24
Apr
(Beyond Pesticides, April 24, 2025) As the congressionally created National Organic Standards Board (NOSB) of organic stakeholders meets this week to receive comments from the public on the semi-annual review of standards and allowed and prohibited substances in production and processing, multiple members of Congress are moving to shore up the organic sector for farmers and consumers. (See testimony here.) The current 119th Congress has brought a wave of bipartisan legislation aimed at improving the U.S. food system, including organic standards and programs. Organic advocates are pleased to see the introduction of a series of bills supporting organic, including the reintroduction of the Organic Science and Research Investment (OSRI) Act, S.1385, the New Producer Economic Security Act, S.1237, (previously Increasing Land, Security, and Opportunities (LASO) Act, H.R.3955, in 2023-24), and the newly-introduced Organic Imports Verification Act (OIVA), S.1398, among others. OIVA, introduced by Senators Pete Ricketts (R-NE), Tina Smith (D-MN), and Tim Scott (R-SC), is intended to improve consumer confidence in imported organic goods with support for the U.S. Department of Agriculture’s (USDA) Strengthening Organic Enforcement Rule. (See a joint press release by Senators Ricketts and Smith here.) Amid federal funding freezes and cuts that business leaders say undermine small […]
Posted in Alternatives/Organics, Congress, Farm Bill, National Organic Standards Board/National Organic Program, NOSB National Organic Standards Board, Organic Foods Production Act OFPA, Uncategorized | No Comments »
01
Apr
(Beyond Pesticides, April 1, 2025) With the second largest award of nearly $2.1 billion (see reporting on largest), a jury in Georgia state court on March 21 found the pesticide manufacturer Bayer/Monsanto guilty of causing a man’s non-Hodgkin’s lymphoma after use of the company’s glyphosate-based weedkiller RoundupTM product. The jury’s award includes $65 million in compensatory and $2 billion in punitive damages, as reported by the Associated Press and Courtroom View Network. This verdict in Barnes v. Monsanto (2025) comes amid a concerted effort by Bayer and other chemical and agribusiness groups to take away the main legal argument, “failure-to-warn,” for the type of litigation that pesticide exposure victims have commonly used to hold companies accountable. This is happening as Governor Brian Kemp of Georgia considers signing into state law a pesticide immunity bill that will prevent future litigation like this in the state. In a deregulatory environment, the courts and state governments are viewed as critical backstops, given the dismantling of the U.S. Environmental Protection Agency’s (EPA) regulatory apparatus and extremely limited Congressional oversight. History of Litigation Bayer has lost almost all of the cases filed against it for compensation and punitive damages associated with the plaintiffs’ charge that […]
Posted in Bayer, Failure to Warn, Georgia, Glyphosate, Litigation, Monsanto, non-Hodgkin's Lymphoma, Preemption, Uncategorized | No Comments »
21
Oct
(Beyond Pesticides, October 21, 2024) To solve the existential crises of climate change, biodiversity loss, and human disease, Beyond Pesticides is urging that organic agriculture grows—over the next decade becoming universally adopted for all agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic. The OCCSP will disappear in 2025 unless Congress passes a five-year Farm Bill with funding or includes sufficient funding in a stopgap bill this fall. Chemical-intensive agriculture, with its dependence on petrochemical pesticides and fertilizers, is a major contributor to the existential health and environmental crises and contamination of air, land, and water. Organic agriculture, certified and labeled in compliance with the Organic Foods Production Act (OFPA) provides: A definition of organic agriculture that defines health-biodiversity-climate friendly practices; A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests; A rigorous process for an allowed/prohibited substances list with a mechanism for […]
Posted in Agriculture, Alternatives/Organics, Biodiversity, Climate, Farm Bill, National Organic Standards Board/National Organic Program, Organic Foods Production Act OFPA, Take Action, Uncategorized | No Comments »
16
Oct
(Beyond Pesticides, October 16, 2024) In a study published in the Journal of Agriculture, Food Systems, and Community Development (JAFSCD), researchers from New York University (NYU) identify gaps in various federal agricultural support systems for organic farmers in a sweeping analysis. The research was spearheaded by Carolyn Dimitri, PhD, chair of the Nutrition and Food Studies program at NYU and a current member of the National Organics Standard Board (NOSB) as a public interest/consumer interest representative serving through January 2026. According to this study, there is a deficiency in institutionalized knowledge of national organic standards among existing U.S. Department of Agriculture (USDA) agents and staff working in various agencies, including Risk Management Agency (RMA), Natural Resources Conservation Service (NRCS), and Farming Service Agency (FSA). “A key recommendation from this study is the creation of specialized, highly trained crop insurance and conservation agents with expertise in organic farming systems to facilitate the application process and program use for conservation programs and crop insurance,” according to the researchers. The authors continue by echoing the sentiments of organic advocates and farmers across the nation on building organic integrity, saying, “The Organic Cost Share Program [a program of USDA’s FSA] would have more impact […]
Posted in Alternatives/Organics, Congress, Federal Agencies, National Organic Standards Board/National Organic Program, NOSB National Organic Standards Board, Organic Foods Production Act OFPA, Uncategorized, US Department of Agriculture (USDA) | No Comments »
25
Jul
(Beyond Pesticides, July 25, 2024) On July 10, the Oregon Court of Appeals ruled that the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) does not preempt pesticide exposure victims’ state law claims against pesticide manufacturers, based on reporting from The New Lede. This decision builds on years of judicial precedent from the Supreme Court of the United States (SCOTUS) that protects individuals’ right to use failure-to-warn claims against producers of toxic pesticides, including Bayer-Monsanto. The importance of judicial review is critical to protecting the public against public health impacts of toxic pesticide use in the context of last month’s SCOTUS decision ending Chevron Doctrine, and with it the end of deferring to federal regulatory agencies on ambiguities in statutory mandates. A growing coalition of environmental and public health advocates, organic farmers, trial attorneys, farmworkers, and physicians are united in pushing back against a concerted effort by industry and its allies to attack victims’ ability to sue under “failure-to-warn” through the Farm Bill, state legislatures, and the proposed federal budget for Fiscal Year 2025. Oregon Court of Appeals In 2022, a local trial court in Oregon ruled in favor of Monsanto on a lawsuit initiated by Jackson County residents Larry and […]
Posted in Bayer, Congress, Corporations, Environmental Protection Agency (EPA), Failure to Warn, Glyphosate, Label Claims, Litigation, Monsanto, non-Hodgkin's Lymphoma, Oregon, State/Local, U.S. Supreme Court, Uncategorized | No Comments »
15
Jul
(Beyond Pesticides, July 15, 2024) It is hot. Really hot. A serious response to this climate emergency requires, according to environmental advocates, a dramatic transformation in land management and an end to the use of petrochemical pesticides and fertilizers. Beyond the real-world adverse effects of the climate crisis— more intense and frequent fires, floods, hurricanes and hail storms, as well as the harm to health and biodiversity—the rising insurance premiums imposed by the insurance industry speaks to the need for an urgent systemic response. According to the paper, Pricing of Climate Risk Insurance: Regulation and Cross-Subsidies, “The unprecedented rise in natural disasters has led to catastrophic losses of more than $600 billion in the United States over the last two decades, roughly twice the losses of the previous 40 years combined.” While the events associated with climate are more accurately described as “human-made” rather than “natural” disasters, a 2023 Washington Post article reports that, “U.S. insurers have paid out $295.8 billion in natural disaster losses from 2020 to 2022, a record for a three-year period.” This has led to dramatic changes in the cost of insurance coverage and the decision of many carriers to deny coverage. The Washington Post writes, “At least […]
Posted in Agriculture, Alternatives/Organics, Climate Change, Congress, Take Action, Uncategorized | No Comments »
04
Jul
(Beyond Pesticides, July 4, 2024) In reflecting on recent U.S. Supreme Court decisions that reduce federal government powers to restrict hazardous chemicals, including pesticides (see Clean Water Act decision and federal restrictions of toxic hazards under the reversal of Chevron decision), two remaining authorities in state and local governments and in the courts have become the next battleground to protect health and the environment. What is at stake are two major backstops to weak federal controls and chemical company disregard for safety: the critical importance of state and local governments’ exercise of authority to restrict toxic chemicals, and the ability of people to sue corporations for their failure to warn about their products’ hazards. The attack on state and local authority in the Farm Bill The Farm Bill in the U.S. House of Representatives: Prohibits the rights of states and local governments to restrict pesticides and protect public health and the environment. The language says the Farm Bill will “prohibit any State, instrumentality or political subdivision thereof… from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or packaging that is in […]
Posted in Agriculture, Alternatives/Organics, Congress, Environmental Protection Agency (EPA), Farm Bill, Holidays, Preemption, Take Action, U.S. Supreme Court, Uncategorized | No Comments »
25
Jun
(Beyond Pesticides, June 25, 2024) It has been a couple of weeks since U.S. Senator John Boozman (R-AR), ranking GOP member on the Senate Agriculture Committee, released the Republican framework vision without statutory language for a Senate Farm Bill that would renew the law’s commitment to chemical-intensive agriculture and undermines efforts to curtail pesticide use and hold chemical company polluters accountable. In his press statement, Sen. Boozman issues an approach that largely mirrors the House-side text, passed by the House Agriculture Committee earlier this month in a 33-21 vote. On the same day that Sen. Boozman announced the framework, the House Agriculture Appropriations Subcommittee approved the federal food and agriculture budget for Fiscal Year 2025 with a $355 million cut from last year’s budget, affecting specific programs that support pollinator health, ecosystem health, and public health related to pesticide use and organic agriculture. The full House Appropriations Committee will vote on this budget on July 10 before moving to the House floor. Advocates are adamant in their resolve to demand more – not less – support from Congress to address the climate emergency, insect apocalypse, and public health implications borne from reliance on toxic petrochemical pesticides and fertilizers. The Senate […]
Posted in Environmental Protection Agency (EPA), Failure to Warn, Farm Bill, National Organic Standards Board/National Organic Program, Preemption, Uncategorized, US Department of Agriculture (USDA) | No Comments »
03
Jun
(Beyond Pesticides, June 3, 2024) Environmental advocates continue to raise concerns about the Farm Bill (H.R.8467—Farm, Food, and National Security Act of 2024) that emerged from the House Agriculture Committee on May 23 with provisions they say will allow the escalation of environmental threats and then insure big agriculture commodity producers for losses attributable to those environmental disasters through an expansion of USDA’s crop insurance program. Through this taxpayer supported program, USDA covers farm revenue losses due to “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” Petrochemical pesticide and fertilizer use in chemical-intensive land management and agricultural production contributes to the climate emergency and associated weather, insect, and plant disease threats. Advocates point out that the House Agriculture Committee Farm Bill reduces environmental protections by (i) preempting local and state government authority to allow more restrictive standards at the municipal level, (ii) taking away the right to sue pesticide manufacturers and allied companies for a failure to fully disclose adverse effects of the products they produce or use, and (iii) weakening the regulatory process intended to protect endangered species and biodiversity from pesticides.  Tell Your U.S. Representative and Senators To Support […]
Posted in Agriculture, Alternatives/Organics, Bayer, Environmental Protection Agency (EPA), Failure to Warn, Farm Bill, Litigation, Preemption, Take Action, Uncategorized, US Department of Agriculture (USDA) | 1 Comment »
30
May
(Beyond Pesticides, May 30, 2024) The House Agriculture Committee voted 33-21 on May 23 to move the Farm, Food, and National Security Act out of committee after a contentious markup and onslaught of amendments that undermine water health, soil health, and local democratic authority to protect people and the environment from toxic pesticide exposure. One of nearly sixty amendments introduced in the markup last week included the continuation of a decade-long attack on National Pollutant Discharge Elimination System (NPDES) permit via Clean Water Act (CWA) for pesticide discharge. What was most illuminating however was not the passage of the bill itself, but Big Agriculture’s raucous approval. Advocates see pesticide industry and its allies’ support for what it is—the reliance on petrochemical-based pesticides leading to economic instability, ecosystem collapse, and the degradation of democratic institutions. With support for entrenched dependency on petrochemical pesticides and fertilizers, the committee’s bill requires taxpayers to pay through the government’s crop insurance program for escalating losses caused by chemical-intensive farming practices, contributing to yield losses that the U.S. Department of Agriculture (USDA) says are “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” However, the frequency of these […]
Posted in Endangered Species Act (ESA), Environmental Protection Agency (EPA), Failure to Warn, Farm Bill, Fish and Wildlife Service (FWS), Habitat Protection, Pesticide Regulation, Preemption, Uncategorized, US Department of Agriculture (USDA), Wildlife/Endangered Sp. | 2 Comments »
23
May
(Beyond Pesticides, May 23, 2024) A study recently published in the journal Nature compared the impact of organic and conventional food production using eight environmental health indicators and found that organic food has a significantly lower environmental impact than conventional food production for six of the eight indicators, including a lower potential for contributing to acidification of the environment, energy use, and biodiversity loss. For the analysis, scientists reviewed 100 different “life cycle assessments” (LCA) of organic and conventionally grown food products from cradle-to-farm gate.   LCA is a commonly used methodology to estimate food production system impacts on the environment through resource depletion and pollutant emissions. The results—that organic food production is less impactful on the environment—add to the robust body of research that underscores the importance of organic farming to the development of a sustainable global food system while addressing climate change. Beyond Pesticides has long argued that one of the most powerful tools in fighting global warming is organic agriculture, as it sequesters atmospheric carbon, eliminates the use of fossil fuel-based synthetic fertilizers and synthetic pesticides, and provides environmental and human health benefits. This study and most of the 100 studies it evaluates, do not recognize that conventional […]
Posted in Agriculture, Alternatives/Organics, Environmental Protection Agency (EPA), National Organic Standards Board/National Organic Program, Organic Foods Production Act OFPA, Regenerative, Uncategorized | No Comments »
20
May
(Beyond Pesticides, May 20, 2024) (Beyond Pesticides, May 20, 2024) The Republican Farm Bill draft in the U.S. House of Representatives, released on Friday, May 17, is a broad attack on pesticide restrictions and the right to sue chemical manufacturers and allied users of pesticides when harmed. “This legislation is a complete nonstarter for the millions of people who want stronger pesticide restrictions, democratic decision making on toxic chemicals in communities, and the right to sue manufacturers and pesticide users when harmed and misled on the hazards of pesticides,” said Jay Feldman, executive director. “We vehemently oppose this Republican legislation with the understanding and experience—bridging farmers, medical practitioners, land managers, local policy makers, and families—that we can and must transition to safe practices and products that protect our health, biodiversity, and climate,” Mr. Feldman continued. The Farm Bill attack takes place on many critical fronts. The draft legislation: 1. Takes away the right to sue for failure to warn when harmed by pesticides. The language says: “prohibit. . .a court from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or […]
Posted in Agriculture, Alternatives/Organics, Environmental Protection Agency (EPA), Failure to Warn, Farm Bill, Genetic Engineering, Litigation, Preemption, Take Action, Uncategorized | No Comments »
14
May
(Beyond Pesticides, May 14, 2024) As research continues to emerge on the value of organic farming, U.S. Congress debates its future as Farm Bill negotiations have been stalled for months. Recent studies published within the past few months show the significance of organic agriculture’s support of fungal and microbial life, which is essential to soil health. Meanwhile, last week the Democrat-led Senate and Republican-led House of Representatives presented their respective visions to amend the 2024 Farm Bill. The office of U.S. Senator Debbie Stabenow (D-MI), chair of the Senate Agriculture Committee, released an initial Senate framework for the (now 2024) Farm Bill. At the same time, U.S. Representative Glenn Thompson (R-PA), chair of the House Agriculture Committee, released an outline of the House version, then followed up with more details. While the Senate Democratic proposal includes more robust support for expanding and strengthening organic product supply chains and domestic production, the House Republican support for organic land management principles and practices demonstrates that the Farm Bill could recognize, across the political spectrum, its economic, ecological, and public health benefits in the United States. Despite this, a growing coalition of advocates is alerting the public and members of Congress that the […]
Posted in Environmental Protection Agency (EPA), Failure to Warn, Farm Bill, National Organic Standards Board/National Organic Program, Preemption, Uncategorized | No Comments »
20
Feb
(Beyond Pesticides, February 20, 2024) With health risks including developmental, metabolic, cardiovascular, and reproductive harm, cancer, damage to the liver, kidneys, and respiratory system, as well as the potential to increase the chance of disease infection and severity, per- and polyfluoroalkyl substances (PFAS) and their toxic trail of contamination in the environment is wreaking havoc with all life. The use of PFAS in industrial and commercial applications has led to widespread contamination of water and biosolids used for fertilizer, poisoning tens of millions of acres of land and posing a significant threat to the biosphere, public health, gardens, parks, and agricultural systems. Farmers and rural communities, in particular, bear the brunt of this contamination, as it affects their drinking water, soil quality, and livestock health.  Tell Congress that the Farm Bill must include the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act to protect farmers and rural communities from PFAS contamination. Led by Chellie Pingree (D-ME), U.S. Senators Tammy Baldwin (D-WI), and Susan Collins (R-ME), a bipartisan and bicameral bill—the Relief for Farmers Hit with PFAS Act—has been introduced to provide assistance and relief to those affected by PFAS. A second bill, the Healthy H2O Act, introduced by Representatives Pingree and David Rouzer (R-NC) and Senators Baldwin […]
Posted in Agriculture, Biosolids, Biosolids/Sewage Sludge, Environmental Protection Agency (EPA), PFAS, Sewage Sludge, Take Action, Uncategorized, Water | 8 Comments »
23
Jan
(Beyond Pesticides, January 23, 2024) Earlier this month, a coalition of over 140 local and state elected officials from over 30 states sent a letter to ranking members of the House and Senate Agriculture committees to reject the proposed Agricultural Labeling Uniformity Act (H.R. 4288), which would preempt local governments’ authority to protect their constituents from toxic pesticides. Members of Congress are negotiating language in the Farm Bill that would preempt local and state authority to restrict pesticides. “We write to express our strong opposition to any efforts to limit longstanding state and local authority to protect people, animals, and the environment by regulating pesticides,” says the signatories. “As Congress considers legislation related to agriculture, including the reauthorization of the Farm Bill and Fiscal Year 2024 appropriations bills, we urge you to ensure that state, county, and local governments retain the right to protect their communities and set policies that best suit our local needs.” The question of local rights to adopt more stringent restrictions on pesticide use has historically been left to the states. However, after the U.S. Supreme Court (Wisconsin v. Mortier, 1991) affirmed the rights of local communities under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), […]
Posted in Colorado, Farm Bill, Illinois, Pesticide Drift, Pesticide Regulation, Preemption, Uncategorized, West Virginia, Wisconsin | No Comments »
09
Nov
(Beyond Pesticides, November 9, 2023) Two-hundred-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields—according to data evaluated by Environmental Working Group—are threatened by potential Farm Bill amendments now under consideration. Legislative language, if adopted, would take away (preempt) the authority of states and local jurisdictions to protect children and restrict agricultural pesticides used near schools. Pesticide drift is a widespread problem throughout the U.S. that has attracted national attention in recent years because of crop damage caused by the weed killer dicamba in numerous midwestern states. In the face of the U.S. Environmental Protection Agency’s (EPA) failure to mitigate drift hazards, states enact limits on when and how pesticides can be used, establish buffer zones around application sites, and in some cases, ban uses. In 2018, Arkansas banned dicamba use from mid-April through the end of October (and survived a Monsanto challenge to the ban. For a historical perspective on the drift issue, see Getting the Drift on Pesticide Trespass. Children, in particular, face unique risks from pesticide and toxic chemical exposures. Due to their smaller body size, they absorb a higher relative amount of pesticides through the food they consume and the air they breathe. Additionally, children’s developing […]
Posted in Agriculture, Alternatives/Organics, Children, Children/Schools, Congress, contamination, Farm Bill, Farmworkers, Federal Agencies, Herbicides, Uncategorized | No Comments »
13
Oct
(Beyond Pesticides, October 13, 2023) Will the chemical industry and pesticide-dependent service industry (e.g., conventional landscaping industry) trample democratic rights and force the allowance of pesticide use against the will of communities across the U.S.? The answer is unequivocally yes, they are trying. In fact, the industries’ campaign is now playing out in the U.S. Congress, as members deliberate on the next Farm Bill. Members of Congress who advocate the pesticide lobby’s anti-democratic position are telling constituents that they do not support their right to restrict pesticides more stringently than the federal government. Please urge your U.S. Representative to sign the Congressional “Dear Colleague” Letter and uphold the right of local governments and states to restrict pesticides. Time sensitive: Please take action today (Friday, October 13, 2023) or as soon as possible. Thank you! Advocates are clearly telling members of Congress that the long-held federal-state balance of local, state, and federal authority will be broken if the federal government steps in to deny localities the authority to control pesticide use more stringently than federal law. The history is clear. The U.S. Supreme Court in Wisconsin Public Intervenor v. Mortier (1991) found, “[The Federal Insecticide, Fungicide and Rodenticide Act] FIFRA nowhere […]
Posted in Announcements, Congress, Preemption, Take Action, Uncategorized | 3 Comments »
17
Jul
(Beyond Pesticides, July 17, 2023) Students of environmental policy quickly learn that the most meaningful change to protect health and the environment begins with action in local communities. The challenge now is to preserve the rights of communities under federal law to restrict pesticides and advance local protections through the adoption of eco- and health-friendly, organic land management practices. As is known from history, with the leadership of local communities, the states and the federal government will follow. History of Action in Communities and States Major actions on the banning or restricting of specific pesticides over the last seven decades—from DDT (in Michigan and Wisconsin), 2,4,5-T [1/2 of Agent Orange] (in Oregon [read A Bitter Fog]), to chlordane (New York)—began with calls from the grassroots about dying wildlife to elevated cancer and miscarriage rates and other diseases. But, these chemical incidents (which continue to today with similar campaigns, but different chemical names like glyphosate, imidacloprid (neonicotinoids), and others), launched broader community-based efforts to curtail overall pesticide use—stop drift, runoff and other nontarget exposure—and require organic-compatible practices. Tracing the history—from Mendocino County, CA to Lincoln County, OR, to Casey, WI (upheld by the U.S. Supreme Court), to Montgomery County, MD, to […]
Posted in Agriculture, Alternatives/Organics, Environmental Protection Agency (EPA), Farm Bill, Preemption, Uncategorized | No Comments »
10
Jul
(Beyond Pesticides, July 10, 2023) [Editor’s note to readers: The local, democratic decision-making process to adopt restrictions on pesticide use, now under attack in Congress, has historically been critical to the protection of health and the environment when federal and state governments have failed in their responsibility. This local democratic right has not only protected communities where action is taken, but it has driven state and federal policy to do better—to do what is required in a society that cares about a sustainable future. While federal and state pesticide policy sets a floor on minimum protections and rights, there is nothing more important than nurturing the local democratic process to increase and strengthen protections that elude government agencies that are unduly influenced by the powerful chemical industry. As we face existential crises of health threats, biodiversity collapse, and the climate emergency resulting from gridlock in legislative bodies that ignore the scientific facts documenting harm and solutions that are within our grasp, there is nothing more important than empowering local communities to embrace meaningful changes that eliminate pesticides and adopt organic land management practices. These changes embrace nature and ecosystem services. While the federal regulatory process is skewed toward assumptions of […]
Posted in California, Congress, Environmental Protection Agency (EPA), Farm Bill, Pesticide Regulation, Preemption, Take Action, Uncategorized | 6 Comments »
07
Jul
The introduction of the Agricultural Labeling Uniformity Act in the U.S. House of Representatives, expected to be a part of the Farm Bill negotiations, is raising the specter (yet again) of undermining local and state authority to protect the health of their residents from pesticides—effectively overturning decades of Supreme Court precedent.
Posted in Agriculture, Alternatives/Organics, Cancer, Congress, Environmental Protection Agency (EPA), Failure to Warn, Pesticide Regulation, Preemption, Uncategorized | 2 Comments »