(Beyond Pesticides, June 14, 2016) To celebrate National Pollinator Week, June 20-26, 2016, several Washington, DC restaurants have teamed up with Beyond Pesticides and the Center for Food Safety to launch a campaign, “Made by Pollinators,” to protect pollinators suffering steep declines. With one out of every three bites of food reliant on bees, the participating restaurants’ patrons will be treated to a special menu featuring pollinator-friendly food and provided with information on what they can do to help pollinators. The restaurants hope to increase public awareness on the importance of pollinators and steps that can be taken to reverse the decline. Participating  restaurants include Busboys and Poets, Founding Farmers, Lavagna, the Tabard Inn and Restaurant Nora. Of the 100 crop varieties that provide 90% of the world’s food, 71 are pollinated by bees. Honey bees alone pollinate 95 kinds of fruits, nuts and vegetables, such as apples, avocados, almonds, and cranberries. The value of pollination services to U.S. agriculture alone amounts to nearly $30 billion and about 80% of flowering plants require animal pollination. A recent government survey reports that U.S. beekeepers lost 44 percent of their colonies between spring 2015 and 2016 —the second highest loss to date. […]

(Beyond Pesticides June 13, 2016) A federal judge in California handed down a decision last week agreeing with the Environmental Protection Agency’s (EPA) that it has no responsibility under federal pesticide law to complete rulemaking on the disclosure of hazardous ingredients in pesticide products. That means that if the decision stands EPA will be allowed to keep the public in the dark on the full list of toxic ingredients in pesticides registered by the agency. A lawsuit filed by the Center for Environmental Health, Beyond Pesticides, and Physicians for Social Responsibility argues that EPA fails to protect consumers from “inert” ingredients found in pesticides. U.S. District Judge William Orrick stated in his ruling,“The EPA has no mandatory duty to require disclosure of “inert” ingredients in pesticides, even if those ingredients qualify as hazardous chemicals under separate statutes.” Advocates have said for decades that people and communities cannot make informed decisions on pesticide products without full disclosure of all product ingredients and that the stated proprietary interests of chemical manufacturers is bogus, given the burgeoning market of pesticide products exempt from registration under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) 25(b) provision, which are required to disclose all ingredients. An […]

(Beyond Pesticides, June 10, 2016) A proposal for a temporary ‘technical extension’ of the EU approval of the herbicide glyphosate failed to secure the support of a majority of EU governments at a meeting of the EU standing committee on plants, animals, food and feed on Monday. This action may force the withdrawal of the herbicide, widely sold as Monsanto’s Roundup, from shelves if no decision is reached by the end of the month, when its license expires. After a proposal to renew the license for glyphosate for up to 15 years failed to win support in two meetings earlier this year, the EU executive offered a limited 12 to 18 month extension to allow time for further scientific study. Yet, despite this compromise, the proposal failed to win the support of member states representing at least 65% of the EU’s population, which is needed for adoption, an EU official told The Guardian. Seven member states abstained from Monday’s vote, 20 backed the proposal and one voted against, a German environment ministry spokeswoman said. According to the news source, Germany was among those that abstained from Monday’s vote. Of note is that Bayer, the German chemical company, recently offered to […]

(Beyond Pesticides, June 9, 2016) The U.S. Congress passed a bill Tuesday to reform the Toxic Substances Control Act (TSCA) of 1976, the national law that regulates industrial chemicals, but in the process took away the right of state governments to adopt more stringent standards than the federal government. A Senate voice vote late Tuesday passed the bill, following a House vote in late May. The bill will now go to President Obama’s desk for signature or veto, but it is likely that he will sign it into law. Congress has taken steps to address the vast shortcomings of the law to protect human health and safety, and  in the process has created opportunities for serious delays and restrictions on states’ ability to enact their own toxic chemical regulations.  As the bill heads to President Obama, environmental advocates are concerned that they will lose an important tool in the fight for public protections —with the adoption of federal legislation that will  diminish the right of states and communities to establish protective laws, regulations, and standards in the face of involuntary toxic chemical exposure. Under  current TSCA law, around 64,000 chemicals are not subject to environmental testing or regulation by the […]

(Beyond Pesticides, June 8, 2016) With years of data documenting the harmful impacts of the herbicide atrazine on aquatic organisms and other wildlife, a recent U.S. Environmental Protection Agency (EPA) assessment now concludes that this widely used chemical poses risks to fish, amphibians, aquatic invertebrates, and even birds, reptiles and mammals. Atrazine is a potent endocrine disruptor with strong associations with birth defects, sex reversal and hermaphroditism in organisms, and whose risk to environmental and human health is exacerbated by pervasive surface, ground and drinking water contamination. Last week, EPA released its triazine ecological risk assessments for atrazine and its chemical cousins simazine, and propazine. The assessments evaluated risks to animals and plants including, amphibians, birds, mammals, fish, reptiles, aquatic invertebrates, aquatic plant communities, and terrestrial plants.  EPA is currently in the registration review process for these chemicals. For atrazine, EPA concludes, “aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risks to fish, amphibians, and aquatic invertebrate in these same locations. In the terrestrial environment, there are risk concerns for mammals, birds, reptiles, plants and plant communities across the country for many of the atrazine uses.” Levels of concerns were […]

(Beyond Pesticides, June 7, 2016) A wholesale change in agricultural practices is necessary to ensure protection of human health and the environment over the long-term, according to a wide-ranging report authored by the International Panel of Experts on Sustainable Food Systems (IPES), “a fully independent panel, without financial or organizational ties to any corporations, governments or intergovernmental agencies.” The report, From Uniformity to Diversity, calls for a paradigm shift from industrial agriculture to diversified agroecological systems. According to the report, diversified agroecology focuses on maintaining multiple sources of food production, and farming by applying ecological concepts and principles to the design and management of food systems. Industrial agriculture, on the other hand, requires highly-specialized production of a single food crop, and, through scale and task separation, focuses on increasing productivity through intensification. While monocultures and concentrated animal feeding operations (CAFOs) are characteristic of industrial agriculture, agroecological practices embrace spatial and temporal diversification (through practices like crop rotation and intercropping), and focus on multiple outputs. Oliver De Schutter, Ph.D., former United National special rapporteur on food and co-chair of IPES, notes to The Guardian: “Many of the problems in food systems are linked specifically to the uniformity at the heart of […]

(Beyond Pesticides, June 6, 2016) Bayer CropScience’s appeal of the cancellation of their toxic pesticide flubendiamide by the U.S. Environmental Protection Agency (EPA) was rejected by EPA’s Chief Administrative Law Judge (ALJ) Susan Biro on Thursday, June 1. Judge Biro dismissed the complaints, saying that the agency was acting within its authority when it pulled its approval for the pesticide earlier this year after the two manufacturers, Bayer CropScience and Nichino America, failed to meet the terms laid out in a 2008 conditional registration. A startling number of pesticides, nearly 65% of the more than 16,000 pesticides now on the market, were first approved by the process of “conditional registration,” a loophole in which EPA allows new pesticides on the market without the full range of legally mandated toxicity tests for a full registration. Meanwhile, the Canadian Pest Management Regulatory Agency finalized its  decision to discontinue granting new conditional registrations, also on June 1. In 2008, EPA granted Bayer a “conditional” registration for flubendiamide, a classification that allows a new pesticide to be registered and used in the field, despite outstanding data points on its toxicological impact. In this case, original data submitted to EPA by Bayer showed concern over […]

(Beyond Pesticides, June 3, 2016) Despite recent reports of continuing bee losses across the U.S., the U.S. Environmental Protection Agency (EPA) has announced plans to reevaluate the use of the bee-toxic insecticide sulfoxaflor, and is proposing an amended registration. Sulfoxaflor’s initial 2013 registration was challenged by beekeepers and subsequently vacated by the Ninth Circuit Court of Appeals due to overwhelming risks to bees and EPA’s inadequate review of the data. Last September, the  Ninth Circuit Court of Appeals unequivocally rejected  EPA’s registration of sulfoxaflor. The Court concluded that EPA violated federal law when it approved sulfoxaflor without reliable studies regarding the impact that the insecticide may  have on honey bee colonies. The Court vacated EPA’s unconditional registration of the chemical, meaning that sulfoxaflor could no longer be used in the U.S. This decision was in response to a suit filed by beekeepers challenging EPA’s initial registration of sulfoxaflor, which cited the insecticide’s threat to bees and beekeeping. The case:  Pollinator Stewardship Council, American Honey Producers Association, National Honey Bee Advisory Board, American Beekeeping Federation, Thomas Smith, Bret Adee, Jeff Anderson v. U.S. EPA  (9th Circuit U.S. Court of Appeals,”¯No. 13-7234) According to the court decision, EPA skirted its own regulations […]

(Beyond Pesticides, June 1, 2016) A study  by researchers at Purdue University has concluded  that honey bees collect most of their pollen from non-crop plants that are frequently contaminated with agricultural and urban pesticides. The researchers found this to be true even in places where croplands dominate the area.  The study, which detected neonicotinoids, pyrethroids, fungicides, and others, highlights the large number of toxic pesticides to which bees are exposed to in the environment. Researchers collected pollen from Indiana honey bee hives at three sites over 16 weeks. The hives were placed in a variety of settings, such as an open meadow with wildflowers, woody shrubs and trees present (non-agricultural), the border of a corn field that was treated with the neonicotinoid clothianidin and three fungicides, and the border of a non-treated corn field. The pollen samples that were collected by the bees represented up to 30 plant families and contained residues from pesticides spanning nine chemical classes. The researchers found 29 pesticides in pollen from the meadow site, 29 pesticides in pollen from the treated cornfield, and 31 pesticides in pollen from the untreated cornfield. The most common chemical products found in pollen from each site were fungicides and […]

(Beyond Pesticides May 24, 2016) Nearly two years after the first legal retail sales of marijuana in Washington State, the state Liquor and Cannabis Board (LCB) finally took action to protect the rights of consumers by strengthening its ability to issue product recalls when there is a risk to health and safety. Under the new rules, businesses will be required to isolate and prevent the distribution of products that violate state pesticide regulations, and, in certain cases, may mandate that some products be destroyed under the LCB’s supervision. This action is the final codification of emergency rules that were passed by the state earlier this year to combat contaminated cannabis products. The move by Washington follows  widespread cannabis recalls  in the City of Denver,  and actions from Colorado’s Governor  to declare pesticide-tainted cannabis “a threat to public safety.” However, it is not all good news as the state also set allowable levels for unapproved pesticides on pot. Washington State currently lists  over 200  pesticide products as permitted in cannabis production, despite their lack of compliance with federal and state testing requirements for the range of consumer, worker, and environmental exposures. Outside of that list, the state previously employed a “zero […]

(Beyond Pesticides, May 20, 2016) With Monsanto’s  earnings forecast cut and shares down 19%, Bayer AG has made a takeover bid for  the company, worth $42 billion, in an attempt to swallow the global seed producer and become the world’s biggest farm chemical supplier. Although the terms of the proposal have not yet been disclosed, Bayer confirmed the bid to Bloomberg News, and Monsanto said it is reviewing the offer. If the offer is accepted, it could be the biggest acquisition globally in 2016, and the largest German deal ever, according to Bloomberg data analysis. Bayer is known for a wide range of products, from aspirin and birth control to flea and tick collars and insecticides. Monsanto is the creator of the widely used and controversial herbicide formulation Roundup, which has glyphosate as its active ingredient. In order to finance the takeover, Bayer may consider selling off its stakes in its animal health business and plastics/foam chemicals business (Covestro AG), worth an estimated $6 billion and $5.5 billion, respectively. The takeover would solidify both companies in certain ways; Monsanto would strengthen Bayer’s seed business, while a deal with Bayer would help reduce Monsanto’s reliance on the agricultural industry. There has […]

(Beyond Pesticides, May 18, 2016) The controversy continues on glyphosate’s (Roundup) cancer causing properties, as some question the influence of the chemical industry and Monsanto, Roundup’s manufacturer, on newly announced  findings, according to The Guardian.  A joint review by the United Nations (UN) and World Health Organization (WHO) on  glyphosate, released this week,  seems to contradict earlier findings (at least based on food exposure) of the International Agency for Research on Cancer (the preeminent scientific body on carcinogenesis in the world), which classified Roundup as a “probable human carcinogen.” The Guardian disclosed, “Professor Alan Boobis, who chaired the UN’s joint FAO/WHO meeting on glyphosate, also works as the vice-president of the International Life Science Institute (ILSI) Europe. The co-chair of the sessions was Professor Angelo Moretto, a board member of ILSI’s Health and Environmental Services Institute, and of its Risk21 steering group too, which Boobis also co-chairs.  In 2012, the ILSI group took a $500,000 donation from Monsanto and a $528,500 donation from the industry group Croplife International, which represents  Monsanto, Dow, Syngenta and others, according to documents obtained by the US right to know campaign. Boobis was not able to comment on the issue, and ILSI’s office in Washington […]

(Beyond Pesticides, May 17, 2016) It was 10 years ago that commercial beekeepers first reported widespread, unsustainable winter losses of their honey bee colonies. A decade after the alarm was first sounded on pollinator declines, results of 2015-16 Colony Loss Survey show no sign the crisis of abating. According to the Bee Informed Partnership survey, beekeepers lost 28.1% of their colonies over this past winter, and a total of 44% of their colonies over the last year. This marks the second year in a row that summer declines (28.1%) were on par with declines experienced during winter. Beekeepers factor in that a small percentage, <15% of their colonies, will be lost each winter, but do not expect to lose colonies during the summer, when there is amble forage and nectar for bees. The costs beekeepers must incur to keep their hives alive continue to increase. More time and money is spent to maintain their hives, yet losses continue to be staggering ”” and unsustainable. As colony collapse disorder (CCD), the cryptic loss of honey bee colonies with no sign of dead bees in or around the hive, has faded from public discussion, concerns over pollinator declines in general, from bees […]

(Beyond Pesticides, May 16, 2016) Pesticide exposure may increase the risk of amyotrophic lateral sclerosis (ALS), according to a study entitled Association of Environmental Toxins With Amyotrophic Lateral Sclerosis, which was  published in JAMA Neurology. ALS, also known as Lou Gehrig’s disease, is a progressive neurodegenerative disease that affects nerve cells in the brain and spinal cord. The study, which investigated a total of 122 persistent environmental pollutants, including organochlorine pesticides (OCPs), polychlorinated biphenyls (PCBs), and brominated flame retardants (BFRs), found that pesticide exposure increased ALS risk five-fold. Researchers conducting the study  looked at 156 patients with ALS and 128 without the disease. Participants were asked about occupational and residential exposure to environmental toxicants  and blood samples were taken to measure their concentrations. Researchers found that the organochlorine pesticides pentachlorobenzene and cis-chlordane increased ALS risk two-fold and nearly six-fold, respectively. This study does not prove that pesticides cause ALS, but it does build on an association suggested in previous research, study co-author Stephen Goutman, MD, told  HealthDay. Dr. Goutman recommends avoiding pesticides. This is especially wise for anyone with a family history of ALS, he added. The link between pesticide exposure and neurological damage has been studied extensively. In 2008, […]

(Beyond Pesticides, May 13, 2016)  Raising questions about Roundup’s (glyphosate) effects on soil health, a study published last month shows that the chemical  is toxic to soil fungus at doses well below levels which are recommended for agricultural use. The commercial formulation of Roundup is  more toxic than technical active ingredient,  glyphosate, highlighting the need to evaluate  full formulation  effects, including  so-called inert ingredients. The study, published in Environmental Science and Pollution Research, looked at Roundup’s effects on  a soil fungus, Aspergillus nidulans. Researchers found that a dilution of Roundup at a rate 100 times less than that  allowed in agricultural production corresponded with 50% mortality of the fungus. A dose only 50 times lower than the recommended application rate for agricultural uses resulted in 100% mortality of the fungus. Even at the median lethal dose (LD50) and lower concentrations, researchers saw impaired growth, cellular polarity, endocytosis and mitochondria (impaired average number, volume and metabolism). The study also found that Roundup has an effect on the soil fungus’ ability to break down nutrients for energy use. Rather than depleting mitochondrial activity, as found in animal cell studies, researchers found a stimulation of mitochondrial activity in the fungal cells, indicating a […]

(Beyond Pesticides, May 11, 2016) Another campus, Macalester College in St. Paul, Minnesota has pledged to become a designated BEE Protective campus. This recognition comes from Beyond Pesticides’ and Center for Food Safety’s BEE Protective Campaign, which aims to protect bees and other pollinators from harmful pesticides like neonicotinoids. As part of its  commitment, Macalester College will  no longer use neonicotinoids on its  campus grounds. Neonicotinoids are a class of pesticides known to have severe impacts on bee populations. Macalester is now one of several campuses around the country that have pledged to protect pollinators and move away from using harmful pesticides that are toxic to these beneficial creatures. Just last month,  Antioch College in Yellow Springs, Ohio pledged to become a BEE Protective campus. In addition to these campuses, several local communities and states are also taking a stand for pollinators by passing policies that restrict the use of bee-toxic pesticides. For more on how your campus or student group can support pollinators and become BEE Protective, visit the BEE Protective Ambassadors webpage. “Macalester’s new resolution to help protect pollinators fits well with our Sustainability Plan and Sustainable Landscaping Master Plan. I’m glad that our college has this opportunity […]

(Beyond Pesticides, May 11, 2016) Beyond Pesticides is pleased to announce that videos are now available from Cultivating Community and Environmental Health: Models for sustainable and organic strategies to protect ecosystems, pollinators and waterways, the 34th National Pesticide Forum! The videos cover the range of topics that were discussed at the Forum and include keynote speeches, panel discussions, and workshops. This year’s forum focused on the adoption of policies to protect human health and the environment, and organic land and building management strategies. Beyond Pesticides encourages activists, community leaders, scientists, and policy makers to attend its annual National Pesticide Forum in person to get together, share information, and strategize create communities that are healthy and free of toxic pesticides. For those who are unable to attend in person, these videos expand the incredible knowledge of the experts to the broader public to help inspire and inform community action. Watch the videos here. You can access the playlist, which includes all of the available videos of the 2016 forum, as well as previous years, on Beyond Pesticides’ YouTube page. Notable presentations include: Pollinators, Biodiversity and Scientific Integrity, by Jonathan Lundgren, Ph.D. Dr. Lundgren is an agroecologist, director of ECDYSIS Foundation, and […]

(Beyond Pesticides, May 10, 2016) Following an apparent accidental release of documents relating to the safety of the herbicide glyphosate, late last month the U.S. Environmental Protection Agency (EPA) also released and then retracted a preliminary ecological risk assessment of another toxic herbicide, atrazine. Under federal law, every pesticide registered in the United States is required to undergo a 15-year registration review to analyze human health and environmental impacts and determine whether the chemical’s use should continue another 15 years. The last decade and a half have seen plethora of studies underscoring that atrazine is harmful to human health, and poses unreasonable adverse risks to ecological health, despite attempts by its major manufacturer, Syngenta, to silence and discredit its critics. EPA’s preliminary ecological risk assessment finds that for current uses at prescribed label rates, atrazine may pose a chronic risk to fish, amphibians, and aquatic vertebrate animals. Where use is heavy, the agency indicates that chronic exposure through built-up concentrations in waterways is likely to adversely impact aquatic plant communities.  Levels of concern, a wonky equation that EPA produces to measure risk, were exceeded for birds by 22x, fish by 62x, and mammals by 198x. Even reduced label rates were […]

(Beyond Pesticides, May 9, 2016) Beyond Pesticides joins a historic “civic mobilization” on May 23, 2016, alongside other citizen advocacy organizations leading in the fight to protect and improve human health and the environment. Breaking Through Power celebrates the 50th anniversary of Ralph Nader’s book Unsafe at Any Speed,  which unleashed fresh energies and sparked the creation of numerous advocacy organizations leading to major consumer, environmental and worker safety protections. This mobilization, organized by the Center for Study of Responsive Law, will be held at the Constitution Hall in Washington, D.C. from May 23-26, 2016.   Beyond Pesticides members and friends are invited and encouraged to attend this important event to help launch the next decade of public interest advocacy. If you are interested, please let us know by contacting Jen Ruocco at [email protected]. Beyond Pesticides executive director, Jay Feldman, will be presenting during the first session, Breaking Through Power: How it’s Done, on May 23, 2016. As Beyond Pesticides celebrates 35 years, we are honored to be joining the diverse group of organizations that, “over decades…have produced amazing accomplishments against powerful odds.” In addition to joining the lineup of incredible speakers, Beyond Pesticides will also be tabling. The theme […]

(Beyond Pesticides, May 6, 2016) Last week, the U.S. Environmental Protection Agency (EPA) published a long  awaited review of glyphosate, the active ingredient in Monsanto’s Roundup, concluding that the chemical is not likely to be carcinogenic to humans —then the agency removed the review from its website. After  pulling the report, the agency stated that the document was not final. In March 2015, the International Agency for Research on Cancer (IARC) released its findings that show  glyphosate to be a probable human carcinogen. The 86-page report was published Friday on  regulations.gov by EPA’s cancer assessment review committee (CARC) and was reviewed  by Reuters. While the report finds  that glyphosate is  not likely to be carcinogenic to humans, EPA told Reuters that it took the action it did because the assessment was not final. According to Reuters, “The agency said the documents were ”˜preliminary’ and that they were published ”˜inadvertently.’” But, a cover memo, which was part of the assessment, described the report as CARC’s final cancer assessment document. “Final” was printed on each page of the report, which was dated October 1, 2015. This only furthers speculation that EPA has concluded that it will  renew glyphosate’s registration. The European Union […]

(Beyond Pesticides, May 5, 2016) Yesterday, a large coalition of national organizations delivered over 500,000 petitions to EPA that demands an end to glyphosate use in the U.S. The groups held a rally outside the White House before marching over to EPA headquarters. The event, organized by Moms Across America and Care2, was also joined by Beyond Pesticides, Organic Consumers Association, Friends of the Earth, SumOfUs, and CREDO Action. Glyphosate  is a pervasive and toxic chemical found in Monsanto’s popular Roundup weedkiller and was classified by the  International Agency for Research on Cancer (IARC)  as a probable human carcinogen in 2015. This comes the week after news reports of the European Union indicating it  will re-approve glyphosate’s registration in the EU,  despite fierce public outcry, for another 10 years. Because EPA has not changed its classification of glyphosate as “not likely to be a carcinogen,” it is expected that  EPA will renew the registration  of glyphosate. (The report concluding that glyphosate is not likely  to be carcinogenic to humans was posted online  by EPA on Friday,  but taken down  the following Monday, pending the agency’s completion of its reevaluation.) “The current science confirms that glyphosate and Roundup are anything but […]

(Beyond Pesticides May 3, 2016) Last week, the Organic Consumers Association (OCA) filed lawsuits against two popular infant formula makers for falsely labeling their products as organic. The claims against both The Honest Co. and Hain Celestial Group allege that their products contain ingredients that are prohibited under the Organic Food Production Act (OFPA) of 1990 as well as non-organic and non-agricultural ingredients. The lawsuit against The Honest Company alleges the product contains 11 synthetic ingredients that are not allowed by federal law in organic products, including sodium selenite and taurine. In the court documents, OCA also claims that some of the ingredients have not been “assessed as safe for human foods — much less for infant formulas.” “No one is more concerned about food labels and ingredients than new mothers responsible for feeding infants whose immune systems and brain development are so underdeveloped and vulnerable. As consumers, these mothers must rely on truthful labeling in order to make the best choices for feeding their infants and toddlers. Our job as a consumer advocacy group is to call out and hold accountable companies like The Honest Co. and Hain Celestial when they knowingly and intentionally mislead consumers,” said OCA International […]

(Beyond Pesticides, May 3, 2016) In a bipartisan victory for bees, last week the Connecticut House of Representatives unanimously (147-0) passed a wide-ranging bill aimed at protecting declining pollinator populations within the state from toxic neonicotinoid (neonic) pesticides. Bill No. 231, An Act Concerning Pollinator Health, was also passed unanimously (36-0) through the Connecticut State Senate on April 21, and now goes to Governor Dannel P Malloy for his signature. Earlier in April, both houses of the Maryland legislature passed the Maryland Pollinator Protection Act, which is currently awaiting action by Governor Larry Hogan (R). Connecticut’s bill addresses a broad range of concerns relating to pollinator health, from pesticides to parasites and habitat remediation, within both residential and agricultural settings. In summary, the bill does the following: Prohibits applying neonicotinoid insecticide (a) to linden or basswood trees or (b) labeled for treating plants, to any plants when such plant bears   blossoms; Bee health experts identified the application of systemic neonicotinoids to Tilia trees as a significant concern for pollinator health after a spate of massive bee-kill incidents on the west coast. In June 2013, over 50,000 bumblebees were killed after a neonic was applied to a linden trees in […]