(Beyond Pesticides, January 13, 2012) A U.S. District Judge in San Francisco has issued a ruling finding that the U.S. Department of Agriculture’s (USDA) decision to deregulate genetically engineered (GE) alfalfa was not unlawful, as has been charged by organic and environmental advocates, including Beyond Pesticides. Judge Samuel Conti of the U.S. District Court for the Northern District of California found that USDA did not act improperly by deregulating the GE Roundup Ready alfalfa, developed by Monsanto Co., and that the agency’s environmental review of the product was adequate. The plaintiffs in the case, including conventional farmers and seed growers, with Center for Food Safety serving as legal counsel, argued that the environmental impact statement (EIS) the agency prepared failed to take several critical matters into consideration in its evaluation. Among the issues neglected by the EIS are the impacts that the crop would have on endangered species, which advocates hold is required to be considered under the Endangered Species Act, as well as the potential effects that the likely increased pesticide applications would have on the environment. For these reasons, the groups argued that the EIS was woefully incomplete and that the agency’s subsequent deregulation of the GE alfalfa […]

(Beyond Pesticides, December 2, 2011) The U.S. Environmental Protection Agency (EPA) has opened a pesticide docket for information and reviews relevant to insect resistance management for plant-incorporated protectants (PIPs) -plants engineered through biotechnology to express pesticidal properties. The agency intends to collect public information on insect resistance management and monitoring for genetically engineered (GE) PIPs after expressing concern that efforts to tackle resistance issues need to be “more proactive” and effective in light of “severe” and rapidly growing insect resistance to GE crops. According to EPA’s Biopesticides and Pollution Prevention Division, the agency is reviewing insect resistance management assessments submitted by registrants in accordance with the ongoing terms and conditions of their registered PIP products. PIPs are genetically engineered to incorporate pesticidal properties in plant genes in order to ward off insects that prey on the plants. PIPs are registered as a pesticidal product under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Many GE plants such as corn, cotton and others include Bacillus thuringiensis (Bt), a bacterium with insecticidal properties whose genes have been incorporated into the plant’s own genetic material. However, recent reports have shown that these PIPs are spawning “superbugs” that have become resistant to this technology. […]

(Beyond Pesticides, November 23, 2011) A Federal Court of Canada has ordered Health Canada -the nation’s public health department- to take a second look at the impacts on amphibians of glyphosate-based pesticides, one of the most widely-used pesticides in Canada and the U.S., which includes products like Monsanto’s Roundup. The decision was the result of an action brought by a pesticide-activist and pediatrician, Josette Wier, M.D., and orders Health Canada to address requests by the public for a review of the safety of a pesticide where there is serious scientific concern about its risks. Dr. Wier’s legal challenge focused on wetlands that provide critical habitat for many species of frogs and amphibians. The original request for a special review of glyphosate-pesticides, especially those containing the “inert” ingredient polyoxyethyleneamine (POEA), and a subsequent 2009 legal challenge was brought because of her concern about possible aerial spraying of Monsanto’s pesticide in the forests near her community in Smithers. In her suit, Dr. Weir stated that the evidence “challenges the scientific validity of the previous evaluations” that led to the registration of the glyphosate herbicides containing POEA. Judge Michael Kelen of the Federal Court of Canada in his decision wrote, “[Dr. Wier] is […]

(Beyond Pesticides, October 26, 2011) A new report highlights scientific research and empirical experiences around the globe that demonstrate the failure of genetically modified (GM) seeds and crops to deliver on their advertised promises to increase yields, reduce pesticide usage, and tolerate drought with “climate ready” traits. A Global Citizens Report on the State of GMOs, “The GMO Emperor has no Clothes,” states that the on-the-ground experience in many countries discloses that GM technology has failed on all fronts, contrary to industry claims. The examples from around the globe include the financial burden borne by farmers. The report describes the cultivation of GM cotton in South Africa where the majority of farmers growing GM cotton are now in debt due to the high costs of seed, chemical, and other farm inputs. The Global Citizens Report confirms that such experiences are repeated in many countries and regions. The stories of Indian farmer indebtedness and increased suicides further emphasize the tragic costs of failed GM technology and its promises. The prevalence of Roundup Ready GM crops has led to the increases of Roundup resistant weeds in the environment. Farmers and agronomists throughout the world are alarmed by the growing epidemic of “superweeds” […]

(Beyond Pesticides, October 18, 2011) The U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) recently announced the availability of a draft environmental impact statement (EIS) that evaluates the potential environmental effects of deregulating (commercializing) sugar beets genetically engineered (GE) to be resistant to the herbicide glyphosate, commonly referred to as Roundup Ready (RR) sugar beets. APHIS considered three alternatives in the draft EIS: deny the petition seeking a determination of nonregulated status (prohibit commercial planting), make a determination of nonregulated status (allow commercial planting), or extend the partial deregulation of RR sugar beets for the root crop, with mandatory conditions and restrictions. Comments will be accepted until December 13, 2011. APHIS originally deregulated RR sugar beets in 2005. A coalition of environmental groups and organic seed companies, led by the Center for Food Safety, challenged the USDA approval in 2008. It argued that GE sugar beets would contaminate organic and non-GE farmers of related crops, such as table beets and chard, as well as increase pesticide impacts on the environment and worsen the current Roundup-resistant “superweeds” epidemic in U.S. agriculture. In September 2009, Judge Jeffrey S. White in the federal district court in San Francisco agreed, […]

(Beyond Pesticides, October 6, 2011) Representatives of the International Federation of Organic Agriculture Movements (IFOAM) presented a special declaration October 1, 2011 to the United Nations (UN), requesting that the international organization commit all of its member nations to a world without genetically modified (GMO) foods and to identify existing GMO foods on product labels. The UN declaration was written in anticipation of the GMO Right2Know March which kicked off at the UN headquarters in New York on October 1 and will end at the White House on October 16. The UN delegation included IFOAM representatives, Joseph Wilhelm, founder of Rapunzel organic products and the force behind “Gene-Free America;” and his employees.” Maria-Luisa Chavez welcomed the delegation and accepted the declaration on behalf of the UN. She will pass it on to the president of the General Assembly, the main deliberative, policymaking and representative organ of the United Nations. Mr. Wilhelm believes that consumers have the right to know whether the food they buy is genetically altered. “Twenty percent of all manufactured foods in the U.S. contains genetically modified ingredients (GMO),” he said. “We hope the Right2Know march will raise consumer awareness and influence U.S. legislators to require that labels […]

(Beyond Pesticides, September 23, 2011) In two weeks, a diverse coalition of organizations, businesses and individuals will begin to march from the Historic Flatbush Food Co-op in Brooklyn, NY to the gates of the White House to ask the Obama Administration to support labeling of genetically modified organisms (GMOs). The GMO Right2Know March will feature daily events between New York and Washington, DC October 1-16 as hundreds of marchers are expected to walk part or all of the 313 miles to the White House. The route and details on daily events can be viewed here. “Pesticide companies develop genetically engineered food crops by combining DNA from plants, animals, bacteria and viruses, to contain or resist pesticide, which results in more pesticides sold and sprayed,” says Michael Hansen, Ph.D, chief scientist of Consumers Union. “Genetically engineered foods contain untested novel foreign compounds that can be detrimental to our health, just as they are to the environment and farmers’ livelihoods. American consumers deserve the choice whether they want to eat GMOs, just like their counterparts in Europe and Japan,” says Hansen who will join the Oct 1 NYC Right2Know March kick-off rally at Prospect Park at 11am to 1pm followed by marchers […]

(Beyond Pesticides, September 19, 2011) Dubbing it the “most anti-environment House in history,” Rep. Henry Waxman (D-Calif.), ranking member on the House Energy and Commerce Committee, released a new searchable database last week listing a staggering 125 pieces of legislation that will reduce environmental protection. The bills, introduced and passed by the Republican-led U.S. House of Representatives, are aimed at limiting the authority of the U.S. Environmental Protection Agency (EPA) and other federal institutions tasked with upholding environmental laws set in place to protect human and environmental health. The database indicates that the legislation will undermine environmental laws, such as the Clean Air Act and Clean Water Act, and breaks down anti-environment bills in the 112th Congress into categories: clean energy, climate change, nuclear power, pipeline safety, pollution prevention, and public lands and coasts. This includes legislation limiting the regulatory authority of EPA by prohibiting it from regulating carbon emissions from power plants, votes to defund enforcement of the Clean Air Act and the Clean Water Act, and efforts to target federal agencies such as the Department of Interior and the Department of Energy. Recent attacks on environmental statutes, including attempts to strip the Clean Water Act of its power […]

(Beyond Pesticides, September 9, 2011) Despite rising concerns over the side effects of herbicide tolerant, genetically engineered (GE) crops, Dow AgroSciences has recently asked for approval of a new GE soybean variety that will be the first ever to be simultaneously resistant to three different pesticides. The soybean variety, which the company is calling “Enlist,” is designed to compete with Monsanto’s line of “Roundup Ready” crops, which are engineered to be resistant to the company’s glyphosate formulation. The Enlist soybean will be resistant to glyphosate as well as glufosinate and 2,4-D. Antonio Galindez, CEO of Dow AgroSciences, told Reuters that the Enlist system is the company’s “most important project ever.” This is likely due to the company’s ambitious target of taking over Monsanto’s dominance of the GE market in American agriculture. Herbicide tolerant (HT) Roundup Ready crop varieties have become nearly ubiquitous in the corn, cotton, and soybean seed markets. Dow will market the product as a replacement for Roundup Ready soybeans. If farmers are finding that weeds in their fields are not responding to applications of Roundup, Dow will argue, then planting Enlist soybeans will allow them to spray a combination of chemicals in order to eradicate the resistant […]

(Beyond Pesticides, September 2, 2011) The widely used herbicide glyphosate, the active ingredient in Roundup, has been detected in significant levels in rain and rivers in agricultural areas across the Mississippi River watershed, according to two new studies released this month by the U.S. Geological Survey (USGS). The studies’ results raise serious concerns about public exposure and potential environmental damages. Detailed results are available in “Occurrence and fate of the herbicide glyphosate and its degradate aminomethylphosphonic acid in the atmosphere,” published in Environmental Toxicology and Chemistry and in “Fate and transport of glyphosate and aminomethylphosphonic acid in surface waters of agricultural basins,” published online in Pest Management Science. Glyphosate is used in almost all agricultural and urban areas of the United States. The greatest glyphosate use is in the Mississippi River basin, where most applications are for weed control on genetically-modified corn, soybeans and cotton. Overall, agricultural use of glyphosate has increased from less than 11,000 tons in 1992 to more than 88,000 tons in 2007. The two studies conducted by USGS examine glyphosate content in air and water samples in the states of Iowa and Mississippi across two growing seasons. The results show that glyphosate is detected 60-100% of […]

(Beyond Pesticides, August 31, 2011) Widely grown corn plants that Monsanto Co. genetically modified to thwart a voracious bug are falling prey to that very pest in Iowa cornfields, the first time a major Midwest scourge has developed resistance to a genetically modified crop. The discovery raises concerns that the biotech crops are spawning “superbugs” and calls into question EPA’s allowance of so-called plant incorporated protectants (PIPs). Fields planted in Monsanto’s Bt corn in some areas of the Midwest are showing damage from the corn rootworm””the very species targeted by Monsanto’s engineered trait. Iowa State University entomologist Aaron Gassmann, PhD has discovered that western corn rootworms in four Iowa fields have evolved and can resist the pesticide built into Monsanto’s genetically altered corn seeds. The scientist said the cases were isolated, but he did not know how widespread the problem could become. Farmers in Illinois are also seeing severe rootworm damage in fields planted in Monsanto’s Bt corn. In 2010, Monsanto acknowledged that in industrial-agriculture regions of India, where Monsanto’s Bt cotton is a dominant crop, the cotton-attacking bollworm had developed resistance. “These are isolated cases, and it isn’t clear how widespread the problem will become,” said Dr. Gassmann in […]

(Beyond Pesticides, August 22, 2011) A US Department of Agriculture (USDA) official speaking at an agricultural conference said that the heavy use of Roundup, an herbicide manufactured by Monsanto and used heavily on “Roundup Ready” genetically engineered (GE) crops, appears to be causing harmful changes in soil and potentially hindering yields of crops that farmers are cultivating. Reuters reported that Robert Kremer, PhD, a microbiologist with the USDA’s Agricultural Research Service, told the audience at the August 12, 2011 conference sponsored by the Organization for Competitive Markets that repeated use of the herbicide glyphosate, the key ingredient in Roundup herbicide, impacts the root structure of plants, and 15 years of research indicates that the chemical could be causing fungal root disease. Dr. Kremer first warned us about his research and questioned the government’s response last year. “This could be something quite big. We might be setting up a huge problem,” Dr. Kremer told Reuters last year. “Science is not being considered in policy setting and deregulation. This research is important. We need to be vigilant.” Monsanto created “Roundup Ready” crops to withstand its Roundup herbicide (with the active ingredient glyphosate). Growing previous Roundup Ready crops such as soy, cotton, and […]

(Beyond Pesticides, August 16, 2011) A lawsuit filed in federal court against the U.S. Fish and Wildlife Service (FWS) seeks to end cultivation of genetically engineered (GE) crops on twenty-five national wildlife refuges across the U.S. Southeast. The suit is the latest step in a campaign to banish GE crops from all refuges. Filed in the U.S. District Court for the District of Columbia on August 12, 2011 by Public Employees for Environmental Responsibility (PEER), the Center for Food Safety (CFS), and Beyond Pesticides, the federal suit charges that FWS unlawfully entered into cooperative farming agreements and approved planting of GE crops in eight states without the environmental review required by the National Environmental Policy Act (NEPA) and in violation of FWS policy. This is the third in a series of lawsuits filed by CFS and PEER challenging FWS’s practice of permitting GE crops on wildlife refuges. In 2009 and 2010, the groups successfully challenged approval of GE plantings on two wildlife refuges in Delaware — Prime Hook National Wildlife Refuge and Bombay Hook National Wildlife Refuge — which forced FWS to end GE planting in the entire 12-state Northeastern region. National wildlife refuges have allowed farming for decades despite […]

(Beyond Pesticides, August 10, 2011) A citizen advisory council in Boulder County, Colorado is preparing to decide on whether or not to recommend that genetically modified organisms (GMOs) be banned from county lands. The County’s Croplands Policy Advisory Group will meet on Wednesday, August 10 (agenda packet here) to decide if they want farmers who plant their crops on county land to be able to be able to grow crops that have been genetically modified. With organic farmers around the country worried about potential contamination of their crops with GMO pollen following a number of recent regulatory decisions, the citizen council model may represent a good way for communities to come together and find a solution. Currently, many farmers grow on land owned by the county, and some want to plant GMOs to stay competitive with other farmers around the country. However, some citizens of the county are concerned about the widespread use of GMOs and the increased reliance on agricultural chemicals that usually accompanies them. Organic farmers in the area are also very worried. Recent decisions by the U.S. Department of Agriculture have led to the deregulation of several genetically engineered varieties of common crops, including alfalfa and sugar […]

(Beyond Pesticides, August 9, 2011) Genetically engineered sweet corn designed to both fight off insects and tolerate Monsanto’s Roundup Ready herbicide is set to enter the market this fall, marking a first for engineered produce in the U.S. by the company. This is the first consumer product developed by Monstanto that will go straight from the farm to the consumer’s plate, rather than first being processed into animal feed, sugars, oils, fibers and other ingredients found in a wide variety of conventional food. The new seeds, which will be available to farmers this fall, will target the relatively small market of 250,000 acres of sweet corn grown that is grown for human consumption, however, many environmentalists worry that if this proves profitable for Monsanto we may see more varieties of GE fruits and vegetables at the grocery store. “There’s a concern with these GE crops that we eat with minimal processing [like sweet corn]…we’re exposed to a lot more of whatever is in it versus a processed corn product,” said Bill Freese, a science policy analyst at Center for Food Safety in an interview with Fast Company. A study earlier this year found that pregnant women and their fetuses were […]

(Beyond Pesticides, August 4, 2011) At least 21 different species of weeds are found to be resistant to the herbicide glyphosate, commonly sold as Roundup and used across thousands of acres of “RoundUp Ready” genetically engineered (GE) crops, according to a series of studies in the current issue of Weed Science. Palmer amaranth, one of the weeds discussed in the journal, can reduce yields of cotton by more than 50 percent if there is a density of at least 10 of these weeds per row. Fifty-two counties in the state of Georgia had infestations of glyphosate-resistant Palmer amaranth last year. Studies confirm that the weed, which also competes with soybean, corn, grain sorghum and peanut crops, is also resistant to the herbicide phrithiobac in addition to glyphosate. Over-application and over-reliance by farmers on glyphosate to solve all of their weed problems has led to the proliferation of so-called “super weeds,” which have evolved to survive the treatments through repeated exposure. The most common species which have evolved these traits include pigweed (palmer amaranth), mare’s tail, and ryegrass. The spread of resistance is what has led farmers to increasingly rely on more toxic alternative mixtures, including weed killers like atrazine. There […]

(Beyond Pesticides, June 27, 2011) A study published in the May 2011 edition of the journal Reproductive Toxicology finds pregnant women and their fetuses contaminated with pesticides and metabolites of the herbicide gluphosinate and the Cry1Ab protein of the insecticide based on the bacterium bacillus thuringiensis (Bt), both affiliated with genetically engineered (GE) food. The study, “Maternal and fetal exposure to pesticides associated to genetically modified foods in Eastern Townships of Quebec, Canada,” also identified the same chemicals, as well as glyphosate metabolites in the bodies of non-pregnant women. The study, conducted by researchers at the University of Sherbrooke Hospital Centre in Quebec, Canada, is intended to pave the way for a new field in reproductive toxicology including nutrition and utero-placental toxicities. Herbicide resistance is the most common genetically modified trait in commercial agriculture. Crops are modified to be able to withstand extremely high doses of glyphosate (Roundup Ready) and gluphosinate (LibertyLink). Current herbicide resistant crops include soy, maize (corn), canola, sugar beet, cotton, with and alfalfa. As of 2005, 87% of U.S. soybean fields were planted with glyphosate resistant varieties. The recently released 2010 Agricultural Chemical Use Report by the U.S. Department of Agriculture’s (USDA) National Agricultural Statistics Service […]

(Beyond Pesticides, June 24, 2011) Attorneys for farmer and environmental organizations filed a motion in court on Monday to seek partial judgment in their case against Secretary of Agriculture Tom Vilsack regarding his department’s recent deregulation of genetically engineered (GE) alfalfa. The plaintiffs, including the Center for Food Safety, Beyond Pesticides, and several seed and farming organizations, filed a Motion for Partial Summary Judgment on the claim in the lawsuit regarding the Endangered Species Act (ESA). The suit claims that the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) is required by the ESA to consult with the U.S. Fish and Wildlife Service (FWS) in decisions regarding regulation of GE products in order to determine any potential impact on endangered species or their habitats. Since APHIS did not consult with FWS prior to its decision to deregulate GE alfalfa, the plaintiffs hold that the decision is invalid until an evaluation is conducted by FWS. Since the alfalfa is engineered by the agribusiness corporation Monsanto to be resistant to the company’s Roundup herbicide products, active ingredient glyphosate, the plaintiffs argue that planting of the so-called Roundup Ready alfalfa will result in significantly increased rates of herbicide application, […]

(Beyond Pesticides, June 13, 2011) A new report released early last week shows that industry regulators have known for a long time that glyphosate, the active ingredient in the world’s best selling herbicide, RoundUp, causes birth defects. The report, “RoundUp and Birth Defects: Is the public being kept in the dark?” published by Earth Open Source, says that regulators misled the public about the safety of glyphosate for over 20 years. According to the report, the German government has known since 1998 and the EU Commission’s expert scientific review panel has known since 1999 that glyphosate causes malformations. As recently as last year, however, the German Federal Office for Consumer Protection and Food Safety told the Commission that there was no evidence of glyphosate causing birth defects. Meanwhile, these actions by industry and regualtors that have kept the public in the dark, the authors point out, has seriously endangered public health. Considering that Monsanto, as well as other producers of genetically engineered (GE) seeds are now pushing for glyphosate-tolerant crop approval in Europe, this is particularly disconcerting. If the Commission grants the approval as the U.S. Department of Agriculture (USDA) had done for GE alfalfa and sugar beets in the […]

(Beyond Pesticides, June 3, 2011) According to the 2010 Agricultural Chemical Use Report released last week by the U.S. Department of Agriculture’s (USDA) National Agricultural Statistics Service (NASS), use of the herbicide glyphosate, associated with genetically engineered (GE) crops, has dramatically increased over the last several years, while the use of other even more toxic chemicals such as atrazine has not declined. Contrary to common claims from chemical manufacturers and proponents of GE technology that the proliferation of herbicide tolerant GE crops would result in lower pesticide use rates, the data show that overall use of pesticides has remained relatively steady, while glyphosate use has skyrocketed to more than double the amount used just five years ago. The 2010 Agricultural Chemical Use Report shows that, in the states surveyed, 57 million pounds of glyphosate were applied last year on corn fields. Ten years prior, in 2000, this number was only 4.4 million pounds, and in 2005, it was still less than half of current numbers at 23 million pounds. Intense corn growing regions have experienced an even greater increase in glyphosate applications. Glyphosate use in the state of Nebraska increased by more than five times in just seven years, going […]

(Beyond Pesticides, June 2, 2011) New threats by Monsanto have led to the filing of an amended complaint by the Public Patent Foundation (PUBPAT) in its suit on behalf of family farmers, seed businesses, and organic agricultural organizations challenging Monsanto’s patents on genetically modified seed. Twenty-three new plaintiffs, including Beyond Pesticides, have joined with the original 60 in the amended complaint, bringing the total number represented in the case to 83. The plaintiffs in the suit, Organic Seed Growers and Trade Association (OSGATA), et al. v. Monsanto and pending in the Southern District of New York, now include 36 family farmer, food, agricultural research, food safety, and environmental organizations representing hundreds of thousands of members including several thousand certified organic, biodynamic, or otherwise non-transgenic family farmers. “Our clients don’t want a fight with Monsanto, they just want to be protected from the threat they will be contaminated by Monsanto’s genetically modified seed and then be accused of patent infringement,” said PUBPAT Executive Director Daniel B. Ravicher. “We asked Monsanto to give our clients reassurance they wouldn’t do such a thing, and in response they chose instead to reiterate the same implicit threat to organic agriculture made in the past.” Soon […]

(Beyond Pesticides, May 24, 2011) Last Friday, the U.S. Court of Appeals for the Ninth Circuit issued a summary order upholding a landmark legal decision requiring the U.S. Department of Agriculture (USDA) to conduct an Environmental Impact Statement (EIS) before approving the planting of genetically engineered (GE) crops. The decision upholds previous court rulings in favor of farmers and conservation advocates in a case on the future commercial uses of GE sugar beets, engineered to be resistant to Monsanto’s Roundup herbicide. “Today’s order cements a critical legal benchmark in the battle for meaningful oversight of biotech crops and food,” said Center for Food Safety (CFS) attorney George Kimbrell. “Because of this case, there will be public disclosure and debate on the harmful impacts of these pesticide-promoting crops, as well as legal protections for farmers threatened by contamination.” CFS, Organic Seed Alliance, High Mowing Organic Seeds, and the Sierra Club, represented by CFS and Earthjustice, challenged the USDA approval in 2008. They argued that GE sugar beets would contaminate organic and non-GE farmers of related crops, such as table beets and chard, as well as increase pesticide impacts on the environment and worsen the current Roundup-resistant “superweeds” epidemic in U.S. agriculture. […]

(Beyond Pesticides, March 22, 2011) Last Friday, attorneys for the Center for Food Safety (CFS), Beyond Pesticides, Earthjustice, and farm and environmental groups filed a lawsuit against the U.S. Department of Agriculture (USDA), arguing that the agency’s recent unrestricted approval of genetically engineered (GE), “Roundup Ready” alfalfa is unlawful. In January, USDA announced plans to fully deregulate GE alfalfa seed, despite contamination risks it poses to both organic and conventional farmers. With the full deregulation of GE alfalfa underway, USDA estimates that up to 23 million more pounds of toxic herbicides will be released into the environment each year. This year has seen a series of decisions by USDA to allow the unrestricted cultivation of genetically engineered crops, and just last month a federal appeals court decided to reverse a federal order to destroy GE sugar beet seedlings. Most GE crops are engineered to be immune to the herbicide glyphosate, which Monsanto markets as Roundup. Currently, USDA data show that 93% of all the alfalfa planted by farmers in the U.S. is grown without the use of any herbicides. The decision to fully deregulate GE alfalfa fails to take several scientifically-validated environmental concerns, such as the indiscriminate nature of GE […]