(Beyond Pesticides, November 11, 2021) Evidence is building that so-called ‘inert’ ingredients in pesticide formulations are harming pollinators and undermining regulatory determinations that designate products as ‘bee-safe.’ According to a new study published in Scientific Reports, the fungicide Amistar causes lethal and sublethal effects that can be primarily attributed not to its active ingredient azoxystrobin, but to alcohol ethoxylates, a co-formulant, or inert ingredient intentionally added to a pesticide formulation. While the U.S. Environmental Protection Agency (EPA) utilizes a ‘bee advisory box’ on pesticide labels to indicate danger to pollinators, results of this and previous studies on inert ingredients underline how EPA’s ‘cute little bee icon’ is little more than window dressing for massive regulatory failures and a pollinator crisis that has shown no signs of abating. Scientists at Royal Holloway University in London, UK began their study with three packaged colonies of Bombus terrestris, a European bumblebee often bred for commercial use in greenhouses throughout the world. In order to suss out differences in toxicity between the various ingredients in the formulated Amistar fungicide, bees were separated into multiple groups. One group acted as a positive control, and was dosed with dimethoate, a pesticide known to be highly toxic […]

(Beyond Pesticides, November 1, 2021) Join with 37 environmental and health groups, farm organizations, and beekeeper councils, who have delivered a letter to the Environmental Protection Agency (EPA) leaders seeking major reforms in the Office of Pesticide Programs (OPP). They provided a comprehensive list of OPP’s major failures as the lead federal office for pesticide regulation and management, including: Allowing chlorpyrifos to stay registered for more than 14 years after health experts and affected farmworkers petitioned for its removal based on its known neurological danger, Allowing unlimited use of Roundup (glyphosate) long after it was shown to contribute to deadly non-Hodgkin’s lymphoma in heavy users and it devastated the treasured monarch butterfly, now driven to near extinction in North America, Approving hundreds of neonicotinoid systemic insecticides, now the most widespread insecticide in the country where they are decimating honey and native bees and other key pollinators and beneficial species; and Registering dicamba in a highly volatile herbicide, a shocking blunder later overruled by a federal court ruling that stated OPP “not only substantially understated the risks …. It also entirely failed to acknowledge other risks, including those it was statutorily required to consider.” Take action: Tell EPA and Congress that the […]

(Beyond Pesticides, October 28, 2021) A study published in Frontiers in Environmental Science finds the popular herbicide glyphosate negatively affects microbial communities, indirectly influencing plant, animal, and human health. Exposure to sublethal concentrations of glyphosate shifts microbial community composition, destroying beneficial microorganisms while preserving pathogenic organisms. Glyphosate is the most commonly used active ingredient worldwide, appearing in many herbicide formulas, including Bayer’s (formerly Monsanto) Roundup®. The use of this chemical has been increasing since the inception of crops genetically modified to tolerate glyphosate over two decades ago. The toxic herbicide readily contaminates the ecosystem with residues pervasive in both food and water commodities. In addition to this study, the scientific literature commonly associates glyphosate with human, biotic, and ecosystem harm, as a doubling of toxic effects on invertebrates, like pollinators, has been recorded since 2004. The authors caution, “[O]utbreaks of several animal and plant diseases have been related to glyphosate accumulation in the environment. Long-term glyphosate effects have been underreported, and new standards will be needed for residues in plant and animal products and the environment.” With an increasing number of reports on the relationship between glyphosate and human health, including potential effects on the human gut microbiome, advocates are calling on global leaders to eliminate chemical […]

(Beyond Pesticides, October 25, 2021) The Environmental Protection Agency (EPA) is requesting public comments on its draft Biological Evaluations (BEs) for neonicotinoid insecticides imidacloprid, clothianidin, and thiamethoxam by 11:59 pm (EDT) on Monday, October 25, 2021. The BEs will factor into EPA’s registration review decisions on the three bee-toxic insecticides. Written comments must be submitted through Regulations.gov. Please feel free to cut and paste parts of  Beyond Pesticides’ comments (linked here) or cut and paste into Regulations.gov the suggested comment language at the very bottom of this alert.  Tell EPA to protect endangered species from pesticides. EPA’s Biological Evaluations for these highly toxic chemicals make no agency conclusion or recommendation that would trigger a request to initiate formal Endangered Species Act (ESA) §7(a)(2) consultations with the U.S. Fish and Wildlife Service (USFWS) to determine a possible jeopardy finding for the listed species and requisite mandatory use restrictions of the relevant pesticide. This, despite the fact that for imidacloprid the agency’s draft Biological Evaluation made a May Affect determination for 89% of the 1821 species considered and 90% of the 791 critical habitats considered. Strikingly, a May Affect determination was made for 100% of amphibian and avian listed species and their […]

(Beyond Pesticides, October 22, 2021) The California Court of Appeal (Third District, Sacramento) has ruled that a statewide pesticide spraying program violates state law. The court found that the program, launched in 2014 and administered by the California Department of Food and Agriculture (CDFA), contravenes California’s landmark 1970 Environmental Quality Act (CEQA). It does so, the court found, by failing to: assess and reduce damages of pesticide applications to bees, other pollinators, and water bodies; conduct site-specific environmental reviews; and notify the public before spraying is conducted. This decision is a victory, and a step toward a less-toxic California, say plaintiffs and many health and environmental advocates, including Beyond Pesticides. The history of CDFA’s actions in the state is riddled with invocations of emergency provisions of California’s Food and Agriculture Code. These emergency declarations have allowed CDFA to conduct pesticide spraying for invasive species nearly anywhere — in back yards, on school and recreational grounds, on organic farms, on public lands, and sometimes, across entire neighborhoods — without any analysis of the health and environmental impacts of those applications, or any notice to the public or opportunity to comment on the program. From 2014 to 2018, CDFA conducted more than […]

(Beyond Pesticides, October 18, 2021) The most recent science on pesticides raises serious health and environmental effects associated with pesticide use for lawn and landscape management. While the data is often not assembled in one place, updated factsheets bring together the science on the 40 commonly used pesticides used for conventional landscape management. Governors have the authority to stop the use of these hazardous materials that are used on parks and playgrounds, either by executive order or through their work with their state legislature, and transition land management to organic practices. Tell your governor to stop hazardous pesticide use on state lands and transition to organic land management. The new factsheets document with scientific citations a wide range of diseases and ecological effects linked to pesticides. The underlying analysis supporting the adverse health and environmental effects identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases. What do the factsheets disclose? Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects… 26 are possible and/or known carcinogens 24 have the potential to disrupt the endocrine (hormonal) system 29 are linked to reproductive effects and sexual dysfunction 21 […]

Health and environmental effects disclosed on factsheets to guide community decisions on lawn and landscape management that do not poison people and contaminate the environment. WASHINGTON, D.C. (October 14, 2021) — Today, the national environmental and public health group Beyond Pesticides is releasing its health and environmental effects factsheets for “40 Commonly Used Lawn Pesticides,” updating and expanding on previous factsheets on 30 pesticides. These comprehensive factsheets documents with scientific citations a wide range of diseases and ecological effects linked to pesticides. The underlying analysis supporting the adverse health and environmental effects identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases. What do the factsheets disclose? Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects, 26 are possible and/or known carcinogens, 24 have the potential to disrupt the endocrine (hormonal) system, 29 are linked to reproductive effects and sexual dysfunction, 21 have been linked to birth defects, 24 are neurotoxic, 32 can cause kidney or liver damage, and 33 are sensitizers and/or irritants. Regarding adverse environmental effects, 21 are detected in groundwater, 24 have the ability to leach into drinking water sources, 39 are toxic to […]

(Beyond Pesticides, October 5, 2021) The U.S. Fish and Wildlife Service (USFWS) will consider listing the American bumblebee (Bombus pensylvanicus) under the Endangered Species Act, according to a notice published in the Federal Register late last month. Earlier this year, the Bombus Pollinator Association of Law Students at Albany Law School and the Center for Biological Diversity petitioned the agency to list the species. USFWS review of the petition indicates that it found “substantial scientific or commercial information indicating that the petitioned actions may be warranted,” and will determine over the next year whether final listing and further protective actions are warranted.  With the American bumblebee experiencing an 89% decline in its population over the last 20 years, scientists and advocates  believe it is critical for USFWS to take steps to protect what remains of this iconic species. At one time, the American bumblebee’s range extended from eastern Canada south through the United States into Florida, and as far west as California. Oregon is the only state in the continental US where the species has never been spotted. Declines are particularly pronounced in the northern part of its range, where recent sightings are nil, and assessments for states like New […]

(Beyond Pesticides, September 17, 2021) Against the backdrop of what The New York Times in 2018 called the “insect apocalypse,” and the dire plight of pollinators in particular, Friends of the Earth (FOE) recently issued its retailer scorecard, which benchmarks “25 of the largest U.S. grocery stores on pesticides, organic offerings and pollinator health”— with the vast majority of retailers failing to protect pollinators. FOE reporting shows some, but far too slow and anemic, progress by corporate actors in enacting pollinator- and bee-friendly policies across both retail sites and supply chains. Such policies, to be genuinely effective and protective of pollinators (and human health), would eliminate or at least dramatically reduce the presence of pesticides in the food supply. The path out of the chemical pesticide quagmire is organic: companies must do more to move suppliers to organic, regenerative production practices, and EPA should be pulling these toxic compounds from the market. Tracking the pollinator policies and enforcement activities of various huge companies yields a useful barometer in monitoring the travel of pesticides to the consumer. Yet the results in the FOE scorecard — e.g., only two of those 25 retailers scored even in the “B” range, and 21 scored […]

(Beyond Pesticides, August 23, 2021) “Biopesticides”—widely regarded as an alternative to chemical pesticides and hence given a special status in regulation—need a better definition. “Biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term can be misleading and mixes contradictory approaches. It is troublesome when we continue to look for product replacements or substitutions for agricultural practices that are clearly ineffective, and in the process avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions. The U.S. Environmental Protection Agency (EPA) uses the following definition for “biopesticides”: Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals); Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient; Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce. Tell EPA it’s time to redefine “biopesticide.” It is deceptive and misleading. The definition should not include genetically modified organisms or synthetic analogs of naturally occurring […]

(Beyond Pesticides, August 17, 2021) “If the bee disappears from the surface of the earth, man would have no more than four years to live.” This quote is often attributed to Albert Einstein (although its true origins are unknown), but it begs an important question: What are the consequences to humankind of a world where pollinators are rapidly declining? Modern-day scientists have begun to explore that question, and a group of 20 experts recently published a global-scale assessment of the risks associated with the ongoing worldwide decline of pollinator populations in the journal Nature Ecology and Evolution. While the study experts do not provide such a dire time frame, the message unfortunately is not too far off from the Einstein-attributed quote. “What happens to pollinators could have huge knock-on effects for humanity,” said lead study author Lynn Dicks, PhD from the University of Cambridge, UK. “These small creatures play central roles in the world’s ecosystems, including many that humans and other animals rely on for nutrition. If they go, we may be in serious trouble.” With a study objective of identifying the key drivers and implications for global pollinator decline, a group of 20 pollinator experts from throughout the world […]

(Beyond Pesticides, August 11, 2021) Multiple stressors, including pesticides, parasites, and poor nutrition, act synergistically to increase the risk of bee mortality, according to a meta-analysis recently published in the journal Nature. The findings are yet another indictment of the U.S. pesticide regulatory system’s ability to protect pollinators, as the authors note that their results, “…demonstrate that the regulatory process in its current form does not protect bees from the unwanted consequences of complex agrochemical exposure.” As scientific community continues to confirm the dangers of pesticides and other anthropogenic stressors to pollinators, it remains up to advocates and other concerned residents to get regulators and policymakers to listen to and act on these critically important conclusions.   Scientists aimed to evaluate how combinations of multiple pesticides, parasites, and lack of floral resulted in bee death or subchronic effects that impacted overall fitness (reproductive ability, colony health, etc), behavior, parasite load, or immune response. The effects of multiple stressors can be characterized as antagonistic when stressors cancel themselves out, additive when the impacts seen are what would be predicted when summing the individual effects, and synergistic when the effects are multiple times more harmful than what would be predicted additively. To […]

(Beyond Pesticides, August 10, 2021) President Biden’s Environmental Protection Agency (EPA), under Administrator Michael Regan, is set to reapprove the highly hazardous herbicide paraquat with fewer protections than those proposed by the Trump administration. Despite strong links to Parkinson’s, and bans on the herbicide in the European Union, China, Brazil, and many other countries, EPA’s press release inexplicably states, “No direct one-to-one alternatives to paraquat are available.” The move is part of a string of actions that have pesticide reform advocates increasingly concerned that the Biden Administration is not living up to his initial promises to improve health and environmental protections. Paraquat is the most toxic herbicide still on the market. As EPA readily admits, one small sip of paraquat can be fatal. Apart from its acute toxicity, chronic exposure to the herbicide is strongly linked to the development of Parkinson’s disease. But its association with Parkinson’s is merely the most well-known health concern – the chemical is a likely carcinogen, harms the reproductive system, and damages organs like the kidney and liver. It is hazardous to birds and bees, and prone to leaching into groundwater, where it disrupts the health of aquatic ecosystems. The Trump administration’s decision to reapprove […]

(Beyond Pesticides, August 9, 2021) What’s going on at the Environmental Protection Agency (EPA)? Last month, Bayer/Monsanto announced it would voluntarily cancel “residential lawn and garden” uses of glyphosate products, “exclusively to manage litigation risk and not because of any safety concerns.” EPA has done virtually nothing to restrict glyphosate/Roundup since the World Health Organization/International Agency for Research on Cancer in 2015 classified the chemical as probably carcinogenic. It is now expected, as with other voluntary cancellations, that EPA will make no health or environmental findings that could affect other uses (e.g., agricultural) of glyphosate, but will accept the action by Bayer/Monsanto. The company refers to its action as “risk mitigation”—that’s risk to the company’s profitability, economic viability, and shareholder investment, not public health or environmental protection. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing. The Biden administration began with high hopes for the environment. Combating climate change is a priority. On his first day in office, President Biden issued an executive memorandum, Modernizing Regulatory Review, that appears to establish a new framework supporting healthy people and ecosystems, as it […]

(Beyond Pesticides, August 5, 2021) A recent report by Turtle Rescue of the Hamptons finds Long Island, New York turtles are experiencing higher rates of deadly aural abscesses or ear blisters from pesticide use. Previous research documents the role chemical exposure from environmental toxicants play in inner ear abscess formation among turtles. However, synergism (collaboration) between viral infection and toxic chemical exposure increases aural abscess instances. Considering these infections are taking a toll on the Long Island turtle population, government and wildlife officials must assess how chemical exposure promotes disease development to safeguard human, animal, and environmental health. Karen Testa, executive director of Turtle Rescue of the Hamptons, cautions, “I’m urging Long Islanders to think about how these pesticides are negatively impacting the natural world. Is your perfect green lawn worth the life of a turtle?” Aural abscesses are painful ear blisters that can grow as big as a golf ball. Medical intervention is necessary to remove abscesses from turtles and treat them with an antibiotic regimen to prevent death. Turtle Rescue facility workers report a staggering 50 percent of turtles currently within their care to have aural abscesses. The percentage of turtles with this diagnosis is much higher than in past years. […]

(Beyond Pesticides, August 4, 2021) Neonicotinoid insecticides applied to nursery plants sold at garden centers kill off wild, solitary pollinators regardless of the amount applied, according to research published in the Proceedings of the Royal Society B. The news is unlikely a surprise for those tracking the science around pollinator declines, but nonetheless a stark reminder of the lack of progress from federal regulators to stop practices that contribute to the ongoing crisis. With new science consistently showing unacceptable hazards to pollinator populations, advocates are urging Congress to take up and pass the Saving America’s Pollinators Act. Since 2006, scientists and beekeepers have singled out neonicotinoids, a class of systemic insecticides, for their role in pollinator die-off and decline. Once applied onto a seed or sprayed on a plant, neonicotinoids distribute themselves throughout the plant’s structure. This causes soft-bodied sucking insects like aphids to be killed when they eat any part of the plant. However, neonicotinoids also make their way into the pollen and nectar the plant produces, as well as the dew drops plants will secrete and pollinators will often use to grab a quick drink. The use of these insecticides on native plants sold at nursery stores throughout […]

(Beyond Pesticides, July 30, 2021) Bayer (Monsanto), the maker of the deadly herbicide glyphosate/Roundup, after hinting in May that it would end the weed killer’s residential uses in the U.S., made it official yesterday. With its announcement to shareholders, Bayer puts an end to residential uses beginning in 2023 and allocates $4.5 billion to cover “the company’s potential long-term exposure” from lawsuits by those harmed by the chemical. At the same time, the company announced it is seeking a U.S. Supreme Court hearing to reverse significant jury verdicts (from $289 million to $2 billion) for individuals who have suffered health damage they tie to glyphosate exposure. Bayer claims that it will argue that federal pesticide law preempts litigation against products that it has registered with the U.S. Environmental Protection (EPA). Similar arguments have been tried before, most notably in Bates v. Dow Agrosciences (2005), and the Supreme Court has found that federal pesticide law does not protect “manufacturers of poisonous substances.” (See more below.) Despite the extensive scientific review (see Pesticide Gateway) of glyphosate/Roundup and a “probable” cancer causing ranking by the World Health Organization/International Agency for Research on Cancer in 2015, Bayer says, “This move is being made exclusively […]

(Beyond Pesticides, July 21, 2021) Western states are in the midst of one of the largest spray campaigns in recent history, targeting native grasshopper species on more than two million acres of rangeland with highly toxic insecticides. Grasshopper populations have exploded this year due to the West’s ongoing drought, and government officials at the U.S. Department of Agriculture are hoping that hazardous pesticide use will stop the voracious winged insects from consuming forage used by cattle operations. Environmental groups are urging changes to the program, which has conducted insecticide campaigns against the native grasshoppers since the 1930s. “Aerial application of insecticides on this scale will eliminate millions of insects that pollinate, recycle plant nutrients and perform natural pest control,” said Sharon Selvaggio, Pesticide Program Specialist with the Xerces Society. “Insecticide sprays on this scale across native ecosystems are short-sighted and unsustainable.” According to a June 2020 press release, USDA’s Animal and Plant Health Inspection Service (APHIS) is spending $5.3 million dollars of taxpayer money in order to conduct what it calls “suppression treatments.” APHIS claims the $5.3 million will protect $8.7 million worth of agricultural resources, but advocates argue that the agency has failed to meet the “level of economic […]

(Beyond Pesticides, July 16, 2021) Recently published research reviews the 2013 Wilsonville, Oregon mass bumblebee die-off from application of the neonicotinoid dinotefuran on 55 linden trees in a big-box-store parking lot. In that single event, the research paper (published in Environmental Entomology) estimates between 45,830 and 107,470 bumblebees from some 289–596 colonies were killed. Reporting on the new study, by Entomology Today, quotes primary conclusions of the co-authors: “Our study underscores the lethal impact of the neonicotinoid pesticide dinotefuran on pollinating insect populations,” and, “It is likely that the vast majority of mass pesticide kills of beneficial insects across other environments go unnoticed and unreported.” As Beyond Pesticides has chronicled, the U.S. and the world are undergoing a pollinator crisis, caused in significant part by agricultural pesticides. Dinotefuran, the neonicotinoid (neonic) that killed those Oregon bumblebees, is used against fleas, thrips, tree-boring caterpillars, emerald ash borers, hemlock woolly adelgids, and in the Oregon case, aphids. Entomology Today (ET) notes that the timing of this particular application could not have been worse: it happened on a warm day when the linden trees were in full flower and the bees out in force. Ironically, it occurred during Nation Pollinator Week. ET pens a […]

(Beyond Pesticides, July 2, 2021) The second highest bee loss in 15 years has reported by the Bee Informed Partnership (BIP) in its 2020–2021 National Colony Loss and Management Survey, released on June 30. For the “winter” period of October 1, 2020 through April 1, 2021, approximately 32% of managed bee colonies in the U.S. were lost. This represents an increase of 9.6% over the prior year’s winter loss and is roughly 4% higher than the previous 14-year average rate of loss. For all of the past year (April 1, 2020 to April 1, 2021) the colony loss was 45.5%. Beyond Pesticides has covered the related issues of Colony Collapse Disorder (CCD), the ongoing and devastating impacts of pesticides on bees and other pollinators, and the larger context of what some have called the “insect apocalypse.” These recent BIP data appear to indicate that “we,” writ large, are failing to remedy these problems. Three out of four food crops globally depend on pollinators, at least in part. Commercially kept bees account for a significant portion of pollination of some U.S. crops; almonds are the leading crop, followed by apples and melons. The commercial bee business is huge — a $691 million […]

(Beyond Pesticides, June 29, 2021) Maine Governor Janet Mills (D) last week vetoed legislation prohibiting the aerial use of glyphosate and other dangerous herbicides in forestry practices. LD125, An Act To Prohibit the Aerial Spraying of Glyphosate and Other Synthetic Herbicides for the Purpose of Silviculture, was supported by a wide range of health and conservation groups, and aimed to bring the state in line with best practices for public health and the environment. With Maine recently passing one of the strongest consumer bans on pollinator-toxic neonicotinoids, advocates are dismayed by the setback from the Governor’s office. In a statement to Maine Public Radio, Senate President Troy Jackson said that Governor Mills should stop referring to herself as an environmentalist. “The science across the country, across the world, says that this stuff kills people, kills wildlife,” Mr. Jackson says. “And all that it is, is a giveaway to the large landowners so they can maximize their profits off the lives of the people in Maine and the wildlife in Maine.” Senator Jackson’s words are stern yet factual. Glyphosate has been identified by the World Health Organization as a probable human carcinogen. Monsanto, now owned by Bayer, has been the subject […]

(Beyond Pesticides, June 18, 2021) As the U.S. Environmental Protection Agency (EPA) continues to drag its feet on protective regulation of neonicotinoid pesticides, states continue to step up to restrict their use. In April, the Maine legislature passed, and Governor Janet Mills has now signed, a new law that will prohibit use of neonicotinoid pesticides with the “active ingredient[s] dinotefuran, clothianidin, imidacloprid or thiamethoxam used for application in outdoor residential landscapes such as on lawn, turf or ornamental vegetation” [links by Beyond Pesticides]. Though short of an outright ban, this law is a solid step forward for Maine in reining in use of these compounds, which are neurotoxicants widely implicated in pollinator (and other insect, bird, and mammal) harms or declines. Until a federal ban happens, Beyond Pesticides offers guidance on avoiding use of neonicotinoid pesticides through its fact sheet, Managing Pests Safely Without Neonicotinoids, and its Bee Protective web pages. This new Maine law does, however, include exemptions for wood preservation, indoor pest control, use on pets, treatment of structure foundations, and controlling invasive insect pests, such as the Asian long-horned beetle, emerald ash borer, and hemlock wooly adelgid. The statute leaves other large loopholes that will permit continued use […]

(Beyond Pesticides, May 11, 2021) Last week, multinational agrichemical company Bayer Cropscience lost its bid to overturn a 2018 ban on bee-toxic neonicotinoids throughout the European Union. The ruling from the European Court of Justice rejected all grounds on which the company filed its appeal, noting, “It must be held that the arguments put forward by Bayer CropScience cannot, in any event, succeed.” In denying the appeal, the court ruled Bayer responsible for paying its own legal fees, as well as the fees of environmental organizations that intervened to defend the ban. Environmental groups are applauding the ruling, as it reinforces several important aspects of the EU’s pesticide policy that favor greater public health and environmental protections. In an interview with EURACTIV, policy officer Martin Dermine at Pesticide Action Network Europe notes that the decision provides more leeway for pesticide regulators to consider new scientific evidence on pesticide hazards. “More than that,” he told EURACTIV, “the Court confirms the definition of the precautionary principle:  in case of doubts on the toxicity of a pesticide, the European Commission is entitled to ban it.” Pesticide regulators in Europe began restricting neonicotinoids in 2013, when a continent-wide moratorium was put in place based […]