(Beyond Pesticides, October 30, 2020) The European Union (EU) adopted, in mid-October, a new strategy on chemicals — including pesticides — that seeks to deal with their combined (synergistic) and cumulative impacts on human and environmental health. A highlight of the new strategy is the acceleration of work, already begun across the EU, to address the “chemical cocktail” impacts of pesticides and other chemicals. Human exposures to such “cocktails” can happen through use of multiple different agricultural pesticides that can persist as residues on food, and via industrial processes and consumer products. Beyond Pesticides has insisted for years that, here in the states, the Environmental Protection Agency (EPA) has been way behind the eight ball in dealing with the potential synergistic and cumulative impacts of the pesticides its registers for use. Advocates have argued that the agency must be far more rigorous in evaluating impacts of exposures to multiple pesticides, as well as cumulative impacts. The toxicity problem the EU seeks to address is that interacting chemicals can have synergistic effects, even at very low levels — effects greater than and/or different from the expected impacts of each chemical per se. Pesticides can also have cumulative “toxic loading” effects in both […]

(Beyond Pesticides, October 26, 2020) A high percentage of the disinfectants approved by EPA for use against coronavirus contain quaternary ammonia compounds (quats). EPA’s approved list is used by schools and other institutions—unfortunately, without guidance for avoiding harmful effects. Quats are very toxic. They are especially dangerous in the context of a respiratory pandemic. Quats increase the risk for asthma and allergic sensitization. Evidence from occupational exposures shows increased risk of rhinitis and asthma with exposure to quats. Quats are on the Association of Occupational and Environmental Clinics list of asthmagens and may be a more potent asthmagen than bleach. Tell the EPA and Congress that EPA must not recommend toxic disinfectants without the context of their damaging impacts and other necessary protective measures. One quat, benzalkonium chloride, has also been associated with dermatitis. Quats appear to be sensitizers and irritants to the skin and mucous membranes and are suspected to display an immunologic cross-reactivity between each other and with other chemical compounds containing ammonium ion. Quats also are mutagenic and reproductive toxicants. Some quats have shown to be mutagenic and to damage animal DNA and DNA in human lymphocytes at much lower levels than are present in cleaning chemicals. […]

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

(Beyond Pesticides, October 5, 2020)  Another example of trading health and environmental protection for the support of special interests, EPA announces the misleading and fraudulently named, “EPA Supports Technology to Benefit America’s Farmers.” This time, EPA announces plans to “streamline the regulation of certain plant-incorporated protectants (PIPs).” Named to sow confusion, PIPs are plants engineered with pesticides in them. PIPs are known in general for two problems arising from incorporating pesticidal ingredients into crops: residues that cannot be washed off and production of crop-eating insects that are resistant to the incorporated pesticide that blankets the agricultural landscape.  Tell Congress that EPA needs to listen to science, not pesticide manufacturers and biotech companies that are causing problems for farmers and the environment. This time, EPA is proposing to exempt from regulation certain PIPs created by biotechnological techniques that are cisgenic (using genes derived from sexually compatible species), such as CRISPR. The distinction that EPA seeks to make between cisgenic plants and transgenic plants (in which the gene of interest may come from any species) is not supported by science. In fact, cisgenic techniques make use of genetic material other than the targeted genes, and that may come from species that are not […]

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

(Beyond Pesticides, August 21, 2020) A foundational study of the toxic insecticide chlorpyrifos left critical data out of its analysis, resulting in decades of an Environmental Protection Agency (EPA) “safe exposure limit” that is flat out wrong, new research says. That 1972 study concluded that the amount of the chemical to which a human could be exposed before adverse effects showed up (the “no observed adverse effect level,” or NOAEL) was more than twice as high as should have been determined had the study not ignored critical data. In addition, the study points to the perennial “fox and hen house” issues at EPA, which include using research commissioned, funded, or even conducted by industry as any basis for regulation. For years, Beyond Pesticides has rung the alarm on this very dangerous pesticide, and advocated for its ban nationwide. News of this omission from the 1972 “Coulston Study” comes from a team out of the University of Washington. The researchers re-analyzed that human intentional dosing study using both the original statistical methods and modern computational tools that did not exist in the 1970s. (An important side note: such a study is unethical by current research standards.) The new analysis finds two significant […]

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

(Beyond Pesticides, August 7, 2020) Research out of the Silent Spring Institute identifies 28 registered pesticides linked with development of mammary gland tumors in animal studies. Study authors Bethsaida Cardona and Ruthann Rudel also report that many of the pesticides they investigated behave as endocrine disruptors; breast cancers in humans are significantly influenced by hormones generated by the endocrine system. The Environmental Protection Agency (EPA) acknowledges that nine of these 28 pesticide compounds cause mammary tumors, but dismisses the evidence of the other 19. The results of this research, published in the journal Molecular and Cellular Endocrinology, evince Beyond Pesticides’ long-standing argument that the risk assessment process used by EPA for its pesticide registration process is substantially inadequate to protect human health. The co-authors cite, as the catalyst for this research project, a Cape Cod resident’s outreach to the Silent Spring Institute several years ago, asking for information about the herbicide triclopyr because utility companies wanted to spray it on vegetation below local power lines. (The compound has also been used by the logging industry in the Pacific Northwest.) They reviewed more than 400 EPA pesticide documents on the health impacts of many registered pesticides for this research, conducted as part […]

(Beyond Pesticides, July 30, 2020) Simultaneous exposure to pesticides and noise from agricultural machinery increases farmworkers, risk of hearing loss, according to the study, “Hearing Loss in Agricultural Workers Exposed to Pesticides and Noise,” published in the journal Annals of Work Exposures and Health. Hearing loss is the 3rd most common health issue in the U.S., affecting eight million Americans. Although specific conditions like age, illness, and genetics, can mediate hearing loss, research suggests other factors can induce auricle (ear) damage, including medications, exposure to toxic chemicals (including pesticides), and loud, ongoing noise. Past studies find an association between hearing loss and pesticide exposure or noise exposure, alone. However, this study is one of the first to associate hearing loss with the additive effect to concurrent, persistent pesticide exposure, and noise. This research is significant as human senses are integral to everyday human activities, and it is vital to understand how chronic pesticide exposure can limit the body’s ability to function normally, for farmers and everyone alike. Researchers in the study note, “[I]t is necessary to understand what work-related factors are contributing to this high prevalence of hearing loss in [Thai] agricultural workers in order to develop effective interventions and […]

(Beyond Pesticides, July 17, 2020) Researchers have discovered that the rivers and creeks that discharge into the lagoon of the Great Barrier Reef are riddled with mixtures of pesticides. The University of Queensland team expected to find some such mixtures in their sampling, but was shocked to find that 99.8% of their samples contained up to 20 different pesticides. Michael Warne, PhD, lead researcher and associate professor at the University of Queensland’s School of Earth and Environmental Sciences, says, “The issue with having mixtures of pesticides is that as the number of pesticides increases the impact to aquatic ecosystems generally increases.” Beyond Pesticides has covered waterway pesticide contamination in Europe and the U.S. The organization has long advocated for protective federal regulation that considers potential synergistic and additive threats, to ecosystems and organisms, from admixtures of pesticides — whether in formulated products, or “de facto” in the environment, as this study addresses. The Great Barrier Reef (GBR) Lagoon is the open water of the Coral sea that lies between the reef and the Queensland, Australia coast. The GBR is the world’s largest coral reef system, comprising more than 2,900 individual reefs and 900 islands, and extending across an area of approximately 133,000 square miles. It […]

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

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

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

(Beyond Pesticides, May 8, 2020) At the height of Covid-19 impacts in the Northeast U.S., Massachusetts Governor Charlie Baker (R) and Lieutenant Governor Karyn Polito (R) filed emergency legislation at the Boston State House that would, according to their April 16 press release, “help the Commonwealth more effectively combat diseases transmitted by mosquitoes, including arboviruses like Eastern Equine Encephalitis (EEE) and West Nile Virus (WNV), by authorizing a coordinated, proactive, statewide approach to mosquito control activities.” Protecting the public from such diseases is an important public health mission. However, the Governor’s bill, H.4650, represents an alarming “over-reach” that would give unitary authority to the State Reclamation and Mosquito Control Board (SRMCB) to conduct mosquito control activities, including ineffective and toxic spraying, with virtually no effective oversight or transparency. Beyond Pesticides opposes this bill, whose passage would enable use of pesticides that can have respiratory and immune impacts — increasing health risks for everyone, but especially for the many people already at higher risk from Covid-19, despite the availability of ecological management approaches that eliminate the need for toxic chemicals. H.4650, An Act to mitigate arbovirus in the Commonwealth — was promulgated in response to a Massachusetts Department of Public Health […]

(Beyond Pesticides, April 28, 2020) Roughly a quarter of the global insect population has been wiped out since 1990, according to new research published in the journal Science. Billed as one of the most comprehensive assessments to date, the study finds significant overall insect declines, but notes of some specific bright spots. While variation in the ongoing crisis is to be expected, ultimately the trends in the data show the need for immediate policy and regulatory action to protect the insect world as the foundation of global food webs. The team of European scientists behind the research analyzed 166 studies spread out over 41 countries, and consisting of over 1,600 sites, with data beginning in the mid-1920s. Overall trends found declines in terrestrial insect biomass to be nearly 1% each year (~9% each decade). However, contrasting this data was a bright spot – freshwater insects were found to be increasing at an annual rate just over 1% (~11% each decade). The authors caution, however, that because fresh water covers only 2.4% of the earth’s surface, the increase may not be a good spatial representative of broader trends. While North America appeared to show more significant declines when compared to Europe, […]

(Beyond Pesticides, April 16, 2020) Pesticide exposure in farmland birds is a concomitant of pesticide-treated muesli (cereal) seed commonly planted during winter months, according to research published in Science of the Total Environment by United Kingdom (UK) scientists. Not only do pesticide-treated seeds pose the highest dietary risk to birds, but pesticide-treated seeds also go underreported as farmers often lack knowledge of what pesticides are on the seeds they plant. This study emphasizes the global effects of treated seeds, and their corresponding pesticide exposure, on bird species. Future risk assessments for bird should address these implications when implementing agricultural pesticide policies.  Farmers use of treated seeds exposes farmland birds to pesticides like neonicotinoids (neonics), including clothianidin (CLO). Pesticide residues then accumulate in the birds’ blood. UK scientists examined pesticides in farmland bird blood samples to connect the field-based use of treated seeds to clothianidin exposure patterns. At the time of this study, CLO was the most widely used pesticide on treated winter cereal seeds in the UK. Scientists recorded the presence of neonicotinoid-treated seed in 39 fields of 25 farms after seeding. Camera traps monitored farmland birds’ seed consumption. To measure CLO concentration in treated seed and seedling, scientists used liquid chromatography-tandem mass spectrometry to identify inorganic, organic, […]

(Beyond Pesticides, April 3, 2020) In mid-March, the Environmental Protection Agency (EPA) rolled out new rules for “biological evaluations” — assessments of pesticide risks to endangered plant and animal species that are supposed to be protected under the Endangered Species Act (ESA). The agency’s press release announcing the change is misleadingly titled: “Trump Administration Takes Major Step to Improve Implementation of the Endangered Species Act.” But as the Center for Biological Diversity (CBD) reports, the “revised methods for assessing pesticide risks . . . will allow widespread harm to most of the nation’s most endangered plants and animals.” Beyond Pesticides reviewed the status of pesticide threats to endangered species in November 2019 and provides ongoing coverage of the issue. ESA requires EPA to conduct biological evaluations (BEs) of pesticides to assess their impacts on listed (endangered and threatened) species and their critical habitats. EPA’s new “Revised Method” ignores many of the ways that protected species are commonly hurt or killed by pesticides, and allows the continued marketing and use of pesticides without sensible constraints that would protect those species. CBD cites two examples of ignored impacts: downstream impacts of pesticide runoff into waterways from treated farmland, and the loss of […]

(Beyond Pesticides, March 2, 2020) Deadline today! Tell EPA to Ban Atrazine; Protect Children and Frogs from this Endocrine Disrupting Pesticide. Atrazine, the second most-used herbicide in the U.S., is an insidious poison. Atrazine is known for producing developmental abnormalities in frogs. It also affects the endocrine system and reproductive biology of humans. In addition to its agricultural uses on corn, sorghum, and sugar cane, atrazine is also used on home lawns, school grounds, and parks, where exposure to children is common. Nontoxic alternatives are available for all of these uses. Act today, March 2. Sign the petition demanding that EPA ban atrazine and its cousins simazine and propazine. Act today! Beyond Pesticides will submit comments: Docket: EPA-HQ-OPP-2017-0750 (FRL-10002-92) Petition to EPA’s Office of Pesticide Programs: We have serious concerns with the proposed interim decisions on reregistration of three triazine pesticides: atrazine, simazine, and propazine. These triazines are highly mobile and persistent in the environment and have been linked to numerous adverse health and environmental effects which have motivated numerous public interest campaigns to ban their use in the U.S. as well as in Europe. The Draft Ecological Risk Assessments for the Registration Review of Atrazine, Simazine, and Propazine dated October 5, 2016 […]

(Beyond Pesticides, February 13, 2020) Congress unanimously passed the Food Quality Protection Act (FQPA) in 1996 to increase protections for children from pesticide exposure. Unfortunately, according to a new study published in Environmental Health, the law is not being employed by the Environmental Protection Agency (EPA) to its full capacity. For most of the 59 pesticides reviewed by the study, EPA did not apply an additional FQPA safety factor and thereby missed an opportunity to protect children’s health. In fact, FQPA solidified EPA’s reliance on risk assessment calculations and mitigation measures that consistently fall short of adequate levels of protection because of serious data gaps, a failure to consider exposure to mixtures and synergistic effects, and a bias against consideration of alternatives (alternatives assessment)  that show toxic pesticides to be unnecessary.  FQPA establishes a safety standard applied to all food commodities that considers specific risks for infants and children. The law requires EPA to assess the “aggregate risk” (considering exposure from multiple sources) and “cumulative exposure” to pesticides that have a “common mechanism of toxicity.” FQPA mandates “an additional tenfold margin of safety for the pesticide chemical residue and other sources of exposure shall be applied for infants and children […]

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

(Beyond Pesticides, January 31, 2020) In the latest of a long litany of destructive decisions by the Trump administration, U.S. Environmental Protection Agency (EPA) Administrator Andrew Wheeler announced on January 23 the establishment of a new weaker federal rule on protection of U.S. waterways, which replaces the 2015 Waters of the United States (WOTUS) rule that the agency repealed in September 2019. In an obeisant gesture to industrial interests — the agrichemical, construction, and mining sectors — Mr. Wheeler chose to announce the replacement rule, the Navigable Waters Protection Rule, at a Las Vegas National Association of Home Builders International Builders’ Show. This decision will significantly weaken protections by drastically reducing the number of U.S. waterways and acreage of wetlands protected, and by jettisoning proscriptions on activities that threaten waterways from a variety of pollution harms. President Obama’s WOTUS, aka Clean Water Rule, has provided protections from pesticide runoff and other pollutants to millions of acres of wetlands and thousands of miles of streams. According to Administrator Wheeler, “‘All states have their own protections for waters within their borders, and many regulate more broadly than the federal government. . . . Our new rule recognizes this relationship and strikes the proper […]

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

(Beyond Pesticides, October 31, 2019) Last week the U.S. District Court in San Francisco ruled that the Environmental Protection Agency (EPA) must assess the risk eight toxic pesticides pose to protected organisms: atrazine, carbaryl, methomyl, and simazine as well as rodenticides brodifacoum, bromadiolone, warfarin and zinc phosphide. The plaintiffs, Center for Biological Diversity (CBD) and Pesticide Action Network North America (PANNA) asserted that EPA and its then administrator Scott Pruitt violated duties under the Endangered Species Act (ESA) by not consulting with the Fish and Wildlife Service and National Marine Fisheries Service in registering these pesticides. The history of this case extends over 8 years. Last year, the court rejected EPA’s attempts to dismiss the lawsuit. According to CBD’s press release, “Under the agreement the agency must complete assessments of four pesticides, including atrazine, the nation’s second most-used pesticide, by 2021. Assessments of four rodenticides, including the widely used rat poison brodifacoum, must be finalized in 2024.” Stephanie Parent, an attorney at the Center for Biological Diversity, said “This important step is only the start. We still have work to do to make sure the EPA addresses the harms of all pesticides, as the law requires. EPA was created after […]