(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 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 27, 2014) Rulng that Hawaii state law preempts local authority to restrict pesticides,  a federal court judge this week struck down Kauai County’s Ordinance 960. The ordinance, which  received widespread support on the Island, was designed to protect local residents and Kauai’s environment from the year-round spraying of large quantities of restricted use pesticides by multinational chemical companies. U.S. Magistrate Judge Barry Kurren on Monday ruled that Kauai County Ordinance 960 is preempted by state law and therefore is unenforceable. Ordinance 960 provides residents of Kauai public access to information related to the application of pesticides used in experimental and commercial agricultural operations within the County of Kauai. It also affords County residents and the environment greater protection from, and information about, potential pesticide drift and the impact of experimental genetically engineered (GE) crops on Kauai. The Kauai County Council voted to enact Ordinance 960 in November 2013, overriding the Mayor’s veto. The ordinance was scheduled to go into effect Aug. 16, but had been postponed to Oct. 1 pending the court’s ruling. Local leaders crafted the ordinance in response to public outcry from residents, many of whom live, work, or have children that go to school […]

(Beyond Pesticides, August 4, 2014) The Clean Water Act (CWA) provides critical safeguards for our nation’s waterways, with the goal of fishable and swimmable waters for all residents of the United States. Last Thursday, the House of Representatives voted to strip away an important part of these protections concerning pesticides applied directly to U.S. waters. The Reducing Regulatory Burdens Act of 2013 (HR 935) would reverse a 2009 ruling in National Cotton Council v. EPA that requires CWA permits for pesticide users who spray over waterways. After failing in a vote under a suspension of the rules last Monday, the House took the bill back up and passed it 267-161. “This is a good bill that reduces burdensome regulations without rolling back any environmental safeguards,” said U.S. Representative Bob Gibbs (R-OH), the bill’s sponsor, to The Hill. Unfortunately, Rep. Gibb’s statement couldn’t be farther from the truth. Under the deceptive title of “Reducing Regulatory Burdens,” this bill would instead eliminate critical CWA protections. “This legislation will undermine one of our nation’s most successful environmental laws, the Clean Water Act, in limiting the potential contamination of our nation’s waters by pesticides. All this would do is make it harder to locate […]

(Beyond Pesticides, July 24, 2014) Last week, the U.S. Environmental Protection Agency (EPA) denied an emergency application to use a hazardous pesticide, propazine, on 3 million acres of Texas cotton fields, after groups representing environmental, public health, and organic farm interests urged the agency to reject the request based on environmental effects and the predictable nature of the weed resistance to currently used chemicals. Despite determining “that an urgent and non-routine condition exists for Texas growers” when certain weed-densities are reached, EPA’s primary reasons for denying the application focused on health and environmental concerns of the pesticide. As EPA explained, “When conducting human health risk assessment for new use the Agency must first consider the risk profile for currently registered uses and determine if an additional use can be added to the cup.” This aggregate risk assessment is required under the Food Quality Protection Actand in the case of propazine, EPA found that “drinking water estimates suggest that risks from drinking water alone may lead to unacceptable risks . . . .” “While we disagree with the EPA that this meets any of the criteria for emergency exemption, we applaud the EPA for putting the health of people and the […]

(Beyond Pesticides, July 8, 2014) [Eds. Note: Because of a procedural glitch in the ordinance, the Ogunquit pesticide ban ordinance was scheduled to be placed on the ballot again on November 4, 2014. The ordinance passed again, this time overwhelmingly.] In another key victory  for public health and the environment, last month residents in the small ocean-side community of Ogunquit, Maine (pop:~1,400) voted to become the first town in the state to prohibit the use of pesticides on public and private property for turf, landscape, and outdoor pest management activities. Ogunquit’s ordinance makes the town the second local jurisdiction in the United States in the last year  to ban pesticides on both public and private property, and the first to be passed by popular vote, 206 to 172. The ordinance, modeled in large part on the first private/public pesticide ban in Takoma Park, Maryland last year, was passed after a three-year education and awareness campaign, initiated by the town’s Conservation Commission. The law expands on  existing pesticide use restrictions on  town-owned property. The passage of this ordinance positions Ogunquit as a leader in the state for environmental sustainability and the protection of public health, and supports the Conservation Commission’s goals […]

(Beyond Pesticides, July 3, 2014) It was predictable that genetically engineered (GE) cotton sprayed with the weedkiller glyphosate (Roundup) would create resistant superweeds. Now that it has, Texas GE cotton growers recently requested an emergency use of a chemical cousin to atrazine, the herbicide that is demasculinizing frogs by disrupting the endocrine system— on 3 million acres of cotton fields where the weeds have become resistant to the chemical of choice —glyphosate. Stop the GE Pesticide Treadmill! Use Beyond Pesticides’ sample comments for guidance. Help stop the GE treadmill and the use of hazardous pesticides. Join Beyond Pesticides in fighting this predictable “emergency” use because it exemplifies EPA’s practice of allowing increasing dependency on highly toxic pesticides in agricultural systems that are predictably unsustainable, harmful to people and the environment, and for which there are safe alternatives.  This situation is the same toxic treadmill and thinking that is ushering in new 2,4-D-tolerant corn to replace Roundup Ready corn. Emergency exemptions and the use of increasingly toxic herbicides must not be the norm for communities and our environment. Can you help us stop EPA from propping up the failed GE agricultural system?  Submit your comment by midnight July 3. Government does […]

(Beyond Pesticides, June 3, 2014) In a letter to the Environmental Protection Agency (EPA) and the U.S. Department of Agriculture, the Center for Food Safety (CFS) challenged EPA’s position that seeds coated with pesticides, commonly neonicotinoid pesticides, are exempt from regulation  under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). EPA currently is arguing that pesticide-coated seeds are treated articles, exempting them from being regulated as a pesticide and should be regulated by USDA under the Federal Seed Act.   However, CFS argues in its letter that FIFRA precludes EPA from approving language at any stage of the pesticide’s supply chain that allows for exposures likely to adversely affect the environment, and which are not mitigated or investigated by EPA or state agencies. Neonicotinod seed treatments have become increasing common and are linked to the explosion of genetically engineered (GE) crops. At least 94% of the nation’s 92 million acres of corn –greater than the total size of the state of Minnesota, Nebraska, or both Dakotas–  will be treated with one of two neonicotinoids, both manufactured by Bayer. According the letter, CFS believes this inaction by EPA has led state regulators to avoid investigating bee deaths from exposure to dust […]

Beyond Pesticides, May 30, 2014) This week, a group of concerned mothers and environmentalists met with U.S. Environmental Protection Agency (EPA) officials  to discuss a recent pilot study that detected glyphosate residues in breast milk. Organized by Mom’s Across of America, which is seeking to stop the sale and use of glyphosate, the meeting  underscored the limitations of EPA’s pesticide registration program in addressing  the real-life impacts of pesticides on children and the concerns of mothers surrounding the dangers of glyphosate in particular.  Glyphosate, the active ingredient in the herbicide Roundup, is the most widely applied herbicide in the U.S., with uses ranging from genetically engineered (GE) crops to lawn turf. The meeting with Moms Across America, Beyond Pesticides, Consumes Union, Organic Consumers Association,  other groups  and EPA came after Mom’s Across America’s five-day phone call campaign urging EPA to recall Roundup. Participants in the campaign made close to 10,000 calls to the agency. The pilot study, supported by Moms Across America, looked at ten breast-milk samples from across America. Three of the ten breast milk samples tests reveal high levels of glyphosate, meaning that the amount of glyphosate found is between 76 ug/l to 166 ug/l. The highest glyphosate […]

(Beyond Pesticides, April 10, 2014) — The results of an on-going investigation into allegations of improper pesticide spraying on timberland near residential areas in Southern Oregon confirmed what residents of the small towns had known since the day they were unwillingly sprayed with dangerous pesticides””the applications were illegal. Statements released on April 8, 2014, by Oregon Department of Agriculture (ODA) concerning its investigation into the allegations, indicated multiple violations by the pesticide operator and applicator responsible for the spraying had been found, as well as evidence of the presence of pesticides on properties in Cedar Valley, near Gold Beach, Oregon. Specifically, ODA concluded that Pacific Air Research — a licensed commercial pesticide operator based in White City, Oregon— and its aerial applicator, allowed pesticide products to fall on properties other than the intended application site, applied one product at a rate above the maximum allowed by the label instructions, and provided multiple false records that misled ODA about the actual products used. The confirmed pesticides at issue, 2,4-D and triclopyr, are a serious matter, exacerbated by spray applications  in excess of pesticide label restrictions and other regulations. Under the Federal, Insecticide, Fungicide, and Rodenticide Act (FIFRA), the nation’s primary pesticide […]

(Beyond Pesticides, April 3, 2014) A food container production company in New Jersey is finding out that the smallest of ingredients can have big implications for public health. Earlier this week, the U.S. Environmental Protection Agency (EPA) announced that it had issued a stop sale order to Pathway Investment Corp., manufacturer of Kinetic Go Green Premium Food Storage Containers and Kinetic Smartwist Series Containers. In addition to the order sent to Pathway, the EPA has also issued warning letters to Amazon, Sears, Wal-Mart and other large retailers directing them not to sell these products. The reason for the order: nanosilver””an extremely small particle of silver that has been added to consumer products of all kinds during the last decade to combat bacteria, mold, and other microorganisms. Because of nanosilver’s properties, it is considered a pesticide and active ingredient under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the primary federal law governing pesticide use in the United States. Under FIFRA, any product containing an active ingredient that acts as a pesticide must be registered with EPA. For public health claims associated with pesticide use, EPA requires manufacturers to show that the product  performs as intended and does not  pose “unreasonable” […]

(Beyond Pesticides, March 6, 2014)  Yesterday, Center for Environmental Health, Beyond Pesticides, and Physicians for  Social Responsibility, represented by Earthjustice, filed a complaint against the U.S. Environmental Protection Agency (EPA) for failing to complete rulemaking that would require pesticide manufacturers to disclose  the inert ingredients on  their pesticide product labels. An inert ingredient is any ingredient that is “not active,” or not targeted to killing a pest. “Consumers and users of pesticide products have a right to know all the ingredients that are in products they purchase so that they can make more informed choices in the marketplace,” said Jay Feldman, Executive Director of Beyond Pesticides. EPA’s 2010 proposal noted public disclosure “may lead to less exposure to”¦ hazardous inert ingredient[s] because consumers will likely choose products informed by the label.” In turn, “pesticide producers will likely respond by producing products with less hazardous inert ingredients.” Billions of pounds of pesticides are dispersed throughout the U.S. and enter our food supply, homes, schools, public lands and waterways. The public knows very little about the chemicals contained in most of these pesticides because under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), pesticide manufacturers are only required to list “active” ingredients […]

(Beyond Pesticides, February 24, 2014) The U.S. Environmental Protection Agency (EPA) last week released its long-awaited proposal to update Farm Worker Protection Standards (WPS),  which are designed to provide protections from pesticide exposure for more than two million farmworkers and their families across the nation.   Historically, farmworker advocates have criticized these protections as woefully inadequate in protecting the health of agricultural workers, but these new revisions attempt to strengthen the standards through increased training for workers handling pesticides, improved notification of pesticide applications, and a higher  minimum age requirement for children to work around pesticides. Farmworkers face disproportionate risks to pesticide exposures, with EPA stating that pesticide exposure incidents are vastly under-reported —in some case by as much as 90 percent. Although these proposed changes are a step in the right direction, there are still ongoing concerns about whether the changes will be adequate to protect workers. Revisions to the 20 year old standard have been under discussion for many years. In 2010, EPA released a document proposing WPS that would determine ways to increase training, improve safety requirements, provide clear emergency information, and create strong protection for applicators. However, EPA documents distributed during a November 2012 Pesticide Program […]

(Beyond Pesticides, February 13, 2014) French scientists from the University of Caen have revealed one more layer of the myth behind so-called “inert” ingredients in pesticides, concluding that pesticide risk assessments that focus exclusively on active ingredients substantially underestimate the potential hazards of the product as a whole. The findings in Major pesticides are more toxic to human cells than their declared active principles indicate that inert ingredients in pesticides can magnify the effects of active ingredients, sometimes as much as 1,000-fold. In conducting their study, Robin Mesnage,  Ph.D.  and  his team of scientists, including Gilles-Eric Seralini,  exposed three human cell lines to the active ingredients of three herbicides, three insecticides, and three fungicides. The team then exposed the cell lines to the well-known commercial formulations that include these active ingredients which also contained “inerts,” and compared the results. Overall the study concluded that the commercial combinations had a magnifying effect on the toxicity of the active ingredients. While many might assume  that three insecticides tested ranked highest in toxicity, the study actually ranked fungicides as having the highest on-average toxicity, followed by herbicides, then insecticides. Leading the pack for on-average toxicity in the herbicides was the well-known Monsanto product, […]

(Beyond Pesticides, February 7, 2014) Flying in the face of  recent science demonstrating that pollinator populations are declining, the U.S. Environmental Protection Agency (EPA) has made the decision to unconditionally register another pesticide that is known to be highly toxic to bees, coming almost one year after EPA registered sulfoxaflor, disregarding concerns from beekeepers and environmental groups. The announcement, posted in the Federal Register on Wednesday, set tolerances for the pesticide cyantraniliprole in foods ranging from almonds and berries, to leafy vegetables, onions, and milk. EPA establishes the allowable limit of the chemical residue, called tolerances, based on what EPA considers ”˜acceptable’ risk.  EPA’s ruling details that “there is a reasonable certainty that no harm will result from aggregate exposure to the pesticide residue,” despite all evidence that cyantraniliprole is toxic to bees and harmful to mammals. Ignoring beekeeper warning and concerns on their impacts to bees, EPA has given the green light for cyantraniliprole after recently registering sulfoxaflor.  In July 2013, beekeepers filed suit against EPA for their decision to register sulfoxaflor when it failed to demonstrate that it will not cause any ”˜unreasonable adverse effects on the environment’ as required by the Federal Insecticide, Fungicide, and Rodenticide Act […]

(Beyond Pesticides, February 6, 2014) We know that pesticides and bees don’t mix and that particular pesticides, such as neonictinoids, pose significant threats to bee populations worldwide, but a recent study conducted by researchers at Pennsylvania State University have identified that it is “the mix” of the many chemicals in the environment that pose a significant threat to honey bee survival. Looking at the four most common pesticides detected in pollen and wax –fluvalinate, coumaphos, chlorothalonil, and chloropyrifos, Wanyi Zhu and other researchers have assessed the toxic impacts of these pesticides on honey bee larvae at real world exposure levels; that is, levels that are found in existing hives outside of a laboratory. But these researchers go beyond the usual one-chemical analysis in their study,  Four Common Pesticides, Their Mixtures and a Formulation Solvent in the Hive Environment Have High Oral Toxicity to Honey Bee Larvae. Rather than just looking at the pesticides in their individual, out-of-the-bottle form, they also mixed them up and broke them apart. Why did they take this mixed-up approach? “Recently, one hundred and twenty-one different pesticides and metabolites were identified in the hive with an average of seven pesticides per pollen sample, including miticides, insecticides, […]

(Beyond Pesticides, January 2, 2014) Near the conclusion of 2013, the U.S. Environmental Protection Agency (EPA) announced a settlement agreement with a Florida-based pesticide producer and distributor, Harrell’s LLC. Alleging multiple violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the agreement requires Harrell’s to pay a hefty civil penalty in the amount of $1,736,560. Under FIFRA, the nation’s primary law governing the manufacture, distribution, and use of pesticides, a pesticide product cannot enter the U.S. marketplace without EPA registration and an approved label that conveys to intended users of the product critical information about its contents, methods and areas of application, and potential hazards. Ideally, the purpose of FIFRA is to ensure that no pesticides are produced, imported, distributed, sold, or used in a manner that pose an “unreasonable risk” to human health or the environment. While there are a number of loopholes and weaknesses in this system, such as conditional registrations, that lead to toxic products entering the marketplace without a full understanding of the potential health hazards and environmental risks associated with those products, FIFRA’s protections are at their core dependent on diligent adherence to the registration and labeling rules. Any product that does not adhere […]

Beyond Pesticides, December 23, 2013) The Environmental Protection Agency (EPA) and the National Oceanic and Atmospheric Administration (NOAA)  in a  Federal Register notice  has found that the state of Oregon’s program to reduce nonpoint coastal pollution is inadequate. Both federal agencies state that Oregon’s program does not adequately protect streams that provide habitat for Coho Salmon, an endangered species, and drinking water from herbicides that are aerially sprayed by lumber companies. This notice comes just after a recent report was released by Beyond Toxics on the health and environmental problems caused by aerial herbicide application on timber forests near Triangle Lake. EPA and NOAA’s proposed disapproval action of Oregon’s Coastal Nonpoint Program finds that the state has failed to adequately protect certain waterways within the state. Under the Coastal Zone Act Reauthorization Amendments (CZARA) of 1990, states are required to submit an approvable Costal Nonpoint Pollution Control Program to NOAA and EPA. In 1998, federal agencies approved the Oregon Nonpoint Program with conditions that the state meet certain water pollution issues. This proposed disapproval action is part of a settlement of a lawsuit brought by the Northwest Environmental Advocates in 2009, which charged Oregon has failed to meet the conditions […]

(Beyond Pesticides, December 4, 2013) It’s farm bill debate time””again. And as conferee members saddle up to the negotiation table to attempt yet another meeting of the minds before the winter recess, most of the public watching and waiting for word on a resolution are focused on issues like food stamps and milk. What most are not waiting for and has not been at the forefront of the media and public discussion concerning the pending farm bill negotiations are the small but dangerous provisions of the House bill concerning the Federal Water Pollution Control Act (expanded and overhauled  as the Clean Water Act (CWA) in 1972) and the U.S. Environmental Protection Agency’s (EPA) ability to regulate pesticides used near, over, and in water. It should be. Seeking to nullify the Sixth Circuit’s ruling in National Cotton Council v. EPA and the resulting general permit, sections 12323 and 100013 amend CWA to exclude pesticides from the law’s standards and its permitting requirements. Known as the National Pollution Discharge Elimination System (NPDES), CWA requires all point sources, which are discernible and discreet conveyances, to obtain either individual or general permits. Whether a point source must obtain an individual or general permit depends […]

(Beyond Pesticides, November 25, 2013) The Oregon Department of Agriculture (ODA) has restricted two pesticide products linked to massive bee die offs experienced in Oregon earlier this year. Both pesticides are neonicotinoid chemicals that are extremely harmful to bees. Though these restrictions are an important step in protecting bee health, the new rules will still not limit all of the uses of these chemicals that can harm pollinators. ODA placed restrictions on dinotefuran and imidacloprid, banning their use  on linden trees, basswood and other trees of the Tilia genus. Pesticide products that contain these active ingredients are now required to have Oregon-specific labels. This is only the second time in the past ten years that ODA has regulated pesticides more strictly than federal standards. These new restriction comes after ODA adopted a temporary rule in June that limited the use of 18 pesticide products that contained diontefuran. That rule was set to expire next month. States and local jurisdictions  have authority under the nation’s pesticide registration law, the  Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), to adopt more stringent pesticide use restrictions than the federal government. However, after the U.S.  Congress rejected proposals to preempt local authority and the Supreme […]

(Beyond Pesticides, November 19, 2013) Last week, the Environmental Protection Agency (EPA), the U .S. Department of Agriculture (USDA), Fish and Wildlife Service (FWS), and National Marine Fisheries Service (NMFS) released a white paper identifying how they plan to reconfigure the pesticide review process to meet the pesticide approval requirements for the Endangered Species Act (ESA). The new approach outlined in the white paper incorporates suggestions from the National Academy of Sciences’ Research Council (NRC) report released last May. The white paper is a step towards overhauling a deeply flawed process, though there will be several challenges to implementing this new approach for the agencies moving forward. Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), before a pesticide can be sold, distributed, or used in the U.S., EPA is required to determine that the pesticide does not cause unreasonable adverse effects on the environment. However, in the case of species listed as endangered or threatened under the ESA, all federal agencies, including EPA, are required to ensure that their actions will not jeopardize the continued existence of a listed species by diminishing the species’ numbers and reproduction. To do this, in its pesticide registration process, EPA is required to […]

(Beyond Pesticides, October 30, 2013) Once again, a bipartisan group of U.S. Senators is urging Farm Bill conference committee members to accept a provision that would eliminate what they call a redundant permitting requirement for pesticide users. H.R. 935: Reducing Regulatory Burdens Act of 2013 is similar to a previous piece of legislation that was passed in the U.S.  House of Representatives  in 2011 to eliminate the requirement that pesticide applicators obtain Clean Water Act (CWA) permits (known as National Pollutant Discharge Elimination  System (NPDES) permit)  for applications where pesticides could be discharged into water. A  bipartisan group of  Senators hope to use the Farm Bill to eliminate permitting requirement, continuing to believe the myth that permits burden farmers and applicators. The Senate and House are now in a conference committee to work out the details of a new Farm Bill to reauthorize the current law. A dozen Senators, led by Sen. Kay Hagan, D-N.C., have asked House and Senate negotiators to do away with the CWA regulation of pesticide discharges as they consider a compromise Farm Bill. Legislation eliminating the CWA permitting requirement last year passed the House, but the move to strip the U.S. Environmental Protection Agency (EPA) […]

(Beyond Pesticides, September 11, 2013) In a report released Monday, the Government Accountability Office (GAO) finds that the U.S. Environmental Protection Agency (EPA)’s use and oversight of conditional registrations is lacking and unreliable. Conditional registration allows pesticides onto the consumer market without all the required data to assess the chemical’s safety. This has created many serious human and environmental health problems, including bee decline, tree death and potential increases in human health risks. GAO recommends that EPA better track conditional registrations, however, Beyond Pesticides and other concerned groups urge the agency to cancel registrations until all relevant data is submitted and reviewed. According to the findings of the GAO’s report, EPA’s system for tracking pesticides with conditional registration is unreliable and thus, the total number of conditional registrations granted is unclear.   This lack of a reliable system for managing conditional registrations constitutes an ”˜internal control weakness’ because the agency lacks an effective mechanism for program oversight and decision making, according to federal internal control standards cited by GAO. The report states, “The extent to which EPA ensures that companies submit additional required data and EPA reviews these data is unknown. Specifically, EPA does not have a reliable system, such […]