(Beyond Pesticides, September 20, 2019) The actual utility of pesticides to achieve their purported goals is an under-recognized failing of the regulatory review of pesticide compounds for use. A study published in Scientific Reports now exposes the faulty assumptions underlying the use of neonicotinoids — the most widely used category of insecticides worldwide. The study demonstrates that use of neonicotinoids (neonics) to treat seeds — a very common use of these pesticides — actually provides negligible benefits to soybean farmers in terms of yield and overall economic benefit. The U.S. Environmental Protection Agency (EPA) should take notice, and consider that efficacy ought to have a role in the agency’s evaluation of pesticides for registration. Neonicotinoids are systemic pesticides that move through a plant’s vascular system and are expressed in pollen, nectar, and guttation droplets (drops of sap exuded on the tips or edges of leaves of some vascular plants). They can also persist in the environment — in soil and water — for extended periods. Neonics are applied to seed, as well as to crop soils and to plant foliage. Corn and soybean seed treatments represent the largest uses of neonics in the U.S.: for somewhere between 34% and 50+% […]

(Beyond Pesticides, September 19, 2019) A coalition of beekeepers is suing the U.S. Environmental Protection Agency (EPA) for its recent new use registrations of the neonicotinoid-related insecticide sulfoxaflor on bee-attractive crops . The environmental nonprofit Earthjustice is representing the Pollinator Stewardship Council, the American Beekeeper Federation, and Jeff Anderson—a beekeeper. This is the second suit of its kind to be filed against the agency in the past month: The Center for Biological Diversity and Center for Food Safety have also filed a lawsuit in the 9th Circuit Court of Appeals on the use of sulfoxaflor on over 200 million acres of crops that draw in pollinators to forage on poisoned nectar, pollen, and guttation droplets. Sulfoxaflor is a systemic insecticide whose mode of action is the same as neonicotinoid pesticides. After application, the chemical is absorbed and distributed throughout the plant, including pollen and nectar. These insecticides are selective agonists of insects’ nicotinic acetylcholine receptors—they bind to the receptor and cause it to activate. The impact on foraging bees is generally sublethal, but devastating on a population level. At the request of industry, EPA waived the legal requirement for a full-field study of sulfoxaflor’s impacts on pollinators, erroneously stating that further research would […]

(Beyond Pesticides, September 11, 2019) Germany is the latest entity to take action on getting glyphosate-based pesticides out of the marketplace. Chancellor Angela Merkel has announced that, beginning in 2020, the country will phase out herbicides that contain glyphosate by the end of 2023. The phase-out will occur through a series of scheduled reductions in amounts allowed for use, with a goal of a 75% reduction over the next four years. The announcement comes after “nation-wide protests and demands from [Merkel’s] junior coalition partner, the Social Democrats, for more decisive action on environmental issues.” This action stands in telling contrast to the U.S. Environmental Protection Agency’s (EPA’s) repeated failures to protect people, ecosystems, and our food supply, from this toxic compound. The German government also plans to oppose any European Union (EU) request for renewal of licensing of these herbicides, according to the environment ministry. Bayer AG, maker of glyphosate-based herbicides and owner of original manufacturer Monsanto, has pushed back, saying that the government is “getting ahead of itself” by banning glyphosate-based herbicides prior to any decision by the relevant EU authority, and that EU laws disallow unilateral decisions by member states. (Pesticide licensing decisions lie with EU governance in Brussels, […]

(Beyond Pesticides, August 23, 2019) The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) recently released a report criticizing EPA’s oversight of states’ Managed Pollinator Protection Plans (MP3s). OIG conducted an audit, on which the report is based, to evaluate agency performance in overseeing MP3s, voluntary plans adopted at the state level with the goal to “reduce pesticide exposure to pollinators (generally, honey bees managed and contracted out to growers for pollination services) through timely communication and coordination among key stakeholders.” The report’s findings include the following: EPA has no means to evaluate the national impact of MP3s. The agency has not developed a strategy to use data from a planned fall 2019 survey (see more below on the AAPCO/SFIREG/EPA survey) to evaluate either the national impact of MP3s or the agency’s support of state MP3 implementation efforts. EPA focuses primarily on acute risks (those that occur during a single exposure to a specific pesticide), and gives insufficient attention to chronic exposures to pesticides and to native pollinator protection activities. The history of the MP3 program starts in 2014, when President Obama issued a memo establishing a Pollinator Health Task Force (PHTF), directing federal agencies […]

(Beyond Pesticides, July 30, 2019) Earlier this month, the U.S. Environmental Protection Agency announced a decision to register new uses for the bee-toxic pesticide sulfoxaflor. The decision closely followed a USDA announcement halting the Honey Bee Colonies Survey, combining blows to already suffering beekeepers. According to the nonprofit Bee Informed, this past winter tallied the most colonies lost in a decade—an estimated 37% between October 1, 2018 and April 1, 2019. “Proposing to register sulfoxaflor for use on bee-attractive crops, in the midst of an ongoing pollinator crisis, is the height of irresponsibility,” said Drew Toher, community resource and policy director for Beyond Pesticides in an interview for Bloomberg Environment. “When all of the available data points to significant risks to pollinators from use of this chemical we must face the facts: EPA is working towards the protection of pesticide industry, not the environment,” he said. Sulfoxaflor is a systemic insecticide whose mode of action is the same as neonicotinoid pesticides. After application, the chemical is absorbed and distributed throughout the plant, including pollen and nectar. These insecticides are selective agonists of insects’ nicotinic acetylcholine receptors—they bind to the receptor and cause it to activate. The impact on foraging bees […]

(Beyond Pesticides, July 12, 2019) The U.S. Department of Agriculture (USDA) announced, on Saturday, July 6 that it would suspend indefinitely the data collection for its Honey Bee Colonies survey and report. The move came, tellingly, less than three weeks after the Environmental Protection Agency (EPA) once again approved “emergency” uses of the pesticide sulfoxaflor, a bee-killing compound similar to the notorious neonicotinoids, insecticides that contribute significantly to the phenomena of pollinator collapse (“colony collapse disorder”) and massive insect loss (“insect apocalypse”) that are underway worldwide. Sulfoxaflor is one of the many toxic pesticides that threaten honey bees, which are critical pollinators responsible for one-third of the food we humans consume. Permitting its use and then ceasing to collect and report data on the status of honey bees that are likely to be impacted is not only a recipe for kneecapping the study of bee decline and imperiling the food supply, but also, another example of the corruption for which this administration is infamous. As The Huffington Post reported, “Critics say the USDA’s move is the latest evidence of the Trump administration’s war on science, and its goal of suppressing information about serious environmental harms increasing under Donald Trump’s presidency.” Union […]

(Beyond Pesticides, July 5, 2019) This is a story about a chemical pesticide, a fungicide, in wide use for which the mode of action, i.e., the ability to cause harm, has not been fully understood. It is not a story unique to this pesticide. Rather, it is an important story to consider when deciding to use a pesticide or allowing a pesticide to be used. The question is whether the chemical could be broadly problematic beyond the target organisms, in this case fungi? In its coverage of a study published in March, the American Association for the Advancement of Science publication, EurekAlert, reported that, “The ability of [the fungicide] fludioxonil to act on a sugar-metabolizing enzyme common to all cells, and to produce the damaging compound methylglyoxal, may mean that the pesticide has more potential to harm non-fungal cells than previously thought. Although fludioxonil has been deemed safe for use, the authors . . . suggest that the effects of this widely used pesticide has upon animals be re-examined.” The research study, published in March in Scientific Reports and led by T. Tristan Brandhorst, PhD (in the lab of Dr. Bruce Klein at the University of Wisconsin–Madison and UW School of […]

(Beyond Pesticides, June 24, 2019) During “Pollinator Week,” last week, the U.S. Environmental Protection Agency betrayed its responsibility to protect the environment and approved “emergency” uses of sulfoxaflor, a bee-toxic insecticide, in 11 states on millions of acres of crops that are attractive to bees. Sulfoxaflor is functionally identical to the neonicotinoid class of systemic pesticides, which are readily absorbed and translocated into the plant tissues, including its pollen and nectar. These insecticides are substantial contributors to the dramatic decline of pollinators and what is now recognized as a global insect apocalypse. Ask Your Elected Members of Congress to Tell EPA that Its Actions Are Unacceptable and Must Be Reversed In 2015, beekeepers sued to suspend the use of sulfoxaflor. A year later, in 2016, the chemical’s registration was amended with the specific exclusion of crops such as cotton and sorghum that attract bees, essentially acting as an aromatic draw to poison. However, EPA regularly utilizes the “emergency exemption” rule under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to circumvent these restrictions. The Center for Biological Diversity reports, “Ten of the 11 states have been granted the approvals for at least four consecutive years for the same ’emergency.’ Five have […]

(Beyond Pesticides, June 19, 2019) On June 17, 2019, the Environmental Protection Agency (EPA) once again approved “emergency” uses of sulfoxaflor, a bee-toxic insecticide, on millions of acres of crops that are attractive to bees. Sulfoxaflor is functionally identical to the neonicotinoid class of systemic pesticides, which are readily absorbed and translocated by the plant, including its pollen and nectar. These insecticides are substantial contributors to the dramatic decline of pollinators and what is now recognized as a global insect apocalypse. In 2015, beekeepers sued to suspend the use of sulfoxaflor. A year later, in 2016 the chemical’s registration was amended with the specific exclusion of crops such as cotton and sorghum that attract bees, essentially acting as an aromatic draw to poison. EPA regularly utilizes the “emergency exemption” rule under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to circumvent these restrictions. The Center for Biological Diversity reports, “Ten of the 11 states have been granted the approvals for at least four consecutive years for the same ‘emergency.’ Five have been given approvals for at least six consecutive years.” The EPA’s Office of Inspector General (OIG) has recognized the broad misuse of Section 18. A 2018 report from OIG notes […]

(Beyond Pesticides, April 16, 2019) Help stop another attack on local authority in Maine – a bellwether state that has upheld local pesticide restrictions and leads the nation. Maine has led the nation in supporting the local democratic process as communities across the state have adopted pesticide use standards on public and private property that are more restrictive than state laws. This will be the third attack on local authority in recent years – each time beaten back with public opposition. This time preemption language has been introduced as a clause in the innocuous sounding bill LD 1518, An Act to Establish a Fund for Portions of the Operations and Outreach Activities of the University of Maine Cooperative Extension Diagnostic and Research Laboratory and To Increase Statewide Enforcement of Pesticide Use. The language was introduced by Rep. Stephen Stanley (D), who ran unopposed in the 2018 Democratic primary. The bill’s language establishes barriers to local decision making, giving sole authority to the state to determine the acceptability of local pesticide restrictions.  As drafted, the bill would force municipalities to submit a request to ban a substance to a statewide board, which would make the decision as to whether the community could block […]

(Beyond Pesticides, March 29, 2019) The U.S. Environmental Protection Agency (EPA) made a low-key announcement on March 19 suggesting that it may change its handling of requests from states to exert stricter controls on use of pesticides than the federal agency sets out in its registration of the compounds — by disapproving them. This is potentially a big deal because it signals that the agency will be less-kindly disposed to states’ desires to establish either somewhat different parameters of use based on local conditions and needs, or more-stringent regulations on pesticide use than those set out by federal regulators. This issue of preemption of localities’ desires to protect their populations and environment has become an increasingly dynamic frontier at the nexus of pesticide use, health, and environment. Beyond Pesticides has written more frequently about this issue in recent years as the tension between centralized, federal regulation and more-local regulation has risen; see more below. EPA appears distressed by some of the approximately 300 annual requests it gets to make some adjustment to the federal regulation. This can happen under Section 24(c) of FIFRA, which allows for a Special Local Need Label, which can be requested under a variety of conditions, including […]

(Beyond Pesticides, March 25, 2019) EPA is using a regulatory loophole – the “treated articles exemption” – to allow systemic insecticides to be used in mass quantities, without regulating or labeling them as required under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). EPA does not currently assess adverse effects on the environment and public health caused by widespread use of neonicotinoid insecticides delivered through seeds coated with the insecticides, resulting in widespread exposure to one of the most environmentally damaging classes of chemicals on the market. Tell your Congressional delegation that EPA must fully regulate treated seeds to protect the environment and public health. Pesticide-coated seeds are now ubiquitous, yet their far-reaching impacts on wildlife and human health continue to go unregulated. The introduction and spread of seed-delivered pesticides to major field crops, beginning around 2003, caused a massive increase in total neonicotinoid use nationwide. As of 2011, 34 to 44% of soybeans and 79 to 100% of maize acres were planted with coated seeds, accounting for an astounding 35-fold increase in nationwide neonicotinoid use from baseline rates prior to 2003 (Douglas and Tooker, 2015). Alarmingly, because the national pesticide survey conducted by the National Agricultural Statistics Service fails to […]

(Beyond Pesticides, March 17, 2019) Forget about single-pesticide issues: this affects every single one of them. EPA is allowing massive data gaps to persist for each and every pesticide product it registers by conducting the bulk of its health and environmental risk assessments using active ingredients alone. With its current practices, EPA is failing its federal mandate to protect public health and the environment and misleading the public about what is “safe.” Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients. When pesticides are sprayed on our crops, lawns, and roadsides, and enter into our waterways, groundwater and drinking water, we are exposed to whole formulations, whole tank mixtures, and whole pesticide combinations, not just active ingredients (those that the manufacturer claims are the only ingredients that attack the target pest). It is the whole formulation that makes the poison, and that whole formulation must be regulated. Active ingredients are far from the whole story of pesticide poisoning. Despite their name, “inert” ingredients are very often not chemically, biologically, nor toxicologically inert or innocuous. According to a peer-reviewed study, as of 2006, more […]

(Beyond Pesticides, March 14, 2019) A study, supported by the USDA’s National Institute of Food and Agriculture, finds that state pesticide preemption laws “compromise public health and economic well-being” by preventing localities from enacting pesticide use restrictions on private property that are more restrictive than their state’s regulations. In the words of the authors, “By eliminating the ability of local governments to enact ordinances to safeguard inhabitants from health risks posed by pesticides, state preemption laws denigrate public health protections.” The study, Anti-community state pesticide preemption laws prevent local governments from protecting people from harm, published in the International Journal of Agricultural Sustainability, reviews scientific and historical evidence of the failure of state and federal pesticide laws to protect localities from pesticide poisoning, and highlights the inability of localities to compensate for that failure under present laws. Communities seeking to protect their residents would typically issue community-wide restrictions to ensure protection of shared community resources, including air, land, and waterways, from pesticide drift, runoff, and other nontarget effects —as is the case with other community decisions on recycling, smoking, and zoning. The study’s authors document how industry influence led to the adoption of state laws that undermine the ability of localities […]

(Beyond Pesticides, February 21, 2019) In 2018, the Environmental Protection Agency (EPA) approved 16.2 million acres of crops to be sprayed with the bee-toxic insecticide sulfoxaflor under an emergency exemption. Sulfoxaflor was used in 18 different states on cotton and sorghum — plants known to attract bees. In response to a lawsuit headed by beekeepers, the EPA reclassified sulfoxaflor in 2016 and, recognizing its toxicity to bees, prohibited use on crops that draw in these pollinators. However, Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) gives the EPA authority to permit temporary emergency use of unapproved pesticides. This loophole is used regularly in response to predictable stressors. “Emergency” use was approved 78 times for sulfoxaflor on sorghum and cotton between 2012-2017. Sulfoxaflor is a systemic insecticide that acts similarly to neonicotinoid pesticides. After application, the chemical is absorbed and distributed throughout the plant, including pollen and nectar. These kinds of chemicals are selective agonists of insects’ nicotinic acetylcholine receptors—they bind to the receptor and cause it to activate. The impact on foraging bees is sublethal, but devastating on a population level. Even at low levels, sulfoxaflor impairs reproduction and reduces bumblebee colony size. Sufloxaflor is functionally identical to […]

(Beyond Pesticides, February 1, 2019) Prior to a pesticide ban taking effect in Montgomery County Maryland Parks, the Department of Parks announced in mid-December 2018 that it would discontinue the use of glyphosate-based herbicides through March 2019. The agency has used these hazardous herbicides as part of its IPM (Integrated Pest Management) program for weed management. Montgomery Parks indicates it will release further information on the use of glyphosate in mid-March. In November last year, Montgomery County Council member Tom Hucker wrote to the head of Parks, supported by a community-wide petition, urging that glyphosate be banned immediately, pending implementation of the county ban. He cited the finding of the International Agency for Research on Cancer’s (World Health Organization) finding that the chemical probably causes cancer in humans and the $289 million jury verdict last year that the chemical caused a school groundskeeper’s non Hodgkin lymphoma. In 2016, Montgomery Parks instituted a pesticide reduction program in compliance with Montgomery County, Maryland’s 2015 adoption of County Code 33B, which aimed to regulate use of pesticides on county-owned property, including parks, and on private property. In 2017, a Montgomery Circuit Court overturned the portion of the law pertaining to a ban on private […]

(Beyond Pesticides, January 28, 2019) A  September 2018 report from the Office Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA) identified issues important to protecting health and the environment. The EPA’s response to the report left many of these problems unresolved. Measures and Management Controls Needed to Improve EPA’s Pesticide Emergency Exemption Process (Report No. 18-P-0281, September 25, 2018), finds that the agency’s practice of routinely granting “emergency” approval for pesticides through its Section 18 program does not effectively measure risks to human health or the environment. Tell Congress to Ask the EPA Administrator to Close the “Emergency” Pesticide Use Loophole, and Adopt All the Recommendations of the Office of the Inspector General. Under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA has the authority to approve the temporary emergency use of unapproved pesticides if the agency determines the pesticide is needed to prevent the spread of an unexpected outbreak of crop-damaging insects, for example. But this provision has been widely abused. The inspector general recommends EPA “develop and implement applicable outcome-based performance measures to demonstrate the human health and environmental effects of the EPA’s emergency exemption decisions.” EPA disagreed and said, [T]he development […]

(Beyond Pesticides, January 14, 2019)  A petition submitted on January 7 by the Center for Biological Diversity calls on the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS) to initiate rulemaking to proscribe nearly all pesticide use in areas that are deemed critical habitat for endangered species. It asks these federal agencies to use the authority they have under the 1973 Endangered Species Act (ESA) to protect wildlife from the threats represented by pesticides — which threats both agencies have long recognized. The language of the ESA says its purpose is “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved.” In its press release on the petition, the Center for Biological Diversity (CBD) notes that it comes “after decades of intransigence by the Environmental Protection Agency, which has refused to comply with the legal mandates of the Endangered Species Act to protect the nation’s most imperiled species from highly toxic pesticides like chlorpyrifos and atrazine that are known to harm wildlife.” CBD environmental health director Lori Ann Burd said, “Pesticides pose a devastating danger to endangered wildlife, from coast to coast. If the EPA isn’t going to […]

(Beyond Pesticides, January 4, 2019) First, the good news: plaintiffs in a 2013 lawsuit against the Environmental Protection Agency (EPA) can allow themselves a small victory dance. In that suit, plaintiffs made a number of claims related to EPA’s failure to protect pollinators from dangerous pesticides, its poor oversight of the bee-killing pesticides clothianidin and thiamethoxam, and its practice of “conditional registration,” as well as labeling deficiencies. The parties in the suit negotiated a settlement, as directed by a federal judge (see below), that was signed in October 2018 and portends some positive movement in curtailing the use of some toxic pesticides [12 products, each of which contains chlothianidin or thiamathoxam as an active ingredient] that harm pollinators in particular, as well as other organisms and the environment. It also establishes a public process for EPA to consider requiring whole formulations of pesticide products during registration, and redefining EPA’s interpretation of law that allows seeds treated with bee-toxic pesticides to escape regulation as a pesticide. The suit was brought by a number of individual beekeepers and several organizations, including Beyond Pesticides, Center for Food Safety (CFS), Sierra Club, and Center for Environmental Health, and named as defendants Steven Bradbury, then-director of the […]

(Beyond Pesticides, December 18, 2018) The ingredients not listed on a pesticide product are not fully reviewed for their adverse effects may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to disclose and test all ingredients in pesticide products, as well as the full formulation that includes “inert” or nondisclosed ingredients. While glyphosate/Roundup is obviously not allowed to be used in organic production, this research reaffirms the need to evaluate full formulations of substances allowed for use in organic. The research on glyphosate tested the toxicity of the herbicide glyphosate, “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, the researchers studied a number of other pesticides. Tell NOP and USDA that “inerts” used in organic production must receive full review by the NOSB. “Inert” ingredients are allowed in pesticides used in organic production as well as those used in chemical-intensive production. The National Organic Program (NOP) allows “inerts,” permitted in conventional production and formerly listed […]

(Beyond Pesticides, December 7, 2018) As medicinal and recreational marijuana continue to be legalized in various states, concerns about the safety of the burgeoning industry — how the substance is grown, harvested, processed, distributed, sold, and used — have emerged. Colorado’s recent experience is a case in point: in early December, the state’s Marijuana Enforcement Division (MED) announced two recalls on cannabis products out of concern about their contamination by pesticide residues. In both cases, the recall announcements from the Colorado Department of Revenue, in conjunction with the Colorado Department of Agriculture (CDA) and the Colorado Department of Public Health and Environment, said that the state agencies “deem it a threat to public health and safety when pesticides that are not on the list of approved pesticides for marijuana use as determined by CDA are applied in a manner inconsistent with the pesticide’s label.” Three off-label pesticides were listed in the recall announcement. Pyriproxyfen was found in samples tested from Colorado Wellness Centers LLC (dba Lush), and bifenthrin and diuron were found in samples from Crossroads Wellness LLC (dba Boulder Botanics). None of those compounds is approved by Colorado for use on marijuana; two are listed as possible carcinogens by […]

(Beyond Pesticides, December 5, 2018)  The Environmental Protection Agency (EPA) has denied a petition seeking to ban M-44s — cyanide-spraying apparatuses used to kill coyotes, foxes, and wild dogs that may prey on livestock. Submitted to the EPA in August 2017 by the Center for Biological Diversity, WildEarth Guardians, the Humane Society of the U.S., Natural Resources Defense Council, Predator Defense, the Sierra Club, and a number of other conservation, wildlife, and environmental organizations, the petition sought cancellation of the registration of cyanide capsules used in M-44s and a functional ban on their use in the “lower 48” states because of their danger to non-target wildlife, domestic pets, and people. In its letter of denial, EPA noted that it “is currently reviewing these products using the Registration Review process and sees no reason, and the Petition provides none, to start a parallel process using Special Review proceedings to look at the same issues.” Although the word “pesticide” generally conjures thoughts of a chemical meant to kill insect “pests,” whether sprayed on crops, coated onto seeds, or in the kit bag of an “exterminator” whose business it is to rout out some infestation in a home or building, these two compounds […]

(Beyond Pesticides, October 29, 2018) Protect the integrity of the organic standard setting process that determines whether a synthetic substance will be allowed in food labeled organic. Help stop an attack on the meaning of the organic label in the Farm Bill, which may be voted out of conference committee by the end of November. By changing the substance review process, a provision will open the floodgates to allowed synthetic chemicals in organic production, handling, and processing under the Organic Foods Production Act (OFPA). OFPA incorporates values and principles that build and regenerate soil, protect pollinators and biodiversity, eliminate toxic pesticide use, and contains a default provision that strictly limits synthetic chemicals in certified organic products. This will all change with the Farm bill amendment. Ask your U.S. Representative and Senators to tell Farm Bill conferees to reject Section 10104(e) National Organic Standards Board in the Senate Farm Bill (S.3042), a provision that will increase the use of synthetic substances in organic food production. OFPA incorporates language that ensures that the process for allowing synthetic chemicals in organic production, handling, and processing is very rigorous. This meets a public expectation that food labeled organic is subject to a higher degree of […]