(Beyond Pesticides, June 10, 2019) On May 20, U.S. Representative Nydia Velazquez, with 18 co-sponsors, introduced H.R. 2854, “To amend the National Wildlife Refuge System Administration Act of 1966 to prohibit the use of neonicotinoids in a National Wildlife Refuge, and for other purposes.” The bill follows an August 2018 Trump administration announcement that reversed a 2014 U.S. Fish and Wildlife Service (FWS) decision to ban neonicotinoid insecticides on National Wildlife Refuges. Tell members of Congress to protect biodiversity by co-sponsoring HR 2854, which reinstates the 2014 U.S. Fish and Wildlife Service ban on neonicotinoid pesticide use in wildlife refuges that was reversed by the Trump administration in 2018. The administration’s action threatens not only pollinators, but contributes to the attack on biodiversity worldwide. “These pollutants upset the delicate ecosystems of our Wildlife Refuges and they have no place in our public lands,” said Rep.Velázquez. “The ban’s revocation comes as mounting evidence suggests the chemical has damaging environmental effects on bees and other pollinators, undermining the national wildlife system,” she continued. In 2014, FWS announced that all National Wildlife Refuges would join in the phase-out of neonics (while also phasing out genetically engineered crops) by January 2016. FWS “determined that prophylactic use, such as […]

(Beyond Pesticides, June 5, 2019) Earlier this week, the National Organic Program (NOP) of the U.S. Department of Agriculture published a memo that will put a stop to the practice of allowing organic certification for container systems produced on land managed with substances, such as the herbicide glyphosate, which are not permitted in organic production. The decision comes after broad opposition to this NOP allowance was vociferously expressed by a cross section of commenters at the April meeting of the National Organic Standards Board. The head of NOP, Jenny Tucker, in response to questions, attempted to clarify her previous comment to farmers indicating that the practice met organic standards, but instead incited outrage at the NOSB meeting by refusing to reject the use glyphosate in container growing operations. The NOP decision is not retroactive for operations earlier allowed to use the chemicals. The NOP memo clarifies and establishes stricter adherence to a pre-existing rule written into the Organic Foods Production Act (OFPA) of 1990. While this clarification represents a victory for those fighting to keep organic strong, the certification of hydroponic and other container systems as organic continues to present a major challenge for the integrity of a system whose […]

(Beyond Pesticides, May 30, 2019) Last week, the U.S. Fish and Wildlife Service (FWS) agreed to a 2020 deadline for reaching a decision on protection status for monarch butterflies under the Endangered Species Act. This agreement comes nearly five years after the filing of a petition by conservationists with the Center for Biological Diversity and Center for Food Safety led to the launch of an ongoing status review in 2014. While FWS deliberates, monarch butterflies continue their staggering, decades-long population decline, perhaps for the last of their decades. In the 1990s, the eastern monarch population numbered nearly one billion butterflies, and the western population numbered more than 1.2 million. Last year’s winter counts recorded around 93 million eastern monarchs and fewer than 200,000 western monarchs. That loss is “so staggering that in human-population terms it would be like losing every living person in the United States except those in Florida and Ohio,” Tierra Curry, a senior scientist at the Center for Biological Diversity, said in a statement to Live Science. Recent studies project that if current trends continue, both eastern and western monarch populations face migratory collapse within the next 20 years. FWS is no stranger to the threats facing monarch […]

(Beyond Pesticides, May 23, 2019) On Monday in the conclusion of a lawsuit, the U.S. Environmental Protection Agency (EPA) announced the final notices of cancellation on the registration of twelve neonicotinoid pesticide products in the Federal Register, each of which contains chlothianidin or thiamathoxam as an active ingredient. The decision to pull these products from the market was required as part of a legal settlement under the Endangered Species Act (ESA) in December 2018 of a successful case, Ellis v. EPA, brought by beekeeper Steve Ellis and a coalition of other beekeepers and environmental groups, including Beyond Pesticides. The case establishes a legal precedent in which the court required action to address the bee-toxic effects of pesticides; however, the effect of the settlement and its impact on overall neonicotinoid and other systemic insecticide use is limited. For all but two of the twelve canceled products, a nearly identical surrogate remains actively registered. Furthermore, the fact remains that there are hundreds more products containing the active ingredients targeted by the lawsuit that have not been removed in any capacity – 106 products containing clothianidin and 95 containing thiamethoxam remain untouched on the market. Breaking down the impacts of the EPA ruling even […]

(Beyond Pesticides, May 23, 2019) Glyphosate weed killers may be contributing to the growing worldwide epidemic f non-alcoholic fatty liver disease (NAFLD), a condition that causes swelling of the liver, and can eventually lead to cirrhosis, cancer, or liver failure. Researchers at the University of California (UC) San Diego found that higher levels of glyphosate detected in urine corresponded significantly with individuals that have also been diagnosed with NAFLD. Advocates are urging lawmakers at every level to respond to the accumulating science on the danger of glyphosate herbicides, ban their use, and adopt policy changes that put into place organic land management practices. “There have been a handful of studies, all of which we cited in our paper, where animals either were or weren’t fed Roundup or glyphosate directly, and they all point to the same thing: the development of liver pathology,” said Paul J. Mills, PhD, professor and chief in the Department of Family Medicine and Public Health at UC San Diego School of Medicine in a press release. “So I naturally thought: ‘Well, could it be exposure to this same herbicide that is driving liver disease in the U.S.?’” Dr. Mills and his team received urine samples from […]

(Beyond Pesticides, May 21, 2019) As farmers nationwide are facing extreme stressors and either consolidating or retiring, organic is going against the grain. Despite overall declines in the number of U.S. farms, the number of organic farms increased 27% between 2012 and 2017, according to new data from the USDA National Agricultural Statistics Service. The value of organic sales in 2017 was $7.2 billion, and the average value of sales per farm has increased a remarkable 84% since 2012. Laura Batcha, the executive director of the Organic Trade Association, told Bloomberg that young families are among the drivers in the organic market as they seek to avoid residues of chemicals, antibiotics, and hormones on food. Organic products fetch a higher price point than conventional. Indiana farmer Joe Mills can sell his organic food-grade corn for about $10.50 a bushel, while chemical-intensive sells for about $3.50/bushel. Mr. Mills notes, “Yes, it’s economical, but there is a huge learning curve and a mindset change. We relied on commercial fertilizers and pesticides for so long.” At the same time, the benefits and affordability of organic food are critical to the market, as consumers consider their purchasing choices. Read the Beyond Pesticides’ report Low Food […]

(Beyond Pesticides, May 20, 2019) The bans of chlorpyrifos in three important agricultural states show the support for a ban of the chemical nationwide. Hawai’i banned chlorpyrifos a year ago with a unanimous vote of the legislature. New York and California banned it this month. States have been pursuing bans since the Environmental Protection Agency rescinded its proposed ban in 2017. Tell Your Governor to Ban Neurotoxic Pesticides and Support Organic; Send Thanks to Your Governor in Hawai’i, New York, and California Like other organophosphate pesticides, chlorpyrifos has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children. A widely used pesticide, agriculture companies annually spray six million pounds on crops like citrus, apples, and cherries.  In the same family as Sarin gas, the substance was initially developed prior to World War II as a chemical weapon. It can overstimulate the nervous system to cause nausea, dizziness, and confusion. With very high exposures (accidents or spills), it can cause respiratory paralysis and even death. When applying the chemical to fields, workers must wear protective garments such as respirators. Workers are then blocked from entering the fields from 24 hours up to 5 days after application due to the chemical exposure risk. A group of leading toxics […]

(Beyond Pesticides, May 14, 2019) Your voice is needed to stop the use of two specific antibiotics, streptomycin and oxytetracycline, whose uses in agriculture are under EPA review. Thank you to those who, last week, told Congress and EPA to ban antibiotic use in agriculture – to help stop the worldwide crisis in bacterial resistance to antibiotics needed for medical purposes in life-threatening cases. Tell EPA and Congress to Ban Streptomycin and Tetracycline in Agriculture In spite of growing bacterial resistance, these two antibiotics are used for important medical purposes. Tetracycline is used for many common infections of the respiratory tract, sinuses, middle ear, and urinary tract, as well as for anthrax, plague, cholera, and Legionnaire’s disease, though it is used less frequently because of resistance. Streptomycin is used for tuberculosis, tularemia, plague, bacterial endocarditis, brucellosis, and other diseases, but its usefulness is limited by widespread resistance. The unnecessary use of these antibiotics in agriculture must be stopped to protect their efficacy for medical purposes. The good news is that organic management practices do not use these antibiotics in crop production and therefore their use is unnecessary with smart sustainable farming practices.  The EPA docket is accepting comments on these two registrations through Friday, May 17. You can sign […]

` (Beyond Pesticides, May 8, 2019) The spread of antibiotic resistance is a health care crisis of major proportions and requires a moratorium on the use of antibiotics in agriculture. The Centers for Disease Control (CDC) call antibiotic resistance “one of the world’s most pressing public health problems.” Many bacterial infections are becoming resistant to the most commonly prescribed antibiotics, resulting in longer-lasting infections, higher medical expenses, and the need for more expensive or hazardous medications. The development and spread of antibiotic resistance is the inevitable effect of the use of antibiotics. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance. Tell EPA and Congress to save antibiotics for important medical uses and eliminate use as pesticides. In spite of the spread of antibiotic resistance, the antibiotics used in plant agriculture are both important for fighting human disease. Tetracycline is used for many common infections of the respiratory tract, sinuses, middle ear, and urinary tract, as well as for anthrax, plague, cholera, and Legionnaire’s disease, though it is used less frequently because of resistance. Streptomycin is used for tuberculosis, tularemia, plague, bacterial endocarditis, brucellosis, and other diseases, but its usefulness is limited by widespread […]

(Beyond Pesticides, May 2, 2019) Researchers have documented an increase in food and drinking water residues of neonicotinoids, insecticides linked to breast cancer. Using the Pesticide Data Program (PDP), 1999-2015, of the U.S. Department of Agriculture, the researchers identified near-peak detection frequencies in 2015, after a decline from 2008-2013. Imidacloprid remains the most common neonicotinoid detected across imported commodities, while the neonicotinoids clothianidin, thiamethoxam, acetamiprid, and flonicamid are replacing imidacloprid in domestic production. Authors note that these newer neonicotinoids are potentially more toxic than imidacloprid, raising concerns for understudied human health and environmental impacts. The study, Trends in neonicotinoid pesticide residues in food and water in the United States, 1999–2015, published in the journal Environmental Health, finds the highest detection frequencies for neonicotinoids in drinking water, with 30% of treated drinking water turning out positive for imidacloprid in 2011. Certain fruits and vegetables are also frequently contaminated by neonicotinoids, with detection frequencies ranging from 20% to as high as 57% in the case of imidacloprid on cauliflower. While the study points to specific fruits and vegetables as posing higher risk, the main message reaches beyond individual commodity or individual neonicotinoid results. Authors uncover a systematic increase in detection of neonicotinoid […]

(Beyond Pesticides, April, 30, 2019) According to the latest blog post from pesticide industry propagandist Henry I Miller, the pollinator crisis either a) is not occurring; b) is not a problem; or, c) caused by varroa mites, pathogens, and habitat loss. Notwithstanding outlandish assertions that there is no pollinator crisis, new research is further undermining the long-held industry claim that it is mites and disease alone, and not pesticides that are harming pollinator populations. Published in the journal Scientific Reports by a team of Canadian scientists, this research finds that realistic exposure to neonicotinoid insecticides impairs honey bees ability to groom mites off of their bodies and increases infection with a disease known as deformed wing virus (DWV). “When bee colonies began to collapse years ago, it became clear there wasn’t just one factor involved, so we were interested in whether there was an interaction between two of the main stressors that affect bees: varroa mites and a neurotoxic insecticide, clothianidin,” said Nuria Morfin Ramirez, PhD, at the University of Guelph, Canada. Dr. Ramirez and her team exposed honey bees to a range of different concentrations (low, medium, high) of the neonicotinoid clothianidin, with some bees receiving combined stressors of […]

(Beyond Pesticides, April 25, 2019) As reported by Mother Jones, the New York Times (NYT) published, on April 6, a distressing report about a deadly fungus that has been advancing steadily across the world during the past five years. Candida auris is an emerging fungal pathogen that threatens those with compromised or immature immune systems, such as infants, the elderly, people taking steroids for autoimmune disorders, diabetics, those undergoing chemotherapy, and even smokers. Nearly half of those who contract a C. auris infection die within 90 days. One of the factors making this fungus so deadly is that it has developed resistance to existing antifungal medicines, with 90% of infections resistant to one drug, and 30% to two or more. As is true for resistant bacteria, culprits in C. auris’s development of resistance may be the overuse of antifungal medications in health care and overreliance on fungicides in agriculture. The Centers for Disease Control and Prevention (CDC) has added C. auris to its list of pathogens considered “urgent threats.” It is an “emerging fungal pathogen,” meaning that the incidence of infection has been increasing across multiple countries since it was first recognized in 2009 in Japan (although a different strain had […]

(Beyond Pesticides, April 22, 2019) This Earth Day, please join us in celebrating, propagating, and educating about a misunderstood and beneficial plant: clover.  Clover: Provides your lawn with enough nitrogen to eliminate any need for ecologically hazardous synthetic fertilizers Acts as an important food source for declining pollinator populations Attracts earthworms and other beneficial soil microorganisms Remains green year-round Resists drought Helps your lawn resist disease A little history: “White clover used to be a standard ingredient in every grass seed mix; 75 years ago no one planted a lawn without mixing a little white clover in with the grass seed,” recounts Roger Swain, host of PBS’ The Victory Garden. After World War II, as the middle class grew and moved to suburban communities, chemicals developed during wartime found new uses on U.S. lawns. Chief among them was 2,4-D – an herbicide originally developed with the intent to wipe out potatoes in Germany and rice crops in Japan in a plan to starve the Axis powers into surrender. While 2,4-D was never used for that purpose, its ability to kill broadleaf plants while sparing grass species made it desirable on the farm for removing weeds around crops like wheat, corn, and […]

(Beyond Pesticides, April 18, 2019) Organic farming promotes natural resistance to common foodborne human pathogens, according to a study that evaluates the benefit of soil organisms. By protecting valuable species of dung beetles and soil bacteria, organic farming systems naturally act to clean up and decompose potentially pathogen-bearing animal feces. While these natural systems suppr ess pathogens on organic farms, coventional chemical-intensive farms are left with higher levels of fecal residues and are therefore significantly more likely to yield produce carrying such foodborne pathogens as E. coli. The authors emphasize that curbing the spread of common foodborne pathogens could save thousands of lives and prevent millions of illnesses each year. The study, “Organic farming promotes biotic resistance to foodborne human pathogens,” published in the Journal of Applied Ecology, compares dung beetle populations, soil bacteria diversity, and feces removal rates on 70 organic and conventional broccoli farm fields across the west coast of the U.S. In addition to studying field conditions, authors conducted additional microcosm studies to directly test the effects of dung beetles and soil microbes on the suppression of introduced E. coli. Results from field analyses show that organic management practices lead to greater biodiversity among dung beetles and soil […]

(Beyond Pesticides, April 17, 2019)  A neurotoxic pesticide labeled “bee-safe” has been found to be harmful to bees, according to a new study. Flupyradifurone (FPF), the subject of the study, is a novel chemical that was hastily registered in the wake of public awareness about the impact of neonicotinoid insecticides on bees. A systemic insecticide and a nicotinic acetylcholine receptor (nAChR) agonist, it functions in the same way as a neonicotinoid, though it is in the butanolide family. “Lethal and sublethal synergistic effects of a new systemic pesticide, flupyradifurone (Sivanto®), on honeybees,” not only debunks the myth that FPF is safe on its own, it also delves into the FPF’s synergistic effects with a commonly used fungicide propiconazole (PRO). PRO, on its own, has no impact on bee mortality. A rarely studied realm of pesticides, the study defines a synergistic effect as, “when combined exposure to two factors results in an effect that is significantly greater than the sum of individual effects.” Researchers manipulated six healthy honey bee (Apis mellifera ligutica) colonies and observed the impact of varying amounts of pesticide exposure, including both individual and synergistic effects, on behavior and mortality. They recorded data over seasons and between worker […]

(Beyond Pesticides, April 12, 2019) The Center for Biological Diversity (CBD) announced on April 3 that it is suing the U.S. Fish and Wildlife Service (FWS) for its failure to release public records, despite multiple FOIA (Freedom of Information Act) requests, that would reveal on-the-ground impacts of FWS allowing use of neonicotinoids and genetically engineered (GE) crops in wildlife refuges. Last August, in yet another rollback of protections for wildlife, the environment, and public health, the Trump administration reversed a 2014 FWS decision to ban the use of neonicotinoids and GE crops in National Wildlife Refuges. If successful, the CBE lawsuit, filed in U.S. District Court for the District of Columbia, would compel the agency to provide the requested documents. This would allow the public, largely through the work of NGO (non-governmental organization) watchdogs, such as CBD and Beyond Pesticides, to understand what harms are being caused on the nation’s protected public lands by the administration’s reversal of the 2014 ban. Hannah Connor, a CBD senior attorney, said, “The goal of the lawsuit is to get them to comply with the Freedom of Information Act and produce the records that have been requested. . . . We aren’t asking them to […]

(Beyond Pesticides, April 8, 2019) Officials in Europe and the U.S. focus on banning problem pesticides, raising concerns about their replacements in the face of pesticide-intensive management strategies, while organic advocates call for a systems change in land management. In reference to widespread community bans of Roundup/glyphosate, Cary Gillam, author of Whitewash, told last year’s Beyond Pesticides’ Forum, “Glyphosate is the poster child for the bigger pesticide problem.” She continues, “If it goes away tomorrow, we are not okay.” Because of this, Beyond Pesticides has strategically sought to transform our country’s approach to pest management, both agricultural and residential/structural, by eliminating a reliance on pesticides and advancing organic management practices that do not rely on toxic inputs. This Daily News Blog post offers updates on progress in the European Union (EU), in the U.S. Congress, and in communities and sates nationwide. The EU is poised to ban clorothalanil, a commonly used — and highly toxic — organochlorine fungicide, The Guardian reported, in mid-to-late May 2019. After a review by the European Food Safety Authority (EFSA), EU states voted to approve a ban. EFSA identified as a chief safety concern the possibility that breakdown products (metabolites) of the compound may cause damage […]

(Beyond Pesticides, April 4, 2019)  Following on its verdict that the herbicide Roundup caused plaintiff Edwin Hardeman’s  non-Hodgkin lymphoma (NHL), the jury on March 27 issued an award of $80 million—$5 million in compensatory damages and $75 million in punitive damages—for improper labeling and negligence on the part of the manufacturer and defendant, Monsanto. The trial, the first federal Roundup cancer trial, marks the first of a multidistrict litigation against Monsanto, with more than 1,600 similar lawsuits pending in San Francisco’s federal court. The jury’s second verdict affirmed Mr. Hardeman’s allegations that Roundup’s design is defective and lacks sufficient warnings, and that Monsanto was negligent by not using reasonable care to warn about Roundup’s NHL risk. The Edwin Hardeman v. Monsanto Co. jury verdict marks the second multi-million dollar award to be granted in a landmark case against Bayer/Monsanto within the past year. Last August in San Francisco Superior Court, California groundskeeper Dewayne “Lee” Johnson was awarded $39 million in compensatory damages, and $250 million in punitive damages in the first case that linked his NHL to Monsanto’s glyphosate/Roundup. In October, the judge in the case upheld the verdict, but reduced the award to $78 million. Mr. Hardeman is represented by […]

(Beyond Pesticides, April 2, 2019) Throughout the month of April, and in celebration of Earth Day on April 22, Natural Grocers is inviting the community to pledge to protect one of nature’s most beloved beneficial insects—the ladybug. From April 1st through the 22nd, Natural Grocers will donate 10 cents to Beyond Pesticides for every pledge taken on their website, up to $25,000. Pledge takers will commit to never use chemicals that are harmful to ladybugs and other beneficial insects, and to support 100% organic produce. The stability of our food web depends on insects, but recent studies suggest they have declined by more than 75 percent in the last three decades.[i] Agricultural pesticide use has steadily increased since 1960.[ii] According to the most recent EPA report (2012), estimates of annual pesticide use in the United States topped 1 billion pounds[iii] in 2011 and 2012, and 88 million U.S. households use pesticides at home.[iv] Natural Grocers is excited to partner with Beyond Pesticides to keep the public informed about the threat toxic pesticides pose to human health, insect health, and the health of the planet. Take the pledge today at https://www.naturalgrocers.com/ladybuglove/!   [i] Hallmann, Caspar A., et al. “More than 75 Percent […]

(Beyond Pesticides, April 1, 2019) National Organic Standards Board (NOSB) meets next month in Seattle, Washington to debate issues concerning what goes into your organic food. Written comments are due April 4. The format for messaging the NOSB requires copying and pasting comments into regulations.gov, so we apologize that this is not a “single click” action. Please add a personal message about why this is important to you at the top of your comments, if possible. Lend your voice to continuous improvement by learning about issues and submitting comments to regulations.gov (directions below, or click here). From the very beginning, with the passage of the Organic Foods Production Act (OFPA) in 1990, “organic” has meant “continuous improvement ” in organic food production. The primary mechanism for this is the high level of public involvement that comes from twice-annual meetings of the stakeholder board and decisions related to the allowance of substances/materials used in organic production. The second mechanism is the sunset process, which helps move synthetic substances out of organic production as we learn more about hazards and alternatives. Those substances allowed in organic production must be placed on the National List of Allowed and Prohibited Substances and may be re-listed every five […]

(Beyond Pesticides, March 29, 2019) The U.S. Environmental Protection Agency (EPA) made a low-key announcement on March 19 suggesting that it may change its handling of requests from states to exert stricter controls on use of pesticides than the federal agency sets out in its registration of the compounds — by disapproving them. This is potentially a big deal because it signals that the agency will be less-kindly disposed to states’ desires to establish either somewhat different parameters of use based on local conditions and needs, or more-stringent regulations on pesticide use than those set out by federal regulators. This issue of preemption of localities’ desires to protect their populations and environment has become an increasingly dynamic frontier at the nexus of pesticide use, health, and environment. Beyond Pesticides has written more frequently about this issue in recent years as the tension between centralized, federal regulation and more-local regulation has risen; see more below. EPA appears distressed by some of the approximately 300 annual requests it gets to make some adjustment to the federal regulation. This can happen under Section 24(c) of FIFRA, which allows for a Special Local Need Label, which can be requested under a variety of conditions, including […]

(Beyond Pesticides, March 27, 2019) Exposure to commonly used pesticides in the womb and during the first year of life is linked to a higher risk of developing autism, according to the study, “Prenatal and infant exposure to ambient pesticides and autism spectrum disorder in children: population based case-control study,” published in the journal BMJ last week. Although the study does not reveal a causal link, it adds to previous literature highlighting autism risks from pesticide exposure, and reinforces calls to limit pesticide exposure during early life critical windows of vulnerability. The authors note their findings “support the need to avoid prenatal and infant exposure to pesticides to protect the developing child’s brain.” Researchers used data from California’s records of autism disorder diagnosis and birth rates from 1998 to 2010. Roughly thirty-five thousand healthy patients acted as a control, while scientists identified nearly three thousand patients with an autism diagnosis, of which 445 also displayed a co-occurring intellectual disability. Data was then drawn from California’s pesticide use recording database, and eleven pesticides (glyphosate, chlorpyrifos, diazinon, acephate, malathion, permethrin, bifenthrin, methyl bromide, imidacloprid, avermectin, and myclobutanil) were analyzed for their use within 2000 meters (1.25 miles) of the homes of those […]

(Beyond Pesticides, March 25, 2019) EPA is using a regulatory loophole – the “treated articles exemption” – to allow systemic insecticides to be used in mass quantities, without regulating or labeling them as required under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). EPA does not currently assess adverse effects on the environment and public health caused by widespread use of neonicotinoid insecticides delivered through seeds coated with the insecticides, resulting in widespread exposure to one of the most environmentally damaging classes of chemicals on the market. Tell your Congressional delegation that EPA must fully regulate treated seeds to protect the environment and public health. Pesticide-coated seeds are now ubiquitous, yet their far-reaching impacts on wildlife and human health continue to go unregulated. The introduction and spread of seed-delivered pesticides to major field crops, beginning around 2003, caused a massive increase in total neonicotinoid use nationwide. As of 2011, 34 to 44% of soybeans and 79 to 100% of maize acres were planted with coated seeds, accounting for an astounding 35-fold increase in nationwide neonicotinoid use from baseline rates prior to 2003 (Douglas and Tooker, 2015). Alarmingly, because the national pesticide survey conducted by the National Agricultural Statistics Service fails to […]