(Beyond Pesticides, December 10, 2010) Announcing a 60-day public comment period, the U.S. Environmental Protection Agency (EPA) yesterday published in the Federal Register a petition filed by 82 public health and environmental groups, led by Beyond Pesticides and Food and Water Watch, to ban the controversial antimicrobial/antibacterial pesticide triclosan, found in products from clothing to soaps, for non-medical use. The Federal Register notice (Petition for a Ban on Triclosan, 75 FR 76461, December 8, 2010) invites the public to comment until February 7, 2011 on the need to ban triclosan under numerous federal statutes. The petition, filed on January 14, 2010, identifies pervasive and widespread use of triclosan and a failure of EPA to: (i) address the impacts posed by triclosan’s degradation products on human health and the environment, (ii) conduct separate assessment for triclosan residues in contaminated drinking water and food, and (iii) evaluate concerns related to antibacterial resistance and endocrine disruption. The petition cites violations of numerous environmental statutes, including laws on pesticide registration, the Clean Water Act, Safe Drinking Water Act, and Endangered Species Act. It also documents that triclosan is no more effective than regular soap and water in removing germs and therefore creates an unnecessary […]

(Beyond Pesticides, December 6, 2010) A new study finds that exposure to dioxin in the womb can affect female reproduction for generations, reducing fertility and increasing the chance for premature delivery. Scientists from the Women’s Reproductive Health Research Center at Vanderbilt University School of Medicine examined the effects of a specific variety of dioxin on female mice and found that subsequent generations of the mice exposed to dioxin are at risk. The study, entitled “Developmental exposure to TCDD reduces fertility and negatively affects pregnancy outcomes across multiple generations,” was published in the journal Reproductive Toxicology. Dioxin refers to a family of chemicals linked to cancer, endocrine disruption, weakened immune systems and reproductive problems. They are persistent organic pollutants that bioaccumulate in humans and other animals, especially in fatty tissue, meaning that concentrations of dioxin in the body generally increase with age. So, even in very low doses, dioxins can cause health problems. Scientists in this study specifically looked at the variety of dioxin that is considered the most toxic, known as 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). TCDD is a well-known contaminant of the herbicide 2,4-D, which was originally a part of the deadly chemical weapon Agent Orange. As such, TCDD is still found […]

(Beyond Pesticides, November 10, 2010) A University of Florida, Gainesville study reports that the antibacterial pesticide triclosan, found in toothpaste, soaps, toys and clothing, interferes with estrogen metabolism in women and can disrupt a vital enzyme during pregnancy. These recent findings raise concerns about triclosan’s possible effects on fetal growth and development. This study is just one of an emerging body of science which supports triclosan as an endocrine disruptor and should be eliminated from consumer products. The study, which was published in the November print issue of the journal Environment International, examines the effect of triclosan on a placental enzyme, called estrogen sulfotransferase. Triclosan is known to inhibit sulfonation of phenolic xenobiotics and is structurally related to other known inhibitors of estrogen sulfotransferase, such as polychlorobiphenylols (PCBs). During pregnancy, the placenta is an important source of estrogen, which is needed for normal fetal development and successful parturition (childbirth), and estrogen sulfotransferase is thought to play an important role in regulation of estrogen availability. Estrogen is a key hormone during pregnancy and controls the way a baby develops many key organs like the brain. Triclosan was found to be a very potent inhibitor of both estradiol and estrone sulfonation. The […]

(Beyond Pesticides, November 1, 2010) The majestic Sydney Harbor, world famous for sights such as the Sydney Opera House and Harbor Bridge, has a more dubious distinction –dioxin contamination as a result of pesticide manufacturing. According to data collected by the New South Wales Department of Environment Climate Change and Water, pesticide manufacturing has caused large tracts of sediments in the harbor, which has some of the world’s highest rates of dioxin contamination. The high level of contamination spread over such a large area mean that despite cleanup efforts in Homebush Bay, the original site of the contamination, fishing bans in Sydney Harbor will stay in place for decades to come. While the source of the contamination is decades old, this issue highlights the long-term and unforeseen impacts of pesticide use and underscores the need to adopt organic products, practices and other green technologies. Tests confirm the source of the contamination is a former Union Carbide site where the now-banned pesticide 2,4,5-T, a component of Agent Orange, was produced. For more than two decades, waste from the chemical plant thar was used for landfill leached into Homebush Bay. Union Carbide, the infamous pesticide manufacturer responsible for the world’s largest industrial […]

(Beyond Pesticides, September 29, 2010) A class action complaint claims Dial Corp. defrauds consumers about its Dial Complete soap by falsely claiming that it ‘kills 99.99% of germs,’ when in fact the product provides no benefit over washing with regular soap and water. The suit states that Dial Corp.’s claims are deceptive and misleading, designed solely to cause consumers to buy the product. Dial Complete contains triclosan, a registered pesticide, which is linked to numerous adverse effects including hormone disruption and water contamination. The suit wants Dial Corp. enjoined from continuing its deceptive advertising, disgorgement and damages for consumer fraud and deceptive business practices. The plaintiff, David Walls, in his suit states there are no reliable studies that show Dial Complete lives up to these claims. His complaint states: “Through its extensive and comprehensive nationwide marketing campaign, defendant claims that Dial Complete ‘kills 99.99% of germs’, is the ‘#1 Doctor Recommended’ brand of antibacterial liquid hand wash and ‘kills more germs than any other liquid hand soap’, when in actuality, it does not, a fact which Dial knew and purposely misrepresented and failed to disclose to consumers. To this day, Dial has taken no meaningful steps to clear up consumer […]

(Beyond Pesticides, September 23, 2010) A study by U.S. Department of Agriculture (USDA) scientists and cooperators provides new details about how fertilizing soils with biosolids also introduces triclosan, an antibacterial agent in soaps and other cleaning supplies, into the environment. Results show that triclosan in biosolids is only slowly degraded and persists at low levels in the environment for long periods of time. Biosolids are illegal for use in organic agriculture. For this study, entitled “Fate of triclosan in agricultural soils after biosolid applications” and published in Chemosphere, Agricultural Research Service (ARS), chemist Clifford Rice, of the ARS Environmental Management and Byproduct Utilization Laboratory in Beltsville, Md., and his partners determined that triclosan levels in Class B biosolids from a Mid-Atlantic wastewater treatment plant averaged around 15.5 milligrams per kilogram. They collected surface soil samples from 26 farms in northern Virginia, mostly from pastures. Some fields had never been amended with biosolids and others had been amended with one to four applications of biosolids within the previous 9 months to 13 years. Most of the biosolid amendments came from the wastewater treatment plant in the study. Generally, conventional chemical-intensive farmers add “Class B” biosolids, also known as treated wastewater solids, […]

(Beyond Pesticides, August 11, 2010) Independent tests of sewage sludge-derived compost from the Synagro CVC plant -distributed free to gardeners since 2007 by the San Francisco Public Utilities Commission (PUC) in their “organic biosolids compost” giveaway program — have found appreciable concentrations of contaminants with endocrine-disruptive properties. These contaminants include polybrominated diphenyl ether (PBDE) flame retardants, nonylphenol detergent breakdown products, and the antibacterial agent triclosan. The independent tests were conducted for the Food Rights Network by Robert C. Hale, PhD of the Virginia Institute of Marine Sciences. The antibacterial triclosan, an endocrine disruptor, was also found in the sewage sludge compost, at an average of 1,312 ng/g (or ppb). Last week, the Centers for Disease Control updated their National Report on Human Exposure to Environmental Chemicals and noted that triclosan levels in people increased by over 41% between just the years 2004 and 2006. Also last week, a scientific paper showed that triclosan from sewage sludge can be taken up by soybean plants and translocated into the beans themselves, then consumed by people and animals. PBDEs are persistent and bioaccumulate in the environment and elevated levels have been found in California citizens. The average total of the PBDE congeners tested […]

(Beyond Pesticides, August 9, 2010) Two separate findings that showcase increased exposure and potential for exposure in humans to the toxic chemical triclosan add to the mounting evidence that the non-medical use of this chemical should be banned. Newly released data from the Centers for Disease Control and Prevention (CDC) finds that levels of triclosan in humans have increased by 50% since 2004. Moreover, a study by the University of Toledo shows that triclosan and triclocarbon, a similar compound, can enter the food chain through use of contaminated water or fertilizer on agricultural crops. CDC’s updated National Report on Human Exposure to Environmental Chemicals finds that the 50% increase in levels of triclosan is across all demographics in the U.S. population. Data was collected on the concentration of triclosan in urine. Affluent people and those over the age of 20 have the highest concentrations of triclosan in their urine. The study released by the University of Toledo, “Uptake of Pharmaceutical and Personal Care Products by Soybean Plants from Soils Applied with Biosolids and Irrigated with Contaminated Water,” examines the potential for crops to take up contaminants such as triclosan from water or fertilizer. Conventional crops are often fertilized with sewage […]

(Beyond Pesticides, July 23, 2010) A new study published in BioMed’s online journal, Environmental Health, links endocrine disrupting pesticides and other chemicals in household cleaning products to an elevated risk of breast cancer. Researchers at the Silent Spring Institute in Newton, MA and Boston University found that women who use household cleaners more often have double the risk of breast cancer, compared to women who use household cleaners less frequently. The study includes over 1,500 women selected from Cape Cod, MA and found a correlation between cases of breast cancer and the number of women who reported using household cleaners, particularly solid, slow-release air fresheners when used more than seven times a year, and mold removers when used more than once a week. The antimicrobials, phthalates and alkylphenolic surfactants often found in mold and mildew products are associated with various health and environmental issues. The antimicrobial triclosan for example, can cause skin irritation, allergy susceptibility, bacterial and compounded antibiotic resistance, and dioxin that jeopardizes fragile aquatic ecosystems. The study highlights methylene chloride (in some fabric cleaners), nitrobenzene (soaps, polishes), perfluorinated compounds (stainresistant, waterproof coatings), phthalates (surfactants), alkylphenols (solvents), parabens (preservatives), triclosan, and polycyclic musks (fragrance) as ingredients of concern. Past […]

(Beyond Pesticides, July 16, 2010) Under pressure from the grassroots group Alaska Community Action on Toxics (ACAT), the city of Anchorage canceled plans to spray the herbicides 2,4-D and dicamba on the Town Square Park citing concerns over the safety of children playing in the park. ACAT members attended the Anchorage Assembly public meeting with an NBC TV affiliate and discussed their reservations over spraying Town Square Park, a popular gathering place for families, workers eating their lunches, and tourists. Soon after, the mayor announced the spraying would be canceled, and that the city would remove dandelions by hand. Environmentalists called the decision a victory for the health of Anchorage residents and the environment. 2,4-D is associated with a host of adverse human impacts, such as non-Hodgkin’s lymphoma, endocrine disruption, reproductive and developmental effects, as well as water contamination and toxicity to aquatic organisms. It is one of the most widely used herbicide for the control of broadleaf weeds in commercial agriculture and residential landscapes in the U.S. About 46 million pounds of 2,4-D are used annually, with 16 million pounds used in non-agricultural settings, including parks, playing fields, and residential lawns. Its health risks prompted a Special Review in […]

(Beyond Pesticides, June 18, 2010) A panel of U.S. and Vietnamese policy makers, scientists, and citizens released a report on Wednesday urging the U.S. government and other donors to provide $300 million to clean up contaminated sites and care for Vietnamese harmed by exposure to Agent Orange, an herbicide used by the U.S. to defoliate large swaths of forest during the Vietnam War that was contaminated by dioxin. Dioxin is a very persistent toxicant that clings to the soil and sediments, and bioaccumulates in the food chain. Many studies have linked dioxin exposure to a myriad of health effects including cancer, neuropathy, diabetes, Parkinson’s Disease, and birth defects. This report comes one month before the U.S. and Vietnam will celebrate 15 years of normalized diplomatic relations. The U.S.-Vietnam Dialogue Group on Agent Orange/Dioxin released the report calling for an estimated $30 million annually for the next 10 years. Since 2007, the U.S. has spent only $9 million on dioxin remediation and assisting disabled Vietnamese. The report lays out a plan with three phases. The first phase, lasting three years and estimated to cost $100 million, would focus on completing remediation in Da Nang, one of the largest contaminated sites. This […]

(Beyond Pesticides, May 26, 2010) Beyond Pesticides has drafted sample text (see below), and we need your help to deliver a letter to your local supermarket, cosmetics store or co-op asking them to stop selling products that contain triclosan. Hundreds of products containing the antibacterial chemical triclosan decorate the shelves of retail stores across the country. From hand soap and toothpastes, to toys and yoga mats, triclosan is everywhere. Product labels will read “triclosan,” “triclocarban” (a related compound found in bar soaps) or “Microban” (a formulation of triclosan used in plastics and fabrics). It is time to take action and demand that this endocrine disrupting chemical is removed from the products we use and love. When consumers demand more for their health and well-being, retailers and manufacturers of triclosan products must listen. Triclosan, which has a similar chemical structure as dioxin, is linked to various health and environmental problems. It is associated with skin irritation, has been shown to interfere with the body’s hormones, and has been linked to an increased risk of developing respiratory illness, or asthma, and cancer, as well as subtle effects on learning ability. Because the chemical goes down the drain, it wreaks havoc with the […]

(Beyond Pesticides, May 20, 2010) Dioxins derived from the antibacterial agent triclosan account for an increasing proportion of total dioxins found in water: researchers at the University of Minnesota found that though levels of all other dioxins have dropped by 73-90% over the last thirty years, the levels of four different dioxins derived from triclosan have risen by 200-300%. The study, which was a collaborative effort between researchers at the University of Minnesota, Pace Analytical (Minneapolis), the Science Museum of Minnesota and Virginia Tech appears in the journal Environmental Science and Technology. Leading the research is the recent Ph.D. graduate in chemistry, Jeff Buth and supervisors William Arnold, a civil engineering professor, and his colleague Krostopher McNeill, all from University of Minnesota. Researchers looked at sediment core samples that contained pollution accumulation records from the past 50 years from Lake Pepin, a part of the Mississippi River 120 miles downstream from the Minneapolis-St. Paul metro area. The sediment samples were then analyzed for triclosan, the four dioxins that are derived from triclosan and the entire family of dioxin chemicals. In papers published in 2003 and 2009, Dr. Arnold and Dr. McNeill discovered that triclosan, when exposed to sunlight, generated a […]

(Beyond Pesticides, May 6, 2010) The European Commission has announced that triclosan has been formally withdrawn from the European list for use as a food contact additive; however, plastic materials that are intended to come in contact with food and placed on the market before November 2010 may still be sold until November 2011. The decision follows the European Union’s 2009 regulations to impose limits on the amount of triclosan contained in cosmetics. Ciba, the Swiss-based company that is a subsidiary of BASF, announced last year that they had withdrawn the application of triclosan as a food contact additive so that they could instead focus their sales in the personal hygiene, health care and medical device sector. The company declared this to be a “strategic business decision” and declared that triclosan use as as an additive in plastics intended to come into contact with food was no longer “appropriate.” In the U.S. in 2009, Ciba requested a voluntarily cancellation of the registrations for the technical grade triclosan regulated by the U.S. Environmental Protection Agency (EPA) and incorporated into plastics and textiles. Ciba continues to market triclosan for medical and personal care products, which are regulated by the U.S. Food and […]

(Beyond Pesticides, April 23, 2010) In recognition of the 40th anniversary of Earth Day, the Dow Chemical Company is a proud sponsor of the Dow Live Earth Run for Water. Yes, that Dow Chemical Company. The same company that manufactures some of the most hazardous pesticides in the world, that was responsible for Agent Orange, and that is liable for the worst industrial disaster of all time is sponsoring what it calls the “largest solutions-based initiative aimed at solving the global water crisis in history.” The series of events held in various cities on April 18 consisted of 6 kilometer runs, concerts and “water education activities.” The Bravo TV network will broadcast a one hour special on Friday April 23 “offering audiences an inside look at the global event and its mission to help solve the world water crisis.” When Environmental Action planned the first Earth Day in 1970 at a cost of $125,000, it accepted no money from corporations. Some 20 million Americans from across the country participated in the day’s marches, demonstrations, lectures, workshops, and other events, making it one of the most successful political events in American History. Since that time, many companies have started making donations […]

(Beyond Pesticides, April 22, 2010) In a new consumer factsheet posted April 8, 2010, the U.S. Food and Drug Administration (FDA) attempts to moderate the position it took in a February 23, 2010 letter to Congress in which it said, “[E]xisting data raise valid concerns about the effects of repetitive daily human exposure to these antiseptic ingredients” and “FDA shares your concerns over the potential effects of triclosan and triclocarban as endocrine disruptors that has emerged since we issued the TFM [Tentative Final Monograph] in 1994.” Instead, in bureaucractic-speak FDA is now saying, “[T]riclosan is not currently known to be hazardous to humans.” Safety advocates say that the FDA’s latest statement creates public confusion as the triclosan market continues to grow and manufacturers in the soap and cosmetics industry daily push misleading advertising claims about the protection from bacteria attributed to the toxic ingredient triclosan. While equivocating on the science on triclosan’s adverse effects, FDA does question the efficacy of the widely marketed triclosan products with the statement, “At this time the agency does not have evidence that triclosan in antibacterial soaps and body washes provides any benefit over washing with regular soap and water.” The new FDA factsheet, featured […]

(Beyond Pesticides, April 9, 2010) U.S. Representative Edward J. Markey (D-Mass), Chairman of the Energy and Environment Subcommittee of the Energy and Commerce Committee, yesterday called for a ban on many applications of the antimicrobial chemical triclosan ””which is found in many consumer soaps and countless other products ranging from toys to lipstick. Rep. Markey called for the ban in conjunction with the release of correspondence from the Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA) that raise serious concerns regarding the use of the chemical triclosan. In response to the FDA and EPA letters, Chairman Markey also announced plans to introduce legislation that will accelerate the evaluation and regulation of substances such as triclosan that may harm the human endocrine system. “Despite the fact that this chemical is found in everything from soaps to socks, there are many troubling questions about triclosan’s effectiveness and potentially harmful effects, especially for children,” said Chairman Markey. In January 2010, Chairman Markey sent letters of concern regarding triclosan to FDA and to EPA. In FDA’s response letter to Chairman Markey, the FDA stated that, “existing data raise valid concerns about the [health] effects of repetitive daily human exposure to these […]

(Beyond Pesticides, March 8, 2010) Twenty local businesses and organizations around New Brunswick, New Jersey announced their commitment to not purchase, use or sell products that contain triclosan, an antimicrobial pesticide shown to pose risks to both human health and the environment. Last week, the national consumer advocacy group Food & Water Watch convened an event with the businesses and organizations as part of its “Wash Your Hands of Triclosan” campaign. Speakers additionally expressed support for a proposed Highland Park ordinance to ban the municipal purchase of products containing triclosan, which will be discussed at the Highland Park Board of Health’s meeting on March 11. The community support behind prohibiting triclosan products is a strong indication of an increasing public rejection of the chemical. Originally developed as an anti-bacterial agent for hospital settings, triclosan is widely found in many consumer and household products ranging from dish soaps and detergents to toothpastes, deodorants, and others. A known endocrine disruptor, triclosan has been linked to antibiotic resistance, and can affect male and female reproductive hormones, which could potentially increase risk for cancer. Due to its prevalence in so many products, triclosan is now showing up in many things, from human breast milk […]

(Beyond Pesticides, February 24, 2010) On February 22, 2010 the U.S. Food and Drug Administration (FDA) issued a federal notice requesting data and information regarding the potential environmental impact of triclosan’s use in acne and antiplaque/antigingivitis products. The agency, in order to comply with the National Environmental Protection Act (NEPA), must complete environmental assessments (EA) for active ingredients before they are included in the agency’s over-the-counter (OTC) drug regulation system. Triclosan, a controversial antibacterial agent found in hundreds of consumer products, from hand sanitizers to toys, is one of 13 chemicals being assessed by FDA for environmental impacts according to their proposed uses. According to FDA regulations, the agency must conduct EAs before chemicals are approved for use in OTC drug products. In this case, triclosan is being considered for use in acne and antiplaque/antigingivitis products. Even though this action is being taken, FDA has never been able to finalize and approve the use of triclosan in any OTC products, despite the proliferation of these products in the consumer marketplace. It appears that EAs for the vast majority of triclosan uses have been completed. Other FDA regulations on triclosan have not been updated since 1994 and much of the data […]

(Beyond Pesticides, February 9, 2010) In an innovative development that could transform the way Americans view the origins of learning and developmental disabilities, the national Learning and Developmental Disabilities Initiative (LDDI) released the first-ever biomonitoring report identifying toxic chemical pollution in people from the learning and developmental disability community. Mind, Disrupted: How Toxic Chemicals May Affect How We Think and Who We Are examines 61 toxic chemicals present in project participants in the context of rising rates of autism, attention-deficit hyperactivity disorder, and other learning and developmental disabilities.   In the U. S., 5-15% of children under age 18 are affected by learning and developmental disabilities. Reported cases of autism spectrum disorders have increased tenfold since the early 1990s. Based on current research, the Centers for Disease Control and Prevention (CDC) states that 1 in 110 eight-year-old children have autism in the United States. Mind, Disrupted measured levels of a set of neurotoxic and endocrine-disrupting chemicals in the participants’ bodies. A growing body of peer-reviewed scientific research, including animal and human studies, shows that these chemicals can disrupt the development and functioning of the brain and nervous system. Eleven of the twelve study participants had detectable levels of triclosan in […]

(Beyond Pesticides, January 15, 2010) Yesterday, environmental and health groups petitioned the Environmental Protection Agency (EPA) to ban the use of the widely used antimicrobial pesticide triclosan, which is linked to endocrine disruption, cancer and antibiotic resistance and found in 75% of people tested in government biomonitoring studies. Over 75 groups, lead by Beyond Pesticides and Food and Water Watch, say EPA must act to stop the use of a chemical now commonly found in soaps, toothpaste, deordorants, cosmetics, clothing, and plastic, with a nearly $1 billion market and growing. In their petition, the groups cite numerous statutes under which they believe the government must act to stop non-medical uses of triclosan, including laws regulating pesticide registration, use and residues, clean and safe drinking water, and endangered species. “Given its widespread environmental contamination and public health risk, EPA has a responsibility to ban household triclosan use in a marketplace where safer alternatives are available to manage bacteria,” said Jay Feldman, executive director of Beyond Pesticides. “Scientific studies indicate that widespread use of triclosan causes a number of serious health and environmental problems,” said Wenonah Hauter, executive director of Food & Water Watch. “EPA needs to ban its use in non-medical […]

(Beyond Pesticides, January 14, 2010) Stating that current water-quality criteria does not reflect the latest scientific knowledge, The Center for Biological Diversity petitioned the U.S. Environmental Protection Agency (EPA) to establish new water-quality criteria for numerous endocrine-disrupting chemicals (EDC) under the Clean Water Act. If adopted, it will be a big step in regulating and eliminating persistent and widespread chemicals that damage reproductive functions in wildlife and humans. The Center for Biological Diversity formally requested that the EPA publish water quality criteria and information taking into account overwhelming science about the effects of EDC pollution on January 11. It says that under the Clean Water Act, EPA has a duty to periodically update water quality criteria to reflect the latest scientific knowledge. The petition presents scientific information on endocrine disrupting chemical pollution found in our waters and requests that the EPA promptly update water quality criteria reflecting this scientific information. Last month, legislation was introduced into Congress to explore linkages between hormone disrupting chemicals in the environment and everyday products and the dramatic increase of autism, hyperactivity, diabetes, obesity, breast cancer, prostate cancer and other hormone related disorders. After the identification of endocrine disruptors, the bill, The Endocrine Disruption Prevention […]

(Beyond Pesticides, January 6, 2010) The House Energy and Environment Subcommittee chairman asked federal regulators for an open discussion about the health and environmental impacts of two controversial chemicals- triclosan and triclocarban- commonly found in antimicrobial hand soaps and other consumer products. Rep. Ed Markey (D-Mass.) is asking U.S. Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA) for answers to questions about triclosan and triclocarban. The synthetic antimicrobial chemicals are found in many soaps, toothpastes, deodorants and cosmetics. “Despite serious questions regarding the safety of these potentially dangerous products, these substances seem to exist in a regulatory black hole,” Rep. Markey said in a statement. “We must ensure that these products … kill germs without adversely impacting human health.” Read letter to EPA and FDA. In the letter to EPA, Rep. Markey questions whether the agency is reviewing existing data on the two chemicals, and if it has made a decision about further regulating them. He also asked if the agency has examined the impact of triclosan on wildlife, and whether it plans to evaluate the chemicals under its hormone-screening program, the Endocrine Disruptor Screening Program. The lawmaker also pushed FDA on its plan for finalizing a […]