(Beyond Pesticides March 23, 2016) Last week, the Vermont House of Representatives passed a bill that authorizes state  regulation of pesticide-treated products,  including  telephone poles and coated seeds, that are exempt from federal pesticide regulations. H.861 is the latest in a string of laws introduced this legislative session in Vermont to address the impact of harmful neonicotinoid insecticides  on Vermont’s ecology and agriculture, and symbolizes a concentrated effort by the legislature to reverse pollinator declines within the state. If passed by the Senate and signed by the governor, the bill will  allow the Secretary of Agriculture to regulate above and beyond current federal laws, which exempt treated articles from regulation completely, and write appropriate rules in response to recommendations from a state Pollinator Protection Committee. The bill, which passed with wide support in the House, gives the Vermont Agency of Agriculture, Food and Markets the authority to regulate “treated articles,” a term coined by the Environmental Protection Agency (EPA) to denote products treated with pesticides, such as utility poles, commercial crop seeds, and lumber. Traditionally, EPA gives rulemaking authority over pesticides to states, but that authority does not extend to products pre-treated with pesticides, which, until this point, has posed […]

(Beyond Pesticides, March 15, 2016) Executive agencies are falling short in their efforts to protect honey bees and other wild pollinators from catastrophic declines, according to a new report from the U.S. Government Accountability Office (GAO). GAO, an investigative agency that works on behalf of the U.S. Congress, was tasked by the Senate to evaluate the progress the Environmental Protection Agency (EPA) and U.S. Department of Agriculture (USDA) have made in their actions to address the multiple threats contributing to declining managed and wild pollinators. Since 2006, U.S. beekeepers have experienced unsustainable colony die-offs, averaging over 30% each year. Concurrent declines in wild and native pollinators are also occurring, though data on the magnitude of these losses have not undergone comprehensive scientific evaluation. While a range of factors, from habitat loss, to climate change, diseases, viruses, and parasites are all contributing to these declines, independent science has identified that pesticides, specifically a new class of systemic insecticides called neonicotinoids, are the major drivers of the crisis for both managed and wild bees. In fact, some studies show that the widespread exposure to neonicotinoids increases bees’ vulnerability to diseases, viruses, and mites. The GAO report recommends a number of action items […]

(Beyond Pesticides, March 8, 2016) A vast majority of German citizens are contaminated with the herbicide glyphosate, according to a report from the Heinrich Boll Foundation. The findings come just one week after another environmental group in Germany, the Munich Environmental Institute, found traces of the popular weed killer in popular German beers. The results of this study add concern to EU-wide deliberations regarding the renewal of glyphosate’s registration. According to the study, 99.6% of the 2,009 German citizens monitored have some level of glyphosate found in their urine. Over 75% of these individuals have  concentrations that are higher than the EU’s legal level for glyphosate in drinking water. Further, children up to age 19 are found to exhibit  higher levels of urinary glyphosate than older adults. Individuals living near agricultural areas also show elevated concentrations compared to those that did not. Given recent data finding glyphosate to be the most widely used herbicide on the globe, it is not surprising that the chemical is near ubiquitous in human bodies. Similar results are expected in the United States. A pilot study conducted by the group Moms Across America in 2014 found that glyphosate may also bioaccumulate in the human body, […]

(Beyond Pesticides, February 29, 2016) Last Thursday, the Munich Environmental Institute stated that it had found traces of glyphosate, the widely used and controversial weed-killer, in 14 of Germany’s most popular beers. These findings are a potential blow to Germany’s Beer Purity Law, which is highly regarded in German beer culture. Industry and German government immediately sought to downplay the results, saying that the levels found did not pose a risk to humans. However, according to the study’s results, all levels found were above the glyphosate residue level allowed in drinking water. Consumers have a right to be worried about the findings, as glyphosate was classified in March 2015  as a probable carcinogen by the International Agency for Research on Cancer (IARC). The results, published  in German, are broken down by beer and by micrograms per liter in picture format. The researchers cite the laboratory test results of the 14 beers, which found glyphosate levels  between 0.46 and 29.74 micrograms per liter. The highest reading is 300 times the legal limit for drinking water in Germany, which is 0.1 microgram per cubic meter. Hasseroeder, a beer brewed in Saxony-Anhalt in eastern Germany and owned by Anheuser Busch Inbev, contained the […]

(Beyond Pesticides, February 25, 2016) Feminine care products sold in France may contain “potentially toxic residues,” according to a study conducted by 60 Millions de Consommateurs, a French consumer rights group. The study finds  traces of chemicals, such as dioxins and insecticides, in 5 of 11 products tested. A separate analysis conducted by Corman, a manufacturer of feminine care products, also finds  residues of the weedkiller glyphosate, which was classified in March 2015  as a probable carcinogen by the International Agency for Research on Cancer (IARC). Researchers at 60 Millions  reported finidng traces of halogenated waste, a by-product related to the processing of raw materials, in Tampax Compak Active Regular Fresh tampons. The researchers also detected residues of organochlorine and pyrethroid pesticides, linked to a wide range of adverse health impacts, in some Always sanitary towels. Highly toxic dioxins, which can be cause cancer, reproductive and developmental problems and damage the immune system, according to the World Health Organization, were also found in products by OB and the European Nett brands. Corman, which makes Organyc panty liners, told the Agence France-Presse (AFP) news agency that it conducted its own analysis that confirmed the trace amounts of glyphosate, the active ingredient […]

(Beyond Pesticides, February 22, 2016) A scientific review was released last week by a group of fourteen scientists in which they expressed concern over the widespread use of glyphosate-based herbicides (GBHs), the lack of understanding regarding human exposure, and the potential health impacts. Along with the reasons for concern, the scientific panel called for increased government scrutiny of glyphosate and further testing. In an excerpt from the review, the scientists’ state that,“A thorough and modern assessment of GBH toxicity will encompass potential endocrine disruption, impacts on the gut microbiome, carcinogenicity, and multigenerational effects looking at reproductive capability and frequency of birth defects.” The study, published in the journal Environmental Health, was authored by 14 health scientists mostly from universities. Pete Myers, founder and chief scientist at Environmental Health Sciences is the lead author of the report. “It’s time to call on the global science and regulatory community to step back and take a fresh look at glyphosate since everyone on the planet is or will be exposed,” said senior author Charles Benbrook, an agricultural economist and consultant at Benbrook Consulting Services. According to the report, federal health agencies, such as the U.S. National Toxicology Program, the U.S. Centers for Disease […]

(Beyond Pesticides, February 19, 2016) Pesticide mixtures are more harmful than individual pesticides, according to a University of California, Los Angeles (UCLA) study that focuses on three commonly used fumigants — chloropicrin, Telone, and metam salts. The study also concludes that, while California law requires the Department of Pesticide Regulations (DPR) and county agricultural commissioners to assess these kinds of cumulative risks when regulating pesticides, they have so far failed to do so. The report, titled Exposure and Interaction — The Potential Health Impacts of Using Multiple Pesticides: A Case Study of Three Commonly Used Fumigants, was published by the Sustainable Technology and Policy Program, based in the UCLA School of Law and the UCLA Fielding School of Public Health. The case study of the three fumigants, which are commonly applied together in California on high value crops, such as strawberries, tomatoes, tree nuts, and stone fruits, finds that: These pesticides may interact to increase the health risk for California farm workers and residents, Workers and residents are regularly exposed to two or more of these pesticides simultaneously, and DPR does not regulate the application of multiple pesticides to prevent or decrease risks to human health, despite having authority to […]

(Beyond Pesticides, February 18, 2016) Last week, 35 members of Congress, led by Representatives Earl Blumenauer (OR-3) and Peter DeFazio (OR-4), signed a letter to Environmental Protection Agency (EPA) Administrator Gina McCarthy, challenging  EPA’s review process for the  glyphosate  and  2,4-D  herbicide mixture, known as Enlist Duo. It is produced by Dow AgroSciences for use in genetically engineered  crops. The letter requests “more information about EPA’s plan to reevaluate Enlist Duo’s health and environmental risks.” The letter comes just weeks after the 9th U.S. Circuit Court of Appeals denied a request from EPA to vacate its own decision to  approve the  toxic herbicide cocktail. Because of the court’s decision, EPA is solely responsible for the decision about Enlist Duo’s registration. “This is part of a vicious cycle that is leading to more potent, dangerous chemicals being widely used on crops across the United States,” said  Rep. Blumenauer. He continued, “With the rise of herbicide-resistant genetically modified crops, herbicides are more widely sprayed causing weeds to grow more resistant — ultimately, requiring the application of even stronger herbicides. EPA must take action to make sure products entering the market to be used on our food are safe for human health and […]

(Beyond Pesticides, February 12, 2015) A new study published last week asserts a viral epidemic driven by parasitic mites is contributing to the global decline in bees, problematically underplaying the significant impact that bee-toxic neonicotinoid insecticides have on pollinator populations, as supported by a growing body of scientific literature, especially findings that show bees’ increased vulnerability to parasites and viruses. Researchers of the study, titled “Deformed wing virus is a recent global epidemic in honeybees driven by Varroa mites” and published in the journal Science, conclude that the deformed wing virus (DWV), which is typically transmitted through its main vector, the Varroa mite, is globally distributed and recently spread from a common source, European honeybee Apis mellifera. Lead researcher Lena Bayer-Wilfert, PhD, of the University of Exeter, said European bees are at the heart of the global spread of what she calls a “double blow” for colonies. “This is clearly linked to the human movement of honey bee colonies around the globe,” she told BBC News. Co-researcher Professor Roger Butlin of the University of Sheffield said DWV was a major threat to honey bee populations across the world with the epidemic “driven by the trade and movement of honeybee colonies.” […]

(Beyond Pesticides, January 29, 2016) This week, the 9th U.S. Circuit Court of Appeals handed a victory to Dow Chemical Company and its  efforts to keep the toxic pesticide Enlist Duo on the market, despite new safety concerns identified by the Environmental Protection Agency (EPA).  Enlist Duo has been marketed as a “solution” for the control of glyphosate-resistant weeds in genetically engineered (GE) crops, brought on by the  widespread use of Monsanto’s  Roundup  on glyphosate-tolerant (Roundup Ready) crops over the last decade. EPA asked the court at the end of November, 2015 to vacate its 2014 approval of Enlist Duo based on new information on the  toxic effects associated with the synergistic interactions of  the chemical cocktail of 2,4-D, glyphosate, and other undisclosed ingredients in the product to plants outside the treated area, including endangered plants. The three-sentence order, which does not include  the judge’s reasoning, denied EPA’s request. While considering other legal options, EPA can choose  to exercise it administrative powers by  canceling specific uses or the entire  registration of Enlist Duo under  its pesticide cancellation process, and within that process could choose to identify an imminent hazard and remove the pesticide from the market immediately, while it faces […]

(Beyond Pesticides, January 21, 2016) The Pest Management Regulatory Agency (PMRA) of Health Canada announced Tuesday that it intends to discontinue the granting of new conditional registrations under the Pest Control Products Act. In the U.S., conditional registrations have been controversial because they allow pesticide use  without complete data, as was the case with the neonicotinoid insecticide chlothianidin, linked to the decline in bee health. A startling number of pesticides, nearly 65% of the more than 16,000 pesticides now on the market, were first approved by the process of “conditional registration,” a loophole in which EPA allows new pesticides on the market without the full range of legally mandated toxicity tests.   Currently, the Pest Control Products Regulations grants conditional registration for pesticides only when “the review of the scientific data and information is sufficient to determine that the risks of a pesticide are acceptable, but PMRA requires additional information, such as monitoring data after a product registration, to confirm the results of models used in the risk assessment.” Because this change will only affect new registration applications and less than  one percent of all existing pesticide registrations in Canada are conditional, this action is unlikely to have a large […]

(Beyond Pesticides, January 14, 2016) Bayer CropScience, revising its stance,  has decided to concur with the  Environmental Protection Agency’s (EPA) preliminary risk assessment of neonicotinoids and acknowledge the finding of harm to honey bees in certain crops. A spokesman for Bayer CropScience said the neonic-selling giant has reviewed the assessment and found it to be “quite good and scientifically sound,” according to a news report.  The Guardian  is reporting that Bayer will be proposing new protections for pollinators, however the company has not yet announced what the new protections will be. This is a stark turnaround from  Bayer’s statement last week, which said EPA’s assessment “appears to overestimate the potential for harmful exposures in certain crops, such as citrus and cotton, while ignoring the important benefits these products provide and management practices to protect bees.” Last week, EPA released its preliminary honey bee risk assessment for one of the most widely used neonicotinoids, imidacloprid, which is  linked to severely declining honey bee populations. The assessment found  harmful residues of the insecticide  in crops where the pollinators forage  and confirmed bees’ widespread and sustained exposure to the highly toxic and persistent chemical through poisoned pollen and nectar. Imidacloprid, like the other […]

(Beyond Pesticides, November 24, 2015) The Canadian province of Quebec has announced plans for a major overhaul of its pesticide laws in order to protect pollinators, public health and the wider environment. Canadian provinces, particularly Quebec and Ontario, have long led the way in crafting common sense pesticide legislation that responds to sound science on the dangers of these chemicals. The proposed reforms will focus on further restricting the most toxic pesticides allowed for use in both agriculture and residential pest control, including atrazine, chlorpyrifos, and the neonicotinoid class of insecticides, which are  widely implicated in pollinator declines. “Québec has made progress in recent years with respect to responsible pesticide management,” said the Quebec Minister of Sustainable Development, Environment and the Fight Against Climate Change. “However, the time is  right to intensify our efforts and become even more proficient at reducing the risks to health and the environment that are associated with pesticide use, particularly by supervising the use of highest-risk pesticides like neonicotinoids, which have a recognized major effect on bee mortality.” Quebec’s Pesticide Strategy 2015-2018  is structured  to incentivize farmers and home gardeners to choose lower risk pesticides through economic motivators such as levies, permits, and compensation fees. […]

(Beyond Pesticides, November 19, 2015) French scientists say that they have found the “missing link” between laboratory studies and field studies that assess the adverse effects of neonicotinoid (neonic) insecticides on bees. The study, published in Royal Society Journal Proceedings B, evaluates the effects of neonics on honey bees in field trials. After 15 years of research into the effects of neonicotinoids on bees, researchers had identified a gap between the results of toxicity assessments on individual bees in the laboratory and  impacts seen at the colony level in the field. The new two-year study made two discoveries: First, they found that field exposure to thiamethoxam combined with imidacloprid contamination is associated with a significant excess mortality in individual free-ranging bees.  Second, while colonies appeared to be able to compensate for the excess mortality and preserve population size and honey production, this was done at the expense of a change in brood laying patterns. Thus, this study provides an explanation for the “missing link” in the discrepancies between labs studies and field studies, where the former establishes harmful and fatal effects that had yet to be replicated in real-life conditions. Because the bees responded to the increased mortality with selective […]

(Beyond Pesticides, November 2, 2015) The Center for Biological Diversity (CBD) submitted a formal notice last week for intent to sue the Environmental Protection Agency (EPA) for approving benzovindiflupyr, a fungicide that is highly toxic to fish and aquatic invertebrates. CBD asserts that EPA recognized that benzovindiflupyr could harm wildlife and critical habitat protected by the Endangered Species Act (ESA), but approved it for use without consulting with expert wildlife agencies as required by the act. This is  not the first time that EPA has approved toxic chemicals without fully understanding the consequences. On August 28, 2015, EPA granted broad approval for use of benzovindiflupyr on most crops, including cereals, corn, vegetables, fruits, turf grass and ornamentals. The agency’s own data show that benzovindiflupyr is highly persistent in the environment and will build up in waterways due to runoff from treated fields. Nonetheless, EPA approved benzovindiflupyr for immediate use. “This pesticide is highly poisonous to fish and other wildlife, but the EPA approved it anyway,” said Stephanie Parent, senior attorney at the Center for Biological Diversity, in their press release. “This agency’s cavalier approach to approving new toxic chemicals without required consultation or studies must end. The EPA’s indifference is […]

(Beyond Pesticides, October 20, 2015) Exposure to neonicotinoid (neonic) pesticides results in profound negative impacts to the health of honey bee queens, according to an international team of researchers led by Geoff Williams, MD, PhD, at the University of Bern in Switzerland. While most studies to date have investigated how neonics effect the health of individual workers or overall colony fitness, Dr. William’s study, Neonicotinoid pesticides severely affect honey bee queens, is one of the first to focus on the health of honey bee queens. Neither the European Union nor U.S. Environmental Protection Agency (EPA) study the impacts of pesticides on queen health before allowing a pesticide to market. The results of this research are particularly concerning, given widespread anecdotal evidence from beekeepers across the globe that ”˜poor quality queens’ are playing a role in bee declines. To test the impacts of these chemicals on queen honey bees, scientists exposed a sample of 29 queens to field-realistic levels of the neonics  clothianidian and thiamethoxam (1 parts per billion and 4 ppb respectively), and compared them to a population of 28 control queens, which were not treated with neonics. Both groups experienced similar environmental circumstances in terms of food availability, rearing […]

(Beyond Pesticides, October 9, 2015) Last week, the Environmental Protection Agency (EPA) released preliminary human health and ecological risk assessments for seven organophosphate pesticides (OPs) and announced the public open comment period for those chemicals. These risk assessments come as a result of the required periodic registration review, as required by  the Federal Insecticide, Fungicides, and Rodenticide Act. In general, OPs are highly toxic and many have been voluntarily removed from the market, considerably restricted, or denied reregistration. Unfortunately, EPA continues to rely on risk mitigation for individual OPs instead of phasing them out altogether. Seven OPs ­ ­—dimethoate, dictrotophos, chloyrophos-methyl, tribufos, terbufos, profenofors, and ethoprop—are among the first wave of chemicals whose preliminary risk assessments have been completed under the registration review program. Each of these was found by EPA to inhibit the enzyme acetylcholine esterase (AchE), which ultimately leads to neurotoxic  central nervous system effects. This information is not new, however. In 2012, University College London found long-term low-level exposure to OPs produces lasting damage to neurological and cognitive functions. In 2013, at least 25 children died after eating school lunches contaminated by OPs. One OP in particular, chlorpyrifos, chlorpyrifos (Dursban), is currently under petition for the same […]

(Beyond Pesticides, September 11, 2015) On Thursday, the Ninth Circuit Court of Appeals unequivocally rejected the U.S. Environmental Protection Agency’s (EPA) unconditional registration of the systemic and bee-toxic pesticide sulfoxaflor. The Court concluded that EPA violated federal law and its own regulations when it approved sulfoxaflor without reliable studies regarding the impact that the insecticide would have on honey bee colonies. The Court vacated EPA’s unconditional registration of the chemical, meaning that sulfoxaflor may no longer be used in the U.S. However, while the decision is good news for now, it still leaves the door open for sulfoxaflor’s future use once EPA obtains the necessary information regarding impacts to honey bees and re-approves the insecticide in accordance with law. The case is Pollinator Stewardship Council, American Honey Producers Association, National Honey Bee Advisory Board, American Beekeeping Federation, Thomas Smith, Bret Adee, Jeff Anderson v. U.S. EPA (9th Circuit U.S. Court of Appeals,  No. 13-7234). Dow AgroSciences (a Dow Chemical company)  joined  the case as an intervenor to support EPA. EPA initially proposed to conditionally register sulfoxaflor and requested additional studies to address gaps in the data regarding the pesticide’s effects on bees. A few months later, however, EPA unconditionally registered […]

(Beyond Pesticides, September 10, 2015) Last week, California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) announced that it intended to list glyphosate (Roundup) and three other chemicals as cancer-causing chemicals under California’s  Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Glyphosate  is a phosphanoglycine herbicide that inhibits an enzyme essential to plant growth. Under California law, Proposition 65 requires that certain substances identified by the International View postAgency for Research on Cancer (IARC) be listed as known cancer-causing chemicals. In March, a study by the IARC classified glyphosate as a Group 2A material, which means that the chemical is carcinogenic based on sufficient evidence of carcinogenicity in experimental animals. The agency considered the findings from an EPA Scientific Advisory Panel report, along with several recent studies in making its conclusion. However, industry supporters of glyphosate all over the globe are conducting their own studies to attempt to prove that it is not a carcinogen. These studies, like one by German Federal Institute for Risk Assessments (BfR), are based almost solely on industry science and classified industry reports, each of which might not consider critical variables. With more glyphosate-focused studies being released, the growing evidence […]

(Beyond Pesticides, September 4, 2015) Research into neonicotinoid insecticides, a class of bee-toxic chemicals, and their effects on bees, needs to be more comprehensive in order to better reflect their global use, concludes a recent review of the current literature. The authors of the review state that despite considerable research efforts, there are still significant knowledge gaps concerning the impacts of neonicotinoids on bees. Since 2006, honey bees and other pollinators in the U.S. and throughout the world have experienced ongoing and rapid population declines. The science has become increasingly clear that pesticides (especially the  neonicotinoid class of insecticides), either acting individually or synergistically, play a critical role in the ongoing decline of honey bees and wild pollinators. Neonicotinoids can be persistent in the environment, and have the ability to translocate into the pollen and nectar of treated plants. The systematic review, titled Neonicotinoid Insecticides and Their Impacts on Bees: A Systematic Review of Research Approaches and Identification of Knowledge Gaps  and published in the journal PLoS ONE, took a look at over 200 primary research studies in order to identify knowledge gaps. While there is a growing body of science examining the impacts of neonicotinoid use, knowledge gaps need […]

(Beyond Pesticides, August 28, 2015) The European Union’s food safety agency confirmed Wednesday that foliar spraying of neonicotinoids (neonics), the widely-used bee-toxic insecticides, poses a risk to bees, bolstering previous research that led to a two-year moratorium on the chemicals in the EU. The European Food Safety Authority (EFSA), which guides EU policymakers, said leaf spray containing three neonicotinoid pesticides — clothianidin, imidacloprid, and thiamethoxam — could harm bees. Previous research found that these chemicals pose a risk as seed treatments or granules, which prompted the European Commission to limit their use in  December 1, 2013. The use of the three neonicotinoid substances in seed or soil treatments is prohibited in the European Union for crops attractive to bees and for cereals other than winter cereals except in greenhouses. “They (the EFSA conclusions) confirm that the Commission was correct to take precautionary measures in 2013,” a Brussels-based EU executive said in a statement. Neonicotinoids have been found by  a growing body of scientific literature  to be linked to honey bee and pollinator decline. Recently, a  study  performed by the Food and Environment Research Agency (FERA) in the United Kingdom provides evidence confirming the link between neonicotinoid pesticides and continually increasing […]

(Beyond Pesticides, August 27, 2015) Last week, Philip J. Landrigan, M.D., and Charles Benbrook, Ph.D., released a perspective article, GMOs, Herbicides, and Public Health, in the New England Journal of Medicine  that outlines  the hazards associated with food residues of  elevated pesticide use in the production  of genetically engineered (GE) crops. While mainstream media continuously misses the central issue  in the GE debate by asserting that these crops are merely an extension of selective breeding and effect a reduction in pesticide use, the authors  focus on  the significance of the actual increase in herbicide use and weed resistance in herbicide-tolerant crops. Drs. Landrigan and Benbrook offer two main recommendations in their article: the U.S. Environmental Protection Agency (EPA) should delay implementation of its decision to permit the use of Enlist Duo (the 2,4-D herbicide used with  Monsanto-engineered GE herbicide-tolerant  crop), and  the U.S. Food and Drug Administration (FDA) should  require labeling of GE foods and couple it with adequately funded, long-term postmarketing surveillance. Dr. Landrigan, Dean for Global Health at Mount Sinai School of Medicine, is an epidemiologist and pediatrician and one of the world’s leading advocates of children’s and environmental health. Dr. Benbrook is a research professor at the […]

(Beyond Pesticides, August 26, 2015) A  study performed by the Food and Environment Research Agency (FERA) in the United Kingdom (UK) provides evidence of confirming the link between neonicotinoid pesticides and continually increasing honey bee colony losses on a landscape level. The study, Evidence for pollinator cost and farming benefits of neonicotinoid seed coatings on oilseed rape, was published in the Nature journal Scientific Reports. This is a significant study, as the UK government has always maintained that neonicotinoid pesticides do not threaten bees, and that honey bee losses are instead caused by the parasitic varroa mite, siding with industry arguments that pesticides are safe when used properly. However, this new study indicates otherwise, confirming a direct link between neonicotinoids and honey bee colony losses at a nationwide level. This study distinguishes itself from  a previous study in the U.S. that extrapolated real world neonicotinoid exposure levels  to  test hives by analyzing actual fields in a  long-term assessment. To a large degree, the new study addresses industry critics of the earlier study design who have tried to discount previous findings of bee decline associated with neonicotinoid use (see Beyond Pesticides’ Sowing the Seeds of Doubt, which addresses these industry myths). […]