(Beyond Pesticides, March 26, 2024) The authors of a case study in Canale D’Aiedda, Taranto, Italy, published in Scientific Reports, conclude that, “[T]he results of monitoring and modeling activities revealed a chronic risk associated with the presence of Cu [copper] from November to April in several river reaches and acute risk associated to the presence of glyphosate in several reaches mainly in the wet season.”  According to the authors, “The most important factor influencing the chronic risk for Cu were the combination of two factors: the high surface runoff and the Cu applications. The most important factor influencing the glyphosate peaks of concentration is the streamflow.” The authors of the study measure the flow of pesticide concentrations through the soil and water assessment tool (SWAT). The ecotoxicological data was collected at two stations in Germany that flow into Italy, within the Canale d’Aiedda basin. The streamflow was monitored between August 2017 and December 2019. Out of hundreds of pesticides and six metabolities investigated in this study, “only traces of copper and glyphosate were found.” The authors continue, “The banks and the bed of the river system are almost all covered by concrete. The hydrological regime is natural and intermittent in […]

(Beyond Pesticides, March 22, 2024) With long-running efforts to keep organic land management in the forefront of public health and environmental measures to eliminate petrochemical synthetic substances, including pesticides and fertilizers, plastic again emerges as an increasing threat in a study linking microplastics to cardiovascular disease. The study by Italian researchers, published in the March 7 issue of the New England Journal of Medicine, finds an elevated risk factor for heart attack and stroke associated with plastics found in the plaque of the majority of patients’ carotid arteries. A holistic approach to agriculture that embraces principles and values to enhance biodiversity and protect health, the organic system requires that synthetic substances are compatible with that system. In this context, the environmental and public health effects of plastics are increasingly subject to scrutiny as they permeate nearly every aspect of food production, including fields, crops, foods, and food packaging. Plastics also migrate from other sectors into agriculture via wind and water and are now ubiquitous in every environment. Removing plastics from any ecosystem is extremely problematic, so getting them out of agriculture will be difficult – but necessary, given the accumulating evidence of their toxicity. Beyond Pesticides continues to push for […]

(Beyond Pesticides, March 21, 2024) Alarming levels of a hazardous pesticide plant growth regulator linked to reproductive and developmental effects, chlormequat, is found in 90% of urine samples in people tested, raising concerns about exposure to a chemical that has never been registered for food use in the U.S. but whose residues are permitted on imported food. Published in the Journal of Exposure Science and Environmental Epidemiology in February 2024 and led by Environmental Working Group toxicologist Alexis Temkin, PhD, a pilot study finds widespread chlormequat exposure to a sampling of people from across the country. U.S. Environmental Protection Agency (EPA) regulations only permit the use of chlormequat on ornamental plants and not food crops grown in the U.S. As explained in the journal article, “In April 2018, the U.S. EPA published acceptable food tolerance levels for chlormequat chloride in imported oat, wheat, barley, and some animal products, which permitted the import of chlormequat into the U.S. food supply.” In 2020, EPA increased the allowable level of chlormequat in food. Then in April 2023, EPA proposed allowing the first-ever U.S. use of chlormequat on barley, oat, triticale (a hybrid of wheat and rye), and wheat. Existing regulatory standards explain the […]

(Beyond Pesticides, March 20, 2024) A report by CBAN unpacks the ecosystem and wildlife health impacts of genetically engineered (GE) corn in the context of Mexico’s 2023 decision to stop its importation into the country. The phase out of genetically modified (GM) corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA), which replaced the North American Free Trade Agreement (NAFTA) as the primary vehicle for North American trade policy. In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban. There has been no public update from the Office of the U.S. Trade Representative as of this writing. The CBAN report highlights the scientific rationale underpinning Mexico’s decision to “safeguard the integrity of native corn from GM contamination and to protect human health” with this ban. In 2020, Mexico announced a four-year phase-out of the weed killer glyphosate, which along with other petrochemical herbicides is integral to GM corn production. When Mexico’s Minister of the Environment announced the phase-out, he said it is part of an effort to transform the country’s food system […]

 (Beyond Pesticides, March 14, 2024)  A recent review in the New England Journal of Medicine (NEJM) highlights the urgent need to address the widespread chemical pollution stemming from the petrochemical industry, underscoring the dire implications for public health. Tracey Woodruff, PhD, author and professor at the University of California San Francisco (UCSF), emphatically states in an email comment to Beyond Pesticides, “We need to recognize the very real harm that petrochemicals are having on people’s health. Many of these fossil-fuel-based chemicals are endocrine disruptors, meaning they interfere with hormonal systems, and they are part of the disturbing rise in disease.” Beyond Pesticides echoes this concern, noting that endocrine disrupting chemicals (EDCs) include many pesticides and are linked to a plethora of health issues such as infertility, diabetes, cardiovascular diseases, obesity, early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers.  (See Beyond Pesticides’ Disease database here and news coverage here). The review further calls on the clinical community to advocate for policy changes aimed at mitigating the health threats posed by petrochemical-derived EDCs and climate change. Beyond Pesticides urgently calls for the elimination of petrochemical pesticides and fertilizers and advocates for a systemic […]

(Beyond Pesticides, March 13, 2024) A comprehensive study released in Journal of Cleaner Production in August 2023 identifies the potential for organic agriculture to mitigate the impacts of agricultural greenhouse gas (GHG) emissions in the fight to address the climate crisis. In “The spatial distribution of agricultural emissions in the United States: The role of organic farming in mitigating climate change,” the authors determine that “a one percent increase in total farmland results in a 0.13 percent increase in GHG emissions, while a one percent increase in organic cropland and pasture leads to a decrease in emissions by about 0.06 percent and 0.007 percent, respectively.” This descriptive study affirms the urgency of Beyond Pesticides’ mission to ban toxic petrochemical pesticides by 2032, given the projected adverse impacts that conventional agricultural dependence on these toxic pesticides will continue to have on people, wildlife, and ecosystems. The study refers to various studies focused on a comparative analysis of conventional to organic farming on energy use, greenhouse gas emissions (GHGe), nutrient leaching, soil quality, and biodiversity. The consensus is that organic farming is more sustainable than conventional agriculture. For example, “[S]everal studies comparing conventional to organic agriculture found that the latter used 10%–70% […]

(Beyond Pesticides, March 12, 2024) A study released in Science of the Total Environment unpacks the threat of emerging chemicals of concern (CECs), including toxic pesticides, in the groundwater of Tunisia. Researchers highlight that the impact of pesticide drift and leaching into groundwater reserves is not siloed to the Middle East and North Africa (MENA) region, but a key concern for most industrialized countries, including the United States. Authors of this study build on literature of CECs already conducted in the region that have broader implications for the spillover effects of pesticide regulation in broader contexts. This descriptive study and accompanying Environmental Risk Assessment (ERA) demonstrate the urgency of Beyond Pesticides’ mission to ban toxic petrochemical pesticides by 2032 because of the pervasiveness of toxic residues, be it pesticides, antibiotics, or other substances, from groundwater systems to human bodies. The researchers performed the tests in thirteen wells in the Grombalia shallow aquifer, an area of northeast Tunisia that feeds into the Wadi El Bay watershed, which is defined as a “high population density [with] intensive agricultural activity [in ‘one of the most polluted areas in Tunisia’].” The researchers gathered data “during two seasons and were analyzed with two high resolution […]

(Beyond Pesticides, March 8, 2024) A major problem has vexed pesticide regulators and researchers for decades: Humans and other organisms almost always have multiple pesticides in their bodies, but techniques for assessing their combined effects, or cumulative body burden from multiple chemical classes are not typically available. A new study from Chinese and British researchers provides the first combined assessment of multiple classes of pesticides in human blood. The authors believe they are the first to develop a way to quantify multiple types of pesticides in human serum (clear liquid part of blood) as opposed to urine or from other sample collection methods. This is a tool that authors say is a more accurate way of assessing the real world exposure and ultimately the adverse impact of pesticide use on human health. The researchers had a small sample of 31 men and 34 pregnant women in Wuxi, China. They chose 73 pesticides and a few of their breakdown products to identify from three categories: fungicides, neonicotinoid insecticides, and triazine herbicides. Their testing protocol confirms their expectation that food—primarily produce—is the major source of pesticide exposures. This result reinforces Beyond Pesticides’ mission of supporting the shift in agriculture to pesticide-free methods […]

(Beyond Pesticides, March 7, 2024) As the threats to health, biodiversity, and climate converge in agricultural policy and practices, the question of defining the fundamental changes necessary to reverse these existential crises takes on life-sustaining importance. Despite the existence of an organic community with governing stakeholders (farmers, consumers, conservationists, retailers, processors, inspectors, and scientists) that has evolved over at least seven decades and is codified in the Organic Foods Production Act (OFPA) of 1990, the term “regenerative” is now increasingly being advanced as a loosely defined alternative to the organic standard and label, which is transparent, defined, certified, enforced, and subject to public input. The publication AgFunderNews (AFN) last month published its updated “2024 list of agrifood corporates making regenerative agriculture commitments,” a who’s who of the largest food and agribusiness corporations worldwide. The list includes companies such as ADM, Cargill, Danone, General Mills, Tyson, Unilever, Walmart, and more with commitments to millions of acres in their supply chain practicing “regenerative” agriculture with target dates ranging from 2024 to 2050. The AFN author reporting on the “regenerative” trend states, “[O]ne big challenge is that ‘regenerative agriculture’ still has no set definition. While that still holds true, the bigger observation in […]

(Beyond Pesticides, March 5, 2024) Buried in a court decision in February that determined that the U.S. Environmental Protection Agency (EPA) violated the law in allowing harm associated with the herbicide dicamba’s registration is language that permits the damages to continue through this year’s growing season. The judge’s ruling, deferring to EPA’s interpretation of the existing stock provision in the federal pesticide law, continues a pattern of “existing stock” allowances that permit hazards to continue well after a finding of harm or noncompliance. This process contrasts with the issuance of a product recall, which is typically done when pharmaceuticals are found to violate safety standards. Despite the finding of dicamba’s harm and EPA’s failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA’s 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. EPA’s pattern of allowing the use of existing stocks has long been a concern for public health and environmental advocates, who have called for the discontinuance of use upon findings of […]

(Beyond Pesticides, February 29, 2024)  In the face of federal inaction, an Oregon regulation banning the agricultural uses of the highly toxic chlorpyrifos took effect on January 1, 2024. Chlorpyrifos was voluntarily withdrawn from the market in 2000 for most residential uses by its manufacturer, Dow Chemical, and has been the subject of extensive litigation. At that time, the U.S. Environmental Protection Agency (EPA) allowed most agricultural uses to continue. Oregon joins four other states that have acted to ban chlorpyrifos, including Hawai’i, New York, California, and Maryland.   Central to state action are nervous system and brain effects in children, especially farmworker children. Chlorpyrifos is banned in 39 countries, including the European Union (see here for more Beyond Pesticides coverage). State action has become important since the November 2023 decision by the U.S. Court of Appeals for the 8th Circuit, which overturned the EPA rule revoking all food tolerances for chlorpyrifos, an effective ban on chlorpyrifos use. The final EPA rule, issued in August 2021, came in response to a 9th Circuit Court of Appeals ruling that found the agency’s inaction on chlorpyrifos unlawful. The case was filed by Earthjustice, on behalf of public health, labor, and disability organizations.  The […]

(Beyond Pesticides, February 23, 2024) The latest string of billion-dollar plaintiff judgments against Bayer/Monsanto, the maker of Roundup™ with active ingredient glyphosate, does not yet signal a capitulation by Bayer or a win for public health or the environment in the United States. A jury award of $2.25 billion, the largest to-date, was handed down in Philadelphia in January. As Beyond Pesticides reported previously, Monsanto has a long history of challenging scientific findings on Roundup/glyphosate and evidence of harm to human health, the environment, and crops themselves (see resistant super weeds here and here), as it seeks to avoid liability claims by those suffering from cancer.  Bayer Looking to State Legislatures for Protection from Lawsuits  As result of its failure in quash lawsuits, Bayer has moved its case to state legislatures, where it is seeking the adoption of statutes that preempt liability claims by damaged parties.  As reported by Beyond Pesticides, a rash of state legislation has been introduced in Idaho, Iowa, Missouri, and Florida, which would block plaintiff liability claims when pesticide products, like Roundup, cause harm. The chemical industry pushes the notion that the registration of its pesticide products with the U.S. Environmental Protection Agency (EPA) is a […]

(Beyond Pesticides, February 21, 2024) In addition to its effects including cancer, and reproductive, immune or nervous system disruption, according to international findings, a review published in Toxics finds that the the widely used weed killer 2,4-dichlorophenoxyacetic acid (2,4-D) causes significant changes in liver structure and function. 2,4-D can damage liver cells, tissue, and inflammatory responses through the induction of oxidative stress. The liver, the largest solid organ in the human body, is an essential part of the digestive system responsible for blood detoxification, nutrient metabolization, and immune function regulation. However, rates of chronic liver diseases are increasing, representing the second leading cause of mortality among all digestive diseases in the U.S. In fact, researchers warn of the rise in liver disorders and metabolic syndrome among young people. Therefore, reviews like this highlight the research available to make decisions on safeguarding human health from chemical exposure to mitigate further disease outcomes and complications. 2,4-D is used on turf, lawns, and rights-of-way, as well as in forestry and aquatic systems. 2,4-D products are available as liquid, dust, and granule fields, as well as fruit and vegetable crops, including in genetically engineered crop production. The chemical is widely used in “weed and feed” lawn products. It is […]

(Beyond Pesticides, February 15, 2024) The latest U.S. Department of Agriculture (USDA) pesticide residue report, the 32nd Pesticide Data Program (PDP) Annual Summary report, released in January, finds that over 72 percent of tested commodities contain pesticide residues (27.6 percent have no detectable residues), mostly below the level the U.S. Environmental Protection Agency (EPA) has set for tolerances (allowable residues) whose safety standards have been called into question by advocates. USDA spins its report findings as a positive safety finding because, as the Department says, “[m]ore than 99 percent of the products sampled through PDP had residues below the established EPA tolerances.” USDA continues, “Ultimately, if EPA determines a pesticide use is not safe for human consumption, EPA will mitigate exposure to the pesticide through actions such as amending the pesticide label instructions, changing or revoking a pesticide residue tolerance, or not registering a new use.” As Beyond Pesticides reminds the public annually when USDA uses the report to extol the safety of pesticide-laden food, the tolerance setting process has been criticized as highly deficient because of a lack of adequate risk assessments for vulnerable subpopulations, such as farmworkers, people with compromised health or preexisting health conditions, children, and perhaps, […]

(Beyond Pesticides, February 13, 2024) Last week, the United States District Court for the District of Arizona struck down the U.S. Environmental Protection Agency’s (EPA) 2021 approval of three dicamba-based herbicides. This is the second lawsuit since 2020 to call out EPA’s violation to both the Endangered Species Act (ESA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to authorize the use of over-the-top (OTT) dicamba-based herbicide products from Bayer and other petrochemical pesticide companies. This rejection of dicamba-based herbicides fuels advocates’ push for stronger regulatory actions by EPA for all petrochemical pesticides and their push for the more widespread adoption of organic practices that do not use these chemicals. The case was filed by Center for Food Safety (CFS), Center for Biological Diversity, National Family Farm Coalition, and Pesticide Action Network North America. Beyond Pesticides has covered the dicamba tragedy for years, including the EPA Office of the Inspector General’s critical 2021 report, EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision. The report identifies EPA’s abandonment of science and assault on agency integrity. In addition to citing adverse impact on nontarget crops and the environment, the Court zeroes in on EPA’s failure to adequately manage […]

(Beyond Pesticides, February 9, 2024) EPA is accepting public comments through today, Friday February 9, on its long-held policy of exempting “treated objects,” including seeds and paint, from pesticide registration. Although EPA does not ask the most important question—“Should pesticide-treated seeds and paint be exempt from the scrutiny given pesticide products?”—this comment period offers an opportunity to respond to EPA’s questions and express concern about hazards associated with chemical use and product ingredients. Despite exposure patterns associated with the use of pesticides in treated objects that are linked to environmental contamination and human poisoning, EPA is focused on labeling and not regulation. Instead of focusing on the exposure and harm associated with the object’s use—whether treated seeds poison pollinators, soil, and water or whether paint treated with fungicides poisons people exposed to the paint—EPA takes the position that unless the manufacturer makes a pesticidal claim, the object is not regulated as a pesticide for its pesticidal effects.  Beyond Pesticides states: At the very least, if EPA deems the hazards associated with the use of the pesticide in the treated article acceptable, then the agency should disclose the chemical used in the treatment (of the seed or the paint) and require […]

(Beyond Pesticides, February 7, 2024) Sun + Earth Certified (SEC), a West Coast third-party regenerative organic certifier of cannabis products, approved the first certification for an East Coast farm in Brattleboro, Vermont – Rebel Grown. The expansion of independent certifications amidst the ongoing legalization of recreational and medicinal marijuana usage raises questions on the regulation of toxic petrochemical pesticides found in a range of cannabis products. SEC does establish, in its standards, the use of “biopesticides…[o]nly if the product brand name is approved for use in certified organic farming.” Additionally, the label goes beyond the stringency of the National Organic Program in its policy on potassium bicarbonate as an approved input. For example, SEC standards dictate that this input should be, “[f]or pest control as a last resort only… [and] only if the product brand name is approved for use in certified organic farming.” Rebel Grown– the new farm that acquired the SEC label – owner reported to Brattleboro Reformer, “Cannabis grown regeneratively, under the sun and in the soil, without toxic chemicals, is not only high quality but also the best for the earth.” Before delving into the weeds, there is important legal context on current regulations regarding marijuana […]

(Beyond Pesticides, January 25, 2024) Legislative efforts to curtail some life-threatening pesticides associated with birds and bees (and other pollinators) decline were weakened in New York State at the end of December 2023 as the governor negotiated and stripped elements of a bill relating to agriculture that had passed the legislature—again illustrating the grip of the agrichemical industry on public policy intended to begin to address the crisis in ecosystem collapse. (See “Study Cites Insect Extinction and Ecological Collapse.”) In passing the Birds and Bees Protection Act, New York joined New Jersey, Nevada, and Maine in banning most nonagricultural uses of neonicotinoid (neonic) insecticides, but, in last-minute changes to avoid the governor’s veto, failed to phase out corn, soybean, and wheat seeds coated with these chemicals. [Pointing to an exemption in federal law that has been challenged by advocates, the U.S. Environmental Protection Agency (EPA) does not regulate treated or coated seeds as pesticides despite their toxic pesticidal properties.] In New York State, the governor can, in consultation with the leadership of the legislative branch, negotiate language changes (called Chapter Amendments) in legislature-passed legislation (originally enacted) before deciding to sign it into law or can simply choose to veto the legislation. […]

(Beyond Pesticides, January 22, 2024) Today, Monday, January 22, is the last day for public comment on a three-year extension of U.S. Department of Agriculture’s (through its Agricultural Marketing Service’s National Organic Program (NOP)) authority to collect information from certifiers entrusted with ensuring compliance with organic standards. Beyond Pesticides, along with allied organizations and organic advocates, is urging USDA to use this process to clarify the need for USDA to collect key information needed to verify compliance with key language in OFPA (Section 6513(b))—a provision that requires farming practices that “foster soil fertility.” Advocates maintain that information on organic farmers’ practices to foster soil fertility, required in the law, is critical to organic integrity, public trust in the organic label, and certifier responsibility. As USDA states, “The Organic Foods Production Act of 1990 (OFPA), as amended (7 U.S.C. 6501–6524), authorized the Secretary of Agriculture to establish the National Organic Program (NOP) and accredit certifying agents to certify that farms and businesses meet national organic standards. Under OFPA, the purpose of the NOP is to: (1) establish national standards governing the marketing of certain agricultural products as organically produced products; (2) assure consumers that organically produced products meet a consistent standard; […]

(Beyond Pesticides, January 19, 2024) A study published in Environmental Health Perspective is one of the first to indicate a link between exposure to the herbicides 2,4-D and glyphosate and the impairment of behavioral performance (i.e., attention/inhibitory control, memory/learning, language, visuospatial processing, and social perception). These adverse effects associated with the neurotoxic impacts of pesticides on behavior have been previously documented. For example, a study in August 2023 finds oral intake (e.g., eating contaminated foods), inhalation, and dermal exposure to glyphosate lowered cognitive function scores, increased the likelihood of severe depressive symptoms, and impaired auditory (hearing) function. Although previous studies find neurotoxic effects from exposure to these herbicides, very few until now have evaluated how this neurotoxic exposure impacts neurotypical behavior among youth (children and teenagers). The ubiquitous use of glyphosate and 2,4-D use in agriculture—which leaves residues of the toxic chemicals in food and in public areas (e.g., parks and walkways) creates a creates a significant risk for exposure. Glyphosate is already implicated in or proven to lead to the development of numerous health anomalies, including cancer, while 2,4-D also has a range of potential hazards, including cancer. Therefore, studies like this help local and government officials make holistic decisions regarding the use […]

(Beyond Pesticides, January 16, 2024) The U.S. Environmental Protection Agency (EPA) has long been criticized for its failure to evaluate the effectiveness (or efficacy) of all the pesticides it registers. A petition, for which there is now an open public comment period (submit comments by January 22, 2024), challenges what advocates call a basic failure of the agency to evaluate the claimed benefits of pesticides. Because of this long-standing situation, those who purchase pesticides do not know that the pesticides they buy will meet expectations for control. For farmers, that means that EPA has not evaluated whether the pesticide’s use actually increases productivity of the treated crops and/or whether over time the target pest (weed, insect, fungus) will become resistant. For consumers, it also means that there is not an independent analysis of whether the pesticide products work. As EPA implements the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), not only is there no agency assessment of whether the pesticide’s use will achieve its intended purpose, there is not a determination as to whether there is a less toxic way of achieving the pest management goal. As Beyond Pesticides cited last year, a piece published in the Proceedings of the […]

(Beyond Pesticides, January 11, 2024) In a move to safeguard public and animal health, the U.S. Food and Drug Administration (FDA) warned nine manufacturers and distributors in December last year to stop selling unapproved and misbranded antimicrobial animal drugs, with the director of FDA’s Center for Veterinary Medicine, Tracey Forfa, explaining to the public that “inappropriate use of medically important antimicrobials contributes to the development of antimicrobial resistance, which affects both human and animal health.”  This action and announcement exhibit a higher degree of concern about antimicrobial resistance—understood as a growing worldwide pandemic—than the history and ongoing inaction by the U.S. Environmental Protection Agency (EPA)—resulting in the allowance of widespread nonmedical uses of antibiotics in agriculture and on synthetic (or artificial) turf. Contrary to broad scientific understanding, EPA told a federal appeals court last year that, “There is no data that antibiotic use in agriculture leads to the presence of antibiotic resistance in bacteria of human health concern,” and that “[a]t the present time, there is little evidence for or against the presence of microbes of human health concern in the plant agricultural environment.” The issue of resistance discussed in the scientific literature concerns reduced susceptibility to clinically important antimicrobials, […]

(Beyond Pesticides, January 8, 2024) Despite successful litigation that stopped the unnecessary use of an antibiotic (streptomycin) in citrus production in December 2023, the court’s reasoning fails to grasp the science behind the biggest emerging threat to U.S. and global health—antibiotic resistance. What is most disturbing and challenging is that the U.S. Environmental Protection Agency (EPA), responsible for applying science in the protection of the public’s health, misled the court on the overwhelming worldwide scientific consensus on the contribution of agricultural antibiotic use to the human death and disability rate linked to antibiotic resistance. On this subject, Beyond Pesticides has written extensively about horizontal gene transfer, which explains the movement of antibiotic resistant bacteria throughout the environment, ultimately making their way to people, as medically necessary drugs become ineffective. As we’ve written, “The human pathogenic organisms themselves do not need to be sprayed by the antibiotic because movement of genes in bacteria is not solely “vertical,” that is from parent to progeny—but can be “horizontal”— from one bacterial species to another.” [Regarding the reliance of the court on EPA’s misrepresentation of the science, the court found, ”EPA emphasized that ‘there is no data that antibiotic use in agriculture leads to […]