(Beyond Pesticides, July 21, 2023) A comprehensive and scathing report, “Neonicotinoid insecticides: Failing to come to grips with a predictable environmental disaster,” issued by American Bird Conservancy (ABC)in June, lays out the dire consequences of neonicotinoid (neonic) pesticides’ continued use. The report is an update of an earlier review from 2013, which warned of the risks to birds, stating starkly: “A single corn kernel coated with a neonicotinoid can kill a songbird. Even a tiny grain of wheat or canola treated with the oldest neonicotinoid, imidacloprid, can poison a bird. As little as 1/10th of a corn seed per day during egg-laying season is all that is needed to affect reproduction with any of the neonicotinoids registered to date.” The story of neonic harm is one that has been repeated for generations with different pesticides. Pesticide manufacturers claim every new generation of their products is safer and more environmentally benign than the previous one. This is seldom true. There is ample evidence that pesticides pose threats to nearly every class of organism on Earth, from earthworms to elephants. The neonicotinoids, introduced in the early 1990s, have been marketed as safe for vertebrates, non-bioaccumulative, and, because of their flexible application methods […]

(Beyond Pesticides, July 12, 2023) A study by University of Delaware entomologist Thabu Mugala and colleagues finds that modifications to their farming methods can reduce slug damage when those changes also encourage natural slug predators, allowing farmers to avoid the endless cycle of pesticide dependency, pest resistance, genetically engineered crops, and synthetic fertilizers. With insects as the target for tens of millions of pounds of agricultural use, growers of the highest-production crops in the U.S., corn and soybeans, continue to find slugs to be a serious problem. Corn and soybean growers who have adopted no-till or conservation tillage and cover crops often think these practices worsen the problem by increasing moisture and decaying plant material in fields, which slugs love. But the cause-and-effect picture is more nuanced and requires strategies that nurture ecological balance. Slugs are the most damaging non-arthropod pest in no-till corn production in the U.S., and truly effective chemical deterrents do not exist at agricultural scale, as Beyond Pesticides noted here, although biological methods may be on the horizon, such as a parasitic nematode already used in Europe that shows promise. The most voracious natural slug hunters are ground beetles, but harvestmen (daddy longlegs), and wolf spiders […]

(Beyond Pesticides, June 23, 2023) Pollinators are especially important to the ecosystem. They pollinate plants by going from flower to flower and transferring pollen. Without pollinators, availability would be severely limited or cut off to many delicious foods, such as apples, almonds, cherries, blueberries, pumpkins, and many others. Many types of pollinators, like honey bees, bumble bees, and butterflies, are declining due to loss of habitat, widespread use of toxic pesticides, parasites, and disease. Help these important beneficial creatures by Not using toxic pesticides Planting pollinator habitats, like colorful flowers, gardens, and trees Telling your friends and family all about the importance of pollinators. Wild and Managed Bees Wild and managed bees play a crucial role in the global food system. About two-thirds of the world’s most important crops benefit from bee pollination, including coffee, cacao, and many fruits and vegetables. Wild pollination is becoming increasingly important with the growing instability of managed honey bee colonies. According to one study, wild bees’ agricultural value is now similar to that of honey bees, which are no longer considered wild in many regions due to their intense management. While many may prefer butterflies and birds to pay a visit to their gardens […]

(Beyond Pesticides, June 22, 2023) Since the early twentieth century, ‘migratory’ beekeepers have provided a critical service to U.S. agriculture by moving their hives seasonally to pollinate a variety of crops. Annually, commercial beekeeping adds between $15 and $20 billion in economic value to agriculture, which is a major industry in the United States, with 21.1 million full- and part-time jobs related to the agricultural and food sectors—10.5 percent of total U.S. employment. Before insects and pollinators like bees evolved to pollinate, pollination occurred through the wind, scattering the pollen from the plants and landing on other flowers that could reproduce. However, commercial pollination services contribute to increased yields. Without commercial pollination, food prices would rise, the farm sector would suffer globally, and the security and variety of the food supply would diminish. With the wild insect pollinator populations already in serious decline, commercial, migratory beekeeping is more than ever a vital piece of the agricultural economy. With pollinator decline, as an integral part of worldwide biodiversity collapse and the “insect apocalypse,” commercial beekeepers face collapse as well. The United Nations states that 80 percent of the 115 top global food crops depend on insect pollination, with one-third of all U.S. crops depending on pollinators, according to the U.S. […]

(Beyond Pesticides, June 21, 2023) Pollinators––bees, butterflies, birds, bats, and other organisms––make a critical contribution to plant health, crop productivity, and the preservation of natural resources. However, pesticides consistently act as a key contributor to dramatic pollinator declines. Much research attributes the decline of insect pollinators over the last several decades to the interaction of multiple environmental stressors, from climate change to pesticide use, disease, habitat destruction, and other factors. Roughly a quarter of the global insect population has disappeared since 1990, according to research published in the journal Science. Monarchs are near extinction, and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies, the foundation of many food chains, and fireflies, the foundation of many childhood summer memories. The declines in many bird species likely have close links to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, have been lost since the 1970s. In a world where habitat loss and fragmentation show no sign of abating, scientists have concluded that the globe cannot afford to continue to subject its critically important wild insects to these combined threats.  Clean air, water, and healthy soils are integral to ecosystem function, interacting between Earth’s four main spheres (i.e., hydrosphere, […]

(Beyond Pesticides, June 20, 2023) Welcome to National Pollinator Week, during which time we recognize—and take action to protect—this important ecosystem link. Pollinators—bees, butterflies, birds, bats, and other organisms—make a critical contribution to plant health, crop productivity, and the preservation of natural resources, but their existence is threatened by their pesticide-contaminated habitat.   Check out this week’s calendar of activities and actions below! On social media, we will be featuring Pollinator Artwork submitted by the community, as well as the numerous cute (and “not so cute!”) pollinators that live in the world around us!  Also, check out our live Pollinator Poll! Follow us and like our page on Facebook, Twitter, Instagram and LinkedIn!  Monday: Juneteenth and Environmental Justice  As Pollinator Week launches with the celebration of Juneteenth, it is time to renew our commitment to environmental justice while seeking the adoption of transformational policies and practices that recognize the urgency to address disproportionate harm inflicted by toxic pesticide use.   Those fighting for environmental justice understand that the harms inflicted by toxic chemical production and use cause disproportionate adverse effects on people of color—from fenceline communities near chemical production plants to the hazardous and inhumane working conditions in agricultural fields, to […]

(Beyond Pesticides, May 26, 2023)The use of pesticides in agriculture, transportation, and domestic settings has created a disastrous conflict for the human species. Two irreconcilable facts confront humans as they try to adapt to the consequences of earlier choices: One, industrial civilization came to believe that because some insects, fungi, and other organisms like to eat the same plants humans eat, humans can kill them with impunity; two, because some insects and other organisms are necessary to the health and reproduction of plants, humans need to protect them. At no point in history have people acknowledged that it is very difficult to kill the “bad” actors while protecting the “good” ones. There are not really two sides to the biological fact; rather, pesticides and biodiversity meet each other on a single plane, like a Möbius strip. Among the most dire effects of pesticides are their ruination of pollinators. Bees spring to mind as our primary pollinators, but they are by no means the only ones. Butterflies, often regarded as mere ornamental additions to a landscape, are actually significant pollinators themselves. Monarchs pollinate many flowers, including calendula and yarrow. Other butterflies pollinate dill, celery, fennel, cilantro, lettuce, peas, and basil, among […]

(Beyond Pesticides, May 18, 2023) A study published in Food and Chemical Toxicology finds pesticide residues in beehive products pose a safety risk from dietary consumption. Beehive products (i.e., bee bread, propolis, beeswax, and royal jelly) from beekeeping or apiculture are said to have nutraceutical (health and medicinal benefits) properties. However, a wide range of pesticide residues (i.e., tau-fluvalinate, coumaphos, chlorfenvinphos, chlorpyrifos, and amitraz), especially acaricides for killing ticks and mites in hives, may accumulate in beehive products up to concentrations that pose a potential health risk. Environmental contaminants like pesticides are ubiquitous in the environment, with 90 percent of Americans having at least one pesticide compound in their body. Many of these chemical compounds remain in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. Therefore, individuals still encounter pesticide compounds at varying concentrations, adding to the toxic body burden of those harmful chemicals currently in use. The research methodology includes a review of the scientific literature on pesticide contamination in hive products and a dietary risk assessment. The risk assessment calculation uses scientific studies to determine the recommended daily intake values and concentration data. Researchers compare exposure values in products to health-based guidance, determining the potential acute and […]

(Beyond Pesticides, May 2, 2023) On April 20, the European Commission’s new rules on endocrine disrupting chemicals took effect. Called “Classification, Labelling & Packaging” (CLP), the rules create four new hazard categories for endocrine disruptors. The categories range from “suspected of causing” or “may cause” endocrine disruption in the environment to “suspected of causing” or “may cause” endocrine disruption in humans. After a transition period, users will have to indicate on labels and packaging if a substance falls into any of the hazard classes. All actors in the supply chain are obligated to provide the information to every downstream participant. The  new CLP rules, implementing a 2022 measure adopted by the European Commission and then the European Parliament, also specify a minimum font size for the hazard information and for the first time include standards for labeling in online commerce and in places where customers use refillable containers to transport, store, and use the chemicals. According to the EU Directorate-General for the Environment: “The new hazard classes are the result of extensive scientific discussions and will provide easier access to information to all users of such chemicals, notably consumers, workers and businesses. They allow further action to address and mitigate […]

(Beyond Pesticides, April 27, 2023) The Nevada Assembly, by unanimous vote, took the state one step closer to banning the use of neonicotinoid insecticides used on plants, with a waiver for commercial agricultural purposes. Despite dramatic declines in bee populations linked to neonicotinoid pesticides and other toxic pesticides, the U.S. Environmental Protection (EPA) and state regulatory authorities have for the most part ignored beekeepers and the independent scientific literature by allowing widespread toxic pesticide use—forcing elected officials to take protective action. Portions of the bill would take effect upon passage or no later than January 1, 2024. Maine and New Jersey have adopted similar legislation. The failure to adequately regulate pesticides under federal law, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and EPA inaction is viewed by environmentalists as the shocking disregard for the importance of biodiversity to sustaining life. The inadequate restriction of pesticides and slower than necessary transition to organic land management practices are viewed as major contributors to the “insect apocalypse.” The legislation (A.B. 162), led by Assemblywoman Michelle Gorelow and a group of nine other Assemblymembers, illustrates a growing trend of local and state legislative bodies asserting their authority to protect against health, biodiversity, and […]

(Beyond Pesticides, April 20, 2023) This Earth Day (Saturday, April 22, 2023), Beyond Pesticides urges individuals to spread awareness of the toxic pesticides that poison people and the environment and the safe alternatives that are available to safeguard communities and the surrounding environment. On Earth Day, reflecting on the beauty and wonder of the natural world highlights the importance of restoration and preservation to maintain the planet’s intricate web of life. However, the natural world on which life depends is under dire threat as the dependence on toxic chemicals (e.g., pesticides) enables ongoing environmental contamination. Mechanized and industrial human activity perpetuates ongoing toxic chemical contamination, resulting in massive die-offs of beneficial organisms, increased rates of autoimmune diseases, endocrine disrupting and transgenerational chemical effects, and widespread pollution of our air and waterways. Beyond Pesticides, has the tools needed to increase environmental awareness in your community. Therefore, this Earth Day, Beyond Pesticides continues to advocate for the adoption of organic practices and policies that alleviate threats to ecosystems and enhance biodiversity. Michigan State University professor Thomas Dietz, Ph.D. highlights, “Continuing the successes of environmentalism—an integration of science, a concern with human well-being and justice, and a recognition of the need to consider […]

(Beyond Pesticides, April 14, 2023) In March, scientists at the National Marine Fisheries Service (NMFS) issued a draft Biological Opinion (BiOp) stating that carbaryl and methomyl — two commonly used carbamate insecticides — cause significant harm to dozens of already-endangered fish species in the Pacific Northwest’s Columbia, Willamette, and Snake rivers. The BiOp indicates that these toxic compounds, in wide use on orchards and field vegetables throughout the Willamette Valley, the Columbia River Gorge, and southeastern Washington, will likely threaten scores of species on the Endangered Species list: 37 species at risk from carbaryl and 30 from methomyl. In addition, the BiOp says, “both are likely to harm or destroy many areas designated as critical habitat for endangered species.” The mitigation measures proposed by NMFS and the U.S. Environmental Protection Agency (EPA), in light of this BiOp, are likely to be inadequate to the problem, given that both compounds can drift through air and/or migrate into groundwater and generate toxic runoff. These two neurotoxic insecticides, carbaryl and methomyl, are very toxic to bees, birds, fish, and other aquatic organisms. In addition, carbaryl is a likely human carcinogen and an endocrine disruptor, and has harmful impacts on multiple bodily systems. Methomyl is […]

(Beyond Pesticides, April 12, 2023) Spring represents a period of increased water, soil, and general ecosystem pollution, correlated with increased pesticide use and increased rainfall. Thus, April showers bring May flowers, and often pesticides. We offer this overview to share with friends, family, and your community in an effort to elevate the urgent need to eliminate pesticides and make the shift to organic land management. Pesticides are pervasive in the environment, affecting all ecosystems, including air, water, and soil. Like clean air and water, healthy soils are integral to ecosystem function, interacting between Earth’s four main spheres (i.e., hydrosphere, biosphere, lithosphere, and atmosphere) to support life. Pesticide use results in pervasive contamination of treated and nontarget sites. Even organic farmers and gardeners globally suffer from the widespread movement of pesticides through the air, water, and runoff from land. Attempts to protect property and ecosystems from pesticide use are a difficult, some say impossible, challenge. Efforts to prevent contamination become a large burden, with attempts to curtail pesticide drift with buffer zone areas and eliminate fertilizers or soil supplements with pesticide residues (e.g., manure and compost). Furthermore, the effects of climate change only exacerbate threats to ecosystem health, as studies show a […]

(Beyond Pesticides, April 6, 2023) A study published in Global Change Biology adds to research demonstrating that climate change can exacerbate the adverse impacts of pesticide exposure on managed and wild bees. Temperature can alter the sublethal effect pesticides, particularly the neonicotinoid (neonic) imidacloprid and the sulfoximine sulfoxaflor, have on bumble bee behavior tied to fitness and pollination services. Both an increase and decrease in temperature can cause diverging thermal responses in bumble bee behavior. However, increasing temperature bares more severe behavior abnormalities than cooler temperatures. The pervasiveness of pesticide exposure combined with climate change threatens global species biodiversity. As has been widely reported, pollinators (such as bees, monarch butterflies, and bats) are a bellwether for environmental stress as individuals and as colonies. Pesticides intensify pollinators’ vulnerability to health risks (such as pathogens and parasites), with pesticide-contaminated conditions limiting colony productivity, growth, and survival. Now more than ever, people are changing their sentiment toward sustainability, with two-thirds of consumers stating the importance of limiting climate change impacts and 88 percent supporting greater pollution reduction. The globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk. With the increasing rate of biodiversity loss, advocates say it is essential for […]

(Beyond Pesticides, March 21, 2023) Placing honey bee hives in agricultural areas creates stress that leads to microbial imbalances, according to research published in Scientific Reports by Croatian scientists this month. The research highlights the fragility and absurdity of chemical-driven agricultural systems dependent upon both pollinators and products that harm or kill off these sensitive species. While regulators in the United States continue to prop up unsustainable practices, more and more consumers are seeking out and engaging with the key alternative to this system by supporting organic farms and foodstuffs at their farmers market and grocery store. Scientists began by creating 33 colonies from three apiaries within an agricultural region in Croatia, utilizing four brood frames, two honey frames, and mated queens. Of these 33 newly created hives, 22 were relocated to a separate agricultural region, and 11 were placed roughly six miles away from a nature preserve and considered a semi-natural area. A separate group of 10 hives that had been established on a small island (Unije, Croatia) in the Adriatic Sea were included in the study in order to represent a completely natural location. After roughly two weeks of colony formation, scientists collected samples to represent the multiple […]

(Beyond Pesticides, March 2, 2023) On February 22, a group of 65 nonprofit organizations (including Beyond Pesticides) filed a citizen petition with the U.S. Environmental Protection Agency (EPA) that asks the agency to close a gaping — and well exploited — regulatory loophole by revoking a 1984 regulation that waived efficacy data requirements in pesticide evaluations. This means that EPA has, for 39 years, registered pesticides without demonstrated proof of efficacy and benefits. The petition is aimed primarily at the widespread use of neonicotinoid insecticides (neonics), which are so harmful to hundreds of species — and to bees, other pollinators, and birds, in particular — that many advocates have insisted they should be banned altogether. Beyond Pesticides has advocated for a neonics ban because of their extensive harms to pollinators, multiple other organisms (including humans), ecosystems, and natural resources. The Center for Food Safety, Pesticide Action Network North America, Center for Biological Diversity, Beyond Pesticides, and other advocates have filed lawsuits in recent years to get EPA to act protectively on neonics and other pesticides. The coalition of groups in the subject case seeks to rein in a plethora of harmful impacts of neonics, given EPA’s overall lack of protective action. (For […]

(Beyond Pesticides, February 22, 2023) Combining neonicotinoid insecticides with other commonly used pesticides can result in synergistic effects on honey bees, increasing toxicity more than any individual chemical could, according to research published in Scientific Reports earlier this month. The data highlight the grave inadequacy of the U.S. Environmental Protection Agency’s (EPA) process for evaluating pesticide risks. Under current regulations, EPA requires chemical manufacturers to submit data only on singular active ingredients. Yet, pesticide products may be packaged or ‘tank mixed’ with other, equally toxic pesticides without any obligation to determine the toxicity of the material that is actually being applied. Independent research is left to fill in these gaps, and the data increasingly shows that toxicity with pesticide mixtures amounts to a roll of the dice: sometimes combinations are less toxic, sometimes their toxicities are merely additive. But more often than not, pesticide mixtures result in synergistic effects that make the product significantly more toxic than either individual chemical alone. To understand how pesticide combinations are harming pollinators, scientists began with baseline data on the individual toxicity range  that common pesticides pose to honey bee colonies. Research was conducted on honey bees reared in the Stoneville Wildlife Management Area […]

(Beyond Pesticides, February 15, 2023) Areas designated to protect insects fail to do so for over 75 percent of global species, according to a study, “Three-quarters of insect species are insufficiently represented by protected areas,” published in the online journal One Earth. Protected Areas (PAs) act as a safeguard for biodiversity. However, PAs in North America, Eastern Europe, Southeast Asia, and Australia do not meet the minimum coverage requirements to safeguard global insect species assessed in the study. PAs are discussed in the 2020 Nature article, “Area-based conservation in the twenty-first century,” in which the authors state that, in view of the global biodiversity crisis, national governments must do much more to increase protected areas with “coverage across different elements of biodiversity (ecoregions, 12,056 threatened species, ‘Key Biodiversity Areas’ and wilderness areas) and ecosystem services (productive fisheries, and carbon services on land and seas).” The authors write, citing the UN Convention on Biological Diversity (to which the United States is not a signatory), “To be more successful after 2020, area-based conservation must contribute more effectively to meeting global biodiversity goals—ranging from preventing extinctions to retaining the most-intact ecosystems—and must better collaborate with the many Indigenous peoples, community groups and private initiatives […]

(Beyond Pesticides, February 1, 2023) Honey bee declines in the United States are “primarily related” to pesticide exposure, parasitic mites, and extreme weather conditions, research published by Penn State scientists have determined. Publishing the results in Scientific Reports, the researchers aim to provide a national overview of the range of factors harming bee colonies. “Some previous studies have explored several potential stressors related to colony loss in a detailed way but are limited to narrow, regional areas,” said study co-author Luca Insolia, PhD. “The one study that we know of at the national level in the United States explored only a single potential stressor. For this study, we integrated many large datasets at different spatial and temporal resolutions and used new, sophisticated statistical methods to assess several potential stressors associated with colony collapse across the U.S.” The results reinforce calls from bee health advocates in the U.S. and around the world: eliminate toxic pesticide use, the lowest hanging fruit contributing to pollinator declines. In order to create a more comprehensive national overview, geographers, entomologists, and statisticians all participated in the study, reviewing publicly available data on colony health, land use, weather, and other environmental factors over a five-year period from […]

(Beyond Pesticides, January 26, 2023) A study published in Food Safety and Toxicology finds that the widely used fungicide azoxystrobin (AZO), used in food production and turf management, can disrupt the function of the intestinal (colonic) barrier responsible for the absorption of nutrients and defense against harmful substances. This and other similar data are important because the U.S. Environmental Protection Agency (EPA), with its required pesticide testing protocol, says that the chemical has “low acute and chronic toxicity to humans, birds, mammals, and bees,” and speaks to the need for the agency to modernize its registration requirements. [The agency does note that AZO is “is highly toxic to freshwater fish, freshwater invertebrates, and estuarine/marine fish, and very highly toxic to estuarine/marine invertebrates.] AZO is a broad-spectrum chemical used in wheat, barley, oats, rye, soya, cotton, rice, strawberry, peas, beans, onions, and a long list of other vegetables, as well as on lawns and golf courses, on a range of fungal diseases. The intestinal (colonic) barrier prevents the internal environment from damage caused by exogenous toxins to ensure internal homeostasis, impeding incidences of systemic inflammatory response syndrome (SIRS), sepsis, and multiple organ dysfunction syndrome (MODS). The intestines host a group of microorganisms that form […]

(Beyond Pesticides, January 25, 2023) Populations of the western bumblebee are in free fall, with 57% declines across the species’ historical range, finds new research led by scientists at the U.S. Geological Survey. These data are in line with trends for other once common bumblebees in the United States, like the rusty patched and American, of which the former is now listed as endangered and the latter is under consideration. Most critically, the study authors did not simply generalize the most likely and common reasons, but instead establish the contribution that pesticide use, climate change, and land use changes have on western bumblebee declines. As the study shows, both the drivers and solutions to pollinators declines are in human hands, necessitating a broad rethinking of the nation’s approach to energy use and food production. The western bumblebee has been under considerable stress for decades. In the 1990s, there were attempts to commercialize the species as a greenhouse pollinator. This industrial approach resulted in the spread of a fungal disease called Vairimorpha bombi, and captive rearing of the western bumblebee was eventually halted and deemed untenable. These dislocations resulted in local declines of the species in certain regions of U.S. Northwest […]

(Beyond Pesticides, January 18, 2023) Sunflower plantings have the potential to significantly reduce mite infestations in nearby honey bee colonies, according to research recently published in the Journal of Economic Entomology by researchers with the U.S. Department of Agriculture (USDA). With pollinators under threat from pesticides, climate change, loss of habitat, and the spread of disease and parasites, sustainable methods that address multiple factors at once are needed. This study points to a way to address destructive Varroa mites, while reducing the need for in-hive use of miticides that can likewise harm colony health. “If sunflowers are as big of a factor in mite infestation as indicated by our landscape-level correlations … having a few more acres of sunflower within a mile or two of apiaries could bring colonies below the infestation levels that require treatment of hives with acaracides (i.e., mite-controlling chemicals),” said lead author Evan Palmer-Young, PhD, of USDA’s Bee Research Lab in Beltsville, MD. Prior research has pointed to sunflower pollen as a potential benefit for a number of common bee diseases and infestations, including the Varroa mite, the fungal parasites Nosema spp, and various viruses. Investigations went through four different experiments aimed at characterizing any potential […]

(Beyond Pesticides, January 9, 2023) The Biden EPA still needs a new vision in order to meet the existential crises in public health, climate change, and biodiversity. The Trump Environmental Protection Agency (EPA) reversed in four years much of the progress made by the EPA in decades. Despite a broad new perspective embodied in President Biden’s Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office, the Biden EPA has not adopted a new direction for regulating pesticides. Tell President Biden, EPA, and Congress to adopt a new direction for pesticide regulation. Immediately following his inauguration, President Joe Biden issued the EM, which directs the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This EM could reverse the historical trend of status-quo regulatory reviews required by the White House Office of Management and Budget (OMB) that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers). The President’s EM sets the stage for the adoption of agency policy across government to […]