(Beyond Pesticides, February 13, 2017)  A study by the World Wildlife Fund (WWF) and others  attributes the reduced number of overwintering monarch butterflies –a reduction of 27% from last year—to herbicide use and other factors. The World Wildlife Fund (WWF), in conjunction with U.S. and Mexican environmental groups, has been leading the effort in tracking monarch butterflies.  Their recently released 2016-2017 study concluded that the population of monarch butterflies decreased 27 percent from last year’s population, which had marked an increase from dangerously low levels over the previous three years.  Overall, this marks an 80 percent decline in monarch population from the 1990’s.  Researchers have estimated that within 20 years the monarch butterfly migration could collapse altogether. The study was conducted in December of 2016 when the colonies of monarchs are expected to be at their peak population in Mexico.  Monarch populations are gauged by the area of land they inhabit, rather than counts of butterflies.   Thirteen butterfly colonies were observed, recorded and tracked using geographic information systems software.  The researchers found that the butterflies occupied 2.91 hectares of forest, which re presents a 27.43 percent decrease in population compared to the 4.01 hectares of forest they inhabited during the […]

(Beyond Pesticides, February 9, 2017) The failure of the U.S. pesticide regulatory system to protect marijuana users was highlighted as Health Canada announced Tuesday that it would begin conducting random pesticide residue testing of marijuana products to ensure that only registered products are being used in medical marijuana production. This comes on the heels of voluntary recalls in 2016 by two licensed Canadian cannabis producers due to the presence of the prohibited pesticides bifenazate, myclobutanil, and pyrethrins in or on marijuana products. Especially concerning is the detection of myclobutanil, a powerful fungicide that, when heated, converts to the hazardous gas hydrogen cyanide. The detection of these toxic chemicals in medical marijuana products is distressing since many users have compromised immune systems or health conditions that make them more susceptible to toxic chemicals. Moves by several states in the U.S. to curb illegal pesticide use in marijuana contain significant pitfalls and loopholes that allow contaminated cannabis to enter the market, where it threatens public health. Without examination of residues in inhaled, ingested, or absorbed cannabis, the user’s health is not protected by pesticide registration addressing other uses. In addition, environmental impacts associated with growing practices are generally ignored. On January 9th, […]

(Beyond Pesticides, February 8, 2017) As the controversy surrounding the Trump Administration and GOP Congress’s plan for the Environmental Protection Agency (EPA) continues to grow, a nonpartisan group of 447 former EPA employees united to write a strongly-worded letter urging the Senate to block Scott Pruitt’s confirmation as EPA Administrator. Citing EPA’s “fundamental obligation to act in the public’s interest based on current law and the best available science,” the group, whose members served under both Democratic and Republican presidents, calls into question Pruitt’s qualifications, given his longstanding record of opposing “longstanding tenets of U.S. environmental law.” This letter is just the latest in the constantly evolving debate over the need for environmental protection. In the past two weeks, the EPA has been under attack by the Trump Administration and Republican lawmakers who would continue to undermine the environmental protections required for clean water, clean air, and healthy natural resources. Myron Ebell, head of Trump’s EPA transition team, suggested last week that the agency’s already understaffed workforce be cut from about 15,000 employees to 5,000, with potentially more cuts to follow. Trump himself then issued an executive order proposing that for every new regulation promulgated, two must be repealed, an […]

(Beyond Pesticides, February 7, 2017) After years of legal battle, the Colorado Court of Appeals last week affirmed a ruling that Colorado rancher, James Hopper, must serve two days in jail and pay a $7,500 fine for spraying pesticides that drifted unto his neighbor’s farm in violation of a 2012 court order protecting his neighbors. In 2012, organic farmers Rosemary Bilchak and her husband Gordon MacAlpine, were granted a permanent injunction prohibiting pesticide applications within 150 feet of the property line in order to reduce pesticide drift. Last week’s decision bolsters a legal precedent that wafting pesticides can constitute a trespass against which adjacent landowners and people with health sensitivities are protected. The legal battle began in 2011 when Mr. Hopper obtained his Colorado pesticide applicator’s license and applied the adulticide Fyfanon, which contains the organophosphate insecticide malathion, to kill mosquitoes on his property. However, the pesticide drifted onto Ms. Bilchak and Mr. MacAlpine’s organic vegetable farm. In 2012, a District Court Judge ruled that they have a right not to have their property invaded by other people or things, and prohibited Mr. Hopper from fogging for mosquitoes within 150 feet of his neighbor’s property or allowing the pesticides to drift, […]

(Beyond Pesticides, February 3, 2017) The Ruby Throated Hummingbird is the pollinator of the month for February. Hummingbirds are nature’s most nimble of birds. They are so quick and agile that most of the time all you’ll see is a flash of red and green before realizing you just encountered a Ruby Throated Hummingbird. This month’s pollinator is the most abundant species of hummingbird on the eastern half of North America. They are named after the coloration of ruby red feathers around their throat. Range The Ruby Throated Hummingbird is the most populous hummingbird found east of the Mississippi. They enjoy mild habitats such as pine and deciduous forests, and can also be found zipping around urban and suburban gardens and orchards.  Ruby Throated Hummingbirds “winter,” meaning they migrate to warmer parts of the globe during the colder winter months. They typically spend that time in parts of Central America and southern Mexico, but have been known to travel as far south as Costa Rica and the West Indies, according to Animal Diversity Web. They will often migrate without stopping, traveling distances as great as 1,600 km in one trip.  According to the Encyclopedia of Life, the hummingbird’s mating grounds are typically east of the 100th meridian in the […]

(Beyond Pesticides, January 30, 2016) The International Agency for Research on Cancer (IARC), the World Health Organization’s (WHO) cancer research branch, is again under attack. The most recent assault comes from the American Chemistry Council (ACC), which represents major U.S. chemical companies such as Bayer, Dow, Dupont and Monsanto and is calling on WHO to rein in IARC, claiming the agency of “dubious and misleading work” when classifying potential carcinogens. According to the ACC’s website, the Council launched the Campaign for Accuracy in Public Health Research this past Wednesday and it is unclear what steps it will take try to undercut the agency. The ACC is specifically criticizing IARC’s monograph program, claiming that the program “suffers from persistent scientific and process deficiencies.” IARC is a France based self-governing branch of WHO, which is an independent agency working with over 150 countries to “build a better, healthier future for people all over the world,” as stated in the mission statement on their website. Monographs published by IARC are evaluations on a variety of products and lifestyle choices that have ranged from the consumption of processed meats and coffee to the usage of mobile phones and the controversial use of glyphosate in agriculture. In March of 2015, […]

(Beyond Pesticides, January 27, 2016) Last week, farmers, environmentalists, and conservation groups filed a federal lawsuit that challenges the U.S. Environmental Protection Agency’s (EPA) approval of a new formulation of the toxic herbicide dicamba. The new formulation is called Xtendimax with Vapor Grip Technology, which is claimed to have lower volatility. The petitioners claim that EPA violated its duties under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) in issuing a conditional registration, and that it did not adhere to duties under the Endangered Species Act that require EPA to consult with the U.S. Fish and Wildlife Service to ensure registration would not harm any listed species. The organizations involved in the lawsuit are National Family Farm Coalition, Pesticide Action Network North America, Center for Food Safety, and Center for Biological Diversity, represented by legal counsel from Earthjustice and Center for Food Safety. Dicamba has caused a lot of controversy in the past. In August 2016, farmers in Missouri, Arkansas, and Tennessee confronted widespread crop damage and braced for lower yields as a result of agrichemical giant Monsanto’s botched roll-out of GE soybean and cotton crops. The company, whose current line of glyphosate-tolerant crops are failing to control weeds throughout […]

(Beyond Pesticides, January 26, 2017) In a startling move that puts independent science at odds with government, the Trump administration’s U.S. Environmental Protection Agency (EPA) transition team stated on Wednesday that scientists will now face “an unspecified vetting process before sharing their work outside the agency.” However, this kind of review is at odds with EPA’s own scientific integrity policy, which “prohibits all EPA employees, including scientists, managers, and other Agency leadership, from suppressing, altering, or otherwise impeding the timely release of scientific findings or conclusions.” This comes on the heels of an announcement by the administration several days ago issuing scientific grant and hiring freezes at EPA nationwide, along with effectively banning science communications through social media platforms. According to ProPublica, an EPA employee stated that, “Hiring freezes happen, but freezes on grants and contracts seemed extraordinary.” These grants are used for financial support to complete environmental testing, remediation and environmental improvement projects across the country. Additionally, on Friday, January 20, after Donald Trump was officially sworn in, he ordered a freeze on all pending regulations from the Obama administration. This included the listing of the rusty patched bumblebee as endangered by the U.S. Fish and Wildlife Service, which had been set […]

(Beyond Pesticides, January 25, 2017) A study conducted at the University of Buffalo recently revealed a connection between two common insecticides and an increased risk for certain metabolic diseases, including diabetes. Researchers found that by binding to and disrupting melatonin receptors that control numerous physiological functions, chemicals such as insecticides can affect melatonin levels, creating a higher risk for metabolic diseases to develop. The study, Carbamate Insecticides Target Human Melatonin Receptors, was published in Chemical Research in Toxicology and was funded by a grant from the National Institute of Environmental Health Sciences, which is part of the National Institutes of Health. The implicated chemicals in this research, carbaryl and carbofuran, are notoriously dangerous carbamate insecticides. Carbamates share structural characteristics and an ability to inhibit acetylcholinesterase (AChE), an enzyme important for the transmission of nerve impulses. When AChE is inhibited, acetylcholine accumulates leading to overstimulation of neurotransmitters, resulting in muscle weakness, confusion, and paralysis, among other symptoms. Carbaryl is said by EPA to be “one of the most widely applied insecticides in the U.S.,” since use began in 1959, with 10-15 million pounds used annually. It is a broad-spectrum insecticide used on a variety of crops, in forestry and on ornamentals, in […]

(Beyond Pesticides, January 24, 2017) An analysis conducted by scientists at the University of St. Andrews in Scotland is calling into question the conclusions reached in a study conducted by multinational chemical company Syngenta, which indicated that honey bees were not at risk from the widely used neonicotinoid insecticide thiamethoxam. The challenge to the Pilling et al 2013 study is important because while many experiments have been performed in the lab or semi-lab environment, this study was a field experiment developed to test pollinator exposure under normal agricultural conditions. The conclusions of such real-world experiments are weighed more heavily by regulators when making safety and use determinations. St. Andrews’ scientists focus in on the Pilling et al claim that because its study did not have high levels of replication, that it would have been misleading to perform formal statistical analysis. They respond that this would indeed be the case if Pilling et al had intended on finding statistical significance and concluded that there was no effect based on those tests. However, Syngenta’s scientists instead simply graphed average values over time based on their measurements (measurements such as number of bees in a hive, hive weight, number of brood, etc.), and compared […]

(Beyond Pesticides, January 23, 2017) Last week, the U.S. Environmental Protection Agency (EPA)  released its final Biological Evaluations of Three Chemicals’ Impacts on Endangered Species, which finds that chlorpyrifos and malathion likely have detrimental effect on 97 percent of all species listed and protected under the Endangered Species Act (ESA), while diazinon adversely affects 78 percent. According to EPA’s release on the subject, this is the “first-ever draft biological evaluations analyzing the nation-wide effects” of these registered chemicals on endangered species after decades of widespread use. The evaluations stem from a legal settlement with the Center for Biological Diversity (CBD) in which CBD sued EPA in April 2014 for its failure to comply with ESA, which requires the agency to carry out consultations with federal wildlife agencies while registering pesticides. According to Nathan Donley, Ph.D., a CBD senior scientist, “We’re now getting a much more complete picture of the risks that pesticides pose to wildlife at the brink of extinction, including birds, frogs, fish and plants. When it comes to pesticides, it’s always best to look before you leap, to understand the risks to people and wildlife before they’re put into use. The EPA is providing a reasonable assessment of those risks, many of which can be […]

(Beyond Pesticides, January 19, 2017) The U.S. Department of Agriculture (USDA) opened a 60-public comment period January 17 on a controversial proposal to establish a federal research and promotion check-off program that has split the organic community, with many family farmers and small farm operators disagreeing with the larger organic industry groups, represented by the Organic Trade Association (OTA), on the benefits that they will derive from a mandatory payment requirement. The application to USDA for a check-off, originally submitted by OTA in 2015, has drawn sharp division on questions of benefits and cost to farmers. OTA believes that the check-off will generate resources to lift the organic market. This program is different from traditional check-off programs, which promote individual commodities. USDA oversees check-off programs under the Commodity, Promotion, Research and Information Act of 1996. According to OTA, the check-off creates an industry-funded promotion, research, and information program for certified organic products, whose overarching goal is to strengthen the position of certified organic products in the marketplace. OTA says this would be achieved by funding research to benefit the organic industry, improving access to information and data across the organic sector, and educating consumers about the benefits of organic, resulting in increased demand for organic […]

(Beyond Pesticides, January 18, 2017) Despite science affirming its hazards, the U.S. Environmental Protection Agency (EPA) has expanded the registration of the toxic herbicide mixture, Enlist Duo, which contains 2,4-D and glyphosate, for use on genetically engineered (GE) cotton and extended its use on GE corn, soybean, and cotton from 15 to 34 states. This approval late last week comes at a time when widespread chemical use is threatening public health and the environment and weed resistance continues to grow, threatening farmers’ productivity and profitability. Over 600 public comments were submitted to EPA on this issue, with many comments vehemently opposing the current uses and the proposed expansion of uses. In its decision, EPA stated that Enlist Duo “meets the safety standard for the public, agricultural workers, and non-target plants and animal species.” However, as Beyond Pesticides stated in comments to the agency, EPA has not fully considered all the environmental costs, including the cost of tackling increased 2,4-D resistant weeds, crop and non-target damages from uncontrolled drift, as well as unanswered questions regarding synergistic chemical effects in non-plant species. Advocates predict weed resistance to Enlist Duo and have urged EPA to reject its continued use and incentive sustainable organic practices. Additionally, […]

(Beyond Pesticides, January 13, 2016) Just prior to the U.S. Environmental Protection Agency (EPA) announcement on January 12 that several neonicotinoid insecticides “do not pose significant risks to bee colonies,” the preprint version of a new review of neonics identified the range of lethal and sublethal effects of the chemicals on non-target organisms.  The review, The Environmental Risks of Neonicotinoid Pesticides: a review of the evidence post-2013, authored by Dave Goulson, PhD, and Thomas James Wood, a PhD candidate, concludes that studies published since the 2013 European Food Safety (EFSA) published risk assessments show even greater risks. The EFSA assessment, which led to a moratorium on neonicotinoid uses, found that certain neonics on specific flowering crops pose a high risk to bees. With reference to the 2013 EFSA risk assessment conclusions as their baseline, the researchers summarize the difference in risk for certain categories, including: “Risk of exposure from and uptake of neonicotinoids in non-crop plants. Uptake of neonicotinoids by non-target plants was considered likely to be negligible, though a data gap was identified. Many studies have since been published demonstrating extensive uptake of neonicotinoids and their presence in the pollen, nectar and foliage of wild plants. Exposure from non-target plants clearly represents a Greater […]

(Beyond Pesticides, January 11, 2017) Ultra-low doses of glyphosate formulations fed to rats is linked to an increased likelihood of developing non-alcoholic fatty liver disease (NAFLD), according to a recently published study in the journal Nature. A lead author of the study, Michael Antoniou, PhD, stated that the findings are “very worrying as they demonstrate for the first time a causative link between an environmentally relevant level of Roundup consumption over the long-term and a serious disease.” The findings point to the growing need to eliminate the widespread use of this herbicide, as it has already been implicated in endocrine disruption, reproductive effects, and kidney and liver damage. The researchers analyzed female rat livers obtained from a previous 2-year study on Roundup toxicity using molecular profiling techniques. These rats were administered Roundup via drinking water at a concentration of 0.1 ppb, which is an allowable level within both the U.S. and the European Union. The molecular analyses conducted by researchers on the internal organs of the rats fed Roundup included testing of liver cell disturbances. Overall, ultra-low dose glyphosate-formulation exposure led to observations of biomarkers also seen in fatty liver disease. These findings have human health implications “since NAFLD is predicted to be the […]

(Beyond Pesticides, January 9, 2017) After the U.S. Environmental Protection Agency (EPA) released its recent human health risk assessment for the organophosphate insecticide (OP) tetrachlorvinphos (TCVP) on December 21, 2016, the agency announced it was allowing the continued use of the neurotoxic chemical to which children are widely exposed through pets’ flea collars and other flea treatments. According to EPA, ” TCVP is used as a direct animal treatment to livestock (i.e., cattle, horses, poultry and swine) and their premises, in kennels, outdoors as a perimeter treatment, and as a flea treatment [including flea collars] on cats and dogs.” In its announcement on January 4, 2017, EPA states, “We advise consumers to take certain precautions when handling TCVP products in residential areas. These precautions are listed on TCVP product labels, including: not allowing children to play with TCVP pet collar products, keeping TCVP spray and powder products out of reach of children, and washing hands thoroughly with soap and water after handling.” Advocates have raised concerns related to similar decisions on flea collars in the past in which EPA has issued warnings to mitigate risks, despite its inability to ensure children’s safety. Children typically come into close contact with pets and their […]

(Beyond Pesticides, January 6, 2017) When it comes to pollination, bees tend to get all of the buzz. While they are crucial to pollinating many crops, it is important to note that bees aren’t the only pollinators working hard to provide the ecosystem services we rely on to support our food system. In fact, one out of every three bites of food we take is made possible by pollinators. In order to raise awareness for the unsung pollinator heroes all around us, Beyond Pesticides created the Polli-NATION Campaign, which highlights the important work of a relatively unknown pollinator each month. With it, we will raise public awareness about these pollinators, their contribution to plant health and productivity and the preservation of natural resources, and the threats they face in their daily lives, including toxic pesticides and habitat loss. Polli-NATION members include species like butterflies, wasps, flies, beetles, birds, bats, and more. By taking the time to read about our featured Polli-NATION pollinator, you will not only learn about the many diverse species we call pollinators, but also discover what you can do in your daily life to help ensure their survival. Our pollinator of the month is the bee fly! […]

(Beyond Pesticides, January 5, 2017) Winegrowers in the Texas High Plains region are concerned that approval of new herbicides by the U.S. Environmental Protection Agency (EPA) will devastate their profitable industry due to chemical damage from pesticide drift. Wine producers in this region of Texas have witnessed chemical damage to their vineyards that they blame on the toxic herbicides, dicamba and 2,4-D, used on cereal crops and pastures on surrounding agricultural land. A new herbicide formulation containing dicamba, XtendiMax with VaporGrip Technology, was approved by EPA, and the agency has recently proposed to register and expand the use of Enlist Duo, a herbicide that contains 2,4-D. EPA’s final decision on registration of Enlist Duo is expected in early 2017. According to Paul Bonarrigo, owner of Messina Hof Winery in Texas, the “approval of these formulations will wind up affecting every vineyard up there.” This will have ramifications across Texas, as the wine industry contributed $1.88 billion to the state’s economy in 2013. Advocates say that the new herbicide formulations present unreasonable adverse risks to humans and the environment in addition to harming the livelihood of farmers. Following on these concerns, Garrett Irwin, owner of Cerro Santo vineyard, stated,“If we get […]

(Beyond Pesticides, January 3, 2017)  A study published in December 2016 in Environmental Contamination and Toxicology, entitled The Effect of Atrazine on Louisiana Gulf Coast Estuarine Phytoplankton, finds that phytoplankton in estuaries in close proximity to agricultural operations are less productive than phytoplankton in an uncontaminated environment. The study examines three different estuaries of the Mississippi river in Louisiana and also evaluates microcosms with different concentrations of atrazine. Phytoplankton, incredibly important to estuary ecosystems and aquatic life, are an integral part of the aquatic food web and ultimately critical to the wild seafood market. As photosynthetic microorganisms, phytoplankton harness the sun’s energy for metabolism and create as a byproduct of photosynthesis dissolved oxygen, which oxygen-breathing sea life require. For the study, the researchers created microcosms, or large containers that are able to closely mimic ecosystems, so that they can observe the effects of independent variables. On average, phytoplankton in the microcosms are less productive at producing chlorophyll a in the presence of atrazine. The microcosm study design is important because it is difficult to separate and measure the effects of chemicals like atrazine in the environment, given the range of potential causes of phytoplankton decline. A variety of factors, like freshwater discharge rates, precipitation, […]

(Beyond Pesticides, December 23, 2016) The Environmental Agency (EPA) has finalized a proposal to ban 72 inert (or secret hazardous) ingredients from use in pesticide formulations following a long fight with environmentalists who, in 2006, asked that pesticide product labels disclose any of 371 inert ingredients that could be in products. While this finalization is a step in the right direction, ultimately the move is viewed by advocates as inadequate. The original petition, submitted by Northwest Coalition for Alternatives to Pesticides, along with Beyond Pesticides, Physicians for Social Responsibility, and nearly 20 other organizations, called on the agency to require disclosure of inerts. To put the announcement in perspective, EPA is acting on 72 inert ingredients that are no longer being used, such as turpentine oil, and nitrous oxide. An inert ingredient is defined as any ingredient that is “not active,” or specifically targeted to kill a pest. According to a 2000 report produced by the New York State Attorney General, The Secret Ingredients in Pesticides: Reducing the Risk, 72 percent of pesticide products available to consumers contain over 95 percent inert ingredients and fewer than 10 percent of pesticide products list any inert ingredients on their labels. The report also found […]

(Beyond Pesticides, December 21, 2016) A California Department of Pesticide Regulation (DPR) report of all pesticide related illnesses in the state in 2014 identifies 1,685 cases “potentially involving health effects from pesticide exposure,” combining exposures from agricultural and non-agricultural use. Of the 798 cases associated with non-agricultural use, 18% of them (146 cases) involved exposure in children under 18 years old. The exposure rates are alarming, and only strengthen efforts by local activists in counties like Tulare to protect children from pesticide exposure. According to the report, Tulare County has the highest number of reported illnesses related to pesticide exposure at 78, followed by Santa Cruz County with 67. The report, Summary of Results from the California Pesticide Illness Surveillance Program 2014, provides a summary of illnesses identified by the Pesticide Illness Surveillance Program (PISP), a program under DPR. Of the 1,685 cases potentially involving health effects from pesticide exposure reported, DPR epidemiologists determined that 1,073 of those cases were “at least possibly associated” with pesticide exposure, representing a 5% decrease from 2013. However, even though the number of associated cases decreased in 2014, PISP did see a 14% rise in the number of associated episodes, defined as “an event in which a single source […]

(Beyond Pesticides, December 19, 2016) The U.S. Environmental Protection Agency (EPA) last week filed a complaint against a Syngenta research farm in Kauai, Hawaii for exposing a dozen agricultural workers to an unregistered insecticide on the farm in early 2016. Syngenta Seeds, LLC is facing over $4.8 million in fines from EPA for allegedly violating multiple federal pesticide regulations meant to protect agricultural workers. At the time of the incident, 19 agricultural workers went to work on fields freshly sprayed with the insecticide chlorpyrifos, an organophosphate insecticide. The incident with this highly neurotoxic chemical sent 10 workers to the hospital for medical treatment. EPA’s complaint states that Syngenta Hawaii LLC misused the pesticide “Lorsban Advanced” and that violated EPA’s worker protection standard. Due to its neurotoxicity, EPA banned chlorpyrifos for residential uses in 2000, but retained most agricultural use. EPA maintains that Syngenta failed to provide a waiting period for the workers to re-enter the fields. Additionally, Syngenta did not provide workers with personal protective equipment, as well as proper decontamination supplies once the exposure had occurred. At the time of the incident, an inspector from the Hawaii Department of Agriculture (HDOA) was present on the Syngenta farm, which triggered an immediate investigation from the […]

(Beyond Pesticides, December 16, 2016) A new meta-analysis has challenged the belief that neonicotinoid (neonic) insecticide seed coatings have little to no effect on the health of beneficial predatory insect populations —on the contrary, researchers have found that the seed coatings impact predatory insects as much as broadcast applications of other insecticides. The study, authored by Margaret Douglas, PhD and John Tooker, PhD, of Penn State University, solidifies previous work that shows beneficial predators are affected through secondary poisoning as a result of neonicotinoid seed coatings. For their meta-analysis, the researchers combined the results of approximately 1,000 observations for field studies across North America and Europe that had looked at the effect of neonicotinoid seed coatings on predatory insects. The researchers compiled datasets that compare predatory insect abundance in plots that are planted with coated seeds to control plots, which are either managed without insecticides, or managed with pyrethroid insecticides. As predicted, the population of predatory insects are reduced in the plots where coated seeds are planted, compared to the plots that are untreated by insecticides. Additionally, the meta-analysis finds that coated seeds affected predatory insect populations similarly to soil and broadcast applications of pyrethroids. Generally, these findings indicate that the […]