(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 […]

(Beyond Pesticides, October 2, 2017) Elementary school students at New York City’s PS 290 are taking a stand against toxic pesticide use in New York City parks, supporting Intro 800, a bill introduced by Manhattan Councilmember Ben Kallos. “We’re going to make a great big fuss,” the children in Mrs. Paula Rogivin’s kindergarten class chanted in a skit performed in front of the NYC Committee on Health this week. Since New York City (NYC) passed Local Law 37, Pesticide Use by City Agencies, in 2005 to stop toxic pesticide use on City owned and leased land, it turns out that some pesticides known to be hazardous were not captured by the law. As a result, the proposed legislation is intended to strengthen restrictions to ensure more comprehensive restrictions that limit pesticides to biological pesticides. Local Law 37 restricts the use of acutely toxic and carcinogenic pesticides as defined by the U.S. Environmental Protection Agency (EPA), and developmental toxicants as defined by the state of California under Prop 65. Exemptions allowing the use of these pesticides are granted based on a waiver review process that requires evidence that the chemicals are necessary to protect public health. Otherwise, City agencies are encouraged […]

(Beyond Pesticides, September 29, 2017) Protect polar bears and “big charismatic wildlife!”  But do not ignore the microscopic organisms essential to ecological sustainability. That is the take from a new study at University of California Berkeley, which, for the first time, links global climate change to the loss of a “shockingly high” number of critical microbial species essential to ecological systems, biodiversity, and organic land management. Other studies link chemical-intensive agriculture, and its reliance on petroleum-based substances, to adverse effects on soil organisms and insects and birds essential to ecological balance, while indicating the importance of organic management practices in protecting biodiversity and curtailing global climate change. As stated in the study, “Models predict that up to 30% of parasitic worms are committed to extinction, driven by a combination of direct and indirect pressures.”  Furthermore, for those species “successfully tracking climate change,” the search for food and water, in once unavailable habitat, will cause them to “invade” and to “replace” native plants and animals with “unpredictable ecological consequences.” Lead author of the study, Ph.D. candidate Colin Carlson, states that for symbiotic parasites, those with numerous beneficial roles, “a loss of suitable habitat” comes as a result of “host-driven coextinctions.” In an interview […]

(Beyond Pesticides, September 18, 2017) Ask California to ban the neurotoxic pesticide chlorpyrifos that’s on the food we eat from California –since the administrator of EPA refused to take the action agency scientists said is necessary to protect children. Tell California to ban chlorpyrifos! In view of EPA’s retraction of its proposal to revoke food residue tolerances of the highly neurotoxic insecticide chlorpyrifos, despite its own assessment that the chemical is too toxic to children, it is especially important that California take action to ban the chemical. California, the home of the largest agriculture industry in the country, used over 1 million pounds of chlorpyrifos on over a million acres in 2012. EPA’s assessment is also support for the classification of chlorpyrifos as a developmental toxicant, an issue being considered on a parallel track by California’s Office of Environmental Health Hazard Assessment (OEHHA), which oversees the “Prop 65” list. EPA’s assessment, which incorporates recommendations from a 2016 Scientific Advisory Panel (SAP), finds that children exposed to high levels of chlorpyrifos have mental development delays, attention problems, attention-deficit/hyperactivity disorder problems, and pervasive developmental disorders. The SAP agreed with EPA that there is an association between chlorpyrifos prenatal exposure and neurodevelopmental outcomes in children. […]

(Beyond Pesticides, September 14, 2017) Children whose mothers took folic acid while pregnant had a significantly lower risk of developing autism spectrum disorder (ASD) even when their mothers were exposed to household or agricultural pesticides. Researchers at the University of California, Davis found that taking folic acid during the window around conception, reduced the risk of pesticide-induced autism. In the study, “Combined Prenatal Pesticide Exposure and Folic Acid Intake in Relation to Autism Spectrum Disorder,” children whose mothers took 800 or more micrograms of folic acid (the amount in most prenatal vitamins) had a significantly lower risk of developing autism spectrum disorder, even when their mothers were exposed to household or agricultural pesticides that are associated with increased risk. The study used data from the Childhood Autism Risks from Genetics and the Environment (CHARGE) study, where researchers looked at 296 children between 2 and 5 who had been diagnosed with ASD and 220 who had developed typically. Mothers were interviewed about their household pesticide exposure during pregnancy, as well as their folic acid and B vitamin intake. The team also linked data from California Pesticide Use reports, which provided important details about agricultural spraying, with the mothers’ addresses. The results […]

(Beyond Pesticides, September, 2017) A recently released report, Gallup-Sharecare State of Well-Being: The Face of Diabetes in the United States, looks at high diabetes rates across various U.S. demographic groups, including those in farming. People working in the transportation sector registered the highest incidence of diagnosed diabetes at 10.6%. But those working as farmers and fishermen came in second, with 8.5% reporting a diagnosis of the disease. Based on a self-reporting survey, The Face of Diabetes in the United States did not differentiate between Type 1 diabetes (which typically manifests in childhood or young adulthood) and Type 2 diabetes (which commonly emerges in adulthood). It did, however, consider lifestyle risk factors that can influence development of each form of the disease. The “farmer and fisher” folks placed more-or-less in the mid-range among all occupations vis-à-vis several of the lifestyle factors that can impact development of the disease (smoking, diet, and obesity), and a bit higher in alcohol consumption, but in fact, reported more exercise than any other category of worker. These data points would seem to suggest that farmers would be at less risk than those in some other occupational categories. For instance, those working in “installation and repair” reported […]

(Beyond Pesticides, August 31, 2017) Researchers at the University of California, Santa Barbara report in a new study that exposure to pesticides as a result of living near agricultural areas increases the risk of giving birth to a baby with abnormalities. These results are more significant for those exposed to very high levels of pesticides, underscoring the continued risks faced by farmworkers and farmworker families, especially mothers living near chemically-intensive treated fields. The study, “Agricultural pesticide use and adverse birth outcomes in the San Joaquin Valley of California,” looked at individual birth and demographic characteristics for over 500,000 birth observations between 1997 and 2011 in the agriculturally dominated San Joaquin Valley, California. The researchers, who report their findings as, “the most comprehensive to date, bringing together the largest data file ever compiled on street-address level birth outcomes and fine scale exposure to agricultural pesticides,” analyzed residential agricultural pesticide exposure during gestation, by trimester, and by toxicity influences on birth outcomes: birth weight, gestational length, or birth abnormalities. Adverse birth outcomes increased by 5–9% among those exposed to very high quantities of pesticides (e.g., top 5th percentile, i.e., ~4,200 kg per square mile applied over gestation). According to the results, “ The magnitude of effects were further enlarged […]

(Beyond Pesticides, August 29, 2017) Air monitoring in Kern County, California, finds levels of the highly neurotoxic pesticide, chlorpyrifos, in excess of the levels of concern established by the U.S. Environmental Protection Agency (EPA) for pregnant women. Chlorpyrifos is linked to low IQs, autism and other developmental neurological effects. Earlier this year, EPA Administrator Scott Pruitt refused to ban chlorpyrifos to the dismay of many scientists, medical professionals, and farmworker organizations. The California Department of Pesticide Regulation (CDPR) released its 2016 air monitoring data where it was revealed that chlorpyrifos air concentrations for a one-month period at the air monitoring site on the campus of Shafter High School in Kern County was 39.4 nanograms per cubic meter (ng/m3) – more than 18 times higher than EPA’s level of concern for pregnant women (2.1 ng/m3).  Shafter High School is some distance from fields in an area where chlorpyrifos use is not as high as in other parts of Kern County or elsewhere in California. More than 1.1 million pounds of chlorpyrifos was used in California in 2015, and more than a quarter of that is used in Kern County. High chlorpyrifos levels at a school means that children and unsuspecting teachers and […]

(Beyond Pesticides, August 25, 2017) While organic agriculture still represents only a fraction of the world’s food production, organic food sales have enjoyed remarkable growth over the past couple of decades, which is captured in a recent article, Building a global platform for organic farming research, innovation and technology transfer, published by Springer online. This growth of organic is propelled by consumers and farmers who recognize significant environmental and health advantages of organic, compared to chemical-intensive agriculture. In this context, studies conclude that organic agriculture may be the best way to meet the world’s food security and environmental needs. A bit of history for some context on this issue: for millennia, of course, all agricultural was “organic.” Even the Industrial Revolution — which brought the combustion engine that enabled machines that made tilling, planting, and harvesting less animal-bound and human-labor intensive — had minimal impact on other aspects of how food was planted, raised, and harvested. In the 1960s, the so-called “Green Revolution” took hold, powered in part by the post-WWII technological and industrial boom in scientific and technical discoveries and applications, and in part by a rapidly growing global population that shared inequitably in the world’s food production. This […]

(Beyond Pesticides, August 21, 2017) Consumers of organic food expect a clear set of production standards that are enforced with a rigorous system of inspection and certification. However, the U.S. Department of Agriculture’s (USDA) National Organic Program (NOP) is currently undermining this central organic principle. During a National Organic Standards Board (NOSB) webinar, NOP Deputy Administrator Miles McEvoy extolled the new “flexibility” of his program in allowing organic certification of operations not permitted by regulations. Although the webinar focused on the program’s allowance of hydroponics, Mr. McEvoy’s comments apply to a wide variety of permitted practices for which USDA has yet to approve standards. Click here to take action: Tell the NOSB, NOP, Secretary of Agriculture, and your Congressional delegation that organic certification must be based on law, not the arbitrary judgment of the Deputy Administrator. Some NOSB members pointed out the problems with NOP’s arbitrary approach to standards –that the criteria for approving them have not gone through the transparent public review process required by law; that problems of health and environmental impacts and consistency with organic principles may be discovered during the public process; that consumers expect certification to be based on uniform standards enforced consistently; and that once […]