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Dicamba was approved as an over-the-top herbicide on soybeans in 2018, and reports of damage from drifting dicamba quickly followed. Known for not staying where it is sprayed, dicamba volatilizes and becomes airborne, where it can damage soybeans that are not resistant to the herbicide, causing leaf-curling (shown here, Photo: Steve Smith) and yield losses.

Archived Blog Posts
  • Russell King | Executive Director Reading Science: A Guide for We Who Are Not Scientists

    By Russell K. King, HHRA Executive Director Less than a week ago, the academic publisher Sage Journals retracted studies that questioned the long-established safety record of mifepristone. In December. Nature ran a piece noting that, in 2023, more than 10,000 scientific papers–a record number–were retracted. Not understanding the data, the anti-science voices decry the retractions as proof of corruption in the research community. Misunderstanding scientific publishing is an old and common problem. Early in my career, I was editor of a peer-reviewed medical journal, and part of my job was to translate the scientific language into messages more easily understood by nonscientific readers. I offer here a guide to reading scientific papers when you’re not a scientist. This method is not the only method, and I didn’t create it, but I’ve found it useful. Before I do, however, I hasten to say that the wave of retractions last year does not indicate a wave of fraud in science. The number of journals in publication rose from 1 million in 1997 to 3 million in 2020, yet the average number of retractions per journal has remained largely flat during that time.  Half of the retractions are for reasons other than fabrication, falsification, or plagiarism. The data seem to say the scientific community has stepped up.  Scientists are pressuring journals, and, in turn, journals are improving their policing of papers after publication. Reading scientific papers Step by step: 1. read the abstract to get the general idea of what the paper is about; 2. read the figures and legends to understand the data (then look to see whether they align with the conclusions in the abstract); 3. read the discussion, where the authors summarize and interpret the data (then see whether it aligns with the data in the figures and the overview in the abstract); and 4. if it’s not your field of expertise (true for most of us, even if it’s hard to admit), read the introduction to get a feel for what the relevant literature says; 5. if you’re evaluating how they got from the data to the conclusions, read the discussion (are they using standard methods, missing controls, using a representative sample and a control group, etc.?); and 6. read through a few references to see whether they say what the authors claim they do (padding the references with papers that do not fit is often a way to build false credibility). Red flags As you’re reading, keep your eyes open for signs that should cause you to pause and question the paper’s validity. Red flags don’t necessarily mean the paper is untrustworthy, just that we should not draw conclusions without digging deeper.  Some such red flags are: 1. the author has no expertise in the subject of the paper (is their degree in a relevant field, have they worked in the field, have they previously published in the field in reputable journals?)–crossovers are not uncommon, but these will typically have a coauthor who has credible expertise; 2. the references are old, meaning fewer than six citations from the past five years; 3. the results asserted are not closely tied to the data or are not placed in context with other studies; 4. the conclusions contradict the literature or general scientific consensus–advances happen, but this should prompt us to withhold judgment until we get more information; 5. funders are not disclosed; 6. conflicts of interest are not declared; and 7. the results have not been peer reviewed. Know yourself Because science and anti-science have become such powerful forces in cultural and political differences, it’s vital that we check ourselves as we read and evaluate scientific papers. No matter how well trained we are in critical thinking, no matter how separate we think we are from the cultural and political echo chambers around us, we are still human and we are still given to myriad thinking errors. To deal with the overwhelming amount of information our brains take in, our brains seek shortcuts to lessen the burden. Sometimes these shortcuts are helpful; too often they are not. At minimum, we process information through our personal confirmation bias and a complex, overlapping, ever-changing matrix of internal filters made of everything from our DNA to what we had for lunch. We must ask ourselves–more often than is comfortable–whether our understanding of what we’re reading is being distorted by our own emotions, preferences, prejudices, assumptions, and hopes. This requires us to be honest with ourselves about our emotions, preferences, prejudices, assumptions, and hopes. Read! Science is always emerging, never static. By the moment, it grows ever broader, deeper, more beautiful, more fascinating, and more important to our lives. We depend on science to bring us new information and understanding, to correct the errors of our past and–yes–to retract papers that are erroneous. The 10,000 retractions of 2023 should enhance, not undermine, our appreciation for the men and women of science who share their work with us.  What’s happening in science is exciting, and I promise you that reading about it is more than worth the effort.    

  • Securing the Future of Science: Planned Giving for HHRA

    Planned giving is the process of donating planned gifts, also known as legacy gifts, which are contributions that are arranged in the present and allocated at a future date. Commonly donated through a will or trust, planned gifts are usually granted when a donor passes away.  If you’d like to plan a gift for to support the important work of HHRA, you may use this form.  Thank you. Tax benefits:  Donors can contribute appreciated property, like securities or real estate, receive a charitable deduction for the full market value of the asset, and pay no capital gains tax on the transfer.  Donors who establish a life-income gift receive a tax deduction for the full, fair market value of the assets contributed, minus the present value of the income interest retained; if they fund their gift with appreciated property they pay no upfront capital gains tax on the transfer.  Gifts payable to the HHRA upon the donor’s death, like a bequest or a beneficiary designation in a life insurance policy or retirement account, do not generate a lifetime income tax deduction for the donor, but they are exempt from estate tax. More information: For those who wish to make legacy gifts that are guaranteed to support their own philanthropic interests and intentions, planned or deferred gifts may be most effective. Planned gifts require more planning than most current gifts or income or equity, often including legal and accounting counsel from a donor’s trusted advisors. Because these gifts produce philanthropic benefits to recipient organizations, there may be benefits to the donors or their heirs via reductions in state or federal income, capital gains, estate, or gift taxes. There are many ways to make planned gifts, the most simple of which are life insurance policies, designated distributions from retirement funds, or bequests, where donors designate a percentage or a specific amount of their estate to the recipient charity.  Specific amounts are preferable, as they do not require a full valuation of the estate before distribution can be made. For donors over the age of 70 ½ years who are required to take minimum annual distributions from their Traditional or Roth Individual Retirement Accounts (IRAs), up to $100,000 may be directed to charitable causes, with potentially significant tax savings each year. More complex planned giving arrangements such as charitable gift annuities, charitable remainder unitrusts, charitable remainder annuity trusts, lead trusts and others may provide donors with guaranteed income for the remainder of their lives in exchange for funds transferred to charities now. The gist of most such gift vehicles involves a donor making a current gift to a charity with commensurate tax benefits, the charity paying the donor per agreed-upon terms from those funds in the years that follow, with the remainder of the funds at the donor’s death remaining with the charity in perpetuity.

  • HHRA Earns 2024 Highest Recognition for Transparency

    By Russell K. King, HHRA Executive Director I’m pleased to announce that the HHRA has once again earned the Candid Platinum Seal of Transparency (our first was in 2023)-–an achievement earned by fewer than one percent of US-based nonprofits. The Candid Platinum Seal is the highest level of recognition offered by Candid (formerly known as GuideStar) and is awarded to organizations that meet the highest standards of transparency and accountability. The Candid Platinum Seal demonstrates the HHRA’s commitment to transparency and accountability. Our board, staff, volunteers, and partners believe that by sharing our data, metrics, and strategic priorities with the public, we can build trust and confidence in our organization and our work. To earn the Candid Platinum Seal, non-profit organizations must meet a rigorous set of criteria, including providing complete and accurate information about their mission, programs, finances, and governance on the Candid website, and sharing strategic priorities and information about outcomes.

  • Russell King | Executive Director The Importance of Integrity

    By Russell K. King, HHRA Executive Director Living, as we do, during an era overwhelmed by misinformation, disinformation, mistrust, grifters, posers, and pretenders, integrity is an increasingly rare and valuable quality. For a nonprofit organization like the HHRA, integrity is essential. By funding the Heartland Study, we are seeking the answer to a controversial question:  Are there health problems for mothers and infants that correlate to higher exposure of agricultural chemicals? Why is that controversial? Because there are people who insist they already know the answer and, regardless of whether they insist it’s “yes” or “no,” they prefer we don’t ask. They have vested interests in the answers they promote and fear an unbiased scientific inquiry may produce an answer that does not support those interests. A vested interest—”a strong personal interest in something because you could get an advantage from it,” according to the Cambridge Dictionary—is deadly to integrity. We don’t know whether we’re being told the truth or being told what advances your interest, so we can’t fully believe you. Doubt will endure and undermine your message. Thankfully, the HHRA has no vested interest in the outcome of the Heartland Study. The chair of the HHRA Science Advisory Committee insists we must be “agnostic about the outcome,” and the chair of the HHRA Board of Directors insists we must not “get ahead of the data.”  The principle investigator for the Heartland Study oft reminds us to “always let the science lead.”  As the HHRA executive director, I don’t care what the answer is, but I’m certain the question must be asked. The HHRA and the scientists working on the Heartland Study are not out to prove the answer is yes or no, but to learn whether the answer is yes or no. Likewise, our donors are supporting the effort to find “the” answer not “an” answer. There are no foregone conclusions here. All of which points to the integrity of our mission and our work. Integrity is demonstrated and enhanced by transparency, which is why the HHRA makes public its IRS determination letter, audited financials, bylaws (including our conflict of interest policy), strategic plan, gift acceptance policy, volunteers and staff, and the Heartland Study’s methods paper, published in a peer-reviewed journal.  Such transparency has already earned the highest award from Candid. Integrity yields many positive results.  First, the people and foundations that support the HHRA can know that the money they donate is being used for its stated purpose.  Second, and more importantly, the people who will eventually learn of our outcomes and recommendations, if any, can know that they can trust what they’re being told. That trust will make it more likely that our work will be used in improving public health.  And that is what it’s all about.

  • Russell K. King | Executive Director Holding the “Splendid Torch”

    By Russell K. King, MBA, HHRA Executive Director This time of year is especially rich with holidays that inspire deeper thoughts about our lives.  While peering through the steam rising from my coffee and contemplating my own mix of Thanksgiving gratitude, Christmas joy, and New Year’s hope and resolution, I heard the words of G. B. Shaw coming back to me: “This is the true joy in life, being used for a purpose recognized by yourself as a mighty one. Being a force of nature instead of a feverish, selfish little clod of ailments and grievances, complaining that the world will not devote itself to making you happy. I am of the opinion that my life belongs to the whole community and as long as I live, it is my privilege to do for it what I can. I want to be thoroughly used up when I die, for the harder I work, the more I live. I rejoice in life for its own sake. Life is no brief candle to me. It is a sort of splendid torch which I have got hold of for the moment and I want to make it burn as brightly as possible before handing it on to future generations.” Shaw’s words drew the HHRA into my musing.  Yes, the mission of the HHRA is a purpose I find “mighty” for which I hope to be “used up,” but I realized it’s much more than just one mighty purpose or worthy cause.  Within the HHRA mission, there are a number of splendid torches we may proudly carry. In the HHRA’s flagship program, the Heartland Study, we can find the worthy causes of maternal health, children’s health and development, environmental health, and public health, among others.  The HHRA’s Dietary Risk Index encompasses at least the worthy causes of consumer choice, food safety, and public health. Our Pesticide Use Data System and policy recommendations activities are also fertile with worthy efforts and promise. In our era, science is too often twisted to suit political, religious, and pecuniary ends, but the HHRA holds high the splendid torch of science as a search for truth.  The chair of our board oft reminds us “not to get ahead of the data,” and the chair of our science advisory committee reminds us of our obligation to be “agnostic about the outcomes” of our study.  I’m proud to say my own life has been spent promoting science and combating both pseudoscience and anti-science.  While much of the world tries to create data to fit their agenda, we are trying to learn what the data tell us.  Of all the splendid torches the HHRA offers us, my own favorite me be this:  Science unfettered by ulterior motives. In this season of reflection and contemplation of the deeper things of life, I urge you to recognize and cherish the worthy causes you are serving with your life.  If you’re still searching for a worthy cause that will bring you a taste of Shaw’s “true joy in life,” I invite you to join and support our work at the HHRA.  Find your splendid torch and carry it high!

A New Day Dawning at EPA? New Memo Raises Hope

by Charles Benbrook | Mar 15th, 2021
by Charles Benbrook | Mar 15th, 2021
Dicamba was approved as an over-the-top herbicide on soybeans in 2018, and reports of damage from drifting dicamba quickly followed. Known for not staying where it is sprayed, dicamba volatilizes and becomes airborne, where it can damage soybeans that are not resistant to the herbicide, causing leaf-curling (shown here, Photo: Steve Smith) and yield losses.

Reporter Emily Unglesbee with DTN/Progressive Farmer has done solid reporting for years now on the trials and tribulations of dicamba herbicide and the XtendiMax GMO soybean and cotton seeds it has been applied on since 2016.

Dicamba is one of the herbicides of intense interest to The Heartland Study science team. It is known to cause reproductive problems and certain birth defects. It has been classified as a possible human carcinogen, and likely will soon be upgraded to probable human carcinogen because of recent findings showing association with cancer from the National Cancer Institute.

The use of dicamba throughout the Heartland has skyrocketed since 2016, as a result of the approval of the GMO seeds engineered to tolerate over-the-top applications of dicamba. Our HHRA interactive herbicide use tables capture clearly just how rapidly dicamba use has grown wherever corn, soybeans and cotton make up a significant share of harvested cropland.

But problems grew in step with use. Dicamba is a highly volatile herbicide. It moves up into the air, especially when it is hot and humid. It can move miles, even hundreds of miles.

The crops, trees, vineyards, shrubs and backyard gardens where it comes back down to earth often pay a price. In short, dicamba is the acid rain of the plant world. It is a plant mutagen and is especially damaging when it lands on a crop during flowering.

On March 12, 2021, Unglesbee broke a troublesome but not unexpected story entitled “EPA: Politics Tainted Dicamba Decision — EPA Ignored Science in Past Dicamba Decision, New EPA Official Says.” It describes a message just sent to EPA employees by Michal Freedhoff, the Acting Assistant Administrator for EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP). In it, Freedhoff bluntly states “I am aware that political interference sometimes compromised the integrity of our science,” and goes on to list specific examples, with the first being the 2018 registration of dicamba herbicides.

The rest of the memo sent by Dr. Freedhoff speaks for itself. I have included it in its entirety at the end of this blog.

OCSPP is the part of EPA that oversees the Office of Pesticide Programs (OPP). I have worked with and watched OPP strive to identify and mitigate high-risk pesticide uses for almost 50 years. Over this span of time, the last four years stands out as a troublesome outlier during which it seemed almost no request from any pesticide registrant was deemed too outrageous to act upon.

Did you hear that there is even an effort afoot to bring back aldicarb??? The controversial insecticide was banned in 2010 due to “unacceptable dietary risks, especially to infants and young children.”

I hope Dr. Freedhoff’s memo signals a rebirth of commitment to science and integrity in decision making in OCSPP. There is much lost time, and ground, to make up.

—Dr. Charles Benbrook, HHRA Executive Director

Below is the EPA Memo in full. View as a pdf here.

Dear OCSPP Colleagues – By now, I’ve been a part of the OCSPP team for nearly seven weeks, and I continue to be deeply impressed by and grateful for your integrity, professionalism, and unmatched commitment to public service and the public good.

I have been particularly pleased to see OCSPP career professionals speak strongly in support of Scientific Integrity. As you know, science is the backbone of EPA. Scientific integrity, in turn, is a bedrock principle for President Biden, Vice President Harris, our incoming Administrator Michael Regan, and me. Scientific Integrity ensures that our science is sound and that we earn and maintain the public’s confidence in our decision-making. I affirm my commitment to you to act with scientific integrity. I expect you to do likewise when working with me and with each other.

Our work as a science-based regulatory office requires us to embody scientific integrity in many contexts. For example, I expect:

• Robust exchange of scientific views, with differing scientific opinions expressed in writing early and shared with mangers throughout the process, including me.
• Truth-telling in briefings: what do I and other managers need to know?
• Courage to point out errors early in the process and a welcoming attitude by managers and peers to those communications.
• Respect for the role of science in risk assessments and the role of policy and law in risk management decisions. This requires the assurance that risk management considerations aren’t the driving influences during the risk assessment phase, and it requires respect among scientists when difficult policy choices are ultimately made.
• Integrity of scientific products.
• Clear, real-time communication with scientists to explain senior scientists’ changes to draft scientific products and an opportunity for scientists to express a different view.
• Understanding that, as a regulatory office, we also need to be mindful of statutory and other deadlines.
• An environment – led in the first instance by OCSPP managers – where everyone feels comfortable identifying errors, asking questions, and expressing differing scientific opinions, all without fear either of retaliation or being denigrated for speaking up.
• An environment free from political interference in the science.

Over the past few years, I am aware that political interference sometimes compromised the integrity of our science. Here are examples:

2018 Dicamba Registration Decision: In 2018, OCSPP senior leadership directed career staff to: (1) rely on a limited data set of plant effects endpoints; (2) discount specific studies (some with more robust data) used in assessing potential risks and benefits; and (3) discount scientific information on negative impacts. This interference contributed to a court’s vacating registrations based on these and other deficiencies, which in turn impacted growers’ ability to use this product.

TCE: White House staff directed OCSPP career staff to alter the draft TCE risk evaluation to change the point of departure used for making determinations of risk to a less sensitive endpoint. While the risk evaluation included a description of the more sensitive endpoint (fetal heart malformations), it was no longer used to determine whether there is unreasonable risk from TCE. Unreasonable risks were nevertheless identified for most uses of TCE, but the magnitude of the risk from exposures to TCE would have been greater had EPA relied upon the fetal cardiac defect endpoint that had been used in previous EPA peer-reviewed assessments.

PFBS Toxicity Assessment: The PFBS Toxicity Assessment that was recently removed from EPA’s website included conclusions purporting to reflect science when in fact they were the product of biased political interference directed in part by OSCPP’s past political leadership. That interference undermined the agency’s scientific integrity policy and eroded the trust that the American public has in EPA, the quality of our science, and our ability to protect their health and the environment.

This is a new day, about communication, trust, transparency and the importance of science in our regulatory decision-making process. All of us are responsible for ensuring the scientific integrity of our work. All of us are responsible for creating a work environment where everyone feels free to speak up without fear.

To this end, I encourage you to read the Science Integrity Policy. I encourage you to browse the Office of Scientific Integrity intranet page and refresh your knowledge by studying their resources and whiteboards. And please don’t hesitate to contact OCSPP’s Deputy Scientific Integrity Officer, Carol Ann Siciliano, at or (202) 564-5489, or EPA’s Scientific Integrity Officer, Francesca Grifo at (202) 564-1687 (office) or (202) 657-8575 (mobile).

I also encourage you to attend the OCSPP Scientific Integrity Training series being launched by Carol Ann. You’ll see more information about that shortly. The first session will feature a presentation and Q&A with Francesca Grifo. The second session will talk about ways to express and resolve Differing Scientific Opinions (DSO). Explore the DSO toolkit here. We also plan a training on Whistleblower protections. Get to know your rights here. More training subjects will follow. Just as important, let’s make Scientific Integrity part of our daily work and our daily conversations. You can count on me. And I know that I can count on you – managers and staff, scientists and non-scientists – to do the same.

All the best,

Michal Freedhoff, Ph.D.
Acting Assistant Administrator
Office of Chemical Safety and Pollution Prevention
U.S. Environmental Protection Agency

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