(Beyond Pesticides, February 1, 2013) The European Commission announced yesterday its position against the use of neonicotinoid insecticides, pushing nations within the European Union (EU) to impose a two year suspension on their use. The proposal, put forward at a meeting of the Standing Committee on the Food Chain and Animal Health, would restrict the application of neonicotinoids as granules, seed-treatment or spray, on crops that are attractive to bees, particularly, sunflowers, rapeseed, corn, cotton, and cereal crops. Environmental groups say that this decision should signal the way forward for the U.S. Environmental Protection Agency (EPA) to suspend neonicotinoids in the U.S. “It’s a great thing,” said New York beekeeper Jim Doan, “I’m hoping that the EPA follows in their footsteps. While I recognize our government works differently, it says something that the European government has recognized the overwhelming data on the impact of these pesticides.” The announcement comes on the heels of research conducted by the European Food Safety Authority (EFSA) which indicated that three neonicotinoid insecticides””imidacloprid, clothianidin, and thiamethoxam, produced by Switzerland’s Syngenta and Germany’s Bayer, pose an unacceptable hazards to honey bees. In its report released January 16th, EFSA concludes that systemic contamination of neonicotinoid-treated crops, neonicotinoid […]

(Beyond Pesticides, January 31, 2012) A new study finds that a mother’s exposure to pesticides before, during and after pregnancy may increase the risk of infant leukemia diagnosed before the age of two. Researchers in Brazil found that children are twice as likely to develop the rare cancers if their mothers were exposed three months before conception when compared to mothers who reported no exposures. A mother’s exposure at any time to the insecticide permethrin also raised the cancer risk for infants. The results support recommendations for women of reproductive age to minimize their pesticide exposure before and during pregnancy and while breastfeeding, and adds to the growing weight of evidence of the dangers of using synthetic pyrethroid pesticides. The study, entitled, “In utero pesticide exposure and leukemia in Brazilian children less than 2 years of age,” is published in Environmental Health Perspectives. Researchers asked mothers in Brazil about their pesticide exposure three months before pregnancy, while pregnant and three months after pregnancy when they were nursing. The women reported their home, work and agricultural contact with pesticides (at least once) between 1999 and 2007. Pesticide exposures from mothers of 252 children younger than two years old and diagnosed with […]

(Beyond Pesticides, January 29, 2013) A new study has discovered the anti-bacterial chemical triclosan and several of its toxic derivatives in sediment samples taken from freshwater lakes. Research published in the journal Environmental Science and Technology reveals the chemical to be present in increasing concentrations since it was first invented in the 1960’s. The results of this study put increased pressure on lawmakers and cosmetic companies to remove this chemical from consumer products. Beyond Pesticides and other groups, which have petitioned the U.S. Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) to remove triclosan from a vast array of consumer products, continues to urge cosmetic companies to take action on the chemical in the face of inadequate regulation to protect human health and the environment. Scientists tested  eight sediment samples from freshwater lakes across Minnesota, including Lake Superior. Bill Arnold, Ph.D.,  co-author of the study and professor at University of Minnesota notes, “We found that in all the lakes there’s triclosan in the sediment, and in general, the concentration increased from when triclosan was invented in 1964 to present day. And we also found there are seven other compounds that are derivatives or degradation products of […]

(Beyond Pesticides, January 28, 2013) Research published Thursday indicates that pesticides widely used on farms are highly toxic to frogs. Researcher Carsten Brühl, Ph.D., at the University of Koblenz-Landau in Germany called the results “alarming” with the potential for “large-scale effects” on amphibians. Two chemicals commonly used in orchards and on grains demonstrated a 100% mortality rate when researchers applied doses recommended on the label, raising serious concerns about the strength of pesticide regulations. The research builds on Brühl’s previous work on the ability of frogs to absorb pesticides through their porous skin, which is necessary for breathing underwater. More importantly, the study highlights the threats that pesticides post to biodiversity. Amphibians are considered the most threatened and rapidly declining vertebrate group, with more than a third of all amphibians listed in the International Union for Conservation of Nature and Natural Resources (IUCN) “Red List” of threatened species. The organization lists loss of habitat, climate change, and disease as the most serious threats to amphibian populations. The scientific community is increasingly recognizing the role of chemical pollutants in amphibian decline. Though sadly, regulatory agencies do not: pesticides are not even required to be tested on amphibians before the pesticide is […]

(Beyond Pesticides, January 24, 2013) Checks are now being sent to 1,085 community water systems across the U.S. in the final phase of a $105 million settlement with Syngenta, the largest manufacturer of the toxic weed killer atrazine. The class action settlement, City of Greenville v. Syngenta Crop Protection, Inc., Case No.: 3:10-cv-00188-JPG-PMF, stems from a lawsuit spanning eight years and is meant to help reimburse communities for past expenses associated with atrazine removal. “Science has been fighting an uphill battle against giant pesticide manufacturers like Syngenta who claim that a little weed killer in your drinking water won’t hurt you. Independent scientists now believe that even trace amounts can harm you and your children for generations to come,” the lead plaintiff’s lawyer Stephen M. Tillery told the media. Atrazine is used nationwide to kill broadleaf and grassy weeds, primarily in corn crops. A potent toxicant, it is the most prevalent herbicide found in Minnesota’s waters. It is widely applied in the midwestern states and has been found in the drinking water supplies in the Midwest at high levels. Researchers at the Centers for Disease Control (CDC) have determined that previous studies that assessed population-based exposure to atrazine were significantly […]

(Beyond Pesticides, January 23, 2013) A new federal report finds toxic contamination remains widespread in the Chesapeake Bay, with severe impacts in some places, which health and environmental advocates say lends support to their push in Maryland for legislative action on pesticides and other hazardous chemicals. In spite of some cleanup, the health of the Bay has not significantly improved. The report, “Technical Report on Toxic Contaminants in the Chesapeake Bay and its Watershed: Extent and Severity of Occurrence and Potential Biological Effects” is based on a review of integrated water-quality assessment reports from the jurisdictions in the Bay watershed (Delaware, Maryland, New York, Pennsylvania, Virginia, West Virginia, and Washington, D.C.), Federal and State reports, and articles in scientific journals. It notes that nearly three-fourths of the Bay’s tidal waters are “fully or partially impaired” by toxic chemicals, with people warned to limit fish consumption from certain areas. Contamination is severe in a handful of “hot spots” around the Bay, including Baltimore’s harbor, largely a legacy of past industrial and shipping activity. Previous reports have called on federal, state and local government to accelerate research into what threats chemical contamination may pose to the Bay, and to step up efforts […]

(Beyond Pesticides, January 22, 2013) The U.S. Environmental Protection Agency (EPA) recently faced tough questioning from the U.S. Court of Appeals for the Ninth Circuit over its decision to conditionally approve a pesticide product containing nanosilver as the active ingredient. The antimicrobial pesticide product, HeiQ AGS-20, contains microscopic particles of silver and has been applied to textiles such as clothes, blankets, and pillowcases, in an attempt to suppress odor and bacterial growth. The main argument in the Natural Resource Defense Council (NRDC) v. EPA lawsuit is that EPA was wrong  to assume that 3-year-olds would be the most vulnerable consumers. Instead, NRDC attorney Catherine Rahm of Washington argued that, “Infants are more likely than any other subgroup to chew on fabrics that could contain this pesticide.” In arguments over whether EPA lawfully granted conditional registration to HeiQ AGS-20, NRDC challenged EPA’s risk assessment for infants and children claiming the agency erred by assuming in its risk assessment that 3-year-olds would be the most vulnerable consumers. Up for debate is oral exposure to the product and whether 3-year-olds chew more aggressively than infants and produce more saliva, an important factor for extracting nanoparticles from products and becoming exposed. NRDC contends EPA’s […]

(Beyond Pesticides, January 18, 2013) Joining the list  of speakers at Beyond Pesticides’ 31st National Pesticide Forum are Tyrone Hayes, Ph.D., the biologist best known for his research on the effects of atrazine on frogs, and Isaac N. Pessah, Ph.D., the  Chair of the Department of Molecular Biosciences at the University of California, Davis School of Veterinary Medicine. The conference will focus on cutting edge public health science, building resilience in our food system and communities, and bringing ecosystems back to balance, and will incorporate regional issues such as water and food sovereignty in the Southwest. The National Forum provides an opportunity for grassroots advocates, scientists, and policy makers to interact and strategize on solutions that are protective of health and the environment. The 31st National Pesticide Forum, Sustainable Families, Farms and Food: Resilient communities through organic practices, will be held April 5-6, 2013 (Friday afternoon and all day Saturday) at the University of New Mexico in Albuquerque, NM. Registration information can be found in our online store. The conference is convened by Beyond Pesticides, La Montanita Coop, and the University of New Mexico Sustainability Studies Program, and co-sponsored by local, state and regional public health and environmental organizations, including […]

(Beyond Pesticides, January 17, 2013) The European Food Safety Authority (EFSA) yesterday presented its report which finds that the neonicotinoid class of insecticides poses unacceptable hazards to bees. The report concludes that certain crops treated with neonicotinoid chemicals –imidacloprid, clothianidin and thiamethoxam– are of “critical concern” for bee health. Beekeepers and environmental activists welcome these recent scientific findings that they say support a U.S. ban on these chemicals. According to Jay Feldman, Executive Director, Beyond Pesticides, “The EFSA report confirms what we have been asking EPA to recognize. Clothianidin and other neonicotinoids are highly toxic to bees, and should be banned by EPA and removed from the environment.” In its investigation, EFSA, which was tasked with assessing the risks associated with these chemicals to bee colony survival and development, found that systemic contamination of neonicotinoid-treated crops and contamination via dust place honey bees and the hives they return to at high risk. Exposure to contaminated dust pose a high risk to honey bees for all three neonicotinoids used on corn and certain other crops, as well as exposure to residues in nectar and pollen. High risks were also identified from exposure to guttation fluid from corn for thiamethoxam. EFSA considered […]

(Beyond Pesticides, January 16, 2013) Children living near chemical-intensive or conventional plantations in Costa Rica are exposed to twice as much of the insecticide chlorpyrifos compared to children living near organic plantations, a study reports. More than half the children, mostly from indigenous tribes- Ngäbe and Bribri – have a  higher daily exposures than allowed under U.S. federal standards. Chlorpyrifos is linked to neurological effects, especially in children, and is still permitted for use on crops. The study,  Indigenous children living nearby plantations with chlorpyrifos-treated bags have elevated 3,5,6-trichloro-2-pyridinol (TCPy) urinary concentrations, was lead by Berna van Wendel de Joode, PhD  (Central American Institute for Studies on Toxic Substances (IRET), Universidad Nacional, Heredia, Costa Rica). It was conducted in Costa Rica’s banana and plantain plantations in the Talamanca region, and  targeted villages situated nearby to the plantations where blue bags treated with chlorpyrifos are routinely used to protect banana and plantain crops from pests. Two villages under study are near plantations that use chlorpyrifos-treated bags, while the organic village is near several plantations  that use little or no insecticide. For 140 children, aged 6 — 9, mostly indigenous Ngäbe and Bribri, parent-interviews and urine samples were obtained. Chlorpyrifos’ environmental levels […]

(Beyond Pesticides, January 15, 2013)  Research published in the journal Environmental Monitoring and Assessment calls into question the value of environmental monitoring, such as water sampling,  on a  fixed date schedule (i.e., once per month), finding that this approach underestimates actual risks. These findings could have a significant impact on how we assess the safety of both endangered species and drinking water supplies. Researchers explain that, although insecticides are applied less often than herbicides and fungicides, they are usually applied in very large amounts when used in response to acute insect infestations. Scientists found that monitoring for insecticides at pre-set intervals, even weekly or daily, did not detect the occurrence of peak concentrations for these chemicals. Co-author of the study, Ralf Shulz, PhD, explains, “Accordingly, by way of example, on the basis of weekly monitoring of a typical agricultural stream none of the total of six insecticide concentration peaks per year described by model calculations is found. Daily sampling detects only two of the six peaks. Only event-related sampling enables the detection of all these peaks.” Authors of the study point to the need for events-related sampling, both to ensure more accurate detections are taken and to reduce costs. Events-related […]

(Beyond Pesticides, January 11, 2012) Environmentalists, farmworkers, and farmworker advocates have become increasingly uncomfortable with the new proposal for pesticide safety measures which does not include details on how the proposed rule will protect agricultural workers, farmers, and applicators. These sentiments stem from the concern that this may mean less stringent regulations than those originally proposed. In 2010, the U.S. Environmental Protection Agency (EPA) released a   document proposing Worker Protection Standards (WPS) that would determine ways to increase training, improve safety requirements, provide clear emergency information, and create strong protection for applicators. However, a recent EPA handout distributed  during a November 2012 Pesticide Program Dialogue Committee (PPDC) meeting downplays the details within those goals, and brings into question the agency’s  previous commitments. Advocacy groups have raised pointed complaints on the new document’s prose: “I have to agree that we are just really in the dark,” said one environmental group lawyer, “It is mysterious that it’s taken them so long to come up with a draft to propose, and the fact that they are being kind of tight-lipped about it and that even the very minimal detail about the proposal that was in the 2010 document disappeared from the 2012 […]

(Beyond Pesticides, January 8, 2013) Neurologists at the University of California, Los Angeles (UCLA) have published their latest research linking pesticide exposure to Parkinson’s disease. Appearing in the online edition of PNAS, the UCLA scientists’ work details the series of events that can occur after individuals are exposed to the pesticide benomyl, which was phased out in 2001. Researchers believe their findings on the series of events the pesticide sets in motion could be applicable even to Parkinson’s patients who have not been exposed to benomyl. According to scientists, exposure to benomyl prevents the enzyme aldehyde dehydrogenase (ALDH) from keeping in check a naturally occurring toxin in the brain called 3,4-Dihydroxyphenylacetaldehyde (DOPAL). Without ALDH regulating DOPAL, the toxin accumulates, damages neurons, and increases an individual’s risk of developing Parkinson’s disease. Researchers postulate that this process may be occurring in people with Parkinson’s who were never exposed to pesticides. The findings of this research provide insight into possible treatments to slow the disease, such as developing new drugs to protect ALDH activity. Although the exact cause of Parkinson’s is still unknown, until this research scientists were focusing in on the protein a-synuclein as a pathway to the disease. The protein, present […]

(Beyond Pesticides, January 4, 2013) On December 31, 2012, the U.S. Environmental Protection Agency (EPA) proposed to clarify its labeling requirement for disclosure of all active and inert ingredients in “minimum risk pesticide products,” exempt from registration under Section 25 (b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The rule (77 FR 250) reorganizes the list of eligible active and inert ingredients by adding identifiers that will clarify for the public, and more importantly for federal and state inspectors, which ingredients are permitted in minimum risk pesticide products. The modification would require labels to use common chemical names in the list of ingredients as well as the contact information for the manufacturer. The lack of clarity on minimum risk pesticide product labels in the past has made it difficult for enforcement officials who must use their own judgment on the applicability of vague descriptors such as cedar leaf oil and cedar wood oil, which are exempt under the current listing of “Cedar Oil” under CFR Section 152.25. While EPA has attempted to improve labeling clarity of minimum risk pesticide products by updating its website, stakeholders have found the measure insufficient. Regulatory Background Currently, EPA is empowered under FIFRA […]

(Beyond Pesticides, December 19, 2012) The Congressional Research Service (CRS) issued its overview report, Bee Health: The Role of Pesticides, in response to a congressional request for more information on the connection between declines in bee populations, colony collapse disorder (CCD) and pesticides, particularly neonicotinoids. The 23-page report, dated December 11, 2012, summarizes the range of scientific studies and regulatory activities without offering a critique of what bee health advocates have identified as serious deficiencies in the regulatory review process and compliance with the pesticide registration law. The review gives equal standing to independent and industry science. The CRS report identifies a range of issues regarding: 1. Changes to managed and wild bee populations (indicating limited information); 2. Factors that are documented to impact bee health, including pesticides, pests and diseases, diet and nutrition, genetics, habitat loss, and beekeeper issues, highlighting that there are multiple exposure pathways that may work synergistically; 3. Scientific research on the role of pesticides; and, 4. Current research and regulatory activity regarding neonicotinoids, a neurotoxic insecticide impacting bees. The report reviews the ‘state of play’ on the issue of bee declines and finds that there are reported to be many factors that contribute to the […]

(Beyond Pesticides, December 18, 2012) Certain pesticide manufacturers are gearing up to try to block EPA’s attempts to cancel certain rodent poisons that are known to be hazardous to children and wildlife, including endangered species. After more than a decade of research and review, and an unacceptably high number of poisoning incidents, EPA has acknowledged that certain active ingredients are too dangerous to remain on the market, and is now requiring all remaining over-the-counter rodent control products to be in secured, tamper-resistant bait stations to reduce the incidents of accidental exposure to children. Granular and powdered products will be banned. But certain chemical companies are refusing to comply with EPA’s order and have indicated that they will challenge the agency’s decision. Every year, more than 10,000 children are exposed to rodent poison products, and the majority of calls to poison control centers concern children under the age of three. Despite the availability of alternatives, industry is leading a campaign against EPA’s decision, trying to scare communities into believing that they will be overrun with rodents and infested with disease if their products are not used. Meanwhile, less toxic rodent control products and those secured in bait stations are available, effective, […]

(Beyond Pesticides, December 17, 2012) Pets are frequently exposed to toxic chemicals used for lawn care, bug sprays, flea and tick products, and rodenticides. Recently, a dog ingested a zinc phosphide based pellet rodenticide, and threw up these toxic chemicals, creating a toxic gas that caused respiratory stress for four of the veterinary staff where the dog was being treated. The incident happened in Vail Valley Animal Hospital in Edwards, Colorado on December 7, and led to one emergency room veterinarian and three technicians being sent to the hospital. Sadly the dog did not survive after releasing this toxic gas. This is not the first incident of phosphine gas exposure at a veterinary clinic as a total of four have been reported from 2006 to 2011 in Michigan, Iowa, and Washington. When zinc phosphide is ingested and comes in contact with water it forms a poisonous gas. In a statement, the local fire protection district explained, “When the dog vomited, this released the [phosphine] gas as the pesticide had mixed with the contents in the dog’s stomach.” According to the Centers for Disease Control and Prevention (CDC), inhalation of high concentrations of phosphine gas can be deadly and can cause […]

(Beyond Pesticides, December 14, 2012) Decision making advice by the Advisory Committee on Pesticides (ACP) and insecticide regulator, the Department for Environment, Food, and Rural Affairs (Defra), were harshly criticized on Wednesday by Members of Parliament (UK), as they discussed the problems associated with neonicotinoids, a group of neurotoxic insecticides linked to serious declines in bee and pollinator populations. The meeting was attended by Members of Parliament, members of the Advisory Committee on Pesticides, Lord de Mauley, the Parliamentary Under-Secretary of State, the Department for Environment, the Food and Rural Affairs and officials, bringing neonicotinoids and their impact on bees to the attention of the international community as well as at home. The discussion focused on the evidence used to make a decision on the allowance of neonicotinoids and plans for the future. ACP members indicated that evidence for future draft plans would be based on new studies developed in 2012 on the effects of neonicotinoids at the colony level, as well as the impact of neonicotinoids exposure in field tests, rather than in the lab. Research will likely fill the extant data gaps, the most important of which were identified by officials of Defra, the environmental regulatory agency in […]

(Beyond Pesticides – December 13, 2012) The 31st National Pesticide Forum, Sustainable Families, Farms and Food: Resilient communities through organic practices, will be held April 5-6, 2013 (Friday afternoon and all day Saturday) at the University of New Mexico in Albuquerque, NM. The conference is convened by Beyond Pesticides, La Montanita Coop, and the Universtiy of New Mexico Sustainability Studies Program, and co-sponsored by local, state and regional public health and environmental organizations, including the New Mexico Department of Agriculture’s Organic Program, Amigos Bravos, Our Endangered Aquifer Working Group, Farm to Table, Holistic Management International. Contact us if your organization is interested in joining as a co-sponsor. Registration fees begin at $35. Online registration coming soon. The conference will focus on building resilience in our food system and bringing ecosystems back to balance, incorporating regional issues such as water and food sovereignty in the Southwest. The National Forum provides an opportunity for grassroots advocates, scientists, and policy makers to interact and strategize on solutions that are protective of health and the environment. Featured speakers Joel Forman, MD, is an Associate Professor of Pediatrics and Community and Preventive Medicine at Mt. Sinai Hospital, New York City. Dr. Forman is currently a […]

(Beyond Pesticides, December 10, 2012) Long-term low-level exposure to organophosphate pesticides produces lasting damage to neurological and cognitive functions, according to researchers at University College London (UCL). This research pulls data from 14 studies over the past 20 years, including more than 1,600 participants, in order to provide a quantitative analysis of the current literature on these dangerous chemicals. Lead author of the study, Sarah Mackenzie Ross, Ph.D., notes, “This is the first time anyone has analyzed the literature concerning the neurotoxicity of organophosphate pesticides, using the statistical technique of meta-analysis.” UCL’s systematic review, published in the journal Critical Reviews in Toxicology, comes to an unsettling conclusion about the hazards of constant low-level occupational exposure to organophosphates. The study notes, “The majority of well designed studies found a significant association between low-level exposure to [organophosphates] and impaired neurobehavioral function which is consistent, small to moderate in magnitude and concerned primarily with cognitive functions such as psychomotor speed, executive function, visuospatial ability, working and visual memory.” In other words, low-level exposure had significant detrimental effect on working memory and information processing. The researchers are hopeful that the results of their analysis will be used to inform governments performing reviews on the […]

(Beyond Pesticides, December 6, 2012) A study published in the December issue of Annals of Allergy, Asthma and Immunology finds that exposure to dichlorophenols may be associated food allergies. Dichlorophenols are used as an intermediary in the manufacturing of some of the most commonly used pesticides, such as 2,4-D, and are also used to chlorinate drinking water. This study may help explain in part why food allergies are on the rise in the U.S. and already affect 15 million Americans. Lead researcher Dr. Elina Jerschow and her associates analyzed the urine of 10,348 Americans who were participants in the U.S. National Health and Nutrition Examination Survey (NHANES) of 2005-2006. Of the over 10,000 surveyed, 2,548 had detectable amounts of dichlorophenols in their urine, and 2,211 of those participants were included in the study. Out of these 2,211 people, 1,427 were found to have some form of either food or environmental allergy. Participants with higher levels of dichlorophenols are more likely to have allergies then those with low levels present in their urine. Researchers in this study argue that by consuming high levels of dichlorophenols individuals are altering the composition of bacteria in their stomachs. By over consuming dichlorophenols individuals are […]

(Beyond Pesticides, December 3, 2012) The Food and Drug Administration (FDA) has denied a 2010 petition filed by the National Resources Defense Council (NRDC) and Pesticide Action Network North America (PAN) to ban the insecticide lindane, which is harmful to human health and ineffective in controlling lice and scabies. Pressure had been mounting on FDA to halt the pharmaceutical use of lindane as, in addition to this petition, Congressman Edward J. Markey (D-Mass.), senior member of the Energy and Commerce Committee, asked FDA to stop the pharmaceutical use of lindane this past summer. Because of FDA’s decision, lindane is still an active ingredient in pharmaceutical insecticide products such as lice shampoos and lotions. Lindane was formerly used in agricultural insecticides until it was banned by the Environmental Protection Agency (EPA) for use on crops in 2006. FDA regulates pharmaceuticals that contain insecticides and pesticides, such as triclosan, that are in cosmetics. Over 160 countries including the United States have signed on to the Stockholm Convention on Persistent Organic Pollutants (POPs) in 2001 which aims to eliminate or restrict the production and use of persistent organic polluntants. Lindane along with nine other chemcials was added to this list on May 9th […]

(Beyond Pesticides, November 30, 2012) A health care institution is weighing in to warn people about potential dangers of genetically engineered (GE) food. On the heels of the American Academy of Pediatrics’ warning on pesticides, the nation’s largest nonprofit health care plan, Kaiser Permanente, has published in its print newsletter, Partners in Health, tips on limiting exposure to genetically engineered food. In the Fall 2012, Kaiser Permanente has published an article, “What you need to know about GMO: Limit exposure to genetically engineered organisms with these tips.” This discussion in the health care sector is part of a growing involvement by health care practitioners in environmental health concerns related to pesticides and genetic engineering of the food supply. While Canadian medical groups have warned the public about the dangers of pesticides and supported phase-outs, institutions representing the medical community in the U.S. have been more reserved. In 2004, the Ontario College of Family Physicians (OCFP) in Canada strongly recommended that people reduce their exposure to pesticides wherever possible, after releasing a comprehensive review of research on the effects of pesticides on human health. OCFP’s Systematic Review of Pesticide Human Health Effects shows consistent pesticide links to serious illnesses such as […]