(Beyond Pesticides, July 24, 2017) A new report by the National Academies of Sciences, Engineering, and Medicine (NAS) is recommending to the U.S. Environmental Protection Agency (EPA) a strategy to evaluate the evidence of adverse human health effects from low doses of exposure to chemicals that can disrupt the endocrine system. NAS believes that EPA’s current process, which utilizes traditional toxicity testing, would miss some effects that occur at doses lower then what EPA evaluates. EPA’s Endocrine Disruption Screening Program (EDSP) is currently screening chemicals for their potential to interact with the endocrine system, but the program is years behind schedule and has been criticized for using outdated methods. Endocrine disruptors are substances that can cause a variation in normal hormone function. Even small alterations in hormone concentrations, particularly during embryonic development and developmental phases of life, can have lasting and significant effects. Mounting science is showing that disruptions to the hormone system can occur at very low doses that according to NAS, are lower than those used in traditional toxicity testing by EPA. This means that some effects may be missed. EPA’s methodologies have been criticized over the years for failing to adequately capture impacts at low doses. EPA requested NAS […]

(Beyond Pesticides, June 29, 2017) On June 16, the European Chemicals Agency (ECHA) decided to classify bisphenol A (BPA) as an endocrine disruptor, and as a substance of “very high concern” due to “probable serious effects to human health.” The classification follows a proposal by the French food security agency (ANSES), which was made earlier this year. The committee, comprised of representatives from all 28 European Union EU countries, agreed to the classification unanimously. With pressure from environmental groups and others, the European Commission (EC) is working to define scientific criteria that will be used to identify endocrine disrupting chemicals (EDCs), and lead to more effective regulation in EU countries. In June 2016, the EC issued weak regulations on endocrine disruptors in pesticide products, undermining the precautionary legal standard that governs pesticide usage in Europe. Many scientists and advocacy organizations criticized the proposed regulations for creating an impossibly high burden of proof for defining harm from endocrine disrupting pesticides and other products. EDCs contained in common household products such as detergents, disinfectants, furniture, plastics, and pesticides, interfere with the body’s hormone system either by mimicking naturally produced hormones, blocking hormone receptors in cells, or effecting the transport, synthesis, metabolism or excretion […]

(Beyond Pesticides, June 21, 2017) More than 200 international scientists and medical professionals have signed the Florence Statement on Triclosan and Triclocarban, which states that triclosan and its chemical cousin triclocarban pose a risk to human health, and urges the international community to limit use of these antimicrobials, which are associated with bacterial resistance and no more effective than soap and water. In 2016 after manufacturers failed to prove efficacy, the U.S. Food and Drug Administration (FDA), which regulates cosmetic triclosan products, announced that manufacturers must, by September 2017, remove triclosan from over the counter hand soaps. The agency still allows the chemical in toothpastes and other products, such as hand wipes. The Environmental Protection Agency (EPA), which regulates triclosan in household items, textiles and plastics, still permits wide use of the chemical in a range of products. The Florence Statement on Triclosan and Triclocarban is “based on extensive peer-reviewed research,” and “concludes that triclosan and triclocarban are environmentally persistent endocrine disruptors that bioaccumulate in and are toxic to aquatic and other organisms.” The statement includes evidence of human health threats, and provides recommendations intended to mitigate harm from triclosan, triclocarban, and other similar antimicrobials. The recommendations are listed below: “Avoid […]

(Beyond Pesticides, May 9, 2017) Last month, San Juan Capistrano (SJC) became the latest community in Orange County, CA to pass an organic landscaping policy for city parks and open spaces. The city’s move follows the passage of an organic land care policy in nearby Irvine, CA last year, and like Irvine, was brought forward by a strong contingent of local advocates, health practitioners, and city officials working together to safeguard public health and the environment. By a vote of 4-0-1, San Juan Capistrano’s City Council put the community on the cutting edge of local changes to pesticide use that are taking place across the country. SJC’s policy is the result of persistent pressure and engagement by community group Non-Toxic San Juan Capistrano with city officials. A change.org petition hosted by the group, which received over 300 signatures, detailed the discussions and responses the group received from local leaders. At the time the City Council took up the issue at a mid-April meeting, Mayor Kerry Ferguson made a strong statement indicating that, “Chemical pesticides and herbicides have been proven to be toxic to children, pets, and the general public.” Mayor Ferguson further said, “While [chemical pesticide] use is somewhat limited […]

(Beyond Pesticides, March 21, 2017) Last week, the California Department of Pesticide Regulation (CDPR) released revised rules regarding notification of pesticide applications near schools, weakening standards despite opposition from community and public health groups. The new rules rescind a requirement that schools be granted 48 hours prior notification for a planned application of agricultural pesticides within ¼ mile of a school site. CDPR has re-opened public comments on the new rules, and concerned residents have until April 4 to submit a short statement urging increased protections to the Department at [email protected]. Public health, farmworker, and community groups had urged CDPR to strengthen, not weaken common-sense protections for children’s health. As the rules currently stand, applications of toxic, drift-prone pesticides will only be restricted within ¼ mile of a school site, and only during the hours of 6am to 6pm on weekdays. The original proposal required 48 hour prior notification for other agricultural pesticide applications occurring within ¼ mile of school sites during these times. However, CDPR’s revised rules now only require 48 hour notification if the pesticides applied are not on a list provided to school officials at the beginning of the year. Applicators will still be required to submit annual reports […]

(Beyond Pesticides, March 2, 2017) On Tuesday, the European Commission (EC) refrained from voting on proposed scientific criteria that would have identified endocrine disrupting chemicals (EDC) and led to regulation on their use in EU countries. This sends the Commission back to the drawing board on the proposal, on which they hope to eventually take a formal vote. The failure to move forward with defined criteria on these hazardous chemicals, which are present in pesticides, biocides, and self-care products, is still largely due to the disagreements of voting member states over the rules reflecting hazard or risk-based criteria. There have been several other meetings of the member states on this proposal, including a meeting in December which highlighted the inadequacies of the criteria. After this meeting, according to Bas Eickhout, of the Greens-European Free Alliance, “Under the Commission’s criteria, it is likely that not a single substance would be identified as an endocrine disrupter, and they would effectively escape specific regulation.” This all follows on the weak regulations issued by the EC in June 2016 to regulate endocrine disruptors in pesticide products, which ultimately undermine the precautionary legal standard that governs pesticide usage in Europe. Many scientists and advocacy organizations criticized […]

(Beyond Pesticides, January 3, 2017)  A study published in December 2016 in Environmental Contamination and Toxicology, entitled The Effect of Atrazine on Louisiana Gulf Coast Estuarine Phytoplankton, finds that phytoplankton in estuaries in close proximity to agricultural operations are less productive than phytoplankton in an uncontaminated environment. The study examines three different estuaries of the Mississippi river in Louisiana and also evaluates microcosms with different concentrations of atrazine. Phytoplankton, incredibly important to estuary ecosystems and aquatic life, are an integral part of the aquatic food web and ultimately critical to the wild seafood market. As photosynthetic microorganisms, phytoplankton harness the sun’s energy for metabolism and create as a byproduct of photosynthesis dissolved oxygen, which oxygen-breathing sea life require. For the study, the researchers created microcosms, or large containers that are able to closely mimic ecosystems, so that they can observe the effects of independent variables. On average, phytoplankton in the microcosms are less productive at producing chlorophyll a in the presence of atrazine. The microcosm study design is important because it is difficult to separate and measure the effects of chemicals like atrazine in the environment, given the range of potential causes of phytoplankton decline. A variety of factors, like freshwater discharge rates, precipitation, […]

(Beyond Pesticides, October 25, 2016) Last week, a study,  Exposure to endocrine-disrupting chemicals in the USA: a population-based disease burden and cost analysis,  published in The Lancet  journal, concludes  that exposure to pesticides and other chemicals found in common household items, such as toys, makeup and detergent, costs the U.S. more than $340 billion annually in  health care costs and lost wages. The chemicals in question, endocrine disruptors (EDCs), interfere with the body’s hormone system, which can lead to a variety of health problems. According to Environmental Health News, the researchers estimate the costs by looking at exposure data and then projecting 15 medical conditions that are linked to endocrine disruptors and their associated health costs and lost wages. The findings came from calculations made by the Endocrine Society, the World Health Organization, and the United Nations Environment Program. A group of flame retardant chemicals called polybrominated diphenyl ethers (PBDEs) were the worst offenders in the U.S., accounting for nearly two-thirds of estimated health problems. These chemicals were estimated to annually cause about 11 million lost IQ points and 43,000 additional cases of intellectual disability, costing around $268 billion. Pesticide exposure, the second most costly chemical group in the U.S., […]

(Beyond Pesticides, June 21, 2016) New regulations issued by the European Commission (EU) last week to regulate endocrine disruptors in pesticide products are being criticized by public interest groups and scientists as undermining the precautionary legal standard governing pesticide use in Europe. Previous  investigations and reports  have uncovered  industry’s attempt to quash efforts to enact robust protections from these harmful chemicals, despite their likely contribution to billions of dollars in lost revenue due to health effects. EC’s new rules endorse the World Health Organization’s definition of endocrine disrupting chemicals (EDC). The WHO defines an endocrine disruptor as “an exogenous substance or mixture that alters function(s) of the endocrine system and consequently causes adverse health effects in an intact organism, or its progeny, or (sub)populations,” However, the proposed regulations go little beyond defining the term. “The WHO definition is not a criteria, it is just a definition,” said Andreas Kortenkamp, PhD to The Guardian. “In effect, the commission has decided to place the burden of deciding how to regulate endocrine-disrupting chemicals onto the assessors on a case-by-case basis.” Of concern is the level to which the rules reflect a hazard or risk-based criteria. While EC asserts that its rules will follow […]

(Beyond Pesticides, April 27, 2016) The  European Union (EU)  has placed a moratorium on two endocrine-disrupting herbicides that are linked to thyroid cancer, infertility, reproductive problems and fetal malformations. The chemicals, amitrole and isoproturon, will be banned as of September 30, 2016, after the European Commission voted unanimously, for the first time, to ban the two endocrine disruptors. Earlier this month, the European Commission’s Standing Committee on Phytopharmaceuticals voted to ban the uses of amitrole and isoproturon in accordance with 2009-EU pesticide rules,  which state that endocrine disrupting pesticides should not be allowed on the European market. The committee finds that amitrole is capable of causing malformations in offspring and inducing thyroid cancer, while isoproturon can cause adverse effects to reproduction and lower fertility. In 2013 amitrole was voluntarily cancelled by the registrant, while isoproturon is not registered for use in the U.S. According to the Guardian, amitrole is widely used in 10 EU countries, including the UK, in industrial farming. But  a European Food Safety Authority (EFSA) analysis concluded  that it was an endocrine disruptor that could damage unborn children, and have toxic effects on the thyroid and reproductive organs. Similarly, EFSA recommended classifying  isoproturon as toxic for reproduction […]

(Beyond Pesticides, April 26, 2016) A study published last month finds that exposure to endocrine-disrupting chemicals (EDC) plays an important role in the development of certain female reproductive disorders, and ultimately results in significant economic costs to society. The study, published in the Journal of Clinical Endocrinology &nMetabolism, and authorized by a team of scientists from New York University School of Medicine and Washington State University’s School of Molecular Biosciences, looked at the monetary impact of EDC-attributed female reproductive disorders in the European Union (EU). This economic valuation is part of series of analyses undertaken by the research team, which determined last year that over €150 billion ($162 billion) in yearly health care costs in the EU are attributable to the loss of brain function induced by EDCs. “There are substantial human and toxicological studies (in mice and other lab animals) that suggest that exposure to these endocrine-disrupting chemicals, many of which are increasing in use, are contributing to female reproductive conditions,” said study co-author Leonardo Trasande, MD, associate professor of pediatrics at NYU School of Medicine to CNN. The study found that the strongest data linking EDCs to female reproductive disorders was exposure to diphenyldichloroethene (DDE) resulting in fibroids, […]

(Beyond Pesticides, March 25, 2016) Glyphosate is found to contaminate California wines, according to a new report from the non-profit group Moms Across America. Glyphosate is pervasive and toxic chemical found in Monsanto’s Roundup weedkiller and was classified in 2015  as a probable carcinogen  by the International Agency for Research on Cancer (IARC). The report finds that all of the ten wines tested positive for glyphosate. The highest level of glyphosate detected was nearly 30 times higher (at 18.74 parts-per-billion, or ppb) than other wines from a 2013 Cabernet Sauvignon  sourced from a conventional, chemically farmed vineyard. The lowest level (.659 ppb) was from a biodynamic and organic vineyard, a 2013 Syrah. According to the owner, the vineyard has never been sprayed, indicating the possibility of pesticide drift from conventional agriculture, which has been a real and persistent problem for organic growers. EPA has done little to protect organic growers, who often bear the burden, both economic and otherwise, of pesticides applied to nearby conventional farmlands and vineyards. The report also points out that “the detection of glyphosate is an indicator of the presence of many other co-formulants in glyphosate-based herbicides, which have recently been shown”¦to be endocrine hormone disruptors […]

(Beyond Pesticides, October 23, 2015) Tests on produce collected by California’s Department of Pesticide Regulation (CDPR) for 2014 show high levels of  illegal toxic pesticide residues. The CDPR report found 1 percent of produce containing an excess amount of pesticide residues, and an additional 5.5 percent of produce tested contained illegal residues of pesticides that are not allowed for use on that product. Additionally, the data shows residues of a banned  chemical, which was taken off the market  over 20 years in the U.S. due to health concerns related to farmworker exposure. These findings showcase issues related to  system-wide failure in  enforcement. Advocates stress that violations may continue to occur due to inadequacies in regulations governing enforcement authorities, which include warnings or low fines for violators. In raising concerns about the safety of food grown with chemical-intensive methods, advocates point to the need to expand the transition to organic agriculture for better protection of public health and safety. The highest percentage of illegal pesticides was found on cactus pads and cactus fruit imported from Mexico. Some of the other tainted fruit and vegetables include limes, papaya, summer squash, tomatillos, chili peppers, and tomatoes, also from Mexico, ginger imported from China, […]

(Beyond Pesticides, October 6, 2015) Last week, the International Federation of Gynecology and Obstetrics (FIGO) released a statement encouraging broad-based policy measures that prevent exposure to toxic environmental chemicals. “The global health and economic burden related to toxic environmental chemicals is in excess of millions of deaths and billions of dollars every year,” the report unequivocally states. FIGO’s statement follows a similar call to action from the American College of Obstetricians and Gynecologists in 2013 and the American Academy of Pediatrics in 2012. The piece lays out broad themes surrounding exposure to toxic chemicals, including issues of environmental justice, prenatal exposure and subsequent health effects, and overall global health and economic burden. Based on these impacts, several recommendations are submitted for obstetricians, gynecologists, midwives, women’s health nurse practitioners, nurses, and other health professionals to follow to achieve a goal of “prevention for all.” FIGO highlights how people of low-income, particularly in poverty-stricken countries, bare a higher burden of toxic exposure than richer nations. “[A]t every stage of development, the consequences of exposure to toxic chemicals —including morbidity and mortality, loss of family income and productivity, and environmental degradation— are disproportionately borne by people with low incomes,” the piece states. FIGO […]

(Beyond Pesticides, August 19, 2015) Local fogging for  mosquito control turned tragic for a Palo Alto, California beekeeper who lost hundreds of honey bees from his backyard hives. The beekeeper, who also produces organic honey, now fears his honey is contaminated. The fogging, which occurred last month, was in response to positive tests for West Nile virus in mosquito samples. Many mosquito control pesticides are toxic to honey bees and given the declining populations of pollinators, vector control officials are being asked to carefully consider the risks associated with pesticide spraying. According to the local NBC affiliate, beekeeper Rondolph Tsien believes he was not given sufficient time to protect his bees from the mosquito fogging and, despite trying to cover his hives with a tarp to protect his bees from drifting pesticides, many were lost. A mosquito sample tested positive for West Nile virus about one mile from Mr. Tsien’s home, putting his property in the catchment area for fogging. Mr. Tsien worries the surviving bees will produce contaminated honey that can no longer be labeled organic. A Santa Clara County Vector Control representative stated during an interview that the county uses  an “extremely low dose” of pesticides during fogging […]

(Beyond Pesticides, August 7, 2015) Parental exposure to environmental stressors, such as pesticides, before a child is conceived can alter the way genes are expressed in the mother and father, ultimately harming the child’s health when those genes are passed down to the next generation, according to an article published in the Endocrine Society’s journal Endocrinology. “In regard to environmental stressors, a good start lasts a lifetime,” said Philippe Grandjean, M.D., Ph.D. Dr. Grandjean is Professor of Environmental Medicine at the University of Southern Denmark and Adjunct Professor of Environmental Health at the Harvard University’s T.H. Chan School of Public Health and an author of the article. “Unfortunately, current testing paradigms do not properly assess the impact of risk factors during vulnerable exposure windows. Without new policies and guidelines, we cannot have a universal healthy start for children.” The article, titled Life-Long Implications of Developmental Exposure to Environmental Stressors: New Perspectives, summarizes the newest science and key insights from the 4th  Conference on Prenatal Programming and Toxicity (PPTOX IV). More than 300 people attended the event in Boston, MA in October 2014. The meeting featured poster presentations discussing the impact of chemical, physical, and biological environmental stressors on the interconnected […]

(Beyond Pesticides, July 6, 2015) With the release of its  Tier 1 screening results  for the first 52 pesticide chemicals (active and inert ingredients) evaluated under  the Endocrine Disruptor Screening Program (EDSP), the U.S. Environmental Protection Agency (EPA) is at odds with a large body of scientific evidence worldwide that identifies many of these chemicals, most notably the herbicides  2,4-D  and  atrazine,  as interacting with the endocrine system or acting as endocrine disruptors. Independent scientific data has shown these chemicals to interfere with the hormone system. EPA’s EDSP is a multi-step process used to ensure that exposure to chemicals does not result in adverse human health and environmental effects that canoccur from the disruption of hormones. The two-tiered screening and testing system requires that EPA identify which chemicals are able to interact with the endocrine system, specifically with three hormonal pathways — estrogen, androgen, and thyroid — in Tier 1. Tier 2 is designed to go one step further, requiring EPA to determine endocrine effects across taxa (e.g. mammals, birds, amphibians, and invertebrates) as well as potential effects on non-endocrine systems (e.g. neurological, immunological, hepatic, and renal).  According to EPA, Tier 1 screening data are the best way to determine […]

(Beyond Pesticides, March 13, 2015) Exposure to endocrine (hormone) disrupting chemicals (EDC) results in approximately € 150 billion ($162 billion) in health care costs in the European Union each year, according to panels of scientists tasked by the EU Commission to study their impact. “The shocking thing is that the major component of that cost is related to the loss of brain function in the next generation,” Philippe Grandjean, M.D. of Harvard University, one of the report’s authors, told the Guardian. EDCs, contained in common household products such as detergents, disinfectants, furniture, plastics, and pesticides, interfere with the body’s hormone system either by mimicking naturally produced hormones, blocking hormone receptors in cells, or effecting the transport, synthesis, metabolism or excretion of hormones. These impacts can result in devastating effects on one’s health, including behavioral and learning disorders, such as Attention Deficit Hyperactivity Disorder (ADHD), birth defects, obesity, early puberty, infertility, cardiovascular disease, and childhood and adult cancers. Nearly 100 percent of people have detectable amounts of EDCs in their bodies, according to the introductory guide to EDCs published by the Endocrine Society and IPEN. “Our brains need particular hormones to develop normally —the thyroid hormone and sex hormones like testosterone […]

(Beyond Pesticides, February 5, 2015) A brewing  battle in the European Union (EU) over removing from the market  Endocrine Disrupting Chemicals (EDC)s has  heated up. An investigative report in  The Guardian  reveals that a European Union (EU) scientific paper, prepared to assist in the development of new mandatory EDC risk assessment standards, was never made public. According to the report, EU Commission sources say the release of the paper was quashed as a result of chemical industry pressure and political influence. At the core of the debate lies two EU regulations, one concerning biocidal products (EU 528/2012) and the second on “plant pest protectants” (EU 1107/2009). Both of these regulations required the EU Commission to produce draft measures concerning specific scientific criteria for the determination of endocrine disrupting properties by December 14, 2013. Under the regulations, chemicals within the biocidal and plant pest protectant categories that are  categorized as having endocrine disrupting properties that may cause adverse effects in humans would be prohibited from use in the market place. As noted in the purpose and subject matter of the biocidal regulations, “The purpose of [the] Regulation is to improve the functioning of the internal market through the harmonization of the […]

(Beyond Pesticides, January 09, 2015) New closed-door international trade agreement proposals between the U.S. and EU could weaken pesticide standards and threaten the U.S. organic food industry. Set forth by European and U.S. trade associations, the proposals were met  with strong disapproval by numerous non-governmental organizations (NGO) and non-profits. Beyond Pesticides and over a hundred other European and U.S.-based organizations signed on to a letter in July 2014 calling for increased transparency of negotiating proposals and  the exclusion of chemical regulations from the entire scope of the prospective Transatlantic Trade and Investment Partnership (TTIP). The proposals are recommended by the trade associations CropLife America and the European Crop Protection Association (ECPA) —which represent major agricultural chemical manufactures like Bayer CropScience, Dow AgroSciences, and DuPont Crop Protection— with claims that the policy would help reduce or get rid of trade barriers and help promote regulatory cooperation and achieve the goals of the TTIP. According to a new Center for International Environmental Law (CIEL) report, however, these proposals push for anemic pesticide residue limits in the EU, which are currently some of the strongest ones in existence and have influenced more stringent standards around the world, including the U.S. The groups recommend […]

(Beyond Pesticides, August 5, 2014) A new study finds that female mice exposed in utero to the pesticide DDT are at greater risk for obesity and type-2 diabetes, adding to a growing body of literature linking metabolic diseases to pesticide exposure. The study, titled Perinatal Exposure of Mice to the Pesticide DDT Impairs Energy Expenditure and Metabolism in Adult Female Offspring, was published in the journal PLoS One. Researchers measure and compare metabolic abnormalities in female mice that were exposed in utero to DDT against a control group of those that were unexposed. After exposure, the two groups were then fed high-fat diets for 12 weeks in adulthood. Females exposed to DDT around the time of their birth were more likely to develop insulin sensitivity, glucose intolerance, high cholesterol, and metabolic complications that could result in liver disease. These results suggest that DDT exposure in and around the time of gestation cultivates conditions that increase an individual’s likelihood of accumulating excess fat over the course of one’s lifespan. Additionally, the results find that changes in the way fats and carbohydrates are metabolized can increase the risk of developing metabolic syndrome, which is a precursor to type-2 diabetes. The researchers’ observations […]

(Beyond Pesticides, July 28, 2014) New research from Michael Skinner, Ph.D.’s laboratory out of Washington State University finds that —yet again”” exposure to pesticides may have devastating consequences for future generations. The study, “Pesticide Methoxychlor Promotes the Epigenetic Transgenerational Inheritance of Adult-Onset Disease through the Female Germline,” published in PLOS ONE, finds that gestating rats exposed to the pesticide methoxychlor develop a higher incidence of kidney disease, ovary disease and obesity in offspring spanning three generations. The incidence of multiple diseases increased in the third generation or “great-grandchildren.” This study suggests that ancestral exposures to methoxychlor over the past 50 years in North America may play a part in today’s increasing rates of obesity and disease. The epigenetic changes observed were specific to methoxychlor exposure and, according to researchers, may prove to be valuable biomarkers for future research on transgenerational disease. For people exposed to the pesticide, Dr. Skinner says his findings have implications such as reduced fertility, increased adult onset disease and the potential to pass on those conditions to subsequent generations. “What your great-grandmother was exposed to during pregnancy, like the pesticide methoxychlor, may promote a dramatic increase in your susceptibility to develop disease, and you will pass […]

(Beyond Pesticides, July 7, 2014) A study led by the U.S. Geological Service (USGS) finds intersex fish in three watersheds of Pennsylvania and shows strong connections between these occurrences and increased pollution in waterways from endocrine-disrupting chemicals. The study, Reproductive Health Indicators of Fish from Pennsylvania Watersheds: Associations with Chemicals of Emerging Concern, examined three species of fish in three separate watersheds of Pennsylvania to assess whether characteristics caused by hormones and hormone-mimicking compounds, such as immature eggs in male fish, were present. In aquatic environments, the presence of these intersex characteristics is widely used as a biomarker for assessing exposure to estrogenic chemicals, as well as anti-androgenic chemicals which inhibit development of male characteristics. Male smallmouth bass from all sites sampled had immature eggs in their testes; prevalence was lowest in the Ohio drainage, intermediate in the Delaware and highest in the Susquehanna. While these findings were disturbing in and of themselves, the study was also able to draw a connection to the increased presence of intersex characteristics and areas of high agricultural use. “The prevalence and severity of the immature eggs in smallmouth bass corresponded with the percent of agricultural land use in the watershed above the collection […]