(Beyond Pesticides, September 29, 2020) While the green revolution is often heralded in conventional agriculture circles as the key agricultural innovation of the last century, new research finds that biological controls likely had a bigger beneficial impact on world crop production. The study, Ecological Pest Control Fortifies Agricultural Growth in Asia–Pacific Economies, published in Nature Ecology and Evolution, makes the case that the introduction of predators to manage non-native pest species was just as important as the introduction of new cereal grain varieties. “Our work constitutes an empirical demonstration of how insect biological control helped solidify the agrarian foundation of several Asia-Pacific economies and, in doing so, places biological control on an equal footing with other biological innovations such as Green Revolution germplasm,” said study co-author Michael Furlong, PhD, of the University of Queensland, Australia. The study, focusing in on the Asia-Pacific region between 1918-2018, relied primarily on the BIOCAT database, a record cataloging “classical biological control” introductions. Of 252 unique interventions reviewed within individual countries, pest predators established themselves in 96. Of those roughly 4 in 10 introductions that were able to maintain populations over the long term, 48% achieved full or partial pest control. The success of these […]

(Beyond Pesticides, September 28, 2020) These comments are due by October 5 at 11:59 pm EDT. Separate comments to the National Organic Standards Board are due October 1 at 11:59 EDT. After hearing for years about inadequate enforcement of the rules governing organic production, USDA has issued a massive draft rule on strengthening organic enforcement (SOE). The draft rule presented to the public constitutes an impressive and far-reaching rewrite of the regulations implementing the Organic Foods Production Act (OFPA). However, unlike the process by which the initial regulations were established in 2002, the National Organic Standards Board (NOSB) was only consulted on a portion of the elements in this draft rule. Public engagement was, thus, also limited. USDA’s National Organic Program (NOP) is accepting comments on its draft rule via Regulations.gov. Please use this opportunity to remind USDA of the proper public process while commenting on the proposed rule itself. Please join us in asking for an extension of the pubic comment to facilitate fuller public scrutiny. Tell USDA that strengthening organic enforcement starts with the National Organic Standards Board. USDA must involve the NOSB and public as required by law. Section 2119 of OFPA states the Secretary shall establish […]

(Beyond Pesticides, September 21, 2020) The National Organic Standards Board (NOSB) meets online October 28-30 to debate issues—after hearing public comment October 20 and 22—concerning how organic food is produced. Written comments are due October 1. They must be submitted through Regulations.gov. Everywhere we look, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, organisms large and small entangled in plastic, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. As we focus on one of the most blatant examples of environmental abuse—the dispersal of toxic chemicals across the landscape—it is important to seek a solution. Organic can be a big part of the solution, but only if it doesn’t stray from its core values and practices. Tell the National Organic Standards Board to support core organic values. From its very beginnings, the organic sector has been driven by an alliance of farmers and consumers who defined the organic standards as a holistic approach to protecting health and the environment, with a deep conviction that food production could operate in sync with nature and be mindful of its interrelationship with the natural world—protecting and enhancing the quality of air, […]

(Beyond Pesticides, September 17, 2020) The apparel industry becomes the latest contributor to global biodiversity loss, directly linking soil degradation, natural ecosystems destruction, and environmental pollution with apparel supply chains, according to the report, “Biodiversity: The next frontier in sustainable fashion,” by McKinsey & Company. Although there are many studies on the fashion industry’s impact on climate change, much less research discusses the impact the industry has on biodiversity. The globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk of extinction. With the increasing rate of biodiversity loss, advocates say it is essential for government agencies to hold the fashion industry accountable for the direct (i.e., excessive agrochemical use, water consumption) and indirect (i.e., water pollution from run-off) impacts on the environment, not only to protect the well-being of animals, but humans, as well. Researchers in the study note, “We expect biodiversity to become an even greater concern for consumers and investors in the coming years. Covid-19, instead of slowing the trend, has accelerated it—perhaps because people now understand more deeply that human and animal ecosystems are interdependent. It’s time for the apparel industry, which to date has contributed heavily […]

(Beyond Pesticides, September 10, 2020) A new analysis by Science of Cannabis Laboratories Inc. (SC Labs) finds detectable concentrations of pesticides and heavy metals in rolling papers, with hemp/blunt wraps and cellulose-based rolling papers containing the highest levels of contaminants. The analysis follows a SC Labs’ finding of high levels of chlorpyrifos—a neurotoxic, organophosphate insecticide—in the rolling paper of pre-rolled cannabis, which was undergoing compliance testing. Although the rolling paper regulations generally track standards for toxic tobacco products (which means there is very little meaningful regulation), the rolling paper use with cannabis may add an addition layer of scrutiny since some statewide cannabis regulations and independent certifications adhere to stricter guidelines similar to organic practices. Researchers note the goals of the experiment “were to assess the exposure risks to the consumer as well as identify any potential liabilities for cannabis producers who use these products to make their pre-roll products.” This report, and others like it, are significant as cannabis use expands in in the U.S. and around the world, and given that one of the most popular ways to consume cannabis product is as a rolled cigarette. Study author and president of SC Labs Josh Wurzer, Ph.D., said, “This [issue] is something that cannabis and paper […]

(Beyond Pesticides, September 1, 2020) In its new report, industry watchdog OrganicEye, a project of Beyond Pesticides, examines the rapidly expanding CBD market, uncovering numerous examples of gross violations flying under the radar. In its report, Spotting the Hackers of Hemp: The Value of Authentic Certified Organic CBD Products, OrganicEye offers examples of companies claiming organic status without going through the rigorous third-party inspection and auditing process required by federal law. As with food, organic CBD, produced from hemp/cannabis, eliminates the risks and hazards of environmentally dangerous farming practices, including the use of synthetic fertilizers, pesticides, sewage sludge, and genetically modified organisms (GMOs). Organics also shuns toxic food ingredients and food processing substances like volatile solvents. Since Congress charged USDA with protecting organic stakeholders from fraudulent practices, illegal organic marketing claims have been the most common violations reported to the agency. “In addition to representing conventional hemp products as organic, marketers have engaged in illegal subterfuge, including creating their own ‘organic’ logos because they can’t use the official USDA seal and using the word ‘organic’ in their brand names when the products do not qualify for organic labeling,” said Mark A. Kastel, a 30-year industry veteran and director of OrganicEye. The meteoric growth […]

(Beyond Pesticides, August 31, 2020) We don’t need to use toxic weed killers to manage unwanted vegetation in Lake Tahoe, given the havoc they will wreak on a treasured and sacred ecosystem. The Tahoe Regional Planning Agency and Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) are accepting comments on a draft environmental impact report/ environmental impact statement (EIR/EIS) analyzing environmental impacts of a proposed Tahoe Keys Lagoons Aquatic Weed Control Methods Test (“Project”). Unless we all speak up, the Project could involve the application of herbicides to Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and should be selected for the proposed weed control test program. Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm. Located on the border of California and Nevada, Lake Tahoe is treasured for its scenic and ecological values not just by residents of those states, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an “Outstanding National Resource Water” under the Clean Water Act, and is recognized nationally and globally as a natural resource of special significance.  The […]

(Beyond Pesticide, August 27, 2020) The latest research finds that pesticides and fertilizers supersede fossil fuels as the greatest contributor of sulfur emissions in the environment, according to U.S. National Science Foundation (NSF)-funded study, published in Nature Geoscience. Particularly, atmospheric sulfur dioxide and reactive sulfur emissions contribute to sulfur deposition via acidic rain and snow, causing a multitude of human and animal of health problems and environmental degradation. Although some U.S. policy regulations curb sulfur emissions from atmospheric sources, alternative sulfur inputs from agricultural sources can cause similar issues as atmospheric sulfur emissions, including acid rain. With peak sulfur concentrations from agricultural outputs up to ten-fold higher than previous 20th-century sulfur levels, studies like these are significant in understanding how underrepresented pollution sources may contribute to overall environmental pollution. Lead author of the study, Eve-Lyn Hinckley, Ph.D., states, “We have an imperative to understand the impact that we’re having on the environment. And then we need to work together towards solutions to mitigate those effects.” Sulfur is a naturally occurring element found in vast, underground deposits. Although relatively stable underground, it is highly reactive once it reaches the surface, transforming into chemical compounds, like sulfur oxides, upon exposure to oxygen. Over […]

(Beyond Pesticides, August 25, 2020) The City of Gaithersburg, MD has chosen to opt-in to Montgomery County’s Healthy Lawns Act, restricting toxic pesticide use on public and private property. According to the local Patch, the mayor and City Council voted to adopt the law in mid-August, and it will take effect for all residents and businesses in city on December 1. Although Montgomery County passed the Healthy Lawns Act approximately five years ago, incorporated cities within the county are required to proactively opt-in to the law for it to apply within their jurisdiction. Gaithersburg is the latest, and largest city to opt-in to the county’s law, which encourages organic practices by limiting pesticide use on lawns and landscapes to products that are certified organic or considered minimum risk by the U.S. Environmental Protection Agency. In mid-June, the Town of Garrett Park also opted in to the law, according to reports. Advocates are advocating that all cities within Montgomery County adopt the law. The same group of grassroots advocates that pushed Montgomery County leaders to adopt its Healthy Lawns Act years ago is also leading the push for opt-ins. Safe Grow Montgomery, a group of concerned mothers and fathers working for […]

(Beyond Pesticides, August 24, 2020) USDA’s Farm Service Agency (FSA) announced on August 10 that it will be reducing reimbursement rates for the organic certification cost share program, which provides reimbursements to organic farms and handling operations. The August 10 Federal Register notice stated that FSA is “revising the reimbursement amount to 50 percent of the certified organic operation’s eligible expenses, up to a maximum of $500 per scope.” The 2018 Farm Bill clearly set reimbursement rates at 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per regulated activity. This change hurts the transition to organic production at a time when it is crucial that the organic sector grows—eliminating petroleum-based pesticides and synthetic fertilizers that are contributing to devastating pollution, the climate crisis, and biodiversity decline. This action by USDA is unwarranted and completely unacceptable. The 2018 Farm Bill provided new funding for the program and also directed USDA to use the program’s carryover balances from previous years to fund the program for fiscal years 2019 through 2023. Given these sources of funding, there should be plenty of funds available for the program’s operation in fiscal year 2020. Either USDA’s accounting for this program […]

(Beyond Pesticides, August 20, 2020) Persistent organic pollutants (POPs), including banned and current-use pesticides are present in snow and ice on top of Arctic glaciers, according to the study, “Atmospheric Deposition of Organochlorine Pesticides and Industrial Compounds to Seasonal Surface Snow at Four Glacier Sites on Svalbard, 2013–2014,” published in Environmental Science & Technology. Past research finds that air contaminated with these environmentally bioaccumulative, toxic chemicals drift toward the poles, becoming entrapped in ice under the accumulating snowfall. As the global climate continues to rise and the climate crisis worsens, studies like this become significant, as glaciers encapsulating these toxic chemicals are melting. Upon melting, some chemicals can volatize back into the atmosphere releasing toxicants into air and aquatic systems, with the ensuing consequences. Although this research demonstrates that specific computer programs can track the trajectory of chemically contaminated air parcels with practical precision, it falls to global leaders to curtail the continued manufacturing of these chemical pollutants. [For related pieces, see Silent Snow: The unimaginable impact of toxic chemical use and DDT in Glacial Melt Puts Alaskan Communities at Risk.] Countless scientists consider Arctic environments to be “pristine,” void of direct chemical inputs from pesticides and other POPs. However, the Arctic has become a sink for […]

(Beyond Pesticides, August 17, 2020) Once numbering in the millions, barely 29,000 western monarch butterflies were found in California at last count. Pesticides pack a one-two punch against monarchs. Insecticides—particularly neonicotinoids—poison the caterpillars and butterflies as they feed. Glyphosate—the active ingredient in Bayer-Monsanto’s Roundup® — is wiping out milkweed, the only food source for monarch caterpillars. This has contributed to monarchs’ 90% decline in the past 20 years alone. They could vanish within our lifetimes. Home and garden stores like Lowe’s and Home Depot can play a huge role in ending the use of this toxic pesticide in our backyards and across the country. Already, Lowe’s is removing neonicotinoid products from its live plant offerings and store shelves, and Home Depot is eliminating use of neonicotinoids in its live plant offerings. They could stop selling Roundup®. More importantly, they could encourage organic practices through their product offerings and consumer education. Ask Home Depot and Lowe’s to get Roundup® off their shelves and promote and educate on organic! Companies like Lowe’s and Home Depot could be leaders by removing products containing glyphosate/Roundup® from their physical stores and online—following the example of their competitor, Costco. This would send a powerful message to Bayer […]

(Beyond Pesticides, August 13, 2020) Levels of the notorious herbicide compound glyphosate in the human body are reduced by 70% through a one-week switch to an organic diet, finds a new, peer-reviewed study published in August 2020 in the journal Environmental Research. This result emphasizes both the ubiquity of this compound in the human body, and diet as the primary source of exposure for most people. It also adds to the evidence for Beyond Pesticides’ assertions that: (1) chemical-intensive agriculture must be abandoned, for a variety of reasons that include human health, and (2) in the lead-up to a transition to organic and regenerative agriculture, consuming organic foods as much as is practicable is powerful protection from glyphosate, and from the assault of multiple chemical pesticides to which most people are exposed. Glyphosate is the active ingredient in the popular weed killer RoundupTM, which has been used intensively in the U.S. and around the world, especially during the last couple of decades. It is very commonly used on crops grown from genetically engineered (GE) companion seeds for a variety of staple crops (e.g., soybeans, cotton, and corn). These GE seeds are glyphosate-tolerant, whose attribute has allowed growers to apply the herbicide and […]

(Beyond Pesticides, August 6, 2020) New research finds that a decline in wild pollinator abundance, notably wild bees, limits crop yields in the U.S., according to the study, “Crop Production in the USA Is Frequently Limited by A Lack of Pollinators.” The study results, published in the journal Proceedings of the Royal Society B, find the annual, national average value of wild bee pollination for the most economically important and pollinator-dependent crops is approximately $1.5 billion, with the total value of all U.S. pollinator-dependent crops equaling $50 billion annually. The United Nations states that 75% of the 115 top global food crops depend on insect pollination, with one third of all U.S. crops dependent on pollinators, according to the U.S. Department of Agriculture (USDA). However, research finds that many insect populations are declining by half with a third threatened by extinction, including managed and wild pollinators, mainly due to habitat fragmentation, climate change, and extensive pesticide use. With the global reliance on pollinator-dependent crops increasing over the past decades, a lack of pollinators threatens food security and stability. The researchers in the study note, “Our findings show that pollinator declines could translate directly into decreased yields or production for most of the crops studied, […]

(Beyond Pesticides, July 30, 2020) Simultaneous exposure to pesticides and noise from agricultural machinery increases farmworkers, risk of hearing loss, according to the study, “Hearing Loss in Agricultural Workers Exposed to Pesticides and Noise,” published in the journal Annals of Work Exposures and Health. Hearing loss is the 3rd most common health issue in the U.S., affecting eight million Americans. Although specific conditions like age, illness, and genetics, can mediate hearing loss, research suggests other factors can induce auricle (ear) damage, including medications, exposure to toxic chemicals (including pesticides), and loud, ongoing noise. Past studies find an association between hearing loss and pesticide exposure or noise exposure, alone. However, this study is one of the first to associate hearing loss with the additive effect to concurrent, persistent pesticide exposure, and noise. This research is significant as human senses are integral to everyday human activities, and it is vital to understand how chronic pesticide exposure can limit the body’s ability to function normally, for farmers and everyone alike. Researchers in the study note, “[I]t is necessary to understand what work-related factors are contributing to this high prevalence of hearing loss in [Thai] agricultural workers in order to develop effective interventions and […]

(Beyond Pesticides, July 16, 2020) Long-term exposure to sublethal (low-level) concentrations of the neonicotinoid in soil negatively affects the health and behavioral development of black garden ants (Lasius niger) colonies, according to a study published in Communications Biology by scientists at the University of Bern, Switzerland. Ants are one of the most biologically significant insects in the soil ecosystem, acting as ecosystem engineers. Their burrowing behavior aerates the soil, allowing oxygen and water to penetrate down to plant roots. Additionally, ants increase soil nutrient levels by importing and accumulating organic material like food and feces, thus enhancing nutrient cycling. Like many other insects, ants are unfortunate victims of the global insect apocalypse or population decline, and much research attributes the recent decline to several, including pesticide exposure. Broad-spectrum pesticides, like neonicotinoids, indiscriminately kill pests and nontarget organisms alike, as their ubiquitous use contaminates soils, even in untreated areas. This study highlights the necessity of rethinking chemical pest management, developing sustainable agricultural practices that reduce the use of agrochemicals, like pesticides, to prevent permanent environmental ecosystem damage. Researchers in the study note, “To prevent irreparable damages to functioning ecosystems, [we] suggest to either fully incorporate long-term effects in risk assessment schemes, or to make a shift […]

(Beyond Pesticides, July 13, 2020) Soil is central to organic production. Therefore, hydroponic operations should not be considered eligible for organic certification, and the National Organic Program (NOP) must take a clear position in opposition to hydroponics and other non-soil-based methods in organic production, including containers. Organic farmers and consumers strongly agree that organic production must be soil-based.  Tell NOP hydroponics is not organic! Educate your congressional representatives and senators. NOP authorizes the certification of hydroponic operations as organic. This undermines the authenticity of organic farming and creates unequal competition, market instability, and consumer distrust in organic certification. Organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on environmentally beneficial methods such as green manure, crop rotation, and biological pest management. On March 3, 2020, the Center for Food Safety (CFS) filed a lawsuit challenging the USDA’s decision to allow hydroponics operations to be certified organic. Organic farmers and consumers believe that the organic label means two things: […]

(Beyond Pesticides, July 9, 2020) Conventional U.S. milk contains growth hormones, antibiotics, and low to elevated levels of pesticides not found in organic milk, according to a study published in the journal of Public Health Nutrition by Emory University researchers. Milk can bioaccumulate certain organic pollutants, making it a valuable medium to assess what chemical we might be ingesting daily. With milk being one of the most consumed beverages in the U.S., in addition to its use in other popular drinks (i.e., coffee and tea), this study discloses widespread contamination and highlights the need for improved regulation. Researchers in the study note, “To our knowledge, the present study is the first study to compare levels of pesticide in the U.S. milk supply by production method (conventional vs. organic). It is also the first in a decade to measure antibiotic and hormone levels and compare them by milk production type.”  The market for conventional milk, produced in chemical-intensive agriculture, is declining, but the demand for organic milk is increasing due to concerns over chemical contamination in consumer products from pesticides and other toxic chemicals. Although the U.S. Environmental Protection Agency (EPA) sets limits for pesticide residues in food products, the agency […]

(Beyond Pesticides, June 30, 2020) A review of scientific literature on the toxic effect of environmental contaminants—including pesticides—published in the journal Toxicological Science, “The Impact of Environmental Chemicals on the Gut Microbiome,” associates these chemicals to changes in the gut microbiome and other adverse health implications. The review, by researchers at the University of Illinois, looks at how environmental contaminants adversely effects and reinforce chemical disruption of the gut microbiome. It highlights the importance of evaluating how environmental contaminants, like pesticides, impact body regulation by gut microbiota. The study has significant implications for considerations that should be, but are not currently, a part of pesticide review and registration by the U.S. Environmental Protection Agency (EPA). Gut microbiota plays a crucial role in lifelong digestion, immune, and central nervous system regulation, as wells as other bodily functions. Through the gut biome, pesticide exposure can enhance or exacerbate, the adverse effects of additional environmental toxicants on the body. Since the gut microbiome shapes metabolism, it can mediate some toxic effects of environmental chemicals. However, with prolonged exposure to various environmental contaminants, critical chemical-induced changes may occur in the gut microbes, influencing adverse health outcomes. Karen Chiu, Ph.D., a graduate research fellow at the […]

(Beyond Pesticides, June 18, 2020) Residential exposure to household pesticide products increases the risk of developing symptoms associated with depression, according to a study published in Environmental Research by researchers at Medical College of Georgia—Augusta University, School of Medicine—Jinan University, and Guangzhou Center for Disease Control and Prevention (CDC), China. Research on pesticide-induced diseases commonly investigates pesticide exposure concerning the development of various physical illnesses, and previous studies show there are occupational risks of developing depression, especially in agriculture where pesticide use is rampant. However, there is a lack of information connecting pesticide exposure to the subsequent psychological (psychiatric) effects on the general population. Additionally, household pesticide exposure varies from occupational exposure via exposure frequency, duration, intensity, and type. This research highlights the significance of researching potential mental health effects resulting from pesticide exposure, especially as society tends to rank mental health risks second to physical health. The study’s scientists note, “Our results highlight the importance of the cautious use of household pesticides because the chronic effects of poisoning may contribute to an elevated risk of depression.”  According to the World Health Organization (WHO), depression affects 322 million people globally, with the number of diagnosed patients increasing by 18.4% from 2005 to 2015. Although the etiology of depression—and […]

(Beyond Pesticides, June 2, 2020) During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of the National Organic Program at USDA to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. The NOSB has only one alternative left to force USDA action—denying relisting at the Fall meeting. Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now. Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.” In fact, the ingredients not listed on a label of a pesticide product—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to […]

(Beyond Pesticides, May 26, 2020) Across the pond, the European Commission (EC) has announced plans to protect biodiversity and build a more sustainable food system, and identified the reduction of pesticide use  and the expansion of organic agriculture as pillars of the scheme. The EC expects that the initiative, which will require EU member states’ endorsement, will advance progress on the EU goal of eliminating greenhouse gas emissions by 2050, given that 10% of emissions arise from the agricultural sector. The EC’s goals are important and laudable, but Beyond Pesticides is clear: reduction of pesticide use in service of them is not an adequate strategy to ensure long-term success. Genuine success requires the elimination of the use of synthetic chemical pesticides, fertilizers, and other toxic inputs, and the transition to agricultural and land management systems that work with nature, rather than fight against it. Regenerative, organic practices are the path to a livable future, according to Beyond Pesticides. The EC, which is the executive branch of the EU, expects its plan to reduce use of pesticides by 50% by 2030; reduce use of antimicrobial chemicals, including antibiotics, in fish and animal farming by 50%; dedicate a minimum of 25% of arable […]

(Beyond Pesticides, May 22, 2020) For years, USDA has been looking the other way as giant corporate agribusinesses, primarily producing conventional eggs and poultry, have squeezed family-scale farmers out of the market and misled and defrauded consumers. Due to a lawsuit challenging the Trump administration on the scuttling of new rules that would make it harder for factory farms to qualify for organic status, USDA is seeking input on what was previously an error-filled and biased economic assessment of the rulemaking. Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings. If you would prefer to write your own custom comment you can submit it on Regulations.gov. Letter to National Organic Program (Jenny Tucker, Ph.D. To the National Organic Program: Please include my comment below in evaluating the economic analysis report pursuant to the Organic Livestock and Poultry Practices rulemaking. Docket number: AMS-NOP-20-0037 Both the current and previous OLPP analyses include the following misstatements and omissions: It is a misconception to refer to, and judge, the economic impacts of the OLPP as if the requirement for outdoor access was a new and onerous regulation. In fact, from the beginning of the USDA organic […]