Tell EPA: No on 2,4-D

EPA is currently considering Dow’s request to permit use of 2,4-D on its “Enlist” genetically engineered (GE) corn and soybeans resistant to this toxic herbicide.  While USDA directly controls the fate of these GE cropping systems, EPA is also assessing whether and how 2,4-D should be sprayed if these new crops are approved by USDA. 

As with USDA, EPA approval of 2,4-D new use for Dow’s new crops would drive a massive increase in use of this toxic herbicide.  This is bad for farmer and consumer health, the environment, and U.S. agriculture as a whole.

Tell EPA to deny these applications!

Comment due date: June 22, 2012

I am writing to urge you to deny Dow’s new use applications to register 2,4-D and/or glyphosate on “Enlist” genetically engineered 2,4-D-resistant corn and soybeans (Dockets EPA–HQ–OPP–2011–0835 and EPA–HQ–OPP–2012–0306). Use of 2,4-D in Enlist systems raises serious issues that fully justify EPA denial.

Dow’s Enlist systems would lead to a dramatic increase in usage of this toxic herbicide in American agriculture, with adverse impacts on human health, the environment, farmers’ welfare, and U.S. agriculture as a whole. Under FIFRA, EPA has a mandate to consider both environmental and economic costs in decisions about pesticides.

If approved for use on Enlist crops, 2,4-D would be used more frequently, at higher rates, on much greater acreage of cropland, and later in the season. Current overall agricultural usage of 2,4-D of 27 million lbs. per year would increase to well over 100 million lbs.

2,4-D exposure has been linked to numerous adverse health effects, including cancer (especially non-Hodgkin’s lymphoma), Parkinson’s disease, liver disease, reduced sperm counts, and birth anomalies in the children of exposed farmers. Increased use would exacerbate these impacts, particularly for exposed farmers.

Industry’s own tests show that 2,4-D is still contaminated with dioxins. In fact, 2,4-D is the seventh largest source of dioxins in the U.S. Although EPA recently set strict new dioxin exposure standards, it has not evaluated the health impacts of increased dioxin exposure from the massive increase in 2,4-D use anticipated with 2,4-D resistant crops.

2,4-D is a volatile herbicide that is prone to drift beyond the field of application to damage wild plants and crops. Current use of 2,4-D in agriculture already poses risks to several endangered species – the Pacific salmon, California red-legged frog and Alameda whipsnake – via adverse impacts on their habitat and prey.

EPA will soon begin a registration review of 2,4-D, the first since 2005. This review will give EPA the opportunity to assess Dow’s proposed uses in light of the issues raised above, the latest science on 2,4-D, as well as the EPA’s ongoing analysis of dioxin toxicity. The agency’s current decision specific to the Dow Enlist crops should be halted until the agency completes its wholesale registration review process for 2,4-D.

For all the above reasons, I urge you to deny Dow’s proposed registrations. At the very least, defer any decision until completion of EPA’s registration review of 2,4-D.
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