Just Label It’s Comment on USDA DEIS on Dow AgroScience Petitions for Deregulation of 2,4-D Resistant Corn and Soybeans

SUBMITTED ELECTRONICALLY

Sid Abel
Biotechnology Regulatory Services
4700 River Road
USDA, APHIS
Riverdale. MD 20737

Re: DEIS on Dow AgroScience Petitions for Determinations of Non-Regulated Status for 2, 4-D-Resistant Corn and Soybean Varieties.

Just Label It (JLI) submits the following comments on the Draft Environmental Impact Statement on Dow AgroSciences’ petition to deregulate corn and soybean varieties for 2,4-D resistant crops.

JLI believes the most troubling aspect of USDA’s decision to deregulate 2, 4-D resistant crops is the agency’s failure to recognize the “chemical treadmill” created by the dramatic expansion of herbicide tolerant crops. As weeds have become more resistant to glyphosate, farmers have been forced to turn to more powerful herbicides like 2, 4-D – a chemical treadmill that benefits companies like Dow at the expense of farmers, human health and the environment. While Dow contends that 2, 4-D will help alleviate the “super weed” problem create by extensive use of glyphosate, Enlist will actually trigger the growth of still more resistant weeds and invite the use of even more toxic herbicides. USDA should reject proposals to regulate 2, 4-D resistant crops and instead use the agency’s authority to reduce – not expand – the use of herbicides.

JLI strongly opposes efforts to expand the use of an herbicide that has been linked to numerous health problems including lymphoma, endocrine disruption and reproductive problems. Although consumers are already routinely exposed to unsafe levels of 2, 4-D through lawn care products, USDA’s proposed deregulation of 2, 4-D resistant corn and soybean would greatly expand the agricultural use of this herbicide to more than 170 millions pounds per year over the next decade. Simply deregulating 2, 4-D resistant corn could increase the use of 2, 4-D on corn by more than 100 million pounds over the next five years.

Deregulation of 2, 4-D creates significant new risks to human health, especially farmers. Despite significant increases in human exposure to 2,4-D, USDA has failed to adequately consider the cumulative impacts of this herbicide, including the impacts on rural residents. Farmers are more likely to suffer from higher rates of certain cancers, such as non-Hodgkin’s lymphoma, that have been linked to 2, 4-D. Numerous studies have found that farmers who use 2, 4-D are more likely to contract lymphoma, leading some countries to ban its use. Other studies have found that 2, 4-D disrupt the human endocrine system, resulting in birth defects, neurological damage, and interference with reproductive functions.

Deregulation of 2, 4-D also creates the risk of significant new economic harms. 2, 4-D is a volatile herbicide that is prone to drift, and the deregulation of 2, 4-D resistant corn and soybeans poses significant economic threats to neighboring farms, including organic and conventional fruit and vegetable farms. Although deregulation of 2, 4-D corn and soybeans will greatly increase the economic harm posed by 2, 4-D, USDA failed to properly assess these impacts and to consider the benefits of alternatives to deregulation of 2, 4-D, such as expanded use of integrated weed management strategies that include crop rotation, cover crops, judicious use of crop tillage, and targeted herbicide applications.

JLI is grateful for the opportunity to submit these comments on the Draft Environmental Impact Statement on Dow AgroSciences’ petition to deregulate corn and soybean varieties for 2,4-D resistant crops. JLI urges USDA to deny Dow AgroSciences’ petition to deregulate 2,4-D resistant corn and soybean varieties.