(Beyond Pesticides, December 10, 2021) In a win for pollinators, a California Superior Court has issued a ruling that sulfoxaflor, a systemic pesticide that is “field legal” but “bee lethal,” can no longer be used in the state. The suit was brought by the Pollinator Stewardship Council and the American Beekeeping Federation. The ruling of the Superior Court of the State of California for Alameda County finds that the argument of the petitioners — that sulfoxaflor approval decisions by the California Department of Pesticide Regulation (DPR) violated the California Environmental Quality Act (CEQA) — is valid. Eliminating this highly bee-toxic pesticide from use in the state is expected to protect not only native bees and other pollinators (including Monarch butterflies in early Spring), but also, the many millions of managed-colony bees that are transported to California for pollination of almond and other crops. The suit was filed against DPR, Corteva inc., Dow Agrosciences LLC, the Siskiyou County Department of Agriculture, and James E. Smith as Siskiyou County Agricultural Commissioner. Having found for the petitioners’ request for a Writ of Mandate (a court order requiring a lower court or public authority to perform its statutory duty), the court instructed the petitioners to […]

(Beyond Pesticides, November 29, 2021) The U.S. Fish and Wildlife Service (FWS) is reviving its proposal to aerially apply (by helicopter) the toxic rodenticide brodifacoum to kill house mice on the Farallon Islands National Wildlife Refuge off the Northern California coast. Globally significant wildlife populations inhabit the Farallones, including hundreds of thousands of seabirds and thousands of seals and sea lions. According to FWS, these include: thirteen species seabird species that nest on the islands including Leach’s Storm-petrel, Ashy Storm-petrel, Fork-tailed Storm-petrel, Double-crested Cormorant, Brandt’s Cormorant, Pelagic Cormorant, Black Oystercatcher, Western Gull, Common Murre, Pigeon Guillemot, Cassin’s Auklet, Rhinocerous Auklet, and Tufted Puffin; pinnipeds including Northern fur seals, Steller sea lions, California sea lions, harbor seals, and northern elephant seals that breed or haul-out onto Farallon Refuge; and endemic species including white sharks, hoary bats, and arboreal salamanders. Tell the California Coastal Commission to deny the proposed aerial dispersal of the highly toxic rodenticide brodifacoum on the Farallon Islands. Brodifacoum is a “second generation anticoagulant rodenticide” (SGAR) that is highly toxic to birds, mammals, and fish. It also poses a secondary poisoning risk to predators. The California Department of Pesticide Regulation quotes the FWS: “Secondary exposure to SGARs is particularly […]

(Beyond Pesticides, November 5, 2021) Once again earning its environmental leadership reputation, California has released a draft strategy document designed to catalyze near- and long-term climate action through focused attention on the state’s natural and working lands, and on nature-based solutions. The California Natural Resources Agency (CNRA) announced the draft Natural and Working Lands Climate Smart Strategy in mid-October. In the announcement, CNRA asserts that the state’s 105 million acres can “sequester and store carbon emissions, limit future carbon emissions into the atmosphere, protect people and nature from the impacts of climate change, and build resilience to future climate risks.” The agency also notes that the plan would secure food and water supplies, improve public health and safety, and forward equity. It has invited public comment, and a coalition of California (and national) nonprofit advocates is delivering a letter that calls on the agency to include, in the plan, ambitious targets to move the state’s agricultural sector away from the use of harmful synthetic pesticides. Beyond Pesticides will sign on to the letter. This “natural and working lands” document will inform California’s 2021 State Adaptation Strategy and the 2022 Scoping Plan — master documents guiding the state’s climate action during […]

(Beyond Pesticides, October 22, 2021) The California Court of Appeal (Third District, Sacramento) has ruled that a statewide pesticide spraying program violates state law. The court found that the program, launched in 2014 and administered by the California Department of Food and Agriculture (CDFA), contravenes California’s landmark 1970 Environmental Quality Act (CEQA). It does so, the court found, by failing to: assess and reduce damages of pesticide applications to bees, other pollinators, and water bodies; conduct site-specific environmental reviews; and notify the public before spraying is conducted. This decision is a victory, and a step toward a less-toxic California, say plaintiffs and many health and environmental advocates, including Beyond Pesticides. The history of CDFA’s actions in the state is riddled with invocations of emergency provisions of California’s Food and Agriculture Code. These emergency declarations have allowed CDFA to conduct pesticide spraying for invasive species nearly anywhere — in back yards, on school and recreational grounds, on organic farms, on public lands, and sometimes, across entire neighborhoods — without any analysis of the health and environmental impacts of those applications, or any notice to the public or opportunity to comment on the program. From 2014 to 2018, CDFA conducted more than […]

(Beyond Pesticides, September 22, 2021) Health and environmental organizations are urging the U.S. Environmental Protection Agency (EPA) and state pesticide regulators to immediately stop the use and sale of dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Recent laboratory testing by the state of California found the presence of hazardous pesticides, including glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl in these products. “From organic farmers to municipal landscapers and home gardeners, consumers employing minimum risk products are working intentionally to avoid the dangers associated with toxic pesticide exposure,” said Jay Feldman, executive director of Beyond Pesticides. “It is critical that EPA and state regulators coordinate to ensure the integrity of the minimum risk program.” Coordination is critical yet reports indicate that EPA is falling down on the job. The issue first came to light in late July, when the California Department of Food and Agriculture’s (CDFA) State Organic Program issued a Stop Use Notice to farmers alerting them to adultered Eco-MIGHT and W.O.W products. The products make a range of claims, marketed as “organic,” “natural,” “glyphosate-free,” and “non-toxic and safe.” As CDFA Secretary Karen Ross noted, “It is imperative that we alert California […]

(Beyond Pesticides, July 14, 2021) Corteva (formerly DowDupont) is facing a potential class-action lawsuit after several California families filed suit claiming that the use of the insecticide chlorpyrifos around their homes resulted in birth defects, brain damage, and developmental problems in their children. Chlorpyrifos is an organophosphate insecticide that has been linked to a range of health ailments, posing significant hazards particularly for pregnant mothers and their children. The lawsuits come as the U.S. Environmental Protection Agency (EPA) approaches a court-imposed 60-day deadline to decide the fate of the pesticide’s registration. Attorneys for the court cases, filed on behalf of individuals located in four California communities (Fresno, Kings, Medera, and Tulare counties), indicate they intend to pursue class-action status, which would allow additional injured parties to join the lawsuit. The plaintiffs argue that the effects of chlorpyrifos exposure lingers in the agricultural communities where they reside. “We have found it in the houses, we have found it in carpet, in upholstered furniture, we found it in a teddy bear, and we found it on the walls and surfaces,” said Stuart Calwell, lead attorney for the plantiffs. “Then a little child picks up a teddy bear and holds on to it.” […]

(Beyond Pesticides, April 21, 2021) The vast majority of bald and golden eagles in the United States are contaminated with toxic anticoagulant rodenticides, according to research published in the journal PLOS One earlier this month. Although eagle populations have largely recovered from their lows in the 1960s and 70s, the study is a stark reminder that human activity continues to threaten these iconic species. “Although the exact pathways of exposure remain unclear, eagles are likely exposed through their predatory and scavenging activities,” said study author Mark Ruder, PhD, assistant professor at the University of Georgia to CNN. Eagle carcasses were retrieved from the University of Georgia’s ongoing Southeastern Cooperative Wildlife Disease Study. Eighteen state wildlife agencies and the U.S. Fish and Wildlife Service all sent in specimens from a period spanning 2014 to 2018. In total, 116 bald eagle and 17 golden eagle carcasses had their livers tested for the presence of anticoagulant rodenticides. Out of the 116 bald eagles tested, 96, or 83% had were exposed to toxic rodenticides. Forty of the eagles  (35%) were exposed to more than one rodenticide compound. Thirteen out of 17 golden eagles were contaminated was rodenticides, with four exposed to a single rodenticide […]

(Beyond Pesticides, September 9, 2020) Late last month the California legislature voted to ban, with limited exceptions, the use of highly toxic rat poisons. The California Ecosystems Protection Act of 2020, AB 1788, was passed after over a year of advocacy by groups and individuals concerned about the impact of second-generation anticoagulant rodenticides (SGAR) on state and local wildlife. Proponents of the legislation are advocating that lawmakers in other states follow California’s lead by passing similar legislation. The bill must be signed by Governor Gavin Newsom or allow the bill to become a law without his signature by September 30, 2020. The legislation hones in on the use of SGARs, specifically the chemicals brodifacoum, bromadiolone, difenacoum, and difethialone, which present significant hazards to non-target wildlife. Unlike the first generation of blood thinning rodenticides on the market (such as chlorophacinone, warfarin, and diphacinone, which present their own hazards), SGARs cannot be quickly excreted by the body and can deal a lethal dose to rodents in a single feeding. However, SGAR-poisoned rodents do not die immediately, and are often left lethargic and exposed to the elements. This makes them easy prey for birds and mammals. In California, SGARs gained considerable attention for […]

(Beyond Pesticides, August 31, 2020) We don’t need to use toxic weed killers to manage unwanted vegetation in Lake Tahoe, given the havoc they will wreak on a treasured and sacred ecosystem. The Tahoe Regional Planning Agency and Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) are accepting comments on a draft environmental impact report/ environmental impact statement (EIR/EIS) analyzing environmental impacts of a proposed Tahoe Keys Lagoons Aquatic Weed Control Methods Test (“Project”). Unless we all speak up, the Project could involve the application of herbicides to Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and should be selected for the proposed weed control test program. Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm. Located on the border of California and Nevada, Lake Tahoe is treasured for its scenic and ecological values not just by residents of those states, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an “Outstanding National Resource Water” under the Clean Water Act, and is recognized nationally and globally as a natural resource of special significance.  The […]

(Beyond Pesticides, June 26, 2020) A court decision in California, challenging a cancer warning on products containing the weed killer glyphosate, highlights the distinct  ways in which scientific findings are applied under regulatory standards, in toxic tort cases evaluated by juries, and by consumers in the marketplace. These differences came into focus as a U.S. court quashed California’s decision to require cancer warning labels on glyphosate products on June 22. The ruling, by Judge William Shubb of the U.S. District Court for the Eastern District of California, bars the state from requiring labeling that warns of potential carcinogenicity on such herbicides. The World Health Organization’s International Agency for Research on Cancer (IARC) in 2015 classified glyphosate as a probable human carcinogen. At this point, Monsanto began a worldwide campaign to challenge glyphosate’s cancer classification. The IARC finding spurred the California Office of Environmental Health Hazard Assessment, in the same year, to announce that glyphosate would be listed as a probable cancer-causing chemical under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). With that announcement came another: the state would mandate that cancer warning labels be applied to glyphosate-based products in the state when any of four […]

(Beyond Pesticides, May 19, 2020) The California Department of Food and Agriculture (CDFA) is taking public comments on a proposal to establish statewide comparable-to-organic standards for cannabis production. Although cannabis remains illegal at the federal level, and thus cannot be labeled with the U.S. Department of Agriculture (USDA) certified organic seal, there is no prohibition on a state-specific program that follows federal organic requirements, but does not use the word “organic.” While such a program has the potential to provide another level of protection for medical patients, questions and concerns remain over the allowance of certain products, and the impact the certifying scheme may have on the future trajectory of the cannabis production industry. Under the Medicinal and Adult-Use Cannabis Regulation Safety Act, passed in 2017 after the success of Proposition 64 by California voters, state agencies were tasked with establishing a state-level program to certify cannabis to the standards set out by USDA’s National Organic Program (NOP). CDFA is required to finalize this program for cannabis production by the start of 2021, while the California Department of Public Health will create a separate program to certify manufactured cannabis products. As outlined by CFDA, cannabis would be certified through third-party […]

(Beyond Pesticides, May 12, 2020) California Governor Gavin Newsom (D) is issuing new enforcement guidelines intended to protect children and residents from toxic pesticides during the Covid-19 pandemic. With schoolchildren spending their time at home while in quarantine, many, particularly those in agricultural communities, are at increased risk of pesticide exposure. “During this public health crisis, it is important to ensure the strict enforcement and oversight of regulations that protect children from pesticide exposure,” Governor Newsom wrote in a letter to the state Environmental Protection Agency (CalEPA). While much of the guidance simply reinforces current legal requirements, it places an emphasis on strict enforcement. County Agricultural Commissioners (CACs), the state’s primary enforcement officers for pesticide laws, must “strictly enforce all applicable health protections around homes and schools” during the pandemic, seven days a week. Further, it stresses that pesticide applications “are expressly prohibited,” when there is, “reasonable possibility of contamination of the bodies or clothing of persons not involved in the application.” The state will prioritize the investigation of any violations made in residential areas. The state will also “take a strict approach to assessing penalties.” Violations of pesticide law that occur near homes or schools during coronavirus quarantine will […]

P-22 is being treated for mange; blood tests found anti-coagulant rodenticides, commonly known as rat poison. (Beyond Pesticides, April 21, 2020) Last week, the California Fish and Game Commission voted unanimously to give mountain lion populations in certain parts of the state temporary protective status, and initiate a year-long study to consider permanent safeguards. Mountain lions in California are under considerable threat from a range of issues, including inbreeding, human developments, and the use of hazardous rodenticides. “There’s an extraordinary urgency for action to preserve this population,” said Commissioner Samantha Murray prior to the unanimous vote, according to the OC Register. According to a study published last year in the journal Ecological Applications, mountain lion populations in Southern California’s Santa Ana and Santa Monica Mountains are at risk of local extinction within 50 years without intervention. Highways and other man-made structures have hemmed in the cougars, resulting in inbreeding that threatens genetic diversity and can result in sterile offspring.  Although specific actions under the new status are not guaranteed, it will force changes within California executive agencies. “For Caltrans, this could include building wildlife crossings over or under existing freeways or as part of freeway expansion projects,” J.P. Rose, staff […]

Photo: Beyond Pesticides’ board member Chip Osborne and student advocate Bridget Gustafson meet on a University of California organic land management pilot site, supported by Beyond Pesticides. (Beyond Pesticides, January 23, 2020) University of California (UC) President Janet Napolitano recently has approved recommendations made by the UC Herbicide Task Force, a proposal that falls short of systems change that student activists are advocating. New changes will, however, restrict the use of some toxic pesticides and increase transparency across the university’s ten campuses. While the decision represents an important step forward, advocates remain critical of integrated pest management (IPM) policy and support an overall transition to organic land management. The UC Board of Regents will meet today to discuss the decision. President Napolitano will continue the suspension of glyphosate, established last year, until a UC-wide integrated pest management (IPM) policy is implemented and all ten UC campus locations complete individual IPM plans. A system-wide “oversight committee” will guide and authorize school IPM committees. The overarching IPM policy will restrict application of highly toxic pesticides, only permitting use after a local IPM committee has reviewed and approved its specific use application following an IPM-based assessment. Other synthetic pesticides will be subject to […]

(Beyond Pesticides, October 27, 2019) The spraying of toxic herbicides for weed control on campuses exposes students, workers and the general public to chemicals linked to health problems such as cancer and reproductive issues. Any day now, the University of California system will decide whether or not to continue using glyphosate and other toxic herbicides — including Roundup — on their campuses. The University of California temporarily banned the use of cancer-causing glyphosate, the main ingredient in Roundup, but the ban doesn’t stop the UC system from using other dangerous herbicides. Student activists are asking UC to commit to transitioning to all organic land care maintenance on all University of California campuses by 2025. This could be an opportunity for the University of California, which prides itself on its commitment to sustainability, to join other universities such as Harvard, the University of Colorado at Boulder, Yale, University of Pennsylvania, and others as a national leader in the field. Tell University of California President Napolitano to issue a full, permanent ban on toxic herbicides and shift the UC land care system to organic! Message to University of California President First of all, I would like to thank you for temporarily suspending the use of glyphosate-based herbicides on […]

(Beyond Pesticides, July 17, 2019) A March 2017 bird kill incident in Modesto, CA can be traced directly back to an insecticide “soil drench” applied to the base of several elm trees by pesticide applicators hired by the city, as detailed in a study published last month in the Journal of Environmental Toxicology and Chemistry. The chemical in question, the neonicotinoid imidacloprid, is implicated in the ongoing pollinator crisis and insect apocalypse, but can also affect bird populations. Prior research estimated that a single seed coated with the insecticide is enough to kill a songbird; this study confirms that such a scenario can and does play out in the real world. Progress and improvement will only occur when pest management practices stop focusing on pesticide use to solve routine pest problems and emphasize prevention. As part of city-wide pest management activities, Modesto officials said that imidacloprid was applied to elm trees in several front yards in a local neighborhood. The application took the form of a “soil drench,” which is when pesticide products are applied to the soil around the base of a tree or shrub. The systemic property of imidacloprid and other systemic insecticides means that the chemical will […]

(Beyond Pesticides, July 10, 2019) The California Coastal Commission will host a public hearing today on a U.S. Fish and Wildlife Service (USFWS) proposal to drop 1.5 tons of the rodenticide brodifacoum, an extremely potent anticoagulant, on the Farallon Islands National Wildlife Refuge. The Los Angeles Times headline on July 7 read, “Biologists say it’s for the best.” At the least, it is important to highlight that all biologists have not come to a consensus and the topic is very much still under debate. The commission has already received over 700 emails regarding the drop, with 600 opposing it. Home to rare, endemic seabirds such as the ashy storm-petrel, the Farallon Islands certainly have a serious mouse problem – 59,000 rodents occupy the rocky islands. Mice compete with native species for resources and attract an average of six burrowing owls a year. Owls feast upon ashy storm-petrels when mouse populations drop during the winter, killing hundreds of petrels annually. The global population of the ashy storm-petrel is small (10,000 – 20,000), but it is not considered an endangered species. The Audubon Society in California, which supports the brodifacoum program, worked with experts who say the eradication of invasive mice is […]

(Beyond Pesticides, May 24, 2019) University of California (UC) President Janet Napolitano announced, on May 15, a temporary ban on the use of glyphosate on all of UC’s 10 campuses. Set to begin on June 1, the ban will affect the more than 200,000 students in the UC system, and countless other staff, faculty, and visitors to the campuses. In announcing the ban, the university cited “concerns about possible human health and ecological hazards, as well potential legal and reputational risks associated with this category of herbicides.” (There are exceptions to the temporary suspension, such as uses for “agricultural operations, fuel-loaded management programs to reduce wildfire risk, native habitat preservation or restoration activities and research that requires glyphosate-based herbicides.”) The UC ban is the latest in a snowball-turning-avalanche of actions and decisions on glyphosate — the active ingredient in the Monsanto (now owned by Bayer AG) products Roundup and Ranger, and in many other herbicides. The suspension of glyphosate use at UC comes in large part as a result of the campaign, Herbicide-Free UC — which began as Herbicide-Free Cal, founded by student-athletes Mackenzie Feldman and Bridget Gustafson. The students became active on pesticides issues when they discovered that herbicides were […]

(Beyond Pesticides, May 20, 2019) The bans of chlorpyrifos in three important agricultural states show the support for a ban of the chemical nationwide. Hawai’i banned chlorpyrifos a year ago with a unanimous vote of the legislature. New York and California banned it this month. States have been pursuing bans since the Environmental Protection Agency rescinded its proposed ban in 2017. Tell Your Governor to Ban Neurotoxic Pesticides and Support Organic; Send Thanks to Your Governor in Hawai’i, New York, and California Like other organophosphate pesticides, chlorpyrifos has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children. A widely used pesticide, agriculture companies annually spray six million pounds on crops like citrus, apples, and cherries.  In the same family as Sarin gas, the substance was initially developed prior to World War II as a chemical weapon. It can overstimulate the nervous system to cause nausea, dizziness, and confusion. With very high exposures (accidents or spills), it can cause respiratory paralysis and even death. When applying the chemical to fields, workers must wear protective garments such as respirators. Workers are then blocked from entering the fields from 24 hours up to 5 days after application due to the chemical exposure risk. A group of leading toxics […]

(Beyond Pesticides, January 10, 2019) The Trump administration is opening the floodgates to allow widespread use of antibiotics in citrus (grapefruits, oranges and tangerines) production, expanding on an emergency use decision it made in 2017. The public has an opportunity to comment on the widespread use of streptomycin by January 19, 2019. You can comment on the federal government’s public comment page (regulations.gov) by leaving a comment opposing any additional use of antibiotics in food production during a national and international crisis of deadly disease resistance to antibiotics. You can copy Beyond Pesticides’ prepared comment below and add your own concerns. Strikingly, the decision allows for up to 480,000 acres of citrus trees in Florida to be treated with more than 650,000 pounds of streptomycin per year, and 23,000 citrus acres in California will likely be treated annually. The two approved antibacterial chemicals to be used as a pesticide in citrus production are streptomycin and oxytetracycline. These uses were permitted by the U.S. Environmental Protection Agency (EPA) under an emergency exemption in May, 2017, allowing residues of antibiotics in Florida orange juice, for the antibiotics streptomycin and oxytetracycline –allowing their use for a bacterial disease, citrus greening (Candidatus Liberibacter asiaticus (CLas) bacterium that causes Huanglongbing), […]

(Beyond Pesticides, December 4, 2018) In mid-November, the state whose agricultural operations used more than 900,000 pounds of chlorpyrifos in 2016 (down from two million pounds in 2005) moved to establish some temporary restrictions on its use. Regulators at the California Department of Pesticide Regulation (CDPR) issued interim restrictions on the compound while the agency works on a formal regulatory process to list chlorpyrifos as a “toxic air contaminant” and develop permanent restrictions on its use. A neurological toxicant, chlorpyrifos damages the brains of young children: impacts of exposure, even at very low levels, include decreased cognitive function, lowered IQ, attention deficit disorder, and developmental and learning delays. It was slated to be banned for food uses by the U.S. Environmental Protection Agency (EPA) last year, but the decision was reversed by the Trump administration. The interim measures in California include: banning aerial application of chlorpyrifos; ending its use on many crops — except for those determined to be “critical” by virtue of there being few, if any, alternatives (as determined by the University of California Cooperative Extension and listed on DPR’s website); establishing a quarter-mile buffer zone for 24 hours after any application of the pesticide; and requiring a 24/7/365, 150-foot […]

(Beyond Pesticides, November 8, 2018) Two months after publishing its first series of tests, part two of an Environmental Working Group (EWG) study finds residues of Roundup’s active ingredient, glyphosate, in all General Mills’ Cheerios and PepsiCo’s Quaker Oats products sampled. Health advocates are expressing concern about the consequences of chronic glyphosate exposure, and say U.S. federal agencies must limit the herbicide’s use on oat-based breakfast foods regularly marketed to children. In addition, organic itself is under threat, as chemical-intensive management practices undermine the future of the growing organic movement. In this second round of testing, EWG scientists purchased products around San Francisco and Washington DC. 28 samples of conventional and 16 samples of organic oat products were collected. Approximately 300 grams of each General Mills and PepsiCo product were packaged and shipped to Anresco Laboratories, in San Francisco. Detected glyphosate residues were compared to EWG’s own health benchmark of 160 parts per billion (ppb). This benchmark is based on risks of lifetime exposure and what EWG scientists consider allowable and protective of children’s health with an adequate margin of safety.  EWG’s results detected glyphosate residues in all 28 samples of conventionally grown oat products. The vast majority (all but two) […]

(Beyond Pesticides, October 22, 2018) The California Department of Pesticide Regulation (DPR) is accepting comments on its proposal to classify chlorpyrifos as a toxic air pollutant. The classification would require DPR to develop control measures that adequately protect public health. What happens in California affects all of us because products of California agriculture are available all over the country –and the world. In addition, policies set by the state of California are often examples for other states and the federal government. Tell California Department of Pesticide Regulation to ban chlorpyrifos. California’s Office of Environmental Health Hazard Assessment (OEHHA) states: Under the Toxic Air Contaminant Identification and Control Act (AB 1807, Chapter 1047, Statutes of 1983) and its implementing regulations (Title 3, California Code of Regulations, Section 6864), one of the criteria for identifying a pesticide as a TAC is if its concentration in the air exceeds one-tenth of the level that has been determined to be adequately protective of human health. The draft TAC document shows that bystanders can be exposed to modeled air concentrations of chlorpyrifos that exceed one-tenth the protective level, and thus meet the criteria for TAC identification. OEHHA’s findings below serve to reinforce this overall conclusion, and […]