more neonicotinoids. The memorandum, dated July 9, 2014, states, “The Pacific Region will begin a phased approach to eliminate the use of neonicotinoid insecticides (by any method) to grow agricultural crops for wildlife on National Wildlife Refuge System lands, effectively immediately. By January 2016, Region 1 will no longer use neonicotinoid pesticides in any agricultural activity.” In February 2014, environmental groups, including Beyond Pesticides, filed a legal petition to ban the use of neonicotinoids on wildlife refuges. The new guidelines go on to explain that the change in policy will also affect the transition period through 2016. During that time, refuge managers must exhaust all remedies before application or use of neonicotinoids, including the use of neonicotinoid-treated seeds. Additionally, starting in 2015 all refuge managers must prepare and submit a Pesticide Use Proposal (PUP) in order to apply any neonicotinoids during the transition to the ban. While not a direct response to the petition filed earlier this year calling for a ban of genetically-engineered crops and neonicotinoids […]

(Beyond Pesticides, June 6, 2014) On June 4,  after a two year dispute between the Environmental Protection Agency (EPA) and a coalition of conservation organizations and fishing groups, an agreement  was finally reached to set reasonable no-spray buffer zones to protect salmon from five harmful insecticides: diazinon, chlorpyrifos, malathion, carbaryl, and methomyl. These buffer zones protect salmon habitat by stopping aerial spraying of pesticides within 300 feet, and ground based spraying within 60 feet of salmon supporting waters. According to the agreement, it also provides detailed notifications to state regulators, pesticide applicators, farmers and the public about the mandatory no-spray buffer zones. These stipulations will remain in place until the National Marine Fisheries Service has completed their analysis of the impacts of those five pesticides.  Then, once the analysis is completed, EPA will execute permanent protections based on their findings. EPA is required by law under the Endangered Species Act to protect what little salmon are left on the Pacific Coast. Salmon are a  critical indicator of how well we are maintaining both marine and terrestrial ecosystems, because their habitats are in streams, lakes, rivers, estuaries and the ocean. The fish  are extremely sensitive to changes in water quality, and […]

(Beyond Pesticides, June 2, 2014) With Friday’s announcement that the production of deadly rodent baits will stop by year’s end, a national public health and environmental group is renewing its request of the nation’s retailers to immediately stop the sale of d-CON ® anticoagulant rodent bait products, citing the poisoning of children, pets, and wildlife. This call comes as the manufacturer of d-CON ®, Reckitt Benckiser LLC, announced an agreement today with the U.S. Environmental Protection Agency (EPA) in which it will cease production, but not sale, of the product by the end of 2014. “It is outrageous that a highly toxic product associated with the poisoning of children, pets, and wildlife remains on the market one more day, let alone for the years it will take to exhaust supplies,” said Jay Feldman, executive director of Beyond Pesticides. “One child harmed from the continued sale of this product is one child too many,” said Mr. Feldman. Between 1993 and 2008, the American Association of Poison Control Centers logged 12,000 to 15,000 poison exposure reports of children under the age of six from mouse and rat baits. Early in 2013, EPA issued a notice to cancel the registration of 12 rodenticide […]

(Beyond Pesticides, May 21, 2014) In response to recent public concern over the use of bee-killing systemic insecticides in treated nursery plants, Minnesota has just passed labeling legislation, HF 2798, which will inform consumers which plants are bee-friendly. The move follows a commitment by two Minnesota state agencies to study the impact of neonicotinoid pesticides, which ””given mounting research implicating neonicotinoids in bee declines”” beekeepers claim do not go far enough. Although the bill does not address agricultural neonicotinoid use, it is the first of its kind to ensure that nurseries keep tabs on the insecticides used on garden plants. Under the bill passed by Minnesota’s House and Senate last week, plants may not be labeled as beneficial to pollinators if they have been treated with detectible levels of systemic insecticides. Specifically, “A person may not label or advertise an annual plant, bedding plant, or other plant, plant material, or nursery stock as beneficial to pollinators if the annual plant, bedding plant, plant material, or nursery stock has been treated with and has a detectable level of systemic insecticide that: (1) has a pollinator protection box on the label; or (2) has a pollinator, bee, or honey bee precautionary statement […]

(Beyond Pesticides, May 14, 2014) New research conducted in Colorado by the U.S. Geological Service (USGS) that examines contaminant transport of biosolids ””otherwise known as sewage sludge”” in soils, has found that the toxic fertilizer can leave traces of household chemicals, antibacterial, and prescription drugs. The research adds to existing evidence of the hazards of sewage sludge fertilizer by demonstrating that chemical contaminants are sufficiently mobile and persistent that they can easily be transported to groundwater, with implication for local drinking water. The study, entitled Dissipation of Contaminants of Emerging Concern in Biosolids Applied to Nonirrigated Farmland in Eastern Colorado,  sampled  regional wheat fields treated with sewage sludge processed in a nearby sewage treatment plant in order to determine contaminant levels and transport in soils. Researchers tested for a total of 57 contaminants of emerging concerns””chemicals that are increasingly being discovered in waters. Tests found chemicals ranging from antibacterial soaps, chemical cleaners, cosmetics, fragrances, and prescription drugs, such as the antidepressant Prozac and the blood thinner Warfarin, which had migrated down the soil column. In fact, 10 of the chemicals examined migrated to depths of 7 to 50 inches over 18 months after treated sewage sludge was applied. “These compounds […]

(Beyond Pesticides, May 13, 2014) After pressure from environmental organizations, the U.S. Fish and Wildlife Service (FWS) dropped plans to spray the synthetic insecticide methoprene in favor of a biological control material  to kill mosquitoes breeding on a national wildlife refuge on the southern Oregon Coast. Several states have banned methoprene due to the chemical’s environmental impacts. The unfolding of this decision illustrates that least-toxic alternatives to manage mosquitos are effective and much safer for the environment. A major restoration at the Bandon Marsh National Wildlife Refuge in 2011 inadvertently created a number of shallow water pools, a perfect habitat for mosquito larvae. Unprecedented swarms of mosquitoes appeared last year, which drove away campers from Bullards Beach State Park and harassed golfers at local courses. FWS did not take into account that this restoration project could create mosquito habitat and initially released a plan to manage mosquitos with methoprene and mineral oil. The insect conservation group Xerces Society, the Center for Food Safety, and others urged the agency to reconsider, arguing the pesticides were a threat to the food chain and the mosquitoes, Aedes dorsalis, did not spread human diseases such as West Nile virus. In a supplemental environmental assessment […]

(Beyond Pesticides, April 30, 2014) A new report, released this week by author  Michele Simon  and Friends of the Earth  documents the tactics used by Bayer and other pesticide companies to delay regulatory action on neonicotinoid pesticides —a key contributor to bee declines. The report identifies public relations tactics reminiscent of those used by the tobacco industry, is now being used by Bayer, Syngenta, and Monsanto. Meanwhile, a Congressional hearing on pollinator health, with a panel dominated by industry, ignored the risks pesticides pose to pollinators, and failed to address sustainable solutions to bee decline. The report,  Follow the Honey: 7 Ways Pesticide Companies Are Spinning the Bee Crisis to Protect Profits,  uncovers the deceptive public relations tactics used by industry giants Bayer, Syngenta and Monsanto, to deflect blame from their products’ contributions to bee declines. The products in question are the chemicals now widely used for seed treatment  —neonicotinoids— as well as on residential sites. They are highly toxic to bees and have been linked to bee decline. Last year, the European Union banned the three most widely used neonicotinoids —imidacloprid, clothianidin and thiamethoxam— based on strong science indicating these insecticides can kill bees outright and make them more […]

(Beyond Pesticides, April 24, 2014) Reports of honey bee deaths have been emerging around the nation: from bee deaths in California’s almond groves and ”˜mysterious’ road-side bee deaths in Oregon, to astronomical overwintering losses in Ohio. The reports are intensifying the ecological crises of Colony Collapse Disorder (CCD) ””a phenomenon typified by the mass abandonment of hives and bee die-off. CCD poses significant issues for many agricultural crops, such as almonds, apples, cherries and blueberries, that are almost completely reliant on honey bees for their pollination services. In California, a total of 80,000 dead or damaged bee hives were reported after pollinating almond trees in the San Joaquin Valley, a region that is known for its agricultural productivity. Beekeepers have pointed to pesticides as the primary culprit. Almond pollination in California requires an army of 1,300 commercial beekeepers from around the nation. However, this year beekeepers have seen higher damages to hives than usual. Damage to the honey bee hives this spring has been so pronounced that the U.S. Environmental Protection Agency (EPA) convened an impromptu meeting with beekeepers in Los Banos, California. The meeting brought together 75 beekeepers who testified that 75 percent of their hives showed severe damage […]

(Beyond Pesticides, April 22, 2014) As we reflect on the beauty and wonder of the natural world this Earth Day and seek to restore  and preserve  the intricate web of life on the planet, we face an urgent need to stop ongoing toxic chemical contamination.  The hard truth of our time is that the natural world on which life depends  is under grave threat from numerous toxic insults resulting from mechanized and industrial human activity. Massive die-offs of beneficial organisms, increased rates of autoimmune diseases, endocrine disrupting and transgenerational chemical effects, and widespread pollution of our air and waterways —all linked to pesticides and other toxic chemicals, establish the critical  need  to adopt organic standards in sync with ecosystems. This Earth Day we ask you to spread awareness of toxic chemicals that pollute the environment. Get active to safeguard your community and the surrounding environment from toxic insults: teach your neighbors how to maintain their land without toxic pesticides, protect honeybees from neonicotinoids insecticides, aquatic species from endocrine disrupting chemicals, and the streams, lakes, and rivers we all depend on from the widespread use of harmful synthetic pesticides and fertilizers. Beyond Pesticides has the tools needed to increase environmental awareness […]

(Beyond Pesticides, April 18, 2014) Test results have confirmed that the charismatic mountain lion named P-22 ””that frequently roams the hills of the San Gabriel Mountains surrounding Los Angeles, California”” has been exposed to highly toxic rat poisons. When remote cameras in Griffith Park caught images of the puma, state park officials saw a thin mangy cat, far different from the majestic shots taken months ago by National Geographic against the Hollywood sign as a backdrop. Upon performing blood testing analysis, they found that P-22 had been exposed to anticoagulant pesticides, stoking the debate around rodenticide use, as further research suggests that these pesticide poisonings are a common occurrence. Researchers already know of the link between pesticides and mange””parasitic mites which burrow into the skin or hair follicles causing bald spots, scabbing and sore, which left untreated has contributed to the death of wild and domestic animals. Previous research by the National Park Service (NPS) has shown that bobcats that have ingested rodenticide are much more likely to suffer from mange. While the cougar has been treated with topical ointments for mange, and a dose of vitamin  D with vitamin  K as an antidote to the rat poisons, it is […]

(Beyond Pesticides, April 15, 2014) A new study released last week by the National Park Service on contaminant use in Alaska, found traces of pesticides in fish ””pesticides which have long been banned and likely never been used within the Alaskan wilderness areas. Researchers examined three Alaskan parks renowned for their remote, pristine and protected wilderness ””Lake Clark National Park, Wrangell-St. Elias National Park and Katmai National Park”” only to find that contaminants, including PCBs at concentrations exceeding those in the lower 48 states. The study, Contaminants of Emerging Concern in Fish from Western US and Alaska National Parks””Spatial Distribution and Health Thresholds, published in the Journal of the American Water Resources Association, sought to compare contaminant level found within fish across the nation. Generally, researchers found that Alaskan fish were more likely to have traces of older chemicals, while those in the lower 48 tended to be dominated by newer chemicals. The most commonly detected chemicals are PCBs, endosulfan, sulfate and p,p’-DDE, a breakdown product of DDT.  Some of these long-banned chemicals actually exceed the U.S. Environmental Protection Agency’s (EPA) guidelines for human subsistence on fish and wildlife. Among those exceeding acceptable levels, dieldrin, chlordane, and p,p’-DDE have been […]