(Beyond Pesticides, June 28, 2019) As is the case in many countries, the conversation about the use of pesticides has been especially vigorous in the past few years. Switzerland is a case in point: it is undergoing deep scrutiny of pesticide use, and the UN Special Rapporteur on Toxics, Baskut Tuncak, has now said publicly that pesticide companies’ behavior is “seriously deficient” regarding human rights (especially those of children), and that the Swiss government should act more aggressively to phase out use of these hazardous chemicals. Recently, the pesticide conversation has ratcheted up several notches, not only in the U.S., but also globally, due to greater public awareness of the health and environmental threats of pesticide use, more and more research underscoring those threats, and pointedly, the cascade of litigation against Monsanto (now owned by Bayer) for harm to individuals who have used its glyphosate-based products. Public awareness in Switzerland is also mounting in response to global developments, to recent discoveries that small streams in Swiss agricultural areas are heavily polluted with pesticides, and to broadening recognition that pesticides are linked to a plethora of harms to human health, pollinators, water, farmworkers, wildlife, ecosystems and biodiversity, and more. In 2017, a UN […]

(Beyond Pesticides, June 12, 2019) A new study finds that the widespread insecticide fipronil causes transgenerational toxicity across generations of zebrafish. Fipronil, already known to be highly toxic to aquatic organisms, is now implicated in causing even more damage than previously thought. Even individuals who are not themselves directly exposed are shown to suffer from maternally transmitted toxic effects, including a more than doubled mortality rate. The study, published in Environmental Pollution, tracks hatching, growth, and survival of offspring whose mothers were exposed to fipronil. Researchers exposed a total of 90 adult female zebrafish to environmentally relevant levels of fipronil, within the range of concentrations known to occur in U.S. surface waters, for a period of 28 days. After exposure, females were mated with unexposed males, and their offspring were monitored for hatching, growth, locomotor behavior, heart rate, toxicity and gene expression assays. The conclusion: maternal fipronil exposure induced multiple toxic effects in offspring, including a 30% reduction in hatch rates and, alarmingly, a more than doubling of the offspring mortality rate. Fipronil is a broad-spectrum insecticide widely used for indoor and turf pest control in the U.S., and identified as a ubiquitous contaminant of U.S. surface waters. Fipronil is […]

(Beyond Pesticides, June 7, 2019) Fruit orchards and vineyards endure some of the most intensive chemical management in all of agriculture. What has not been investigated — until now — is how pesticide drift from such agricultural sites may be affecting nearby public spaces. A recent, first-of-its-kind study out of northern Italy tested 71 public playgrounds near to apple orchards and vineyards in four valleys of the North Tyrol, and finds that 45% are contaminated with a single pesticide, and 24% by more than one. Study authors note that the playground contamination will likely grow worse over the course of the growing season. This would likely amplify the impacts of such chemical trespass on nearby public spaces, never mind the varieties of harm to the sites themselves and the food produced on them. Organic agriculture, of course, remedies all these concerns. The study randomly chose 71 public playgrounds in the four South Tyrolean regions, and analyzed grass samples for potential contamination by 315 different pesticides. Because pesticides applied to agricultural fields, orchards, and vineyards are easily volatized, carried aloft by wind, and/or washed by rain off of the target site, the study also evaluated the impacts of those (and other) factors […]

(Beyond Pesticides, May 13, 2019) The Center for Biological Diversity (CBD) filed four lawsuits last week challenging the Trump administration’s failure to release a trove of documents detailing how the administration is regulating dangerous pesticides, especially as they relate to endangered species. Meanwhile, the U.S. Environmental Protection Agency (EPA) released a set of proposed changes last week that would dramatically reduce protections for the nation’s most endangered plants and animals from pesticides known to harm them. The proposals ignore the real-world, science-based assessments of pesticides’ harms, instead relying on arbitrary industry-created models. The EPA proposals would, for example, gut protections for endangered plants that are pollinated by butterflies and other insects by ignoring the fact that animals routinely move back and forth between agricultural areas and places where endangered species live. The proposals follow intensive efforts by Interior Secretary David Bernhardt to halt federal work on protecting wildlife from pesticides. They were released over a year after a draft biological opinion that was scuttled by the Trump administration found that the loss of pollinators from the insecticide chlorpyrifos would put hundreds of endangered species on a path to extinction. The so-called “refinements” will make it easier for the EPA to claim that pesticides […]

(Beyond Pesticides, May 10, 2019) The Earth, its natural systems, and as many as a million species are at enormous risk from human activity, says a new assessment from the United Nations Decade on Biodiversity project — the IPBES Global Assessment Summary for Policymakers. The net finding might be expressed as: humans are not immune from the sequelae of biodiversity loss; the ecosystem functions on which human lives depend are in increasingly dire straits. The 1,500-page report, convened by IPBES (Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services), is the most comprehensive look to date at the biodiversity crisis and its implications for human civilization. A summary of the report’s findings, approved by representatives from the U.S. and other member countries, was released in Paris on May 6; the complete report is expected later in 2019. It is of note and commendable that the summary, though lengthy, is digestible for a lay audience. IPBES is an intergovernmental body of 132 member states, established in 2012, that assesses the state of biodiversity and of the ecosystem services such diversity provides to societies. The group also provides reporting to policymakers on those assessments, and on the dynamics (i.e., causes and impacts) between human […]

(Beyond Pesticides, May 9, 2019) On Wednesday, the U.S. Environmental Protection Agency (EPA) issued a proposed interim decision on glyphosate’s registration review, ignoring widespread scientific consensus on the herbicide’s carcinogenicity and instead restating the agency’s firm position that glyphosate is “not likely to be carcinogenic to humans.” EPA’s bold statement stands in stark contrast to scientific consensus to the contrary. In 2015, the World Health Organization’s International Agency for Research on Cancer (IARC) found glyphosate to be a probable human carcinogen. In response to resistance from the European Food Safety Authority, 94 expert scientists published an article in support of IARC’s methodologies and findings. Since 2015, several more publications have added significant weight to the body of evidence supporting glyphosate’s carcinogenicity. A February 2018 meta-analysis of studies on glyphosate suggested “a compelling link between exposures to GBH [glyphosate-based herbicides] and increased risk of NHL [non-Hodgkin lymphoma]. A February 2019 University of Washington study found that glyphosate increased the risk of non-Hodgkin lymphoma by as much as 41%. Despite attempts by current and former EPA top officials to “kill” their report, Agency for Toxic Substances and Disease Registry (ATSDR), a agency at the U.S. Department of Health and Human Services, released its […]

(Beyond Pesticides, March 28, 2019) A set of documents obtained by the Center for Biological Diversity reveals that the Trump administration has known for over a year – and actively concealed – that the organophosphate insecticide chlorpyrifos jeopardizes the existence of 1,399 endangered species. Top officials at the U.S. Department of the Interior, including Acting Secretary David Bernhardt, were privy to and prevented the release of a “biological opinion,” completed by the Fish and Wildlife Service (FWS) in 2017, which contains a full analysis of the extensive environmental impacts wrought by three organophosphate insecticides. While chlorpyrifos is the worst of the three, the censored biological opinion includes similarly concerning findings for two other organophosphate pesticides, malathion and diazinon, which are currently jeopardizing 1,284 and 175 species, respectively. The U.S. Environmental Protection Agency (EPA) has determined that that all organophosphates have a common mechanisms of effect and therefore the multiple exposures to these pesticides lead to a cumulative risk. “It’s outrageous that Trump, Bernhardt and the industry hacks inhabiting this administration are speeding the extinction of nearly 1,400 endangered species by refusing to take any action on chlorpyrifos,” said Lori Ann Burd, environmental health director at the Center for Biological Diversity […]

(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 4, 2019) Last week, U.S. Representative Earl Blumenauer (D-OR) reintroduced the Saving America’s Pollinators Act (H.R.1337) to cancel specific bee-toxic pesticides and establish a review and cancellation process for all pesticides that are potentially harmful to pollinators. The specific pesticides targeted in the bill include the systemic insecticides imidacloprid, clothianidin, thiamethoxam, dinotefuran, acetamiprid, sulfoxaflor, flupyradifurone, and fipronil. The bill also establishes requirements for review of other potentially bee-toxic chemicals by an independent pollinator protection board, and requires annual reports on the health and population status of pollinators. The bill creates a sustainable model for pollinator protection in the face of ongoing obstruction by an increasingly industry-influenced EPA. There are 29 cosponsors to date. The current bill is the fifth version of Saving America’s Pollinators Act (SAPA), which was first introduced by U.S. Representative Conyers (D-MI) in 2013. The newest version differs from previous bills in its bold definition of who should have responsibility for assessing harm to pollinators. SAPA 2019 calls for the establishment of a Pollinator Protection Board, to be composed of expert scientists, beekeepers, farmers, members of environmental organizations and other key stakeholders, nearly all of whom must not have any conflict of interest or affiliation […]

(Beyond Pesticides, February 8, 2019) Scientists from the U.S. Geological Survey (USGS) and the University of Iowa (UI) have published worrisome news on the neonicotinoid front. The experts discovered two metabolites of imidacloprid (a neonicotinoid insecticide) residues that had not previously been identified in drinking water — desnitro-imidacloprid and imidacloprid-urea. The researchers note both that these metabolites have never been evaluated for their potential risks to human and environmental health, and that there may be potential risks of anthropogenic compounds that can be created when water with neonicotinoid residues, and thus, these metabolites, undergo typical water treatment (often chlorination and/or pH treatment). They note that, “The mammalian toxicity of transformation products formed during water treatment processes remains unknown. It is possible that chlorination of neonicotinoids and their metabolites will . . . alter their bioactivity.” The joint, federally funded collaboration investigated neonicotinoid pesticides (“neonics”) in tap water to determine whether neonic metabolites are relevant to pesticide exposure through drinking water, and to identify any products of the chlorination of neonics and their metabolites. The scientists simulated realistic drinking water conditions in their research to demonstrate, in laboratory circumstances, that chlorinated disinfection byproduct chemicals are produced. The study, conducted by seven researchers […]

(Beyond Pesticides, January 29, 2019) After eight months of deliberation and discussion, the European Parliament’s Special Committee (the PEST Committee) overwhelmingly approved its draft report in early December 2018 with recommendations to strengthen pesticide restrictions. PEST was established in January 2018 to assess the European Union’s authorization procedure for pesticides. The group’s charge was to review the European Union’s (EU’s) pesticide authorization process, identify its failures in evaluating and approving pesticides and their use (including any conflicts of interest impacting the process), and make recommendations to improve the protection of human, animal, and environmental health from pesticides. The 30-member committee concluded: improvement of the system will require changes in the entirety of the pesticide approval process — from the point of industry application for authorization of a pesticide, to the sale and use of any products containing the compound in EU Member States, to evaluation of impacts of its use once on the market. The approval, sale, use, and regulation of what the EU calls “Plant Protection Products” [PPP] — active substances used to “1) to protect plants or plant products against pests/diseases, 2) to influence the life processes of plants (such as substances influencing their growth, excluding nutrients) and […]

(Beyond Pesticides, January 9, 2019) It is news to approximately no one that pollinators are in trouble worldwide. A series of papers by biologists at the University of Guelph, Ontario, posits that pesticide regulations aimed at protection of honey bees fall far short of the critical task of protecting the multitude of bee species that are important pollinators of human food crops. These recent papers arose from 2017 workshops that involved 40 bee researchers from various universities, and representatives from Canadian, U.S., and European regulatory agencies, and from the agrochemical industry. Beset by shrinking habitat, pathogens, and toxic chemical exposures, bee pollinator populations are at great risk, even as “‘our dependency on insect-pollinated crops is increasing and will continue to do so as the global population rises,’ said [Professor Nigel] Raine, [PhD], [a] co-author of all three papers recently published in the journal Environmental Entomology. . . . Protecting wild pollinators is more important now than ever before. Honeybees alone simply cannot deliver the crop pollination services we need.” There are, in fact, more than 20,000 bee species worldwide, and 3,500–5,000 bee species in North America alone. Although regulators across many countries have focused narrowly on assessing the risk of pesticides to honey bees, many […]

(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, November 30, 2018) A study published this month in Science of the Total Environment reveals numerous pesticide residues persisting in soil, harming the viability of agricultural lands and increasing risk of off-site contamination. Funded by the Horizon 2020 programme of the European Commission, researchers from the European Diverfarming project at the University of Wageningen in the Netherlands suggest nations urgently reevaluate conventional land use and inputs including water, energy, fertilizers, machinery and pesticides. Researchers decrying the lack of soil protection policies endeavored to determine which pesticides had the highest soil persistence and toxicity to non-target species. Three hundred seventeen surface soil samples were analyzed from 11 European countries. Selected countries were those with the largest amounts of active agricultural land, characterizing six distinct cropping systems. Sampled soils purposefully represented different soil properties and were taken from crops with the highest pesticide use per hectare. Samples were then analyzed for the concentration of 76 pesticide residues. These 76 pesticides were selected as being most often applied on conventional crops. Eighty-three percent of samples contained varying degrees of pesticide residues, with 25 percent showing one pesticide residue and 58 percent showing mixtures of two or more. Only 17 percent of […]

(Beyond Pesticides, August, 20, 2018) Health Canada’s Pest Management Regulatory Agency (PMRA) has announced a plan to phase out the outdoor use of two neonicotinoid insecticides — thiamethoxam and clothianidin — over three to five years, due to concerns about their effects on aquatic invertebrates. This comes after their 2016 proposal to phase out another neonicotinoid, imidacloprid, for the same concerns, but the proposal has not been finalized. In April, the European Union (EU) voted to ban the most widely used neonicotinoids, citing risks to bees. Earlier this year, PMRA proposed to phase out a number of uses of neonicotinoids in order to mitigate risks to pollinators. And now, after the Canadian agency initiated a special review based on a preliminary analysis of available information on the concentrations and frequency of detection of clothianidin in aquatic environment, the agency has proposed another round of phase-outs. The agency’s review focused on assessing potential risk to aquatic invertebrates exposed to clothianidin applied as a seed, foliar or soil treatment. The assessment finds that, in aquatic environments in Canada, clothianidin and thiamethoxam are both being measured at concentrations that are harmful to aquatic insects. These insects, according to the agency, are an important part of […]

(Beyond Pesticides, August 7, 2018) At the same time that a new analysis by California’s Department of Pesticide Regulation (DPR) finds current neonicotinoid uses in the state expose bees to residue levels known to cause harm, the Trump administration has reversed a 2014 U.S. Fish and Wildlife (FWS) decision to ban neonicotinoids on National Wildlife Refuges. In 2014, newly passed state legislation required DPR to study the impacts of neonicotinoids (imidacloprid, thiamethoxam, clothianidin, and dinotefuran) and adopt control measures to protect sensitive pollinator health within two years. In its report, released last month, DPR finds the highest risk to bees is posed by use of two neonicotinoids, thiamethoxam and clothianidin, on cereal grains like corn, wheat, rice, and barley. The seeds of these crops are typically coated with neonicotinoids before planting, where residues persist in the pollen and nectar. Although these findings are not surprising and have been documented in the scientific literature, California’s analysis indicates neonicotinoids can cause much broader harm, including to pollinators commonly found on many types of vegetables, cereal grains, tree nuts, fruits and tobacco. Shortly after a decision in the Pacific Region, FWS announced that all National Wildlife Refuges would join in the phase-out of neonics (while also phasing out genetically […]

(Beyond Pesticides, August 1, 2018) According to new research from the University of Sussex, bees living in suburban habitats are still being exposed to high levels of neonicotinoid pesticides. Even though there is a European Union (EU) ban on these chemicals, the ban focuses on agricultural and not residential applications. The study’s authors are urging gardeners to forgo the use of these pesticides in favor of more holistic, pesticide-free approaches. The authors of the study say it is the first of its kind to highlight the risk to bees in urban areas posed by garden use of pesticides. Entitled Monitoring neonicotinoid exposure for bees in rural and peri-urban areas of the UK during the transition from pre- to post-moratorium, the study sampled pollen and nectar from bumblebee colonies in rural and peri-urban habitats in three UK regions–Stirlingshire, Hertfordshire, and Sussex over three years. Sampling began prior to the ban (2013), during the initial implementation when some seed-treated winter-sown oilseed rape was still grown (2014), and following the ban (2015). Honey bee colonies in rural habitats were also sampled to compare species-level differences between bumblebees and honey bees. Not surprisingly, the researchers find pesticide contamination in more than 50 percent of the samples, […]

(Beyond Pesticides, July 6, 2018) Two years ago, thirteen bald eagles were found dead on a farm in Maryland. Now the investigation has revealed that these birds died after ingesting the highly toxic pesticide, carbofuran. Carbofuran, whose use has been phased out in the U.S., is so toxic to birds that one granule is all it takes to kill. Irresponsible and illegal use of pesticides is still responsible for primary and secondary poisonings of wildlife, as is the case of these bald eagles. According to the necropsy results by U.S. Fish and Wildlife Service (FWS), which analyzed six of the thirteen eagle carcasses, five of the carcasses were found to have undigested raccoon remains in their systems. Carbofuran was detected in the stomach and/or crop contents of all birds, as well as on the partial remains and fur of a raccoon that was found nearby. The granular form of carbofuran has been blamed for the deaths of more than a million birds in the U.S. who mistook the granules for seed. The granules were finally banned in the early 1990s, while the liquid formulation was banned on food crops in 2009, although the painfully slow process of cancellation by the U.S. […]

(Beyond Pesticides, July 2, 2018) The U.S. House of Representatives is considering an appropriations bill that includes “report language” that would restrict independent evaluation of pesticide hazards by the Agency for Toxic Substances and Disease Registry (ATSDR), part of the Centers for Disease Control and Prevention. The report language, as part of the U.S. House of Representatives Department of the Interior, Environment, and Related Agencies FY2019 Appropriations Bill, directs ATSDR to “focus on its core mission of assessing hazardous exposures and working with communities, if requested, near toxic waste sites and not agricultural operations” [emphasis added]. As some may recall from “The Monsanto Papers,” Monsanto pushed to stop ATSDR from researching the cancer-causing properties of its herbicide Roundup/glyphosate. [Unsealed internal Monsanto documents from a federal lawsuit, dubbed “The Monsanto Papers,” showed evidence of questionable research practices by the company, inappropriate ties to a top EPA official, and possible “ghostwriting” of purportedly “independent” research studies.] There is also a significant cut to the budget. The Senate Appropriations Committee does not include the same restrictive language. Tell your U.S. Senators and Representative to reject language, attached to the House appropriations bill, that prohibits independent evaluation of agricultural chemical hazards by the government’s research agency (ATSDR). […]

(Beyond Pesticides, June 12, 2018) Two recent studies are contributing to the growing understanding that challenges basic toxicological precepts as inadequate to comprehensive assessments of impacts, particularly in the realm of human exposures to chemicals. One investigation tackles the role of chemical pesticide exposures in the risk of developing Parkinson’s Disease. That study appeared in The FASEB (Federation of American Societies for Experimental Biology) Journal in April 2018. The other, published earlier this year in the journal Food and Chemical Toxicology, assesses potential negative health outcomes of long-term, low-dose exposure to admixtures of chemicals that more realistically represent real-life exposures than those typically created in a lab setting — one chemical at a time. A basic concept of the classical scientific method is that relationships among phenomena, whether causal or associative, can be evaluated only through the isolation and consideration of elements one at a time. A core tenet of toxicology is the dose-response notion: that the lesser or greater the dose or exposure, the smaller or larger, respectively, the organismic response will be. Paracelsus is credited for the terse summary, “The dose makes the poison.” Most research into the health and environmental risks of toxic chemicals in the materials stream […]

(Beyond Pesticides, June 7, 2018) Health Canada is proposing to phase out a number of uses of neonicotinoids in order to mitigate risks to pollinators. The agency has completed its review of clothianidin and thiamethoxam — two neonicotinoids that have been linked to pollinator decline and finds risks of concern for bees. However, these measures do not go as far as those recently made in the European Union, but further than label restrictions issued by the U.S. Environmental Protection Agency (EPA). Health Canada concluded its Pollinator Re-evaluation for clothianidin and thiamethoxam after examining hundreds of laboratory and outdoor field studies that examined the possible effects on bees from wide-ranging situations. The agency finds that uses of these neonicotinoids have “varying degrees of effects on bees,” and that some uses “may pose a risk of concern to bees.” However, instead of a complete ban of the neonicotinoids, the agency is proposing mitigation measures to minimize potential exposure to bees, which includes the phase-out of many uses and certain additional product label statements. Clothianidin will see a phase-out of the following uses: Foliar application to orchard trees and strawberries, and Foliar application to municipal, industrial and residential turf sites. There will also […]

(Beyond Pesticides, June 6, 2018) By the close of 2018, three top neonicotinoid (neonic) pesticides, linked to the worldwide decline in bee populations, will be banned for outdoor use in the European Union (EU), based on the General Court of the European Union’s (GCEU) ruling last month. The GCEU, the equivalent of the U.S. Supreme Court, ruled in favor of taking precautionary action to protect pollinators from clothianidin, imidacloprid, and thiamethoxam. This ruling allows for the limited use of neonic-treated seeds grown in permanent greenhouses where contact with bees is not expected. In its lawsuit, multinational seed and chemical companies, Syngenta and Bayer –manufacturers of the neonics in question– argued unsuccessfully that the pesticides do not necessarily harm bees if farmers use them according to label instructions. Syngenta also sought compensation of approximately $435 million to offset market losses resulting from the ban, but that, too, was denied. In rejecting the arguments of Syngenta and Bayer, the high court aligned itself with the European Food Safety Authority (EFSA) and its assessment of the harm caused by the widely used pesticides. EFSA’s updated assessment, released in February of this year, provided convincing evidence that neonics represent a risk to wild bees and […]

(Beyond Pesticides, May 25, 2018) The results of a pilot study conducted by an international team of researchers finds that exposure to the herbicide glyphosate results in adverse health effects at levels below those regulators deem “safe” or acceptable. These results represent the first phase of a Global Glyphosate Study based at the Ramazzini Institute in Bologna, Italy, in coordination with the University of Bologna, the Italian National Institute of Health, George Washington University, and the Icahn School of Medicine at Mount Sinai, NY. Researchers are aiming to provide a truly independent, comprehensive evaluation of the risks posed by glyphosate-based herbicides. The pilot study, available now on the research team’s website and later this month in the journal Environmental Health, focused on generating data on how glyphosate effects early-life stages of development. A three-month study on rats, used as a surrogate for human development until 18, exposed the animals to both technical grade glyphosate and the formulated herbicide Roundup. Rats ingested 1.75 miligrams of glyphosate or Roundup per kilogram of body weight each day from the womb until 13 weeks after weening. This is the chronic reference dose used by the U.S. Environmental Protection Agency, and an exposure rate at which the […]