We’ve just finished testing off-the-shelf tobacco products from local mini-marts in Portland, Oregon and among the 20+ hidden, unregulated xenobiotic contaminants that we were able to identify (see below) we found extremely high concentrations of Carbendazim. This contamination occurred in a little cigar brand that is #1 in Latino communities and high in popularity in African-American, Native American and other marginalized & low-income communities where tobacco product choices are restricted to the cheapest, and now we know the most contaminated brands.
Carbendazim has been banned in the EU since 2014. It attacks and destroys the reproductive and immune systems of young people, particularly young Latinos, African-Americans, and Native Americans whose genetic materials are known to be more vulnerable to Carbendazim than youth of European ancestry. As you can see in the data, Carbendazim is only one many previously hidden, unregulated contaminants we found, each with it’s own health impact. But for the moment let’s focus just on the Carbendazim 0.843 mg/kg that’s being inhaled 20-40-60 times a day by @ 850,000 young people in the US right now today.
Carbendazim contamination disproportionately impacts marginalized young people who fall victim to tobacco products and who, because of poverty and carefully targeted marketing, have few choices available to them other than the cheapest and most contaminated brands. Please notice the relationship between price and contamination in the data below.
Community Tobacco Control Partners Test Results 12/18
As you can see, Carbendazim shows up in our first-ever data on pesticide contaminants of tobacco products (right hand column third row). This brand, Swisher Sweets, is #1 in popularity among young smokers, who are also right in the middle of their reproductive years. It is heavily marketed to youth, and is designed with sweet flavors and heavy social media advertising to be part of a cool lifestyle.
This means that these young people, in the middle of their reproductive years, are at the highest possible risk for suffering the known consequences of Carbendazim exposure. (And all the other pesticides you see there, each of which deserves it’s own discussion.) This is made more serious by the route of exposure, because inhalation exposure is far more toxic than eating or skin exposure, and the frequency, because smokers (and fetus and child) are exposed to the pesticides with every puff.
The bottom line is that 0.843 mg/kg is an extraordinary level of Carbendazim to find in any consumer product, but especially in an off-the-shelf tobacco product being marketed heavily to kids, considering that it has been totally banned in much of the world since 2014, is strictly regulated in the US, and is totally illegal on tobacco. Imagine the response of health authorities if this were found on school lunches, slurpees at the 7/11, beer at the mini-mart or granola at Whole Foods?
The problem isn’t just that the Carbendazim is present. For there to be that much Carbendazim residue, it had to have been sprayed on the tobacco deliberately, heavily and recently. There is full knowledge of the EU ban, and the reasons for it. All tobacco manufacturers have notified by their own scientific authority CORESTA. The manufacturers know, or have every reason to know, that they are committing serious race-based crimes against humanity. I can only assume that they have been at this for so long that they actually don’t realize what they are doing to so many people.
Here are just a few of the peer-reviewed research data links that throw light on this hidden relationship
“The literature review indicates that CBZ induces reproductive and developmental toxicity through alteration of many key events which are important to spermatogenesis. It seems that this fungicide may influence the hypothalamus-pituitary-gonad axis in addition to being a testicular toxicant.”
“2,5-Hexanedione (2,5-HD), a taxol-like promoter of microtubule assembly, and carbendazim (CBZ), a colchicine-like inhibitor of microtubule assembly, are two environmental testicular toxicants that target and disrupt microtubule function in Sertoli cells.”
“Administration of carbendazim induced significant decrease in testis weight, diameter, and germinal epithelial height of the seminiferous tubules. Histological results revealed degeneration of seminiferous tubules, loss of spermatogenic cells, and apoptosis. Moreover, carbendazim caused elevation of testicular malondialdehyde (MDA), marker of lipid peroxidation, and reduced the activity of the antioxidant enzymes, superoxide dismutase (SOD) and catalase (CAT).”
“Sertoli cells are the primary cellular target for a number of pharmaceutical and environmental testicular toxicants, including 2,5-hexanedione, carbendazim, and mono-(2-ethylhexyl) phthalate. Exposure to these individual compounds can result in impaired Sertoli cell function and subsequent germ cell loss. The loss of testicular function is marked by histopathological changes in seminiferous tubule diameter, seminiferous epithelial sloughing, vacuolization, spermatid head retention, germ cell apoptosis, and altered microtubule assembly.”
“We found that carbendazim causes embryotoxicity, apoptosis, teratogenicity, infertility, hepatocellular dysfunction, endocrine-disrupting effects, disruption of haematological functions, mitotic spindle abnormalities, mutagenic and aneugenic effect.”
And the issue isn’t just Carbendazim as you can see looking back in the data. Most of the individual contaminants are concerning by themselves, but they are additive and synergistic in effect and their impact on human health in that regard is absolutely unknown. What is known now, and IMO it ought to be enough, is that young smokers are inhaling a toxic cocktail of chemicals each designed to operate in different ways at the nano-level to disrupt basic life processes. The dosage of the most advanced pesticides doesn’t matter – they don’t need a “critical mass” to work. A couple of molecules, well below the level of detection, is enough for them to do what they were designed to do to the reproductive systems and genetic materials of bugs, and human teens are simply unfortunate collateral damage in the tobacco industry’s search for increased profits through chemistry.
If you want a new way to control the damage that Tobacco products do to your community, then this may interest you.
This post offers credible tobacco industry data showing all of the pesticides that contaminate Tobacco products worldwide. It is published by CORESTA, the tobacco industry’s captive science & research institute. This information alone can empower local initiatives by offering credible evidence that banned toxic substances may be contaminating locally-sold Tobacco products.
If your local health department has regulations that allow it to investigate whether a product being sold in your community is contaminated with banned pesticide residues, then this list will give them probable cause to sample locally-sold Tobacco products and test for the presence of banned pesticide chemicals.
It is important for you to keep in mind, when making such a request, that (1) it doesn’t matter that the products are Tobacco – they are just like pesticide contaminated candles, air fresheners or incense – and (2) these contaminants are present because of negligence by the manufacturer and lack of regulatory oversight by any superior authority, so the local authorities have to act in the interest of public health and safety.
So this is it – the official (but highly confidential) June, 2018 tobacco industry guide to the pesticide chemicals used on tobacco worldwide. It’s an industry list cautioning manufacturers to ‘watch out’ for these chemicals that remain on Tobacco from the fields, which means that it’s a list of what the industry knows is potentially present in any Tobacco product anywhere.
Many of these pesticides are damaging to human health at very low levels of chronic exposure – just like a smoker gets 100-200 times a day, 365 days a year puffing away and inhaling the pesticide residues invisibly contaminating the tobacco in their cigarette. (Except that it isn’t really tobacco, but that’s another post.)
But the really severe public health threat created by pesticides on Tobacco lies in the industry’s attempt to pivot toward vaporizing. Imagine that instead of being at least partially destroyed by combustion and smoking, all those pesticides are now being gently vaporized and delivered full-strength to your lungs as IQOS Tobacco vapor.
While the tobacco industry publishes pesticide standards for its members, it makes clear that nobody actually has to follow this industry guidance. The tobacco companies are safe from accountability because there is no testing of commercial cigarettes in the United States for the presence of any of these chemicals, and what little testing the FDA, EPA and USDA do perform almost seems deliberately designed to shield the tobacco industry from investigation. It’s not as if the FDA doesn’t have the authority to demand that Tobacco companies at least keep the contamination down a little.
907(a)(1)(B) of Section 907 of the Federal Food, Drug, and Cosmetic Act:
(B) ADDITIONAL SPECIAL RULE.—Beginning 2 years after the date of enactment of the Family Smoking Prevention and Tobacco Control Act, a tobacco product manufacturer shall not use tobacco, including foreign grown tobacco, that contains a pesticide chemical residue that is at a level greater than is specified by any tolerance applicable under Federal law to domestically grown tobacco.
Please keep that language in mind as you browse the list below. Chronic low-dose exposure to any one of the pesticides on this list, just by itself, is enough to cause serious damage to human adults, children and babies. The US government, along with the health authorities of every state, seem collectively uninterested in knowing what dozens of these violent chemicals, all being either burned or heated, smoked or vaporized and then inhaled actively or passively are doing to smokers or vapers, their families and everybody else downwind every day of their lives.
One last thing – notice that there are a lot of banned pesticides on the list. That’s because the Tobacco industry recognizes that large stores of these chemicals still exist and farmers still use them for one simple reason – they kill bugs. It might also be that these chemicals are still being made in black factories in India and China.
Whether using banned pesticides or not, most small farmers in the Third World can’t even read the labels, if there are any, so all they care about is killing bugs and fungus. Every pound of tobacco that bugs eat and fungus destroys is one less pound the farmer has to sell to feed his family, which doesn’t mean that the kids just go without a snack for a day or two.
So of course hundreds of thousands of small tobacco farmers worldwide are going to use triple-witching stuff like Endrin, Heptachlor, Aldrin, and Dieldrin whenever they can get it or whenever they are told to use it. Because while manufacturing of these incredibly toxic chemicals is banned almost everywhere, ‘black’ factories in China and India are churning out the oldies but goodies by the ton and selling them in countries where 50% of all pesticides are used on just one crop – tobacco.
But of course regulatory authorities in the ‘advanced’ countries like the US don’t test for these banned pesticides in anything anymore, much less in tobacco products like cigarettes, because “nobody uses them anymore and all the old stores have been used up or destroyed long ago”.
This is not a list of recommended CPAs (Crop Protection Agents) for tobacco. That is a matter for official and/or industry bodies in each country.
GRLs have not yet been set for all CPAs registered for tobacco. Setting GRLs is an ongoing process based on a list of priorities decided by frequency of use and importance to leaf production.
The presence of a compound does not imply endorsement by CORESTA
The entries in the list do not replace MRLs (Maximum Residue Levels) set by the authorities. Compliance with MRLs is a legal requirement for countries that have set them for
No.
CPA
GRL
(ppm)
Residue definition
Notes
1
2,4,5-T
0.05
2,4,5-T
2
2,4-D
0.2
2,4-D
3
Acephate
0.1
Acephate
4
Acetamiprid
3
Acetamiprid
5
Acibenzolar-S-methyl
5
Acibenzolar-S-methyl
6
Alachlor
0.1
Alachlor
7
Aldicarb (S)
0.5
sum of Aldicarb, Aldicarb sulfoxide and Aldicarb sulfone, expressed as Aldicarb
In countries where fungal diseases such as blue mould are a persistent problem in the field throughout the growing season, the use of dithio- carbamates (DTC) fungicides may be an essential part of the season-long disease management strategy and in keeping with GAP as a means of ensuring crop quality and economic viability for the producer. Under high disease pressure residues of dithio- carbamates (DTC) fungicides slightly in excess of the specified GRL may be observed. In countries where there is not a field fungal disease problem the use of fungicides is not necessary, and there should be no residues detected. Consistent with GAP, dithiocarbamates (DTC) fungicides must be used only according to label instructions to combat fungal diseases in the seedbed and in the field.
No.
CPA
GRL
(ppm)
Residue definition
Notes
47
Endosulfans (S)
1
sum of alpha- and beta-isomers and Endosulfan-sulphate expressed as Endosulfan
48
Endrin
0.05
Endrin
49
Ethoprophos
0.1
Ethoprophos
50
Famoxadone
5
Famoxadone
51
Fenamiphos (S)
0.5
sum of Fenamiphos, Fenamiphos sulfoxide and Fenamiphos sulfone expressed as Fenamiphos
52
Fenitrothion
0.1
Fenitrothion
53
Fenthion (S)
0.1
sum of Fenthion, Fenthion sulfoxide and Fenthion sulfone expressed as Fenthion
54
Fenvalerate (S)
1
Fenvalerate (sum of all isomers including Esfenvalerate)
sum of Heptachlor and two Heptachlor epoxides (cis- and trans-) expressed as Heptachlor
62
Hexachlorobenzene
0.02
Hexachlorobenzene
63
Imidacloprid
5
Imidacloprid
64
Indoxacarb (S)
15
Sum of S isomer + R isomer
65
Iprodione (S)
0.5
sum of Iprodione and N-3,5- dichlorophenyl-3-isopropyl-2,4- dioxoimidazolyzin-1-carboxamide expressed as Iprodione
66
Malathion
0.5
Malathion
67
Maleic hydrazide
80
Maleic hydrazide (free and bounded form)
In some instances, where GAP is implemented and label recom- mendations with regard to application rates and timing are strictly adhered to, residue levels may exceed the current GRL of 80 ppm as a result of extreme weather conditions and the current technology available for application. However, as with all CPAs, all efforts should be made to strictly follow label application rates, and use should be no more than necessary to achieve the desired effect.
68
Metalaxyl (S)
2
sum of all isomers including Metalaxyl-M / Mefenoxam
69
Methamidophos
1
Methamidophos
70
Methidathion
0.1
Methidathion
71
Methiocarb (S)
0.2
sum of Methiocarb, Methiocarb sulfoxide, and Methiocarb sulfone expressed as Methiocarb
sum of Dichlorvos, Naled, and Trichlorfon expressed as Dichlorvos
see Dichlorvos
107
Trifluralin
0.1
Trifluralin
Carbendazim is the degradation product of Benomyl and Thiophanate-methyl. In the case the same sample contains residues of both Carbendazim and/or Benomyl/Thiophanate-methyl, the sum of the residues should not exceed 2
Deltamethrin is the degradation product of Tralomethrin. In the case the same sample contains residues of both Deltamethrin and Tralomethrin, the sum of the two residues should not exceed 1
Dichlorvos is the degradation product of Naled and In the case the same sample contains residues of both Dichlorvos and/or Naled/Trichlorfon, the sum of the residues should not exceed 0.1 ppm.
Omethoate is the degradation product of Dimethoate. In the case the same sample contains residues of both Dimethoate and Omethoate, the sum of the two residues should not exceed 0.5
The Dithiocarbamates Group includes the EBDCs: Mancozeb, Maneb, Metiram, Nabam and Zineb – as well as Amobam, Ferbam, Policarbamate, Propineb, Thiram and
Methomyl is the degradation product of Thiodicarb. In the case the same sample contains residues of both Methomyl and Thiodicarb, the sum of the two residues should not exceed 1
Fluopyram added to GRL list June
If you like what I’m trying to do here please hit that little donate button below and drop a thank you on me – I would appreciate knowing that you care about the work I’m doing. Thanks.
Can you believe that RJR tried to get a tax credit for disposing of tobacco waste by processing it into cigarettes instead of dumping it in the landfill? Check it out – links to the original court case are below.
As this post is written the tobacco fields of Virginia and the Carolinas are flooded and destroyed. There are millions of pounds of waterlogged tobacco lying in mud mixed with sewage and dead pigs,the whole mess waiting to be plowed under or hauled away.
Or not. It turns out that cigarette giant RJR has a series of secret processes for making all kinds of tobacco waste into cigarettes. The tobacco farmers may be 100% wiped out, but I’ll bet RJR already has crews out there gathering up those dead stalks while they’re firing up the equipment to run that crap through their secret “G-Series” processes. More on that shortly.
But … if a few months from now that second-hand cigarette smoke drifting around on the streets suddenly starts smelling faintly like rancid pigshit with maybe a hint of faux mint you’ll know why.
Here’s the background on the secret G-Series processes that RJR doesn’t voluntarily reveal to anyone.
To Set The Scene
Picture a North Carolina courtroom in 1998. The great, all-powerful RJ Reynolds has just filed an appeal against a ruling by the North Carolina Department of Environment & Natural Resources. And lost.
The ruling says sorry, RJR can’t classify the tobacco stems, scraps, dust and trash that it uses to manufacture its cigarette products as solid waste.
Now, doesn’t that bring up the question – why would RJR want to classify its manufacturing materials as solid waste?
It sounds like a sneaky little tax loophole but hey, if RJR wants to get a tax credit for disposing of their waste in an environmentally sound fashion, what’s the problem?
The problem is that RJ Reynolds claims it is “disposing of” this waste by manufacturing it into cigarettes, and says that qualifies it for tax breaks because the waste isn’t going into landfills. It’s being bought and smoked by their customers.
There are some really clever folks down North Carolina way.
Can’t you just see those no-neck monsters with cheap haircuts sitting around the table gloating, all fashionably attired in blue dress shirts with white collars. “Get this – we already know how to take all that trash that doesn’t cost us a dime and get a bunch of dumb fucks to pay us big bucks to smoke it, and now our lawyers are saying we’re gonna get ourselves a big tax break for making them smoke that shit and not tossing it into the landfill. Pretty damn sweet!”
The Secret G-Series Processes
What made the RJR boys giggle is that their research scientists have been really successful over decades of work in coming up with a whole series of ways to use worthless tobacco trash and waste to make cigarettes. These processes, code-named the “G Series” were a major set of developments for RJR. They form the base of a major part of their wealth, allowing them to manufacture synthetic smoking materials out of tobacco trash and recycled waste and supply it to the entire US cigarette industry. (The Europeans won’t touch this shit.)
Here’s a quick look at some of the code-named RJR projects to develop processes for turning trash into cigarettes.
The RJR G-Series Codes
Internal Identification Codes for G-Processed Tobaccos follow this pattern:
G__-nnL = base for item id.
G = is a number for the process
Nn i= a number for a specific version
L = a letter for a modification
The G-Code Family
G7, G16, and G17 series codes refer to reconstituted tobacco processes while G13, G14 and G18 refer to expanded tobacco processes. G15 series refers to pectin release cast sheets.
G-Code Examples:
G7-A Ammoniated tobacco sheet developed in response to Marlboro (RJR, 1991b).
G7AE Ammonia applied to the G7 extract prior to making the reconstituted sheet (Gignac et al, 1988).
G7-10B 1.2% DAP Treated G7-1 Sheet
G7-DAP Evaluate DAP for improving the taste of G7A (RJR, 1989b).
RJR’s “Toxic Waste Into Cigarettes” Court Case – The Smoking Gun
The “Toxic Waste Into Cigarettes” case number is no. COA01-74 in the North Carolina Court of Appeals filed: 19 February 2002. The full text of the case and the court’s ruling is available at
The basic idea is that since RJ Reynolds is disposing of millions of pounds of waste every year by making it into cigarettes and selling them to American smokers rather than dumping all that waste in a landfill, the company therefore deserves a tax break for being good environmental stewards. The testimony of RJR and others recorded in this lawsuit reveals information about how RJ Reynolds manufactures its products that ought to give any cigarette smoker, and any regulator, and any jury, cause to realize the extent of the knowingly deceptive and harmful practices of this cigarette giant.
The only reason all this doesn’t set off alarm bells is that the so-called “tobacco” industry has spent (quite literally) billions of dollars on social conditioning so that your reaction on reading anything negative about cigarettes is very likely “So what – I know all that. I’m tired of hearing about it. It’s old news.”
If you think those ideas are your own, think again. They are implanted.
But really consider the evidence, so cleverly hidden in plain sight, and it becomes compelling and conclusive even in partial outline. Sooner or later the cigarette industry is going to have to answer for this hidden but discernible criminal conspiracy against humanity, which is of a magnitude and horror that makes it virtually incomprehensible even to thoughtful minds. And that, of course, is exactly the idea.
The Evidence
Here are a few of the details directly from the court papers from COA01-74 North Carolina:
In manufacturing tobacco products, Reynolds does buy tobacco leaves at auction. The tobacco is sent to a stemmery, where the stems (hard, woody part of the leaf) are separated from the lamina portion of the leaf (material in between the stems). The separation process also generates small scraps of tobacco (scraps) and very fine scraps of tobacco (dust). The usable tobacco lamina material is sent to the manufacturing operation where it is blended and becomes part of what winds up as a cigarette.
The stems, scraps and dust are packed into containers and sent to a storage facility until they are either processed into reconstituted sheet tobacco, through related treatments known as the G-Series processes, or are discarded. The reconstituted sheet tobacco is shredded and blended with the processed lamina strips and made into filler for cigarettes. The reconstituted tobacco filler is part of most brands of cigarettes made by Reynolds, and enables cigarettes to be made with lower tar and nicotine content which according to Reynolds has been “demanded by smoking consumers”.
Reynolds uses approximately seventy million pounds of tobacco stems, scrap and dust each year in making reconstituted sheet tobacco for its own use, and many millions more for other manufacturers. Reynolds also disposes of between five and seven million pounds of tobacco waste materials in landfills each year. This material is of a lower quality than the stems, scrap and dust used in the G-Series processes; much of it is generated by the manufacturing process, rather than the stemmery, though some tobacco waste generated by the stemmery is also disposed of.
In order to keep up with its production requirements for reconstituted tobacco, Reynolds imports tobacco stems purchased overseas. For example, in 2006 (the latest year for which US Government data is available), the US imported 136.8 Million pounds of Tobacco stems. In other words, there weren’t nearly enough stems being produced from US tobacco for the manufacturers to use in making their products. These manufacturers, on the other hand, would probably say “Well, Tobacco stems are still real Tobacco, so what’s the big deal?” The big deal of course is that many of the most dangerous pesticides used on tobacco overseas (like slug and snail control chemicals) are taken up from soil application into the roots and stems, and others translocate from the leaf where they are sprayed into the stems and stalks.
Reynolds sells reconstituted tobacco to other manufacturers of tobacco products, and manufactures reconstituted sheet tobacco for other tobacco manufacturers, using stems, scraps and dust supplied by them. As you can read in the case file, one of Reynolds’ witnesses testified that even if there were no tax incentives for recycling and resource recovery of or from solid waste, “Reynolds would still operate the G-7 process because of its cost-effectiveness.”
While it’s bad enough that this corporation wants tax breaks for selling waste to its customers, what isn’t revealed here is that this “tobacco” waste is highly contaminated with toxic, carcinogenic, mutagenic and endocrine-disrupting agricultural chemicals and pesticides. That single sentence “In order to keep up with its production requirements for reconstituted tobacco, Reynolds imports tobacco stems purchased overseas” holds the clue. When you look at where RJ Reynolds buys its tons of waste overseas you find that it is coming from countries that have absolutely no regulations on pesticide and other toxic chemical use on tobacco crops. This means that the waste that RJ Reynolds is putting in its cigarettes, and that Reynolds is selling to other cigarette manufacturers as reconstituted “sheet” contains high levels of pesticides that are totally banned for use on any crop in the US.
Many of these chemicals are known carcinogens, they are known to destroy nervous systems, they are known to produce deformed babies, and they are known to produce a range of debilitating and fatal diseases in humans. Furthermore, carefully-done research studies show that many of these pesticides, especially the more recent chemicals that attack DNA and other genetic materials in insects, are far more dangerous to children, young women, and the unborn in every population, and to people with Latin, Native American, Asian or African biological ancestry, than they are to adult Caucasian males. That explains why pesticide residues in cigarettes “aren’t a problem” for the white guys running the so-called “tobacco” industry.
RJ Reynolds and all the others could choose to manufacture their cigarette brands from pure tobacco leaf grown in the US or even other countries under strict pesticide regulations. The reason they choose to pack their products with toxic waste instead is because it is so profitable to do so, and because nobody has called any of them on the practice.
RJR Lost That One
As it happened, not so fast smart guys. The North Carolina judge actually ruled that time even the mighty RJR legal department had gone too far. The judge said no, the Dept. of Environment & Natural Resources is right, and you can’t claim a tax credit for disposing of your toxic waste by getting your customers to smoke it. Boo Hoo. RJR lost that one – or did they?
They didn’t get a tax credit for making people smoke their waste instead of polluting the landfill with it, but I’m betting that what the engineer says in the court testimony remains true – “it’s so profitable that even if they don’t get a tax break they’ll still use G-7”.
I can’t tell whether or not RJR is still using any of its patented “G-Series” processes in 2018 for disposing of toxic waste by making it into cigarettes and telling smokers they’re getting “true tobacco taste” or “natural tobacco”, or something equally deceptive. However, RJR is the biggest supplier of tobacco “sheet” to other manufacturers, and appears to be the biggest importer of tobacco waste for that purpose, so my guess is that the “G-Series” is not only alive and well (unlike smokers) but flourishing (also unlike smokers).
So just to see what’s happening these days I’ve just filed a FOIA request for the USDA records that cover the $2 Billion worth of tobacco stems and trash imported in 2017. These records will show every US company that imported this toxic waste, the waste’s country of origin, and the importer’s certification for each shipment that it isn’t contaminated with residues of any banned pesticide like dioxin or DDT.
Update (10/30/18) – no need to file a FOIA request – all the data on tobacco waste imports by American ‘tobacco’ companies that make that waste into cigarettes is right here.
It turns out that RJR is NOT the biggest importer of tobacco waste for cigarette manufacturing – that honor goes to Philip Morris as you can see if you click here.
Now if you would like to see a short video by Philip Morris that explains how they turn waste into cigarettes,click here. Just keep in mind that they slip the Big Lie in at about 2:11 into the video.
That’s all they have to do to import those millions of pounds of toxic waste they’re going to make into cigarettes. They just sign and go, and nobody ever checks again. That may change.
A little donation would go a long way toward supporting my efforts here.
Thanks.
I’ll share the results of this FOIA inquiry in another blog post.
