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"One thing that is distinct about the Center for Food Safety is that they are very effective litigators on these issues and no one has more success in raising issues in the courts..."
-Michael Pollan
Award-winning author of The Omnivore's Dilemma and In Defense of Food
Half a Million Ask EPA to Reject Expanded Agricultural Use of Toxic Pesticide 2,4-D
July 1st, 2014

Center for Food Safety Exposes EPA's “Deeply Flawed” Review

Over half a million people have submitted comments to the Environmental Protection Agency (EPA) asking the agency to reject Dow Chemical's plan to sell Enlist Duo herbicide for use on corn and soybeans genetically engineered (GE) to withstand 2,4-D. U.S. Department of Agriculture (USDA) has previously warned that approval of the herbicide and its corresponding GE crops would lead to a three- to seven-fold increase in agricultural use of 2,4-D, a toxic herbicide linked to Parkinson's disease, non-Hodgkin's lymphoma, and other health harms.  Over 500,000 people submitted comments during the agency's public comment period which ends today.

In detailed legal and scientific comments also submitted today, Center for Food Safety (CFS) outlined the deficiencies of EPA's review of Enlist Duo. CFS asks the agency to deny the proposed registration or postpone approval pending rigorous analysis of recent science on the negative health impacts of 2,4-D and other issues ignored by EPA.

“American agriculture stands at a crossroads. Approval of these crops and pesticides would set American agriculture down a dangerous path that will only exacerbate the problems farmers are already facing,” said Bill Freese, science policy analyst at Center for Food Safety. “These crops would lead to more intensive use of old and toxic pesticides, increased rates of cancer and other diseases, environmental harms, more crop damage from herbicide drift, increasingly intractable weeds, and sharply rising production costs on the farm.”

EPA is poised to permit Dow Chemical to sell Enlist Duo herbicide for use on GE crops that are resistant to both Dow Chemical's 2,4-D and glyphosate, the active ingredient in Monsanto's Roundup. Separately, USDA has proposed to allow Dow Chemical to sell corn and soybeans resistant to 2,4-D and glyphosate branded as Enlist corn and soybeans. USDA found during its environmental review that approval of the crops and corresponding pesticide would increase agricultural 2,4-D use to as much as 176 million pounds per year by 2020, a seven-fold increase over current use.

“Enlist is the first of a new generation of pesticide-promoting crops that will lead to dramatically increased use of pesticides with serious consequences for the American people.  While of obvious benefit to Dow, Enlist crops are strongly opposed by hundreds of thousands of average citizens, who have demanded that EPA reject the proposal,” said Freese.

“EPA's review of Enlist Duo herbicide is wholly deficient. EPA must postpone any decision on Enlist Duo until it has the opportunity to carefully consider input from the public and redress the flaws.  We are confident that a fair, science-based assessment would lead to rejection of the proposed registration of Enlist Duo,” added Freese.

Center for Food Safety finds EPA's assessment to be deeply flawed for several reasons:

1)       EPA is tasked with protecting the environment, but nowhere in its assessment does EPA even mention, much less discuss, the three- to seven-fold increase in agricultural 2,4-D use projected by Dow Chemical and USDA.

2)       In assessing the human health impacts, EPA ignores the medical literature linking exposure to 2,4-D and herbicides of its class with cancer, Parkinson's disease and other harms; does not consider numerous reports of adverse reactions to 2,4-D; and leaves unanswered serious questions about contamination of 2,4-D with highly toxic dioxins.

3)       EPA greatly underestimates the potential for 2,4-D drift to damage neighboring and distant crops, and the mitigation measures it proposes are entirely unrealistic and unworkable in the real world.

4)       Even though Enlist Duo is a potent killer of common milkweed, and monarch butterfly populations have declined precipitously in part due to the loss of milkweed host plants, EPA fails to assess its impact on monarchs.

5)       Although use of Enlist Duo would lead to rapid emergence of 2,4-D and multiple herbicide-resistant weeds, EPA does not propose any mandatory measures to prevent their emergence, but rather only a Dow-led monitoring program that is certain to fail.

6)       EPA violates federal law by failing to assess the many economic and environmental costs of approving Enlist Duo.

7)       EPA has failed to make numerous key assessment documents and interagency memos available to the public in the docket, for instance “confidential memos” on the dioxin content of 2,4-D.

The half a million comments were submitted by a coalition of organizations including Center for Food Safety, Food & Water Watch, Pesticide Action Network, National Family Farm Coalition, Environmental Working Group, Just Label It, CREDO Action, SumOfUS and Organic Consumers Association.

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