(Beyond Pesticides, October 28, 2020) This month the U.S. Environmental Protection Agency (EPA) finalized decisions allowing continued use of a range of highly toxic pesticides, including the herbicide paraquat, and the synthetic pyrethroid class of insecticides. The move has been met with stinging criticism from the health and environmental community, but the decisions come as no surprise. Continued allowance of hazardous pesticides is a result of a weak law, lax regulations, and an administration that has consistently refused to follow even deficient protections. “The EPA’s pesticide office has sunk to a despicable new low in allowing farmworkers, small children and the environment to be sacrificial pawns in the profit schemes of its friends in the pesticide industry,” said Nathan Donley, PhD, senior scientist at Center for Biological Diversity. “In rushing to reapprove these deadly chemicals, it’s ignored its own scientists and independent researchers, refused to protect human health and the environment, and shown itself to be the panting lapdog of a morally bankrupt industry.” EPA reregistered paraquat despite overwhelming evidence that the chemical cannot be used without ‘unreasonable adverse effects on the environment’ — the lackluster standard in federal pesticide law to which the agency is required to regulate a […]

(Beyond Pesticides, October 27, 2020) The insecticide fipronil is more toxic to aquatic insects than previously thought, often present in U.S. waterways, and can trigger trophic cascades that disrupt entire aquatic ecosystems, finds new research published by the U.S. Geological  Survey (USGS). The data have important implications for waterways throughout the country, but particularly in the Southeast U.S. where the chemical was found at hazardous levels in over half of sampled steams. Despite the high quality of the findings by a U.S. government agency, pesticide regulators at the U.S. Environmental Protection Agency (EPA) do not adequately consider ecosystem-level effects when determining whether to register a pesticide. As a result, without public pressure on the agency, it is unlikely it will follow the science and take the action necessary to rein in use and safeguard the environment. Fipronil is a systemic pesticide that can travel through plant tissues and be expressed in its pollen, nectar, and dew droplets. Due to its systemic properties and similar toxicity profile, it is often targeted for restriction alongside the notorious neonicotinoid class of insecticides. Although fipronil is equally concerning, there is less data on the range of harm the chemical may cause. To better understand […]

(Beyond Pesticides, October 22, 2020) Prolonged dermal (skin) exposure to hazardous disinfectants, via handling and/or residue on surfaces, can induce the risk of adverse skin reactions (i.e., inflammation, burns, necrosis), according to a novel review analysis published in Clinics in Dermatology. Researchers of the review, “Dermatologic reactions to disinfectant use during the COVID-19 pandemic,” examine skin reactions associated with dermal exposure to various disinfectants approved for use against COVID-19 by the European Chemical Agency (ECA) and the U.S. Environmental Protection Agency (EPA). The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) classifies disinfectants as pesticides, so it is up to the states to delegate training, registration, and enforcement. Many states enforce pesticide training that allows professional applicators to learn how to handle, apply, and store pesticides properly. However, many of these same states do not have professional training for disinfectant use, especially wide-scale applications. Consequently, disinfectant applications are now more pervasive than ever, especially as school reopenings ensues. Considering failure to “Comply with Labeling and Permit Conditions” was the most common pesticide use violation of 2018, according to the California Department of Pesticide Regulations (DPR), advocates are urging global leaders to recognize the potential impacts that frivolous disinfectant use can have on […]

(Beyond Pesticides, October 15, 2020) A review of scientific literature on the correlation between respiratory diseases and pesticides exposure—published in the journal Annals of Agricultural and Environmental Medicine (AAEM), “Influence of pesticides on respiratory pathology—a literature review”—finds that exposure to pesticides increases incidents of respiratory pathologies (i.e., asthma, lung cancer, and chronic obstructive pulmonary disease [COPD]—or chronic bronchitis). The review by researchers at the Iuliu Hatieganu’ University of Medicine and Pharmacy Cluj-Napoca, Cluj-Napoca, Romania, looks at how pesticide exposure adversely propagates and reinforces respiratory diseases in humans. This review highlights the significance of evaluating how pesticide exposure impacts respiratory function, especially since contact with pesticides can happen at any point in the production, transportation preparation, or application treatment process. Researchers in the study note, “Knowing and recognizing these respiratory health problems of farmers and their families, and also of [pesticide] manipulators/retailers, are essential for early diagnosis, appropriate treatment, and preventive measures.” This study results are critically important at a time when exposure to respiratory toxicants increases vulnerability to Covid-19, which attacks the respiratory system, among other organic systems. The respiratory system is essential to human survival, regulating gas exchange (oxygen-carbon dioxide) in the body to balance acid and base tissue cells for normal […]

(Beyond Pesticides, October 9, 2020) A new study demonstrates that emerging “novel” insecticides can cause significant, sublethal harm to beneficial organisms at typical “real life” exposure levels. As neonicotinoid insecticides have come under fire for their terrible impacts on a broad variety of beneficial insects — including their major contributions to the decline of critical pollinators — more such “novel” pesticides are being brought to market in response. The study results, the co-authors say, “confirm that bans on neonicotinoid use will only protect beneficial insects if paired with significant changes to the agrochemical regulatory process. A failure to modify the regulatory process will result in a continued decline of beneficial insects and the ecosystem services on which global food production relies.” Beyond Pesticides would add that the study outcome points, yet again, to the grave recklessness of the pervasive “addiction” to chemical pesticides in agriculture. The solution to this chemical morass is known, doable, and scalable: a transition to organic, regenerative agricultural practices that get everyone off the “toxic treadmill.” Neonicotinoid pesticides (neonics) are the class of chemical pesticides most commonly used worldwide, both on crops and as seed treatments. They are systemic, meaning they infiltrate all tissues of a […]

(Beyond Pesticides, September 30, 2020) Low doses of neonicotinoid (neonic) insecticides are known to disrupt insect learning and behavior, but new science is providing a better understanding of how these effects manifest at a cellular level. Published in the Proceedings of the National Academy of Sciences, this study finds that the neonic imidacloprid binds to brain receptors, triggering oxidative stress, reducing energy levels, and causing neurodegeneration. “Although many studies have shown that low doses of insecticides can affect insect behavior, they have not uncovered whether insecticides trigger changes at the cellular and molecular levels,” said lead author Felipe Martelli, PhD, of Monash University in Melbourne, Australia. “The goal of this work was to have a better understanding of the effects of low doses of the common insecticide imidacloprid at the cellular, physiological and behavioral levels.” Researchers used the fruit fly Drosophilia melanogaster, a common experimental organism, as it contains a number of nicotinic acetylchloline receptors, the primary site of action for imidaclorpid. The neonic binds to these receptors, which regulate a number of physiological processes, such muscle contraction. Binding closes these channels, leading to the range of harm researchers observed through their study. Larval fuit flies were exposed to imidacloprid […]

(Beyond Pesticides, September 18, 2020) In late August, Consumer Reports magazine (CR) issued a report titled, “Stop Eating Pesticides,” which offers consumers a rating system CR developed and employed to help them “get the health benefits from fruits and vegetables while minimizing [the] risk from toxic chemicals.” In addition to providing its analysis and ratings of the pesticide risk of a variety of produce items, CR recommends eating organically grown and raised foods whenever possible. It also makes a host of recommendations on federal pesticide policies and emphasizes the importance of maintaining the integrity of the National Organic Standards (of the USDA-housed National Organic Program). Beyond Pesticides appreciates that this mainstream publication has arrived at many shared, science-based assessments of the risks of pesticides. That said, a wholesale transition to organic and regenerative agriculture — rather than making the public figure out which fruits and vegetables are “safer” or “less safe” — is the real answer to the health risks of pesticides in the food supply, according to Beyond Pesticides. The CR analysis used data from the U.S. Department of Agriculture’s (USDA’s) Pesticide Data Program for 2014–2018. Those pesticide residue data were compiled from tests of approximately 450 pesticides across 24,000 […]

(Beyond Pesticides, September 7, 2020) On Labor Day during this coronavirus pandemic, it is especially appropriate that we thank all essential workers—but thanks are not enough. We must redouble our efforts to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color. As the commentary in New York Magazine by Sarah Jones states, “[T]okens of appreciation are just that: tokens, which signal nothing deeper than gratitude. That doesn’t pay anyone’s rent.” And, all our gratitude does not protect anyone’s health. Nobody should have to risk their health for a job. As we as a nation recognize that systemic change is needed to fight racial and economic injustice, we are faced with questions that go to the core of our society—the distribution of wealth, a livable wage, investment in and access to education and health care, and an environment that sustains life. It could be said that an environmental organization, like Beyond Pesticides, that works on environmental, health, and agriculture and land management issues should “stay in its lane” and not delve into broader issues that address our social and economic structure. However, the events of the […]

(Beyond Pesticides, September 4, 2020) When pesticide drift is investigated, it is most often drift from agricultural fields that is examined. A new study shows that off-target drift of pesticides from greenhouses is also a reality. This research deduced such drift of organophosphate and carbamate pesticides from crop applications done in Ecuadoran floriculture greenhouses by evaluating the acetylcholinesterase enzyme (AChE) activity, necessary to the transmission of nerve impulses, in children residing nearby. The team finds that children living in homes near greenhouses in which these insecticides (widely recognized as cholinesterase inhibitors) are used exhibit reduced activity of this enzyme and abnormal functioning of the nervous system. Beyond Pesticides has monitored the pesticide drift issue intensively, and has long advocated for far better protections for farmworkers. This new information connects those issues, and expands the “drift” concerns to include risks to people working in greenhouses, and to those, especially children, who happen to live near greenhouse-type structures in which these toxic chemicals are used. The study evaluates data during three separate periods (2008, April 2016, and July–October 2016) on 623 children, aged 4–17, living in floricultural communities in Ecuador. The research is part of the study of the Secondary Exposure to Pesticides […]

(Beyond Pesticides, August 26, 2020) Neonicotinoid insecticides damage the health of shrimp and oysters, according to two (1, 2) new studies published by Australian researchers. Although this class of chemicals is best known for its hazardous impacts on pollinator populations, it is becoming increasingly clear that the entire food chain is at risk from continued neonicotinoid use. This study builds on an already established body of literature showing these systemic chemicals poison waterways. Researchers began by collecting samples of shrimp and oysters from growers along the coast, and acclimating the species to laboratory conditions. Both collections were separated into different test groups. Oysters where exposed in their tanks to various concentrations of the neonicotinoid imidacloprid. Shrimp were exposed to imidacloprid through two methods: in their feed, and in their tanks. Each separate test group was further separated into high and low exposures. A control group that did not receive any pesticide exposure was also established in each experiment. For the oyster populations, scientists found a range of negative effects. Imidacloprid inhibits the proper functioning of the enzyme acetylcholinesterase, a well-known impact of many pesticides that results in damage to the nervous system. Detoxification mechanisms are activated, and changes are observed […]

(Beyond Pesticides, August 11, 2020) Petitioners who mounted a legal challenge to the Environmental Protection Agency’s (EPA’s) registration of Enlist Duo, a relatively new and highly toxic pesticide product, recently learned of a mixed decision from the U.S. Ninth Circuit Court of Appeals in the case. The good news is that Judge Ryan D. Nelson, writing the opinion for the court, found that EPA, in registering the herbicide Enlist Duo, had failed to protect monarch butterflies, which are under consideration as a threatened species under the Endangered Species Act (ESA). On the other and disturbing hand, the court concluded that EPA registration of the product was otherwise lawful — which means that this toxic compound will for now remain on the market. As one of the plaintiffs in the case, Beyond Pesticides is adamant that this product should not be registered for use by EPA. George Kimbrell, Legal Director of Center for Food Safety and Lead Counsel for the plaintiffs, commented on the decision in the organization’s July 22 press release on the decision: “The panel majority’s unprecedented decision is contrary to controlling law and established science, and Center for Food Safety is analyzing all legal options, including seeking a full […]

(Beyond Pesticides, August 3, 2020) The effects of pesticide use are important, yet ignored, factors affecting people of color (POC) who face elevated risk from Covid-19 as essential workers, as family members of those workers, and because of the additional or cumulative risk that pesticides pose. As a part of this deadly combination, exposure to pesticides occurs at work, in community parks, schools and playing fields, and through food residues. EPA is ignoring the real hazards resulting from a combination of exposures that is reflected in the statistics that have emerged—with farmworkers suffering a rate of coronavirus five times higher and landscapers three times higher than community rates. Why is this the case? Because pesticide exposure weakens the respiratory, immune, and nervous system and makes those exposed more susceptible to the coronavirus.  EPA has the power to immediately, on an emergency basis, adjust allowable pesticide use and exposure, recognizing that we have alternative practices and products to meet food production and landscaping needs. Tell Congress to require EPA to examine the contribution of pesticide exposure to Covid-19 and protect those at greatest risk, people of color. Farmworkers and landscapers have been deemed essential employees during the coronavirus outbreak, but without mandated […]

(Beyond Pesticides, July 27, 2020) Evian bottled water, produced by the French company Danone, is supposed to be so pure that scientists will calibrate their measuring devices with it. But new data from Swiss researchers finds it to be contaminated with a toxic fungicide. “The fact that even the Evian springs in the French Alps, which are hardly affected by humans, contain pesticide residues is alarming and shows the far too careless handling of these substances,” Roman Wiget, president of the international drinking water association AWBR told the German-language Swiss weekly. The answer is not to simply ban another toxic pesticide, only to be followed by another toxic pesticide, but foundational changes to agriculture and land management with a shift to organic practices.  Tell Evian to protect water quality and the integrity of its purity claim by prominently supporting a worldwide shift to organic agriculture and land management. Danone claims that the purity of Evian bottled water comes from its source in Cachat Spring at the base of the French Alps in the town of Évian-les-Bains, France, where it is “[p]rotected under a fortress of geological layers built by glaciers 30,000 years ago, it slowly travels through natural snowy, glacial […]

(Beyond Pesticides, June 22, 2020) In the latest issue of Pesticides and You, the quarterly journal of Beyond Pesticides, articles focus on the key issues of the day—a safe response to novel coronavirus (Covid-19) without toxic disinfectants, and confronting environmental racism in communities with campaigns to take toxic pesticides out of public parks. A Critical Moment in History In introducing the issue, Beyond Pesticides executive director, Jay Feldman, writes: “Nurturing and sustaining life is at the core of the environmental work going on in communities across the country. However, as the events of the past months have illustrated, if we are to ensure that our society and planet are sustainable, it will require the protection of those facing the greatest hazards and attention to the underlying disparities behind them.” “Stopping Systemic Environmental Racism in New York City Parks” Lead article, “Stopping Systemic Environmental Racism in New York City Parks,” focuses on the  report, Poison Parks, written by The Black Institute in January, documents New York City public spaces in low-income people of color neighborhoods being sprayed with the weed killer glyphosate (Roundup) at significantly higher rates than other parts of the city. The report notes, “Minority and low-income communities suffer […]

(Beyond Pesticides, July 16, 2020) Long-term exposure to sublethal (low-level) concentrations of the neonicotinoid in soil negatively affects the health and behavioral development of black garden ants (Lasius niger) colonies, according to a study published in Communications Biology by scientists at the University of Bern, Switzerland. Ants are one of the most biologically significant insects in the soil ecosystem, acting as ecosystem engineers. Their burrowing behavior aerates the soil, allowing oxygen and water to penetrate down to plant roots. Additionally, ants increase soil nutrient levels by importing and accumulating organic material like food and feces, thus enhancing nutrient cycling. Like many other insects, ants are unfortunate victims of the global insect apocalypse or population decline, and much research attributes the recent decline to several, including pesticide exposure. Broad-spectrum pesticides, like neonicotinoids, indiscriminately kill pests and nontarget organisms alike, as their ubiquitous use contaminates soils, even in untreated areas. This study highlights the necessity of rethinking chemical pest management, developing sustainable agricultural practices that reduce the use of agrochemicals, like pesticides, to prevent permanent environmental ecosystem damage. Researchers in the study note, “To prevent irreparable damages to functioning ecosystems, [we] suggest to either fully incorporate long-term effects in risk assessment schemes, or to make a shift […]

(Beyond Pesticides, June 29, 2020) Bayer’s Monsanto is requesting non-regulated status for corn that will increase the use of drift-prone and toxic herbicides. This means that the planting of a new genetically engineered (GE) variety of corn, which requires substantial weed killer use, will not be restricted in any way. The syndrome of ‘more-corn, more-pesticides, more-poisoning, more-contamination’ must stop—as we effect an urgent systemic transformation to productive and profitable organic production practices. Because USDA is proposing to allow a new herbicide-dependent crop under the Plant Protection Act, the agency must, but does not, consider the adverse impacts associated with the production practices on other plants and the effects on the soil in which they are grown. Business as usual is not an option for a livable future. Sign the petition. Tell USDA we don’t need more use of 2,4-D, Dicamba, and other toxic herbicides associated with the planting of new GE corn. Bayer-Monsanto has developed multi-herbicide tolerant MON 87429 maize, which is tolerant to the herbicides 2,4-D, dicamba, glyphosate, glufosinate, and aryloxyphenoxypropionate (AOPP) acetyl coenzyme A carboxylase (ACCase) inhibitors (so-called “FOP” herbicides, such as quizalofop). Now the company wants this corn to be deregulated—allowing it to be planted and the herbicides […]

(Beyond Pesticides, June 23, 2020) Next-generation systemic insecticides, billed by the agrichemical industry as “safer for bees” than neonicotinoids, have been found to stress and kill honey bees. As reported, a study by researchers at Oregon State University in the journal PLOS One, sulfoxaflor and flupyradifurone (in the products Transform and Sivanto, respectively) were found to increase apoptosis (cell death) and increase oxidative stress in exposed honey bees. The study indicates that, “With the recent Environmental Protection Agency (EPA) approval for use of both flupyradifurone and sulfoxaflor, and with the growing concern regarding pollinator health, it is important to better understand any potential negative impacts (especially sub-lethal) of these pesticides on bees.” However, this statement begs the question ‘why these two new bee-toxic pesticide were approved by EPA in the first place.’ This process is familiar and frustrating to those who continue to fight against the decline of pollinators: the chemical industry introduces and EPA approves new toxic pesticides marketed as “safer” to the specific problem caused by its older products, only to find out through independent and academic research that the problem is not solved in the least. Researchers conducted two exposure assessments: one six-hour long study, and another […]

(Beyond Pesticides, June 22, 2020) In the wake of the national groundswell for equity and justice in the face of rampant inequality and police brutality against people of color, we acknowledge, during Pollinator Week, holistic actions are needed to solve systemic societal problems that cause racial disparities. Those fighting for environmental justice understand that the harms inflicted by toxic chemical production and use cause disproportionate adverse effects on people of color—from fenceline communities near chemical production plants, to the hazardous and inhumane working conditions in agricultural fields, to the elevated risk factors for black and brown people from toxic pesticide exposure patterns.  Pollinator Week reminds us that we must nurture the ecosystem, which we depend on for life, with a fierce commitment to its inhabitants and a focus on those at highest risk. Therefore, this week is a time to renew our commitment to environmental justice and seek the adoption of policies and practices in our communities, and across the nation and the world, that recognize the urgency to address the disproportionate harm inflicted by toxic pesticide use.  TAKE ACTION! Here are three things you can do today. Protect Low-Income and People of Color Communities—As The Black Institute in New […]

(Beyond Pesticides, June 17, 2020) The June 3 decision in a high-profile “dicamba case” — against the U.S. Environmental Protection Agency (EPA) and for the plaintiffs, a coalition of conservation groups — was huge news in environmental advocacy, agriculture, and agrochemical circles. The federal Ninth Circuit Court of Appeals vacated EPA’s 2018 conditional registration of three dicamba weed killer products for use on an estimated 60 million acres of DT (dicamba-tolerant through genetic modification/engineering) soybeans and cotton. There is, however, a related issue that accompanies this and many other pesticide cases. When EPA decides to cancel or otherwise proscribe use of a pesticide (usually as a result of its demonstrated toxicity and/or damage during litigation), the agency will often allow pesticide manufacturers to continue to sell off “existing stocks” of a pesticide, or growers and applicators to continue to use whatever stock they have or can procure. Beyond Pesticides has opposed, covered, and litigated against this practice. To greenlight predictable harm is a violation of any recognized moral code, never mind of the agency’s mission — “to protect human health and the environment.” According to Beyond Pesticides, EPA should never permit continued use of a dangerous pesticide once that compound’s […]

(Beyond Pesticides, June 9, 2020) EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. These three states (and others) have received emergency exemptions for this use for the nine previous years and it must not be allowed for a tenth year. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses. Sign the Petition to EPA and Send a Letter to Your Congressional Representative and Senators: EPA Must Deny Routine “Emergency” Exemptions As a neocotinoid insecticide, dinotefuran presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack. Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, […]

(Beyond Pesticides, May 26, 2020) Across the pond, the European Commission (EC) has announced plans to protect biodiversity and build a more sustainable food system, and identified the reduction of pesticide use  and the expansion of organic agriculture as pillars of the scheme. The EC expects that the initiative, which will require EU member states’ endorsement, will advance progress on the EU goal of eliminating greenhouse gas emissions by 2050, given that 10% of emissions arise from the agricultural sector. The EC’s goals are important and laudable, but Beyond Pesticides is clear: reduction of pesticide use in service of them is not an adequate strategy to ensure long-term success. Genuine success requires the elimination of the use of synthetic chemical pesticides, fertilizers, and other toxic inputs, and the transition to agricultural and land management systems that work with nature, rather than fight against it. Regenerative, organic practices are the path to a livable future, according to Beyond Pesticides. The EC, which is the executive branch of the EU, expects its plan to reduce use of pesticides by 50% by 2030; reduce use of antimicrobial chemicals, including antibiotics, in fish and animal farming by 50%; dedicate a minimum of 25% of arable […]

(Beyond Pesticides, March 31, 2020) Adding to the widespread and problematic use of neonicotinoid pesticides as seed treatments, a recent study published in BioScience finds that there are significant knowledge gaps among some farmers about the seeds they are planting. The research indicates that those gaps contribute to underreporting of accurate data on the use of pesticide-coated (often with neonicotinoid pesticides) seeds — because farmers may not know what pesticides are on the seeds they plant. Pennsylvania State University reports on the study, in Phys.org, saying, “This lack of data may complicate efforts to evaluate the value of different pest management strategies, while also protecting human health and the environment.” Beyond Pesticides advocates for widespread adoption of organic, regenerative systems and practices that precludes the use of such pesticides.  The research was conducted by a team of scientist from around the U.S., led by Claudia Hitaj, PhD, of the Luxembourg Institute of Science and Technology, and former economist at USDA’s Economic Research Service. In the Phys.org coverage of the study, assistant professor of epidemiology and crop pathology at Penn State, Paul Esker, PhD, notes that this lack of farmer knowledge can lead to overuse of pesticides, which would increase the already considerable risks […]

(Beyond Pesticides, March 27, 2020) Faced with the COVID-19 (coronavirus) threat, there is tremendous pressure to use toxic disinfectants, despite the availability of safer products. In fact, while the Centers for Disease Control and Prevention (CDC) is recommending 70% alcohol for surface disinfection, the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs is advising the use of unnecessarily toxic substances, and reducing standards that govern their allowance on the market. EPA’s pesticide program allowed 70 new disinfectants yesterday, at the same time that the agency overall announced that it is waiving enforcement of environmental standards during the coronavirus outbreak—a devastating blow to public health and environmental protection. Beyond Pesticides, in its factsheet, Protecting Yourself from COVID-19 (coronavirus) without Toxic Sanitizers and Disinfectants, says, “Fight the coronavirus with common sense prevention and safer disinfection products. Avoid products that increase vulnerability to respiratory problems.” (See the factsheet below.) To some extent, the expanded allowance of disinfection products on top of the 281 disinfectants previously permitted has been made possible by relaxing oversight on so-called “inert” or other ingredients that are not disclosed on product labels and often highly toxic. The agency says it is allowing the use of these “inerts” with “no […]