(Beyond Pesticides, July 3, 2024) In June, the Vermont legislature officially passed H.706 into law – a bill that narrows and reduces the use of neonicotinoid insecticides and neonicotinoid-treated seeds. The legislature came together to override a veto of the bill issued by Governor Phil Scott (R). Gov. Scott said the bill’s language had “the potential to produce severe unintended environmental and economic consequences–—particularly for Vermont’s dairy farmers.” The advocacy in support of the legislation called for a holistic, systems change approach to legislative priorities that considers economic, ecological, public health, and climate resilience. The Vermont legislation builds on New York legislation, which in turn is inspired by Quebec’s “verification of need” prescription model (a.k.a. emergency exemptions) that has proven to dramatically reduce the use of certain neonicotinoids, yet enables the continued use of toxic pesticides and a legacy of pesticide dependency in land management and crop production. Vermont Bill Building on New York The Vermont Bill (See pages 29 to 44 for final text) mirrors the language of New York’s Birds and Bees Protection Act (S. 1856-A and A. 7640) and adopts New York’s language on timing regarding when critical sections go into effect. The Vermont language contains trigger language that […]

(Beyond Pesticides, July 28, 2024) Most people don’t like bugs, but the fact is that insects form the foundation of human flourishing, both for their ecosystems services, like pollination of food crops, and for their aesthetic joys. But insect populations globally are declining two to four percent a year, with total losses over 20 years of 30-50 percent, according to a new study of the interacting effects of pesticides, climate, and land use changes on insects’ status in the Midwest. Teasing out the relative influence of these stressors has been a major obstacle in determining the causes of the declines and ways to mitigate them. The icon of insect beauty in the U.S. is the monarch butterfly, whose vibrant coloring, elegant form, and spectacular migrations inspire everyone. Beyond Pesticides has covered the distressing decline of these creatures, most recently in the June 24 Daily News. Monarchs prefer milkweed plants, but also visit many other flowers. Milkweed often grows along the margins of fields, so monarchs are widely exposed to pesticides and habitat disturbances associated with agriculture. The new study was published in PLoS One by a team of scientists from the Washington Department of Fish and Wildlife, Michigan State University, […]

(Beyond Pesticides, June 21, 2024) A recent review of the scientific literature, published in Science of The Total Environment, analyzes multiple species of bees on a molecular level to better understand the poisoning mechanisms that could, as the authors see it, inform chemical risk assessments with more precision. The mechanisms “implicated in the tolerance of bees to specific pesticides, and thus as determinants of insecticide sensitivity, … include metabolic detoxification, insecticide target proteins, the insect cuticle and bee gut microbiota,” the authors write. This review references more than 90 studies performed over the last 30+ years, with most being published in the last 5-10 years, as the understanding and importance of molecular determinants of bee sensitivity has emerged. Pollinators, such as bees, provide crucial ecosystem services by pollinating both wild plants and essential crops. The exposure these insects are subjected to threatens their existence, which occurs through pesticide contamination that can lead to impacts on growth and development or even colony collapse.    “While bees have only been exposed to human-made pesticides over the recent past (last 80 years) they have co-evolved with plants and fungi which produce a range of xenobiotics, including plant allelochemicals and mycotoxins,” the authors state. […]

(Beyond Pesticides, June 17, 2024) Every year, Beyond Pesticides announces National Pollinator Week—this year beginning today, June 17—to remind eaters of food, gardeners, farmers, communities (including park districts to school districts), civic organizations, responsible corporations, policy makers, and legislators that there are actions that can be taken that are transformative. All the opportunities for action to protect pollinators, and the ecosystems that are critical to their survival, can collectively be transformational in eliminating toxic pesticides that are major contributors to the collapse of biodiversity. This is why Beyond Pesticides starts most discussions and strategic actions for meaningful pollinator and biodiversity protection with the transition to practicing and supporting organic. In launching National Pollinator Week, Beyond Pesticides makes suggestions for individual actions to increase efforts to think and act holistically to protect the environment that supports pollinators. The impact that people have starts with grocery store purchases and the management of gardens, parks, playing fields, and pubic lands. The introduction of pesticides into our food supply and our managed lands has contributed to a downward spiral that is unsustainable. The good news is that it is now proven that we do not need toxic pesticides to grow food productively and profitably […]

(Beyond Pesticides, June 14, 2024) The influence of the chemical industry over public policy and regulation, especially in agriculture, is glaringly obvious and has little popular support, yet no one can seem to do anything about it. Numerous analyses have detailed the ways this influence is applied—through lobbying and political donations including dark money; industry experts named to regulatory agency scientific advisory boards; and the massive public relations machines that create and sustain public uncertainty using the tobacco industry playbook revealed by Naomi Oreskes and Erik Conway in their 2010 book Merchants of Doubt. A more insidious tendril of industry influence is explained in U.S. Right to Know’s (USRTK) report, released this month, on pesticide manufacturers’ infiltration of the Entomological Society of America (ESA). The report, “Anatomy of a science meeting: How controversial pesticide research all but vanished from a major conference,” examines the ESA’s 2023 annual meeting—its program, sponsorships, presentations, panelists, poster sessions, meet-and-greets, budget, revenue sources, and other aspects of the event. What is revealed is a systematic and comprehensive industry presence throughout the society and its meeting. A direct consequence is the near-elimination of any scientific presentations addressing the effects of neonicotinoid pesticides on insects, particularly bees. […]

(Beyond Pesticides, June 13, 2024) A study published in Conservation Letters, a journal of the Society for Conservation Biology, exposes critical shortcomings in the U.S. Environmental Protection Agency’s (EPA) ecological risk assessment (ERA) process for modeling the risks that pesticides pose to bees and other pollinators. For the study, “Risk assessments underestimate threat of pesticides to wild bees,” researchers conducted a meta-analysis of toxicity data in EPA’s ECOTOX knowledgebase (ECOTOX), an EPA-hosted, publicly available resource with information on adverse effects of single chemical stressors to certain aquatic and terrestrial species. The meta-analysis found that the agency’s approach, which relies heavily on honey bee data from controlled laboratory studies, drastically underestimates the real-world threats from neonicotinoid insecticides (and likely other pesticides) to native bees and other pollinators. The study “challenges the reliability of surrogate species as predictors when extrapolating pesticide toxicity data to wild pollinators and recommends solutions to address the (a)biotic interactions occurring in nature that make such extrapolations unreliable in the ERA process.” Beyond Pesticides executive director Jay Feldman remarked, “EPA’s ecological risk assessment process is fundamentally flawed and puts thousands of bee species at risk of pesticide-caused population declines and extinctions.” Mr. Feldman continued, “This underscores the urgent […]

(Beyond Pesticides, June 5, 2024) Individuals living near chemical-intensive agricultural environments have heightened risk of Alzheimer’s disease relative to the general population, according to a study published earlier this year in Psychiatry Research. This finding builds on existing peer-reviewed studies that document the relationship between chronic pesticide exposure and elevated risk of neurodegenerative disorders including Alzheimer’s disease, as well as Parkinson’s disease, dementia, multiple sclerosis (MS), and Huntington’s disease. In light of the mountains of scientific evidence, advocates continue to demand for a wholesale transformation of agricultural and land management systems to one based in organic principles in alignment with the U.S. National Organic Program. Study Analysis This study was published online on May 1, 2024 with the full entry to be published in July 2024. The researchers are physicians, health professionals, and professors at the University of Almeria in southern Spain, specifically working in the Health Research Center and the Department of Nursing, Physiotherapy and Medicine. There is also a researcher, Cristofer Ruiz-González, who works at the Torrecárdenas University Hospital also located in Almeria, Spain. Researchers gathered case information from over 40,000 patients between 2000 and 2021 living in demarcated health care districts with high and low levels of […]

(Beyond Pesticides, June 4, 2024) A study published in the most recent edition of the journal Ecotoxicology and Environmental Safety documents for the first time the presence of the herbicide glyphosate in human sperm. The study looked at 128 French men with an average age of 36 years who tested positive for glyphosate in their blood. Seventy-three out of the 128 men were found to also have glyphosate in their seminal plasma. Not only that, the amount of glyphosate in seminal plasma was nearly four times higher than what was detected in the blood.   Methods  The study involved a population of 128 infertile French men from whom seminal and blood plasma samples were collected. The study was conducted at the “Pole Santé Léonard de Vinci” medical center, located centrally near Tours, France. This region is recognized for its urban characteristics as well as being a major agricultural hub, particularly for grain and wine production. The study authors note, “This area reflects the common herbicide exposure in France” and the district ranks third highest in terms of pesticide purchases. While additional qualitative data was collected, only 47 of 128 participants fully completed a questionnaire about their profession, diet (organic or […]

(Beyond Pesticides, May 24, 2024) Even allegedly “low-toxicity” pesticides such as flupyradifurone (insecticide), azoxystrobin, and difenoconazole (fungicides) pose adverse health effects to solitary ground-nesting squash bees (Xenoglossa pruinose), according to a study published in Biological Sciences. Fungicide exposure led to less pollen collected per flower, while exposure to flupyradifurone (FPF) produced larger offspring (which make it more challenging for them to fly). Simultaneous exposure to the three pesticides “induced hyperactivity in female squash bees relative to both the control and single pesticide exposure, and reduced the number of emerging offspring per nest compared to individual pesticide treatments.” With United Nations Food and Agriculture Organizations-sponsored World Bee Day earlier this week, now more than ever advocates are calling for the elimination of toxic insecticide classes, such as neonicotinoids and butanolides, and their wholesale replacement with organic land management principles. This study was written by Sabrina Rondeau, PhD, postdoctoral Fellow in the Department of Biology at the University of Ottawa, and Nigel E. Raine, PhD, professor at University of Guelph’s School of Environmental Science. Published on March 20, 2024, the researchers delve into the individual and co-exposure impacts of two fungicides and one insecticide, which is important, given the documented synergistic effects […]

(Beyond Pesticides, May 16, 2024) In a recent study at the Institute of Biochemistry and Molecular Biology at Ulm University in Germany, published in Current Research in Toxicology, scientists exposed embryos of South African clawed frogs (Xenopus laevis) to three neonicotinoids (NEOs), which led to developmental effects down to a molecular level. These frogs are a well-established model species often used in ecotoxicology studies as bioindicators for overall environmental and ecosystem health. When amphibian species like Xenopus laevis are exposed to contaminants in the water, it leads to negative impacts in the food chain and harms biodiversity. The study concludes that exposure to NEOs directly or through contaminated water leaves entire ecosystems vulnerable.    The NEOs that the embryos were subjected to include imidacloprid (IMD), thiamethoxam (TMX), and its metabolite clothianidin (CLO). NEOs are a class of insecticides that target the central nervous system of insects and lead to death. These insecticides pose a potential hazard to nontarget organisms, such as animals and humans, since they are persistent in the environment and “are found in natural waters as well as in tap water and human urine in regions where NEOs are widely used,” this study states. The authors continue by […]

(Beyond Pesticides, May 13, 2024) A study published in Environmental Research finds that “early life organophosphate pesticide exposure has been linked with poorer neurodevelopment from infancy to adolescence.” Researchers in this study acknowledge that there is still much more to be done in furthering understanding of “neural mechanisms underlying these associations,” and yet there is “notable consistency” in their Center for the Health Assessment of Mothers and Children of Salinas (CHAMACOS) birth cohort study. This study’s findings are consistent with decades of substantial, peer-reviewed scientific literature documenting the adverse health impacts of organophosphate pesticides on public and ecological health. Organic advocates believe that a transition away from chemical-intensive agriculture and land management is the most viable solution to avoid adverse health impacts and end reliance on toxic chemicals in households and communities. The researchers for this study are based at the University of California, Berkley (Center for Environmental Research and Community Health as well as Center for Interdisciplinary Brain Sciences Research), Department of Public Health at University of California, Merced, and Stanford University (Departments of Radiology and Pediatrics in the School of Medicine). “We have reported associations of prenatal [organophosphate] exposure with poorer cognitive function and executive function, and more attention and […]

(Beyond Pesticides, April 26, 2024) Researchers build on existing research when assessing the relationship between long-term exposure to organophosphorus pesticides—widely used in food production and homes and gardens—and the human gut microbiome. In a new study published in Environmental Health, an interdisciplinary research team from University of California, Los Angeles determined, “that exposure to [organophosphorus pesticides] is associated with changes in the abundance of several bacterial groups and differential functional capacity in metabolic pathways supported by the human gut microbiome.” The study draws upon data from a “Parkinson’s, Environment and Gene study (PEG)” in which 190 participants were asked to submit fecal samples and answer interview questions. “[The study] was initially designed to investigate the etiology of Parkinson’s disease (PD) and participants were recruited in two study waves [‘over the full 10-year exposure window’]: 2001–2007 and 2012–2017. At baseline, [Parkinson’s disease] patients were diagnosed within the past 5 years and randomly selected community controls were also recruited,” the research team shares in their Methodology section. “Since 2017, we invited previous study participants who could be contacted to enroll in a pilot study of the gut microbiome. In addition, we invited a household or community member of [Parkinson’s] patients to participate.” […]

(Beyond Pesticides, March 29, 2024) Last week during National Agriculture Week, U.S. Senator Ben Ray Luján (D-NM) introduced S.4038, the Children’s Act for Responsible Employment and Farm Safety (CARE), aiming to elevate labor standards for young workers in the agricultural sector, as protection from pesticides remains weak. Currently, agriculture stands as the sole industry that permits children—as young as 12 years old—to work without significant limits on their hours of employment outside of school time. This scenario is a reality for hundreds of thousands of children across the U.S., who undertake the demanding tasks of planting, harvesting, processing, and packaging the food produced nationwide. The CARE Act proposes to align the age and working hour criteria for underage workers in agriculture with those enforced in other sectors. Additionally, the legislation seeks to toughen both civil and criminal penalties for violations of child labor laws and to enhance safeguards for children against the risks of pesticide exposure. It is important to note, however, that the CARE Act would exempt farm-owning families, allowing their children to work on the family farm under the current guidelines. Exemptions to the Fair Labor Standards Act (FLSA) currently allow children to work unlimited hours, outside of school  hours, […]

(Beyond Pesticides, March 11, 2024) Inside a recent disagreement between the Office of the Inspector (OIG) and the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) on the agency’s review of pet flea and tick collars—leading to thousands of deaths and poisonings—is a basic question of the adequacy of pesticide regulation. The disagreement is over the cause of 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury, and the February 2025 OIG report’s conclusion that “[EPA] has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” While the disagreement focuses on a number of EPA process failures, Beyond Pesticides urges that the findings advance the need for the agency to address a key element of chemical mixtures in pesticide products not currently evaluated, potential synergistic effects—the increased toxic potency created by pesticide and chemical combinations not captured by assessing product ingredients individually.  Key to the dispute is what many see as a foundational failure of EPA to evaluate the effect of pesticide mixtures and full formulations of pesticide end products, a longstanding criticism of the agency’s pesticide registration process, which focuses on pesticide products’ active […]

(Beyond Pesticides, March 8, 2024) A major problem has vexed pesticide regulators and researchers for decades: Humans and other organisms almost always have multiple pesticides in their bodies, but techniques for assessing their combined effects, or cumulative body burden from multiple chemical classes are not typically available. A new study from Chinese and British researchers provides the first combined assessment of multiple classes of pesticides in human blood. The authors believe they are the first to develop a way to quantify multiple types of pesticides in human serum (clear liquid part of blood) as opposed to urine or from other sample collection methods. This is a tool that authors say is a more accurate way of assessing the real world exposure and ultimately the adverse impact of pesticide use on human health. The researchers had a small sample of 31 men and 34 pregnant women in Wuxi, China. They chose 73 pesticides and a few of their breakdown products to identify from three categories: fungicides, neonicotinoid insecticides, and triazine herbicides. Their testing protocol confirms their expectation that food—primarily produce—is the major source of pesticide exposures. This result reinforces Beyond Pesticides’ mission of supporting the shift in agriculture to pesticide-free methods […]

(Beyond Pesticides, February 29, 2024)  In the face of federal inaction, an Oregon regulation banning the agricultural uses of the highly toxic chlorpyrifos took effect on January 1, 2024. Chlorpyrifos was voluntarily withdrawn from the market in 2000 for most residential uses by its manufacturer, Dow Chemical, and has been the subject of extensive litigation. At that time, the U.S. Environmental Protection Agency (EPA) allowed most agricultural uses to continue. Oregon joins four other states that have acted to ban chlorpyrifos, including Hawai’i, New York, California, and Maryland.   Central to state action are nervous system and brain effects in children, especially farmworker children. Chlorpyrifos is banned in 39 countries, including the European Union (see here for more Beyond Pesticides coverage). State action has become important since the November 2023 decision by the U.S. Court of Appeals for the 8th Circuit, which overturned the EPA rule revoking all food tolerances for chlorpyrifos, an effective ban on chlorpyrifos use. The final EPA rule, issued in August 2021, came in response to a 9th Circuit Court of Appeals ruling that found the agency’s inaction on chlorpyrifos unlawful. The case was filed by Earthjustice, on behalf of public health, labor, and disability organizations.  The […]

(Beyond Pesticides, February 28, 2024) The U.S. Environmental Protection Agency (EPA) is putting on hold its Vulnerable Species Project (VSP) after vociferous comments from the petrochemical pesticide industry to instead, “create a narrow, tailored policy rather than a sweeping, burdensome one,” according to a recent op-ed in the Wall Street Journal. Upon heavy pushback from the petrochemical pesticide industry and agribusiness, EPA is hosting a variety of workshops and openings for the public to provide feedback not just on VSP, but the Endangered Species Act (ESA) Workplan the Biden Administration originally introduced in 2021 in its entirety. Advocates are calling for the strengthening of pesticide regulation given the impending decisions that may shape the fate of ESA-FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) compliance for years to come. As EPA continues through its pesticide registration program to advance continued dependency on pesticides through its interpretation of FIFRA, despite the availability of nontoxic alternatives, endangered species extinction and biodiversity collapse has never been a high priority. While EPA has initiated efforts to address a significant backlog of pesticide evaluations, Civil Eats has reported that the agency faces a task so extensive that it may require several additional decades to fully catch up. EPA officials stated, “Even if EPA completed […]

(Beyond Pesticides, February 23, 2024) The latest string of billion-dollar plaintiff judgments against Bayer/Monsanto, the maker of Roundup™ with active ingredient glyphosate, does not yet signal a capitulation by Bayer or a win for public health or the environment in the United States. A jury award of $2.25 billion, the largest to-date, was handed down in Philadelphia in January. As Beyond Pesticides reported previously, Monsanto has a long history of challenging scientific findings on Roundup/glyphosate and evidence of harm to human health, the environment, and crops themselves (see resistant super weeds here and here), as it seeks to avoid liability claims by those suffering from cancer.  Bayer Looking to State Legislatures for Protection from Lawsuits  As result of its failure in quash lawsuits, Bayer has moved its case to state legislatures, where it is seeking the adoption of statutes that preempt liability claims by damaged parties.  As reported by Beyond Pesticides, a rash of state legislation has been introduced in Idaho, Iowa, Missouri, and Florida, which would block plaintiff liability claims when pesticide products, like Roundup, cause harm. The chemical industry pushes the notion that the registration of its pesticide products with the U.S. Environmental Protection Agency (EPA) is a […]

(Beyond Pesticides, February 15, 2024) The latest U.S. Department of Agriculture (USDA) pesticide residue report, the 32nd Pesticide Data Program (PDP) Annual Summary report, released in January, finds that over 72 percent of tested commodities contain pesticide residues (27.6 percent have no detectable residues), mostly below the level the U.S. Environmental Protection Agency (EPA) has set for tolerances (allowable residues) whose safety standards have been called into question by advocates. USDA spins its report findings as a positive safety finding because, as the Department says, “[m]ore than 99 percent of the products sampled through PDP had residues below the established EPA tolerances.” USDA continues, “Ultimately, if EPA determines a pesticide use is not safe for human consumption, EPA will mitigate exposure to the pesticide through actions such as amending the pesticide label instructions, changing or revoking a pesticide residue tolerance, or not registering a new use.” As Beyond Pesticides reminds the public annually when USDA uses the report to extol the safety of pesticide-laden food, the tolerance setting process has been criticized as highly deficient because of a lack of adequate risk assessments for vulnerable subpopulations, such as farmworkers, people with compromised health or preexisting health conditions, children, and perhaps, […]

(Beyond Pesticides, February 9, 2024) EPA is accepting public comments through today, Friday February 9, on its long-held policy of exempting “treated objects,” including seeds and paint, from pesticide registration. Although EPA does not ask the most important question—“Should pesticide-treated seeds and paint be exempt from the scrutiny given pesticide products?”—this comment period offers an opportunity to respond to EPA’s questions and express concern about hazards associated with chemical use and product ingredients. Despite exposure patterns associated with the use of pesticides in treated objects that are linked to environmental contamination and human poisoning, EPA is focused on labeling and not regulation. Instead of focusing on the exposure and harm associated with the object’s use—whether treated seeds poison pollinators, soil, and water or whether paint treated with fungicides poisons people exposed to the paint—EPA takes the position that unless the manufacturer makes a pesticidal claim, the object is not regulated as a pesticide for its pesticidal effects.  Beyond Pesticides states: At the very least, if EPA deems the hazards associated with the use of the pesticide in the treated article acceptable, then the agency should disclose the chemical used in the treatment (of the seed or the paint) and require […]

(Beyond Pesticides, January 25, 2024) Legislative efforts to curtail some life-threatening pesticides associated with birds and bees (and other pollinators) decline were weakened in New York State at the end of December 2023 as the governor negotiated and stripped elements of a bill relating to agriculture that had passed the legislature—again illustrating the grip of the agrichemical industry on public policy intended to begin to address the crisis in ecosystem collapse. (See “Study Cites Insect Extinction and Ecological Collapse.”) In passing the Birds and Bees Protection Act, New York joined New Jersey, Nevada, and Maine in banning most nonagricultural uses of neonicotinoid (neonic) insecticides, but, in last-minute changes to avoid the governor’s veto, failed to phase out corn, soybean, and wheat seeds coated with these chemicals. [Pointing to an exemption in federal law that has been challenged by advocates, the U.S. Environmental Protection Agency (EPA) does not regulate treated or coated seeds as pesticides despite their toxic pesticidal properties.] In New York State, the governor can, in consultation with the leadership of the legislative branch, negotiate language changes (called Chapter Amendments) in legislature-passed legislation (originally enacted) before deciding to sign it into law or can simply choose to veto the legislation. […]

(Beyond Pesticides, January 16, 2024) The U.S. Environmental Protection Agency (EPA) has long been criticized for its failure to evaluate the effectiveness (or efficacy) of all the pesticides it registers. A petition, for which there is now an open public comment period (submit comments by January 22, 2024), challenges what advocates call a basic failure of the agency to evaluate the claimed benefits of pesticides. Because of this long-standing situation, those who purchase pesticides do not know that the pesticides they buy will meet expectations for control. For farmers, that means that EPA has not evaluated whether the pesticide’s use actually increases productivity of the treated crops and/or whether over time the target pest (weed, insect, fungus) will become resistant. For consumers, it also means that there is not an independent analysis of whether the pesticide products work. As EPA implements the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), not only is there no agency assessment of whether the pesticide’s use will achieve its intended purpose, there is not a determination as to whether there is a less toxic way of achieving the pest management goal. As Beyond Pesticides cited last year, a piece published in the Proceedings of the […]

(Beyond Pesticides, December 19, 2023) Last week, farmworker organizations and Beyond Pesticides, represented by the Center for Food Safety, filed a petition with the U.S. Environmental Protection Agency (EPA) urging that the weed killer glyphosate be removed from the market. The petition cites 200 studies, which represent a fraction of the independent scientific literature on the hazards of glyphosate and formulation ingredients of glyphosate products. This action follows previous litigation in 2022 in which a federal court of appeals struck down EPA’s human health assessment, finding that the agency wrongfully dismissed glyphosate’s cancer risk. The farmworker groups petitioning include Farmworker Association of Florida, Organización en California de Lideres Campesinas, Alianza Nacional de Campesinas, and the Rural Coalition.   Meanwhile, verdicts against glyphosate’s manufacturer, Bayer, continue to pile up with a December jury verdict in Pennsylvania awarding $3.5 million and a November jury in Missouri ordering $1.56 billion to be paid to four plaintiffs. All link their cancer to use of the Roundup. Bayer has lost almost all of the cases filed against it for compensation and punitive damages associated with plaintiffs’ charge that its product (previously manufactured by Monsanto) caused them harm.  The petition summarizes its purpose and justification as […]