(Beyond Pesticides, February 4, 2020) It was a good day for Bayer/Monsanto. The chemical company’s weed killer glyphosate and its neonicotinoid insecticides are set for reapproval by the U.S. Environmental Protection Agency (EPA), according to interim decisions published last week. EPA reapproval of human carcinogens and chemicals contributing to the pollinator crisis is disappointing for health and environmental advocates, but not surprising to those watchdogging the agency during the current administration. “This is how a captured agency behaves,” said Beyond Pesticides community resource and policy director Drew Toher. “When EPA’s decision making repeatedly reflects the exact wishes of the chemical industry, public trust erodes, and we must look to new policy mechanisms that support the protection of health and the environment.”   On Glyphosate EPA’s glyphosate decision document glosses over the hazards of the chemical and is requiring very few new safety measures when using the herbicide. These measures are focused on agriculture, including minor label changes around drift, guidelines on resistance management, and a label advisory indicating the chemical is toxic to plants and may adversely impact pollinator foraging. The restrictions fail to match those proposed by Health Canada in 2015, which included buffer zones and restricted entry intervals. […]

(Beyond Pesticides, January 28, 2020) The practice of coating seeds with insecticides, now widely adopted as a result of the agrichemical industry, has created increasingly toxic conditions for pollinators foraging on US cropland, finds a study published in Scientific Reports by Penn State University scientists. The data finds that even as overall volume of insecticide use has decreased, the total “bee toxic load” – a term branded by researchers – has increased markedly due in large part to the use of hazardous seed coatings. The switch from one toxic chemical to another is indicative of a chemically-driven agricultural system that, in order to reverse insect, pollinator and bird declines, must undergo rapid changes over the next several decades. Researchers used information from multiple US databases to determine regional patterns in pesticide use and corresponding toxicity loads to pollinators. Thus the term “bee toxic load” was determined by combining the area of land where insecticides were applied with the total toxicity of the particular insecticide used. To compare the impact of changes in the mode of action of the insecticides used, toxicity data was separated between oral and contact toxicity.    Findings indicate that from 1997-2012, contact bee toxic load remained […]

(Beyond Pesticides, January 28, 2020) In more bad news from the insect world, recent research reveals a precipitous decline in numbers of mayflies in territories where they have been historically abundant. Reported by National Geographic and published in the Proceedings of the National Academy of Sciences, the research finds that in the Northern Mississippi River Basin, seasonal emergence of burrowing mayfly (genus Hexagenia) adults declined by 52% from 2012 to 2019; in the Western Lake Erie Basin, from 2015 to 2019, the reduction was a shocking 84%. Neonicotinoid insecticides are a significant factor in this decline because mayflies are exquisitely vulnerable to their impacts, even at very low exposure levels. Ephemeroptera to entomologists — and “mayflies” to the rest of us — are a keystone species, one on which other species in an ecosystem are very dependent, and without which, the ecosystem would undergo drastic change. The Latinate name is apt: mayflies are among the most short-lived organisms, with lifespans across the 2,000+ known species lasting from five minutes to one day to a few weeks. Like damselflies and dragonflies, members of an ancient group of insects, the 600 North American species, as do their global kin, make optimal reproductive […]

(Beyond Pesticides, January 17, 2020) In Brussels, the European Commission (EC) has just decided not to renew approval of the neonicotinoid pesticide thiacloprid, citing both environmental and health concerns related to use of and exposure to the pesticide. The decision was approved by a majority of European Union (EU) governments last fall, after the EC had made the proposal to them. The EC based that proposal on findings of the European Food Safety Authority (EFSA) published in January 2019, which highlighted concerns about toxicity to humans and high concentrations in groundwater. European Commissioner for Health and Food Safety Stella Kyriakides commented, “There are environmental concerns related to the use of this pesticide, particularly its impact on groundwater, but also related to human health, in reproductive toxicity.” The current EU use approval for thiacloprid products expires on April 30, 2020. The EC decision — functionally, a ban — means that farmers will need to turn to other means to deal with the primary thiacloprid targets in agriculture, aphids and whiteflies. Beyond Pesticides and many organic agricultural resources advocate for widespread adoption of organic, regenerative systems and practices. Such systems may include management features such as mechanical and biological controls, trap crops, natural […]

(Beyond Pesticides, December 5, 2019) Five years after three neonicotinoids were banned for use on bee-attractive crops in the EU, researchers found that these bee-toxic chemicals are contaminating soils and poisoning the nectar of oilseed rape (canola). The results of this research point to an immediate need to end the use of persistent environmental contaminants and promote organic practices. Researchers set out to determine whether the EU moratorium eliminated the risk for bees that forage on oilseed rape nectar. They tested for imidacloprid, thiamethoxam, and clothianidin residues in the nectar of winter-sown oilseed rape in from 291 oilseed rape fields in western France for five years following the EU moratorium (2014-2018). Results show all three neonicotinoids were present at least once in the study’s time period. Imidacloprid was detected every year with “no clear declining trend,” though its prevalence fluctuated widely between years. Two samples from 2016 show residues that are five times the expected maximum concentration in nectar of a plant directly treated with imidacloprid. Residue levels in the nectar depend on soil type and increase with rainfall. The researchers put forth in their discussion that the imidacloprid contamination may likely be caused by runoff from neighboring, treated plants. […]

(Beyond Pesticides, November 22, 2019) The potential exit of the United Kingdom from the European Union (EU) — aka “Brexit” — may portend greater pesticide use and exposures, according to a report from the Soil Association and the Pesticide Action Network UK. As covered by The Guardian, the report’s prediction points to uncertainty, despite reassurances from the United Kingdom (UK) government, about what regulatory standards will actually be in effect if and when Brexit occurs. The report also highlights the under-regulated issue identified in the report’s title — The Cocktail Effect — synergistic impacts of exposures to multiple synthetic pesticide compounds. Beyond cessation of pesticide use, Beyond Pesticides advocates for more rigorous review of synergistic effects of pesticides in the U.S. In the UK, environmental and health advocates are voicing worries that the government’s reassurances that existing standards will be maintained after a Brexit is unconvincing. UK Environment Secretary Michael Gove insists that environmental standards would be enhanced following a UK exit from the EU. But advocates are concerned about potential loopholes that could allow farmers to use more pesticides on crops than the EU regulations permit, and could greenlight the import of foodstuffs with greater amounts of pesticide residue than […]

(Beyond Pesticides, November 21, 2019) The City of South Miami last month became the first organic community in the state of Florida, passing a landmark ordinance limiting hazardous pesticide use on public property in favor of safer practices. An increasing number of communities in the state have begun to restrict the use of toxic pesticides, with North Miami passing an Integrated Pest Management plan last year, and Miami, Stuart, and Key West banning glyphosate. South Miami, under the direction of Mayor Phillip Stoddard, PhD, professor of Biological Science at Florida International University, has a history of leading the state in the protection of public health and the environment. In 2014, the City Commission voted to declare all of South Miami a wildlife sanctuary, thereby restricting the use of highly toxic mosquito adulticides. The move protected populations of the state’s rare and endemic wildlife, such as the Florida bonneted bat, which begins to feed on mosquitoes in the spring at the same time spraying usually begins. The City’s move toward organic landscaping was borne out of two years of successful trials by city workers and contractors. In 2017, its landscaping request for proposals (RFP) required that, in addition to practices intended […]

(Beyond Pesticides, November 19, 2019) Legislatures in two New England states continue to deliberate environmental and public health measures aimed at protecting pollinators, safeguarding schoolchildren, and eliminating toxic pesticides. In Massachusetts, dozens of advocates packed a crowded hearing room for a slate of 16 bills before the Joint Committee on Environment, Natural Resources and Agriculture. In New Hampshire, advocates were dismayed that, after a successful vote in subcommittee, the House Environment and Agriculture committee voted to weaken HB646, the Saving New Hampshire’s Pollinators Act, into an interim study measure. The stalling of NH’s HB646 came as the pesticide industry, state agencies, and the state agricultural commissioner placed significant pressure on lawmakers, forwarding the idea that the science on the dangers neonicotinoids pose to pollinators is too complex for lawmakers to understand. Local advocate Fawn Gaudet of Save Our NH Pollinator Coalition responded with a passionate, science-based editorial in the Concord Monitor underlining the need for urgent action. However, arguments from pesticide industry proponents sowed the seeds of doubt, deferring to the current Environmental Protection Agency, despite its repeated failures to step up and protect pollinators. An amendment weakening the legislation was introduced by State Representative Peter Bixby (D-Strafford), but not […]

(Beyond Pesticides, November 15, 2019) The Endangered Species Coalition has released its newest annual report on the 10 U.S. species most threatened by pesticide use, Poisoned: 10 American species imperiled by pesticides. Produced with seven of its member groups, the coalition introduces the report by noting, “Our world is awash in chemicals. We’re particularly addicted to pesticides.” It points to well-known harms, and identifies the exacerbating factors of both climate change and the Trump administration, the latter of which “denies the reality of climate change and has dramatically changed how the Endangered Species Act (ESA) is implemented, leaving vulnerable species at far greater risk.” The introduction ends on a somewhat encouraging tone, saying that previous administrations have supported record growth in organic farming — the solution to pesticides harms that Beyond Pesticides has long endorsed — and that “any administration has the power to get us back on track and away from pesticides.” Impacts on wildlife linked to pesticide exposures — including mammals, bees and other pollinators, fish and other aquatic organisms, birds, and the biota within soil — have been well documented by Beyond Pesticides, and include reproductive, neurological, renal, hepatic, endocrine disruptive, and developmental anomalies, as well as […]

(Beyond Pesticides, November 6, 2019) Between 1981 and 1992, Japanese fishers annually reaped an average of 240 tons of smelt from Lake Shinji. After 1993, their nets turned up about 22 tons – a 90% drop in their yield. Eel catches dropped by 74%. New research, published in the journal Science, implicates the introduction of neonicotinoids to the abutting watershed in the decimation of these aquatic populations, stating, “In Lake Shinji, neonicotinoids indirectly reduced fishery yields by decreasing the abundance of invertebrates that serve as food for smelt and eels.” Researchers analyzed decades of data on zooplankton, midges, and water quality as well as annual fishery yields of eel and smelt spanning from 1981-2014. Zooplankton biomass, an important fodder for smelt, plummeted from 108 µg C L−1 to 18.2 µg C L−1 after imidacloprid was introduced for use on rice paddies in May of 1993. Midges (Cyathura muromiensis) that were found in abundance in 1982 totally disappeared from all sample sites by 2016. While the smelt and eel populations drastically declined, the authors note that icefish, which eat a more diversified diet, were not impacted. Though researchers considered the possibilities of other influencing factors such as invasive species, hypoxia, and […]

(Beyond Pesticides, November 1, 2019) The recently published report Pesticide Residue Monitoring Program Fiscal Year 2017 Pesticide Report, from the U.S. Food & Drug Administration (FDA), provides data on the levels of pesticide residues that show up on the foods U.S. consumers eat. The report adds fuel to public concern about contamination of the food supply, and to discussion in the scientific and advocacy communities about what is and is not safe for human health. It is also a sobering reminder of just how much chemical-intensive agriculture depends on pesticides, whether insecticides, herbicides, or fungicides. This FDA report has been prepared annually since 1987 and is based on the agency’s Pesticide Residue Monitoring Program, which evaluates both domestically produced and imported human food samples, including fruit, vegetable, and animal products. As the report notes, “Three federal government agencies share responsibility for the regulation and oversight of pesticide chemical residues in or on food. The U.S. Environmental Protection Agency (EPA) registers (i.e., approves) the use of pesticides and establishes tolerances for pesticide chemical residues in or on food resulting from the use of the pesticides. Tolerances are the EPA-established maximum residue levels (MRLs) of a specific pesticide chemical that is permitted in […]

(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 17, 2019) The poisonous farm fields migratory birds forage on during their journey reduce their weight, delay their travel, and ultimately jeopardize their survival, according to new research published in the journal Science.  Like their effects on pollinator populations, neonicotinoid insecticides generally are not killing migratory songbirds outright, but instead precipitating a cascade of sublethal impacts that reduces their fitness in the wild. As the authors told Environmental Health News, the study is a call not simply to ban neonics or one class of chemical, but to change the entire farming system toward more sustainable bird and bee-friendly practices. Using new technology, this study was not only able to dose wild-caught songbirds (white-crowned sparrows), but also track their migration route using automated telemetry. Apart from the control group that received no pesticide exposure, sparrows were treated at levels well below the median lethal dose (3% of the lethal dose in the ‘low’ exposure group and 10% within the ‘high’ exposure group), and permitted to continue on their migratory path. These are exposure amounts similar to a songbird accidentally ingesting a few treated seeds, according to the study. Within six hours, both the ‘low’ and ‘high’ exposure group […]

(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, August 15, 2019) An article in the journal Plos One, “An assessment of acute insecticide toxicity loading (AITL) of chemical pesticides used on agricultural land in the United States,” shows that recent shifts in insecticide use—from organophosphates and carbamates to synthetic pyrethroids and neonicotinoids—have made a large contribution to the ongoing insect apocalypse. This shift to insecticides that target insects based on both selective toxicity and delivery method occurs within a context of shrinking habitat and biodiversity. The study, by Michael DiBartolomeis, PhD, Susan Kegley, PhD, Pierre Mineau, PhD, Rosemarie Radford, and Kendra Klein, PhD, presents a measure of acute insecticide toxicity loading that incorporates acute toxicity, quantity used, and the rate at which the insecticide degrades. Goulson et al. applied a similar measure in Great Britain that did not incorporate the rate of degradation. Both studies use the median lethal dose (LD50) to honey bees as a measure of acute toxicity and calculate the potential number of bee deaths based on the number of lethal doses of various insecticides applied in the field. In both cases, researchers used toxicity estimates for honey bees because they are widely available. Other insects may be more or less sensitive. The […]

(Beyond Pesticides, August 9, 2019) A recent study, published in the Proceedings of the National Academy of Sciences, demonstrates a food chain vector for exposure of beneficial insects to neonicotinoid pesticides — the invasive mealybug, in this case. The finding may also be relevant for other phloem-feeding hemipterans, which can feed on neonicotinoid-contaminated plants and excrete so-called “honeydew” that is then consumed by beneficial insects. A primary “fix” for the decimation of insects and pollinators — caused chiefly by pesticide use, habitat destruction, and impacts of a rapidly changing climate — is, of course, the cessation of use of these toxic compounds in agriculture. The most common route of exposure of beneficial insects to neonicotinoids is through contaminated floral nectar and pollen. The discovery of this “honeydew” vector is important because it could potentially affect far more insects than nectar and pollen consumption, given that honeydew is more abundant, especially in agricultural fields. Pollinators such as honey bees, solitary bees, bumblebees, and even birds have been observed feeding on honeydew. Neonicotinoids represent more than 20% of the insecticides used worldwide; they are used on crops such as citrus, cotton, oilseed rape, soybean, fruits, potatoes, rice, corn, sunflowers (for seed), ornamentals, fruits, […]

(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, June 8, 2019) Scientists studying the precipitous decline in populations of monarch butterflies are searching for causes, and pesticide use is one of the factors under their (figurative) microscopes. Purdue University entomology professor Ian Kaplan, PhD and doctoral student Paola Olaya-Arenas recently turned their attention to a poorly studied potential factor — exposure during monarchs’ larval stage to non-target pesticides on their primary host plant and food source, common milkweed (Asclepias syriaca). In Frontiers in Ecology and Evolution, the researchers report finding evidence of 14 different agricultural pesticides on milkweed near Indiana farm fields, including neonicotinoids clothianidin and thiamethoxam, the pyrethroid deltamethrin, and imidacloprid in a few samples. The research team’s primary aim was to identify and measure the range of pesticides to which monarch caterpillars might be exposed, or which they might consume, on milkweed plants in agricultural landscapes. Secondarily, they hoped to learn how pesticide presence varies with distance between milkweed plants and nearby agricultural sites. In the subject Indiana environs, where corn and soybeans are dominant crops, the study found neonicotinoid residues on milkweed, particularly those of the active ingredients in clothianidin and thiamethoxam. They note, “Although seed treatment data are no longer reported for U.S. […]

(Beyond Pesticides, June 24, 2019) A study finds that the interaction of a common honey bee parasite with neonicotinoid insecticides causes 70% reductions in overwintering honey bee survival. These results help to explain the unsustainable honey bee colony losses observed in recent decades. Neonicotinoids (neonics) are a class of insecticides that share a common mode of action that affect the central nervous system of insects. Studies show that neonicotinic residues accumulate in pollen and nectar of treated plants, and, given their widespread use and known toxic effects, there is major concern that neonics play a major contributing role in pollinator declines. In the early 2000s, Colony Collapse Disorder (CCD) brought national attention to increased honey bee colony losses. During the same period that CCD and colony losses spiked, neonic prevalence skyrocketed, in large part due to the introduction of seed-delivered technologies. As of 2011, 34-44% of soybeans and 79-100% of maize hectares were preemptively treated with neonics. While CCD prevalence has decreased, colony loss rates (and systemic insecticide use) remain high. A 2018 national survey indicates that U.S. beekeepers currently experience an average annual colony mortality rate of 30.7%, double the pre-CCD baseline of 15% losses. In the present study, […]

(Beyond Pesticides, June 21, 2019) As Pollinator Week 2019 comes to a close, Beyond Pesticides is encouraging individuals to take steps in their backyard and community to Bee Protective of pollinator populations. The situation for pollinators and the insect word is dire, but there are a range of activities that can be taken in both the short and long term to shore up populations where you live. If you’re working towards positive change on pollinators, or simply want to know more about how to get involved, join the Pollinator Week #ProtectPollinators twitter chat today at 12 noon ET. ManageSafe Pest problems are a part of everyday life. But the first step in addressing them should never be reaching for a hazardous pesticide. To protect you and your family from pests while also protecting pollinators visit Beyond Pesticides Managesafe website.  Start by selecting the location of your pest problem – whether indoors or out, and click through to choose the pest in question. If the pest problem you’re dealing with isn’t listed there, reach out to Beyond Pesticides at [email protected] for one on one assistance. One of the biggest impacts we can make for the health of pollinators is to forgo […]

(Beyond Pesticides, June 19, 2019) To mark National Pollinator Week (June 17-23), more than 10,000 people across the country are joining to demand that Kroger (NYSE: KR) help stop the extreme decline of pollinators. Customers are delivering letters to stores asking the nation’s largest conventional grocery store to eliminate pollinator-toxic pesticides from its food supply chain and increase domestic organic food offerings to help stop the catastrophic decline of pollinators and other insects. Pollinators and other insects could go extinct within a century, threatening a “catastrophic collapse of nature’s ecosystems,” the first comprehensive global meta-analysis of insect decline states. This is largely due to the widespread use of neonicotinoids and other toxic insecticides in industrial agriculture. “Systemic neonicotinoid insecticides and the broad range of pesticides that harm people and pollinators have no place in our food supply,” said Drew Toher, community resource and policy director at Beyond Pesticides. “Kroger customers are asking the company to be part of the solution to the pollinator crisis by eliminating hazardous pesticides and expanding organic options.” “To avoid the ‘bee apocalypse’ it is critical that Kroger immediately commit to stop selling food with pollinator-toxic pesticides,” said Tiffany Finck-Haynes, pesticides and pollinators program manager at […]

(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, June 10, 2019) On May 20, U.S. Representative Nydia Velazquez, with 18 co-sponsors, introduced H.R. 2854, “To amend the National Wildlife Refuge System Administration Act of 1966 to prohibit the use of neonicotinoids in a National Wildlife Refuge, and for other purposes.” The bill follows an August 2018 Trump administration announcement that reversed a 2014 U.S. Fish and Wildlife Service (FWS) decision to ban neonicotinoid insecticides on National Wildlife Refuges. Tell members of Congress to protect biodiversity by co-sponsoring HR 2854, which reinstates the 2014 U.S. Fish and Wildlife Service ban on neonicotinoid pesticide use in wildlife refuges that was reversed by the Trump administration in 2018. The administration’s action threatens not only pollinators, but contributes to the attack on biodiversity worldwide. “These pollutants upset the delicate ecosystems of our Wildlife Refuges and they have no place in our public lands,” said Rep.Velázquez. “The ban’s revocation comes as mounting evidence suggests the chemical has damaging environmental effects on bees and other pollinators, undermining the national wildlife system,” she continued. In 2014, FWS announced that all National Wildlife Refuges would join in the phase-out of neonics (while also phasing out genetically engineered crops) by January 2016. FWS “determined that prophylactic use, such as […]