(Beyond Pesticides, April 4, 2025) In March, the California Department of Pesticide Regulation (DPR) announced the launch of SprayDays California, “a first-of-its-kind statewide system designed to provide transparent, accessible and timely notifications and information about the use of specific pesticides[,]“ according to the agency’s press release. The state says that notification will occur in “advance of the scheduled use of California restricted material pesticides in production agriculture.” Growing out of the passage of AB 617 Community Emissions Reduction Act in California, passed in 2017, farmworker safety advocates have long been urging an implementation strategy that provides notification of pesticide spraying. In late 2017, the California Air Resources Board (CARB) began implementation of AB 617, a bill enacted with the stated intent of addressing the air quality crisis in many communities of predominantly people of color who are disproportionately harmed by toxic chemicals. While the overall goal of the law is to reduce air pollution in these communities, farmworker advocates have sought to operationalize a pesticide spraying notification system to warn communities when nearby spraying is scheduled to take place. The idea behind notification programs and transparency in government is that it enables those potentially exposed to take precautionary measures to […]

(Beyond Pesticides, January 17-20, 2025) Martin Luther King Day recognizes the achievements of a remarkable civil rights leader while asking the nation to assess what more the country must do to ensure equality and environmental justice, as well as protection for those who suffer disproportionately from toxic chemical exposure. Advocates and disproportionately affected communities acknowledge the historic nature of the Biden Administration’s commitment to elevating environmental justice in the decision-making of the U.S. Environmental Protection Agency (EPA). However, according to Willy Blackmore, writer for Minnesota Spokesman-Recorder (“the oldest Black-owned newspaper in the state of Minnesota and one of the longest-standing, family-owned newspapers in the country”), “[T]he more systemic change that [Administrator] Regan’s EPA tried to bring about was stonewalled by legal challenges that threatened to undermine the agency’s strongest tool for righting environmental injustices.” Black communities across the nation face disproportionate impacts to petrochemical infrastructure and toxic chemicals, including pesticides and fertilizers. A 2021 study published in BMC Public Health found that biomarkers for 12 dangerous pesticides tracked over the past 20 years were found in the blood and urine of Black participants at average levels up to five times those in White participants. A University of Michigan study found […]

(Beyond Pesticides, December 16, 2024) The fact that three-quarters of all U.S. fruits and nuts and one-third of all U.S. vegetables are grown in California means that all U.S. food eaters have a stake in how food is grown there. California is proposing the continued use of the fumigant 1,3-dichloropropene (1,3-D, also known as Telone), which can cause deadly effects to farmworkers and endocrine disrupting effects to communities of people exposed through nontarget chemical drift from farmland. So, it is with deep concern that Beyond Pesticides is urging the state of California, where the chemical is undergoing review, to ban the toxicant. Endocrine disruption, an adverse effect for which the U.S. Environmental Protection Agency (EPA) has never completed a pesticide testing protocol, adversely affects the functioning of glands and hormones and is linked to major life-threatening diseases in most organ systems in the body—contributing to attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, diabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorders, and childhood and adult cancers. In a recently released draft regulation, the California Department of Pesticide Regulation (CDPR) will allow highly elevated exposure to 1,3-D, ignoring the scientific literature and advice of the state’s own toxicologists at […]

(Beyond Pesticides, December 13, 2024) In October, the U.S. Environmental Protection Agency (EPA) approved the registration applications of BASF Corporation and Mitsui Chemicals Crop & Life Solutions, Inc. for the use of different formulations of the L-isomer of glufosinate (also known as “L-glufosinate” and “glufosinate-P”) as new active herbicidal ingredients. This decision marks one of the first times that EPA has employed its new Herbicide  Strategy Framework to determine the level of mitigation necessary to protect listed species and critical habitat under the Endangered Species Act (ESA). Glufosinate is an organophosphate, with known neurotoxic, reproductive/developmental effects, toxic to aquatic life, and mobile in soils (see Beyond Pesticides Gateway). Scientists have found that formulated glufosinate is generally more toxic to aquatic and terrestrial animals than the technical grade active ingredient. Manufacturers are introducing newer glufosinate products as alternatives for glyphosate-based herbicides, like Bayer/Monsanto’s ‘Roundup’ and dicamba. The Center for Biological Diversity notes in comments submitted to EPA on this decision, “L-glufosinate has the potential to be used on tens of millions acres of land every year given the crops EPA has proposed to register it on. The scale of potential use is far above most new active ingredients.” This first significant application […]

(Beyond Pesticides, November 25, 2024) When the U.S. Department of Agriculture (USDA) announced at the end of October a $15 million program to expand access to organic dairy products in schools, it added funds to an agency effort underway that is intended to support and incentivize farmers to grow organic and make organic food more widely available. While the millions being invested is a fraction of what organic advocates say is necessary, Congress and USDA have established a framework that recognizes the need to address the current health, biodiversity, and climate crises with accelerated adoption of organic. The issue now is whether organic will garner the support necessary to meet the life-sustaining challenges in the next Farm Bill, which may not be taken up until the next Congress is sworn in and the new administration is inaugurated. The U.S commitment to organic has been building since the adoption of the Agricultural Productivity Act in 1983, which established the Low Input Sustainable Agriculture program (later becoming the Sustainable Agriculture Research and Education (SARE) program) at USDA, and then the passage of the Organic Foods Production Act in 1990. However, among the articles published on the subject, research reported in Environmental Science & […]

(Beyond Pesticides, October 28, 2024) STARTS WEDNESDAY—NATIONAL FORUM: IMPERATIVES FOR A SUSTAINABLE FUTURE. As scientific articles and regulatory reviews by the U.S. Environmental Protection Agency (EPA) focus on individual pesticides or families of pesticides and specific health outcomes associated with exposure, legislation introduced by U.S. Senator Cory Booker (D-NJ), S. 5084, Safe School Meals Act (SSMA), proposes a holistic response to the protection of children by banning pesticides in school lunches. While focused on the elimination of certain individual pesticides and other chemicals of known concern, the bill unilaterally allows children to be served food from certified organic farms. The overwhelmingly large body of scientific findings on the adverse effects of pesticides in the food that children eat in schools and generally. For example, last week Beyond Pesticides commented on EPA’s Draft Human Health and/or Ecological Risk Assessments for Several Pesticides, citing scientific findings that, “Neonicotinoids . . .have been found to affect mammalian nicotinic acetylcholine receptors (nAChRs) [which] are of critical importance to human brain function, especially during development and for memory, cognition, and behavior.” (See more here.) This month, Jennifer Sass, PhD, et al., in Frontiers in Toxicology, published a review of  unpublished rodent developmental neurotoxicity (DNT) studies […]

(Beyond Pesticides, October 24, 2024) When U.S. Senator Cory Booker (D-NJ) introduced S. 5084, Safe School Meals Act (SSMA) in September, he identified four objectives: Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals. The limits will be based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure. Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement. Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals. Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA’s analysis. While groups like Beyond Pesticides applaud Senator Booker’s initiative to restrict exposure to some of the most hazardous toxicants, especially the most vulnerable subpopulation of children, their goal is to provide organic food to school children. In this spirit, groups have advocated that the U.S. Department […]

(Beyond Pesticides, September 13, 2024) While chemical companies persist in pushing simplistic solutions to complex problems, there is a large amount of evidence that organic farming presents effective solutions to many of those problems. Now there is new evidence that organic agriculture prevents the untold harms of pesticide-driven monoculture. In a new study, German researchers compared 16 agricultural landscapes in Lower Saxony and northern Hesse that had different combinations of semi-natural habitat, organic practices, and annual and perennial flower strips. Overall, the researchers find that organic farming provides the highest benefit to the bees, along with the presence of diverse flowering plants in and near monoculture fields. The study compares the effects of three honey bee conservation methods on the prevalence of the parasitic mite Varroa destructor and the 11 parasites Varroa transfers to bees, and the impact of these destructive organisms on bee colony growth. The findings were reported in the June issue of the Journal of Applied Ecology. Organic practices lead directly to lower parasite load and higher colony growth—essentially, the more organic crops, the more bees, and the more parasites, the fewer bees. Pesticides plus monoculture doubles the damage: Pesticides increase mortality, damage bees’ immune systems, and […]

(Beyond Pesticides, August 16, 2024) The International Panel of Experts on Sustainable Food Systems (IPES-Food) released a report, Food from Somewhere: Building food security and resilience through territorial markets, in July identifying the importance of moving beyond toxic chemical dependent, industrialized agriculture and toward “sourcing local and organic food” through alternative models, such as farmer and consumer-owned cooperatives, alternative certification schemes, and fostering relationships between organic producers and consumers through territorial markets. “[T]erritorial markets are closely associated with agroecology, and in many cases help to provide market outlets for farmers using natural fertilizers and pesticides that work with nature, rather than the fossil-fuel based synthetic inputs associated with corporate value chains,” the authors state and go on to advocate for transformative action based on various case studies rooted in organic principles and practices. Territorial markets are a nascent concept rooted in agroecology (“an integrated approach that simultaneously applies ecological and social concepts and principles to the design and management of food and agricultural systems”) and political ecology, which depending on the perspective may have differing definitions. However, there are several commonly held principles of territorial markets that include ideas of “closer to home,” “largely or fully outside of corporate chains,” […]

(Beyond Pesticides, August 5, 2024) As the longstanding problem of involuntary pesticide exposure through chemical drift continues unabated, EPA announced “new, earlier protections” that are being criticized by Beyond Pesticides as inadequate. The organization is calling on the public to let EPA and Congress know that it must comprehensively eliminate nontarget chemical trespass. Beyond Pesticides notes that the recent EPA announcement does not stop the movement of pesticides off the target sites restricted by pesticide product labels and therefore does not protect the public and environment in agricultural, rural, suburban, and urban areas from resulting health and ecological threats. EPA’s July 15, 2024, press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift” states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.” >> Tell EPA and Congress that EPA must protect against all forms of pesticide drift. Pesticide drift—more properly designated “chemical trespass”—is a threat to people living in agricultural, rural, suburban, and urban areas, […]

(Beyond Pesticides, July 30, 2024) The U.S. Environmental Protection Agency (EPA) announced on July 15 what it described as a new process for evaluating the risks of spray drift—the migration of pesticides from their target area to off-site zones. According to a statement by EPA Chemical Safety and Pollution Prevention Assistant Administrator Michal Freedhoff, PhD in an Oregon Public Broadcasting story, the agency took the step so that “people don’t have to wait years for the protections they deserve and need.” However, EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in [its] 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” EPA has said, “Spray drift is governed by a variety of factors which govern how much of the pesticide application deposits on surfaces where contact with residues can eventually lead to indirect exposures (e.g., children playing on lawns that are next to treated fields and where residues have deposited).” The new policy will add spray drift evaluation to occasions when the agency receives an application for a new pesticide and when a registered pesticide is intended for a new use or applied to a new crop. […]

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

(Beyond Pesticides, July 1, 2024) Comments on proposed new dicamba uses are due Friday, July 5 The U.S. Environmental Protection Agency (EPA) is accepting public comments until July 5 on whether it should allow the expanded use of the weed killer dicamba, which has been associated with adverse impacts related to its propensity to drift off of the target application site. The comment period addresses a BASF chemical company proposal for additional food use of a dicamba product on dicamba-tolerant cotton and dicamba-tolerant soybeans. (See Beyond Pesticides’ comments.) This application is similar to Bayer CropScience’s application for XtendiMax®, for which Beyond Pesticides submitted comments in June. The proposed label for BASF’s Engenia® allows for application preplant, at-planting, preemergence, and postemergence (in-crop) for broadleaf weeds. >> Tell EPA to ban use of dicamba and other drift-prone pesticides. The U.S. Supreme Court Reversal This proposal is under consideration on the heels of a U.S. Supreme Court decision on June 28 that reverses a 40-year old decision in Chevron v. Natural Resources Defense Council, which created a deference to federal agencies in the rulemaking process. In the dissent to this 6-3 decision of the court, the dissenters focus on the role of executive […]

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

(Beyond Pesticides, November 13, 2023) The news of a federal Appeals Court’s reversal of a U.S. Environmental Protection Agency (EPA) decision in early November calls into question the value of the basic structures, processes, and authorities of pesticide law that the public has been told are protective of health and the environment. After decades of review and litigation, this reversal, especially on a highly neurotoxic insecticide like chlorpyrifos, identifies a fundamentally flawed system that does not protect the health of people, in this case, children’s brains. >>Tell your governor and mayor to adopt policies that support organic land management.  It was EPA’s finding that chlorpyrifos was destructive of the nervous system, particularly in children, and the functioning of the brain that led to an EPA-negotiated chemical company (Corteva/Dow Chemical) settlement in 1999 (took effect in 2000) that removed residential uses of chlorpyrifos from the market. The 2020 EPA decision, 21 years later, to stop agricultural uses followed another Appeals Court decision, departing from the agency’s usually long drawn-out negotiations that ultimately compromise health and the environment. EPA banned agricultural uses of chlorpyrifos in 2016 in the Obama Administration, but the decision was reversed by the Trump Administration in 2017. Because […]

(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 […]

(Beyond Pesticides, May 5, 2023) Low level exposure to pyrethroid insecticides found in common pesticide brands like RAID and ORTHO result in neurodevelopmental damage to laboratory animals, reinforcing evidence of harm found in epidemiological studies on human exposure to these chemicals. According to research published in PNAS Nexus, mice exposed to the pyrethroid deltamethrin displayed atypical behavior similar to humans with developmental disorders. “We are not saying these mice have autism or that they have ADHD. That’s not the goal here,” said James Burkett, PhD, study coauthor and assistant professor of neuroscience in the UToledo College of Medicine. “What we are saying is that something in their brain has been altered by this exposure and it’s resulting in the same kinds of behaviors that we see in children with autism.” Scientists arrived at this determination by exposing a group of mouse mothers to consistent low levels of deltamethrin in their food during preconception, pregnancy, and lactation. The study notes that the amount of pesticide provided was “well below the benchmark dose for regulatory guidance.” A separate control group was given no pesticide in its food. Offspring from the female mice were then put through behavioral tests on social behavior, restrictive […]

(Beyond Pesticides, March 6, 2023) After the Trump EPA was blocked from weakening the application exclusion zone (AEZ) provisions for protecting farmworkers, the rules reverted to the Obama era rules. Now, EPA proposes to reaffirm part of that rule, while accepting some of the weakening amendments from the Trump administration. Tell EPA to strengthen pesticide rules to protect farmworkers. Tell President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.    EPA’s Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworkers, their children and communities. Under the WPS, AEZs are buffer zones where people are not allowed to enter during the course of a pesticide application. Like all buffer zones, they are designed to allow application of toxic pesticides while providing a nominal degree of protection. Pesticides drift long distances when being applied and they […]

(Beyond Pesticides, February 28, 2023) The Environmental Protection Agency (EPA) filed a proposed rule this month to update the way farmers, farmworkers, and bystanders are protected from toxic pesticide applications. The rule, which governs “Application Exclusion Zones” (AEZs), is being put forth to reinstate an Obama-era rule with the addition of some new industry-friendly provisions. EPA characterizes a return to the past with the adoption of former protections, after a period of deep deregulation under the Trump Administration, as a step forward in protecting farmworkers from toxic exposure. “EPA’s top priority is to protect public health and the environment, and today’s proposal is a significant step forward to further protect the farmworkers, farmers and pesticide handlers who deliver the fuel, fiber and food that runs America,” said EPA Administrator Michael S. Regan. “Farmworker justice is environmental justice, and we’re continuing to take action to make sure these communities are protected equally under the law from pesticide exposure.” However, within the historical context of this proposal, it appears as though the agency will end up with rules that are weaker, and more industry-friendly than those currently in place before the Trump Administration. AEZs are buffer zones where individuals are not allowed […]

(Beyond Pesticides, October 19, 2022) Pet flea collars containing the insecticide tetrachlorvinphos (TCVP) are set to be banned by the U.S. Environmental Protection Agency, according to the agency’s long overdue response to a petition from the Natural Resources Defense Council (NRDC). The highly toxic pesticide has not been used on crops since 1987, yet was permitted for decades in flea collars where children could be intimately exposed to the chemical while petting and playing with the family pet. The decade-long process of bringing use of these products to an end exposes the failures of the U.S. pesticide regulatory system, and how EPA’s weak and flawed decisions that infect the marketplace with severe consequences. One may ask: How many veterinarians prescribed these dangerous flea collars to pet owners, assuming that EPA has properly assessed exposure risks to their human owners? Advocates concerned about EPA’s ongoing propensity to defer to the pesticide industry are urging an overhaul of the regulatory process and a reorientation toward toxic pesticide elimination and the adoption of organic in order to address serious health and environmental threats. NRDC originally filed its petition to ban all uses of TCVP in 2009. The petition noted that the agency completely […]

(Beyond Pesticides, September 16, 2022) A report issued on September 7 analyzes the U.S. regulatory structure that is supposed to protect agricultural workers from the harms of pesticide use. Its conclusion? The current, “complex system of enforcement . . . lacks the capacity to effectively protect farmworkers. . . . [and] the cooperative agreement[s] between federal and state agencies makes it nearly impossible to ensure implementation of the federal Worker Protection Standard.” The report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, was developed by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice. Beyond Pesticides’ coverage of farmworker exposure to pesticides and resultant harms began in the late 1970s; it continues today, most recently with attention to incidence of kidney damage, systemic racism in the farmworker policies of EPA (the U.S. Environmental Protection Agency), and extra risks endured by farmworkers during the COVID-19 pandemic. Exposed and At Risk is issued as part of the Center for Agriculture and Food Systems (CAFS) Food System Workers Law and Policy Project. Previously, CAFS issued a report in conjunction with the Johns Hopkins Center […]

(Beyond Pesticides, May 27, 2022) In a U.S. Environmental Protection Agency (EPA) court document filed on May 16, the agency signaled potential changes to the labeling it requires for “over the top” (OTT, or post-emergent) herbicides containing dicamba, a very problematic pesticide. The filing — in U.S. District Court for the District of Arizona, where EPA currently faces litigation about its 2020 dicamba registrations — comes as a result of Bayer, Inc.’s March 2022 proposed amendments to EPA registration for its XtendiMax herbicide, which contains dicamba and glyphosate. Beyond Pesticides has covered the dicamba saga for years, including the EPA Office of the Inspector General’s critical 2021 report citing an abandonment of science and assault on agency integrity for EPA’s dicamba decisions during the Trump years. Dicamba has been linked to cancer, reproductive effects, neurotoxicity, birth defects, and kidney and liver damage. It is toxic to birds, fish, and other aquatic organisms, and is known to leach into waterways after application. Dicamba also causes serious damage to non-GE (genetically engineered), non-target plants, damaging habitat and food sources for various organisms, especially for birds and insects. According to Progressive Farmer, EPA is currently considering some dicamba use restrictions after Bayer submitted them to […]

(Beyond Pesticides, March 11, 2022) With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that allows the continued use of the deadly organophosphate insecticide malathion. This just the latest example of what advocates see as an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.   In a head-spinning development, the U.S. Fish and Wildlife Service (FWS) announced on March 8 its final Biological Opinion (BiOp) on malathion, which opinion claims that the commonly used insecticide poses no extinction risk to any protected animal or plant. The FWS review and BiOp are part of EPA’s evaluation of whether malathion — an organophosphate insecticide that causes serious damage to many organisms — should retain its registration. The Executive Summary of the BiOp concludes: “Our findings suggest that no proposed species or candidate species would experience species-level effects from the action [i.e., registration and thus, permitted use of malathion], and, therefore, are not likely to be jeopardized. We also conclude the proposed action is not […]