Thank you for your support and collaboration. Onward in 2018! (Beyond Pesticides, December 22, 2017)  We deeply appreciate your donation to our program in 2017 and it is easy to donate HERE. Year in Review At Beyond Pesticides, we collaborate with organizations and advocate across the country to get our message out on the threat that pesticides pose to human health and the environment. We support local action to stop this threat. And, we assist communities nationwide with the adoption of organic management practices that are more effective and protective than chemical-intensive practices. The partnerships that have been established are, at a more rapid pace, resulting in the adoption of land management practices that are supported by Beyond Pesticides’ strategic vision for a world free of toxic pesticides. Information for Action Beyond Pesticides expanded its role in the forefront of pesticide and organic advocacy with our Action of Week  and Q&A of the Week, in addition to our Daily News, which identifies and delves into key science, policy, and actions that inform local action. The Summer issue of our journal, Pesticides and You, highlighted David Montgomery’s talk at Beyond Pesticides’ National Forum on the importance of soil microbiota and gut microbiome to healthy ecosystems […]

(Beyond Pesticides, December 21, 2017) On December 18, the U.S. Environmental Protection Agency (EPA) declared that glyphosate is likely not carcinogenic. Relatedly, after weeks of stalemate on a decision by European countries, the European Union (EU) voted, in late November, to extend the license for the herbicide for another five years, despite massive opposition in member countries. In the U.S., the Center for Biological Diversity charged that the EPA assessment relied heavily on industry studies to arrive it its conclusion, and ignored its own guidelines for assessing cancer risks. Senior scientist at the Center for Biological Diversity Nathan Donley said, “The only way the EPA could conclude that glyphosate poses no significant risks to human health was to analyze industry studies and ignore its own guidelines when estimating cancer risk. . . . The EPA’s biased assessment falls short of the most basic standards of independent research and fails to give Americans an accurate picture of the risks posed by glyphosate use.” Glyphosate is due for its EPA registration review in 2019, and opponents are concerned that the December 18 announcement portends likely re-registration — which advocates say is bad news for human health and the environment. As the chief […]

(Beyond Pesticides, December 18, 2017)  Organic certification cost share enables small and medium-sized organic farms to become certified. The costs of annual certification are increasing.  The two federal programs providing certification cost share offer a modest, partial (75 percent) reimbursement of up to $750 annually per certification, to help defray these costs. Having a diversity of scale of operations involved in organic production helps to maintain the integrity, vitality and opportunity of the U.S. organic sector. Tell Congress to reauthorize both the National Organic Certification Cost Share Program (NOCCSP) and the Agricultural Management Assistance (AMA) program through the next Farm Bill, to provide assistance needed by small and medium-sized organic producers. Organic certification cost share helps to increase domestic production of organic products to better meet growing demand. Sales of organic products continue to grow at a rapid rate. Nationwide, U.S organic sales reached $47 billion in 2016, with nearly 24,000 family farms and other businesses represented. However, U.S. organic production is lagging behind demand for organic products.  Unless we are able to get more U.S. farmers certified as organic, the United States will continue to import a growing percentage of organic food and feed from other nations. There are […]

(Beyond Pesticides, December 14, 2017) Tests of waterways in the United Kingdom (UK) reveal rivers contaminated with neonicotinoids, the class of chemicals highly toxic to bees and aquatic invertebrates. And now, although neonicotinoids were banned from use on certain crops in the European Union (EU) in 2013, an EU vote to extend the ban has been delayed. The test results raise concerns over neonicotinoids’ impacts on waterways, especially to fish and birds. Under a new EU mandate -Water Framework Directive ‘Watch List’ initiative – the UK was required to monitor for all five commonly used neonicotinoids: imidacloprid, clothianidin, thiamethoxam, acetamiprid and thiacloprid. Twenty-three sites were sampled in 2016, 16 in England, four in Scotland, three in Wales and three in Northern Ireland. This is the first systematic testing of neonicotinoids in rivers in Britain. According to the results, half the rivers tested in England had either chronic or acute levels of contamination. Of the 23 rivers tested across Britain, all but six contain neonicotinoids. Eight rivers in England exceed recommended chronic pollution limits, and two are acutely polluted. Neonicotinoids are not only highly toxic to bees but also highly toxic to aquatic insects, which are a vital food source to […]

(Beyond Pesticides, December 13, 2017) A recent study finds that environmental exposures contribute to increasing disease burden and corresponding health costs that may exceed 10% of global gross domestic product (GDP). Neurological impairments particularly add significant costs to both individuals and societies. This European study combined cost calculations for exposures to environmental chemicals, including pesticides, air pollution, and endocrine disrupting substances, and suggests that a shift in priority setting for environmental policy is needed. The study’s authors, from Harvard University, the University of Southern Denmark, and the EHESP School of Public Health in France, say that calculations currently used as international references are “serious underestimations” of the economic costs associated with preventable environmental risk factors. Published in Environmental Health, the study, Calculation of the disease burden associated with environmental chemical exposures: application of toxicological information in health economic estimation, combined and extended cost calculations for exposures to environmental chemicals, including neurotoxicants, pesticides, air pollution, and endocrine disrupting chemicals, where sufficient data were available to determine dose-dependent adverse effects. The study utilized risk valuations to assess the environmental burden of disease, and used country-specific monetary values of metrics for length and quality of life (Disability-Adjusted Life year or DALY – a […]

(Beyond Pesticides, December 12, 2017) According to a Reuters story, agrichemical company Monsanto plans to offer farmers a cash incentive to use its highly toxic and drift-prone dicamba-based herbicide next season, despite links to widespread crop damage that has pitted neighbor against neighbor in agricultural communities throughout the country. The move comes as more and more states enact or consider restrictions on use of the herbicide, which is intended to be paired with genetically engineered (GE) soybean seeds resistant to both dicamba and another controversial herbicide produced by Monsanto, glyphosate. Monsanto plans to provide farmers more than half of the cost of herbicide per acre as an incentive to plant its GE seeds. However, given the range of new regulations surrounding the products, as well as the social stigma around its use, it remains to be seen whether the offer will sway farmers. Dicamba has stirred up fights between neighbors in a number of agricultural communities. Bader Farms, which grows over 110,00 peach trees on over 1,000 acres in Missouri, is suing Monsanto after its insurance company issued a refusal to pay for damages caused by dicamba drift from surrounding farms. In June of this year, University of Arkansas’ agricultural […]

(Beyond Pesticides, December 4, 2017) You told the Arkansas Plant Board to exercise its authority to protect farmers, consumers, and the environment from use of the herbicide dicamba on genetically engineered (GE) soybeans, and the board listened. Now, we need to ask the board to stop the use of 2,4-D on GE cotton. The action of states is critical as the federal government ignores basic safety concerns. Action in Arkansas will influence other states. Tell the Arkansas Plant Board to adopt the proposed rule and to prohibit use of 2,4-D on cotton! The decision concerning 2,4-D use on herbicide-tolerant cotton goes to the Arkansas Plant Board on December 12. The choice has many similarities to the decision to allow — and then prohibit — the use of dicamba on herbicide-tolerant soybean varieties. Both 2,4-D and dicamba are phenoxy herbicides — 2,4-D being the infamous ingredient (along with 2,4,5-T) of Agent Orange. Our voices were heard when the Arkansas Plant Board considered dicamba, so please weigh in on 2,4-D. At this December 12 meeting, the Arkansas Plant Board is holding a hearing on a proposed regulation that would allow the Board to request more information from pesticide registrants, which could support restrictions based on conditions within Arkansas. The […]

(Beyond Pesticides, November 30, 2017)  A French court suspended the license of two pesticide products citing their toxicity to bees. The products, Closer and Transform, both contain the active ingredient, sulfoxaflor, which is highly toxic to bees. The ruling overturned the decision by France’s health and environment agency, ANSES, to allow the use of the sulfoxaflor products. Sulfoxaflor use was also challenged in the U.S. by beekeepers concerned about its impact on already declining bee populations. Sulfoxaflor is a relatively new active ingredient whose mode of action is similar to that of neonicotinoid pesticides. Even though it has not been classified as a neonicotinoid, it elicits similar neurological responses in honey bees, with many believing that sulfoxaflor is a new generation of neonicotinoid. Its initial 2013  U.S. registration was challenged by beekeepers and subsequently vacated by the Ninth Circuit Court of Appeals due to overwhelming risks to bees and the U.S. Environmental Protection Agency’s (EPA) inadequate review of the data. The court concluded that EPA violated federal law when it approved sulfoxaflor without reliable studies regarding the impact that the insecticide may have on honey bee colonies. By vacating EPA’s unconditional registration of the chemical, sulfoxaflor could not be used […]

(Beyond Pesticides, November 28, 2017) Bumblebees exposed to field-realistic levels of neonicotinoid insecticides have problems with “buzz pollination” that results in reduced pollen collection, according to new research published in Scientific Reports. This is the latest science to tease out the complex ways in which neonicotinoids interfere with these important pollinators, providing yet another reason to eliminate these highly toxic, systemic insecticides from the environment. Flowers that bumblebees pollinate require the insects to emit soundwaves, or ‘sonicate’ to release their pollen, and bumblebees must perfect their techniques over time in order to maximize the pollen they are able to collect. Researchers tested the effect of neonicotinoids on bumblebees’ sonication abilities by exposing them to field realistic doses of the insecticide thiamethoxam at rates of 2 parts per billion (ppb) and 10 ppb, and observing their ability to successfully collect pollen. A control group that never came in contact with thiamethoxam was also used to compare the progress of the exposed group. Lead author of the study, Penelope Whitehorn, PhD, indicated, “We found that control bees, who were not exposed to the pesticide, improved their pollen collection as they gained experience, which we interpreted as an ability to learn to buzz […]

(Beyond Pesticides, November 27, 2017) Congress is working on the 2018 Farm Bill, which will determine how $956 billion of our tax money will be spent over the coming years in shaping our food system. This year, U.S. Representative Earl Blumenauer (D-OR) has introduced a bill that, if passed, will implement many of the food policy reforms that sustainable agriculture policy advocates have long supported. Ask Your Congressional Delegation to Support the Food and Farm Act! The bill, which is co-sponsored by Reps. Rosa DeLauro (D-CT), Chellie Pingree (D-ME) and Don Beyer (D-VA), is a result of a two-year conversation, “Sing Your Own Farm Bill,” in which the U.S. Representative engaged a diverse group of farmers, ranchers, fiscal hawks, food and agriculture policy experts, environmentalists, animal welfare advocates, and others to brainstorm ideas for shaping future farm and food policy. According to Farm Forward, factory farms receive approximately $4 billion in annual benefits under the current Farm Bill –which result in many negative impacts, such as: •    Diet-Related Disease – A diet high in food commodities subsidized by the Farm Bill is linked to a greater probability of diabetes, heart disease and stroke. •    Climate Change –The top five factory-farm mega-corporations […]

(Beyond Pesticides, November 21, 2017) Both the active and inert ingredients in common herbicides induce antibiotic resistance in human pathogenic bacteria, according to the latest research from New Zealand scientists, published in Microbiology this week.  Previous research from the same team found in 2015 that commercial formulations of Roundup (containing glyphosate and inert ingredients) and Kamba (containing 2,4-D, Dicamba, and inert ingredients) caused antibiotic resistance to develop in Salmonella eterica and Escherichia coli, but this new research drills down into what ingredients in these formulations resulted in the effect. Lead author of the study, Jack Heinemann, PhD, University Canterbury’s School of Biological Sciences, explains that ultimately this research indicates that, “The sub-lethal effects of industrially manufactured chemical products should be considered by regulators when deciding whether the products are safe for their intended use,” Scientists parsed out the effects of individual active and inert ingredients by obtaining pure, technical grade dicamba, 2,4-D, and glyphosate, as well as the inert co-formulants “Tween80” and “CMC,” which are respectively, used to reduce surface tension and regulate the viscosity in a formulated herbicide, though also used as emulsifiers in foods like ice cream and in medicines. The technical grade herbicides were first applied to […]

(Beyond Pesticides, November 16, 2017) With a petition signed by over one million people, farming, consumer, and environmental groups called on the U.S. Department of Justice (DOJ) this week to block the proposed merger of Bayer (BAYN) and Monsanto (MON). The signatures were delivered as two new reports reveal devastating impacts that will be caused by the merger on consumers and farmers, including higher food prices, less innovation, limited seed choices, and escalating dependency of toxic chemical inputs in food production.  On Tuesday November 14, 2017, Friends of the Earth, SumOfUs and the Open Markets Institute released an analysis, “Bayer-Monsanto Merger: Big Data, Big Agriculture, Big Problems,” which  explores the implications of a combined biotechnology, chemical, and seed platform owned by Bayer and Monsanto and how it may impact competition and farmer choice. The release of the analysis coincided with a hearing on technology in agriculture and data-driven farming in the U.S. Senate Committee on Commerce, Science, & Transportation. Consumer Federation of America also released a report, “Mega-Mergers in the U.S. Seed and Agrochemical Sector the Political Economy of Tight Oligopolies on Steroids and the Squeeze on Farmers and Consumers.” The report uses the concept of a “tight oligopoly on […]

(Beyond Pesticides, November 14, 2017) The European Commission has again been unable to come to a consensus over renewing approval for Monsanto’s popular herbicide,  glyphosate.  Member states voted last week, but failed to approve, continued use even after months of deliberation over the controversial herbicide. Glyphosate (Roundup) is also up for review in the U.S., but many expect the herbicide to be reregistered by the U.S. Environmental Protection Agency (EPA), despite health concerns. The proposal to renew the European Union (EU) license for glyphosate for another five years failed to a reach a qualified majority, meaning a decision has again been postponed, according to reports. The current license is due to expire on December 15, 2017, but there is an 18-month grace period. Fourteen countries voted in favor of the renewal, nine against, while five, including Germany, abstained from voting. According to reports, a qualified majority requires that 55 percent of EU countries vote in favor and that the proposal is supported by countries representing at least 65 percent of the total EU population. France, which voted against the proposal, said it would only support a renewal for three-year phase-out. The proposal could now be referred to an appeals committee, or alternatively, the Commission could draw […]

(Beyond Pesticides, November 9, 2017) Vietnam veterans suffering from certain Agent Orange-related health conditions will continue to wait for compensation. U.S. Department of Veteran Affairs (VA) Secretary David Shulkin announced last week he intends to delay a decision to expand coverage to new illnesses. Despite a robust review by the National Academy of Medicine, which recommended expanding disability compensation for bladder cancer, hyopothyroidism, high blood pressure, and Parkinson’s-like tremors due to past exposure to the toxic herbicide cocktail, the VA decided to take no action. “After thoroughly reviewing the National Academy of Medicine (NAM)’s latest report regarding Veterans and Agent Orange, and associated data and recommendations from the NAM Task Force, I have made a decision to further explore new presumptive conditions for service connection that may ultimately qualify for disability compensation,”  Secretary Shulkin said in a press release last week.  “I appreciate NAM’s work and the commitment and expertise of VA’s NAM Task Force, and look forward to working with the Administration on the next steps in the process.” Given a promise from VA Secretary Shulkin to provide a decision on the new ailments by November 1st, Veterans groups are crying foul, and placing blame on the Trump administration, […]

(Beyond Pesticides, November, 8, 2017) Farmers who purchased and handled Monsanto’s new treated seed product, NemaStrike, for nematode or roundworm control (nematicide) have been reporting skin irritation, including rashes that occurred after use. Now the seed giant is pausing a full rollout of the product, while blaming farmers for not using gloves and other protective equipment to handle the treated seeds. This is another blunder from Monsanto and the latest incident highlighting the deficiencies in the U.S. Environmental Protection Agency’s (EPA) pesticide registration process in light of the millions of acres of crop damage from Monsanto products green-lighted by EPA. While touting that NemaStrike went through three years of extensive field trials and “extensive evaluations” by EPA, Monsanto stated in a bulletin to its customers on its website that it will pause commercialization of the product in light of reports of skin irritation from users. These adverse reactions to the product are being blamed on the failure of users to wear gloves and other protective equipment when handling the treated seeds. This is not the first time that Monsanto has tried to shift responsibility for the toxic effect of its products to users. Last year, Monsanto blamed farmers for drift […]

(Beyond Pesticides, November 6, 2017) The next Farm Bill will be up for negotiation soon. Bi-partisan legislation to address two issues that are important for organic agriculture –increasing funding for organic research and strengthening enforcement of the organic standards: The Organic Agriculture Research Act (H.R. 2436) will provide $50 million in funding annually for the USDA’s flagship organic research program, the Organic Agriculture Research and Extension Initiative (OREI).  The Organic Farmer and Consumer Protection Act of 2017 will improve oversight of organic imports. This action will allow you to send messages to your U.S. Representative requesting that they co-sponsor the bills or thanking the member if she/he is already a co-sponsor. Ask your U.S. Representative to support organic in the next Farm Bill by co-sponsoring these two bills. If your Representative is already a co-sponsor, send a thank you. Organic is one of the fastest growing sectors in U.S. agriculture. The bi-partisan Organic Agriculture Research Act (H.R. 2436) introduced by U.S. Representative Chellie Pingree (D-ME) will help more farmers transition to organic production in response to growing demand in the marketplace. Organic research helps farmers become more productive, efficient, and profitable and leads to the development of new agricultural practices that can […]

(Beyond Pesticides, October 31, 2017) Scientists warn that inadequate federal testing, disproportionate industry influence, and subverted regulatory oversight threaten decades of progress on protecting people from hormone disrupting chemicals. This from a new paper with findings that regulators face a critical need to fully understand and address the hazards from these dangerous substances. Hormone disrupting chemicals, also known as endocrine disruptors, are substances that have been shown to interfere with the hormone system, leading to long-term health impacts ranging from cancer to neurological developmental impairments. Even small alterations in hormone concentrations, particularly during “critical windows” of embryonic development and developmental phases of life, can have lasting and significant effects. Mounting science is showing that disruptions to the hormone system can occur at very low doses that are lower than those used in traditional toxicity testing. Now, commentary from scientists at Rutgers University and North Carolina State University, “Endocrine disrupting chemicals and behavior: Re-evaluating the science at a critical turning point,” states that inefficient federal testing and outsized industry influence in Washington threaten decades of progress. “The significant progress made over the past couple of decades to understand endocrine disrupting chemical-related effects and mitigate exposures is now at serious risk,” write the authors […]

(Beyond Pesticides, October 30, 2017) Tell the Arkansas State Plant Board to stand up to Monsanto, and protect farmers by banning dicamba’s use in Arkansas agriculture. Comment period closes today, Monday, October 30, 2017, at 4:30pm (Eastern Time). Your comments are needed to stop the disaster in Arkansas being created by Monsanto’s new genetically engineered (GE) cropping system, which relies on the toxic pesticide dicamba. If Arkansas bans dicamba, other states should and will follow —given the chemical industry’s takeover of the U.S. Environmental Protection Agency (EPA), which is allowing this extremely hazardous pesticide use. This is a problem that has regional and national implications, given the breakdown of the EPA and its pesticide program. We cannot let this failure of protection stand in Arkansas or anywhere in the country. Promoted by Monsanto as a way to address rampant Roundup (glyphosate) resistance, Monsanto’s new GE soybeans are now able to withstand both glyphosate and dicamba, an older herbicide with a range of documented health effects —from neurotoxicity to reproductive problems. Dicamba is also highly volatile and, as a result, has drifted across crop fields throughout the region, damaging high value fruit tree and organic operations. The Arkansas State Plant Board is […]

(Beyond Pesticides, October 25, 2017) Oregon is the most recent site of an effort by a locality to establish more-protective pesticide regulations than are provided by the state. Voters in Lincoln County, on the north-central Oregon Coast, approved a ballot measure earlier this year that established a ban on aerial spraying of pesticides in the county. Immediately, county landowners Rex Capri and Wakefield Farms, LLC, both of whom use aerial spraying on their properties, filed a legal challenge to the ordinance created through that vote. The issue is whether the state of Oregon has the legal authority to stop its local political subdivisions from adopting more rigorous than those enacted by the state. When the state of Maine considered legislation to preempt its local jurisdictions (take away their authority to act) this summer, Beyond Pesticides wrote, “The democratic process is foundational to the culture of Maine and the country. LD 1505 betrays the democratic process. Maine communities want to be able to adopt standards that exceed or are more stringent than state standards as a matter of public health and environmental protection, or quality of life. Why would a town or city want to do use its local authority to adopt […]

(Beyond Pesticides, October 20, 2017) Last week, the U.S. Environmental Protection Agency (EPA) announced that label changes to the herbicide dicamba would be made to try to minimize drift that has left thousands of acres of crops already damaged this season. The label changes include making dicamba “restricted use,” which allows only certified applicators to apply the chemical. Dicamba drift has been damaging farmers’ crops for at least two years due to the approval of new dicamba-tolerant genetically engineered (GE) crops. Advocates says that the new changes do not ensure that drift will be eliminated. According to EPA, the agency reached an agreement with the makers of dicamba, (Monsanto, BASF and DuPont) to restrict its application. This comes after hundreds of official complaints of crop damage related to dicamba across 17 states this year alone, leading to questions about the new formulation of the chemical used in genetically engineered (GE) crop productioon. New GE crops developed by Monsanto must be paired with specific formulations of dicamba, and thus led to a vast increase in dicamba use over the past couple growing seasons. Dicamba-based herbicide use has climbed dramatically as farmers have adopted, especially, Monsanto’s GE soybean seeds; in the 2017 season, 20 […]

(Beyond Pesticides, October 18, 2017) Effective immediately, the European Parliament has banned Monsanto lobbyists, excluding the chemical company from access to committee meetings and digital resources, as well as no longer permitting Monsanto lobbyists to meet with any Member of the European Parliament (MEP). This limit to its influence is a serious blow to Monsanto’s advocacy campaign to promote the safety of its weedkiller glyphosate, (Roundup). The decision to ban came amid mounting public pressure to deny European Union re-licensing of glyphosate, one of the world’s most widely used herbicides. (See glyphosate listing in Beyond Pesticides’ Pesticides Gateway, the active ingredient in Monsanto’s Roundup herbicide.) Glyphosate is classified as “probably carcinogenic to humans” by the World Health Organization’s International Agency for Research on Cancer (IARC). Monsanto, the world’s largest GE-seed and seventh-largest pesticide company, is eager to suppress IARC’s ranking. In fact, before being banned, the European Parliament had questioned Monsanto’s funding of counter-studies in order to discredit independent scientists working to limit the public’s exposure to toxic chemicals. In a related development, independent scientists sent a letter to the scientific journal Critical Reviews in Toxicology, calling for the retraction of a 2016 paper that refuted glyphosate’s cancer risks after it was learned that […]

(Beyond Pesticides, October 17, 2017) In a letter to the scientific journal Critical Reviews in Toxicology, scientists called for the retraction of a 2016 paper that refuted glyphosate’s cancer risks after it was learned that the paper was secretly edited and funded by Monsanto, manufacturer of glyphosate. The paper in question, “An Independent Review of the Carcinogenic Potential of Glyphosate,” is a review of the 2015 decision by an expert Working Group of the International Agency for Research on Cancer (IARC) to designate glyphosate, the active ingredient in Monsanto’s flagship product, Roundup, as “probably carcinogenic to humans” (Group 2A). However, a new report this summer discovered conflict of interests not revealed at publication. Contrary to the journal’s conflict-of-interest disclosure statement, Monsanto directly paid at least two of the scientists who authored the paper, and a Monsanto employee substantially edited and reviewed the article prior to publication, in clear contradiction to the disclosure statement. The retraction-request letter highlights a range of failures involved in the published review: Failure to disclose that at least two panelists who authored the review worked as consultants for, and were directly paid by, Monsanto for their work on the paper. Failure to disclose that at least […]

(Beyond Pesticides, October 11, 2017) Last week, the Natural Resources Defense Council (NRDC) filed a lawsuit challenging the U.S. Environmental Protection Agency’s (EPA) registration of neonicotinoid pesticides – acetamiprid, dinotefuran, and imidacloprid, and the agency’s failure to first consult with the U.S. Fish and Wildlife Service on the pesticides’ impact on threatened or endangered species. The lawsuit, filed in the U.S. District Court for the District of Columbia, challenges the failure of the federal government to evaluate the impacts of neonicotinoid pesticides (“neonics”) on threatened and endangered species, like the rusty patched bumble bee, the black-capped vireo, and the San Bruno elfin butterfly. The suit cites widespread presence of neonics in the environment which presents serious risks to wildlife across large portions of the country. It contends that they pose significant adverse consequences to threatened and endangered species. According to the lawsuit, because of toxicity and pervasive environmental contamination, NRDC is now challenging EPA’s registrations of pesticide products containing one of three main neonic active ingredients—acetamiprid, dinotefuran, and imidacloprid—and seeks vacatur of those registrations until EPA complies with the law. “The EPA ignored endangered bees, butterflies, and birds when it approved the widespread use of neonics,” said Rebecca Riley, a senior […]