Dow AgroSciences response to activist claims regarding 2,4-D

Strikingly, pesticide opponents are making these same claims – again – only weeks after EPA announced its rejection of a Natural Resources Defense Council petition against 2,4-D (Agronews 2012-04-10) that contained many of the very same misrepresentations that pesticide opponents are making today.

Pesticide opponent hyperbole aside, the fact remains that the herbicide 2,4-D is available for use in U.S. crop production today because EPA has determined, after evaluating all human health and safety considerations – including the concerns expressed by activists – that current uses (including currently authorized uses on corn) pose “a reasonable certainty of no harm.”

This EPA conclusion was reached only after the Agency had considered all relevant data over a period of years with detailed input from science advisory panels composed of third-party health and safety experts. This regulatory conclusion is supported by mainstream health and safety experts who have thoroughly evaluated the product.

Dow AgroSciences’ new technology package for herbicide-tolerant corn, which will include our new 2,4-D choline, will offer growers a new product that is significantly less prone to off-target movement with a demonstrated 92 percent reduction in volatility and a 90 percent reduction in drift, based on research data recently presented at scientific meetings.

Although pesticide opponents continue to repeat the same old claims, the fact remains that EPA has thoroughly evaluated and responded to them, in great detail, on multiple occasions in the past, in a transparent public process in which all stakeholder opinions –including the opinions of pesticide opponents – were carefully taken into account by regulators charged with the protection of public health.

Comments submitted to the public docket must be assessed in terms of quality, not quantity.

• A regulatory process designed to weigh facts and render sound conclusions should not be disrupted by sensational claims that detailed evaluations have previously found lacking on multiple occasions.

• As regulatory authorities continue their review, Dow AgroSciences remains confident both in the value of our new technology package to American agriculture – and in the transparent, science-based processes under which EPA and USDA evaluations are conducted.

In response to some of the specific concerns expressed:

• 2,4-D is currently authorized for use in more than 70 nations worldwide, contrary to the impression left by pesticide opponents claiming that the product is “banned” in other countries. Current regulatory authorizations for 2,4-D include registrations in the U.S., Canada, the United Kingdom, Germany, France, Denmark, Sweden and Australia, based on highly precautionary health and safety evaluations.
 
• EPA announced in 2004 that it had not found a link between 2,4-D and cancer, after a detailed 17-year evaluation which included the input of third party health and safety experts. No substantive data suggesting such a link has caused EPA to change its position since that time. Studies suggesting an association with non-Hodgkin’s lymphoma (a topic often raised by pesticide opponents) were not borne out in a scientific review conducted by some of the same researchers who had proposed that specific cancer connection 15 years earlier. (Roos et al., Occupational and Environmental Medicine, June 2003, vol. 60.) As early as April 12, 2012, EPA noted in its rejection of the NRDC petition that "these data do not support classification of 2,4-D as a carcinogen." 
 
• Controversies over Agent Orange were associated with the presence of a trace contaminant in 2,4,5-T, which has been well established as the herbicide of concern – not 2,4-D. The herbicide 2,4,5-T was phased out of use in the U.S. a quarter of a century ago. Using historical allusions to a conflict that ended 40 years ago to cast doubt on 2,4-D when its uses have just recently been reaffirmed by EPA in terms of health and safety essentially amounts to product disparagement.
 
• 2,4-D and so-called “Superweeds.” Farm herbicide use has been steadily increasing for a number of years, and that increase is going to get worse without new agricultural technology like our herbicide-tolerant corn to combat glyphosate-resistant weeds.
 
• 2,4-D is already used on corn. Rates of herbicide application per acre of corn will not increase with our new technology package.
 
• Farmers are responsible stewards of the land. Pesticide opponent claims that growers will disobey contractual obligations and label directions in order to use a generic product are an insult to the vast majority of American farmers. These farmers are good neighbors, respect pesticide use directions and agreements for product use, avoid practices that might damage their neighbors' crops, and need new technology to combat resistant weeds on their farms now.
 
• The surest way to increase per acre herbicide volume is to do nothing to solve the weed resistance problem. Returning to agriculture as it was 20 years ago, as advocated by some, will merely force farmers into additional cultivation connected with increasing erosion, agricultural runoff, soil compaction and fuel use with attendant contributions to air pollution.

The recommendations that pesticide opponents are making today would make farming less efficient at a time when global crop production is barely keeping pace with food demand driven by world population expansion. It would also further impair U.S. farm productivity in a difficult economy at a time when ag exports are one of the single greatest contributors to our nation’s balance of trade.