(Beyond Pesticides, October, 16, 2014) Despite a massive outpouring of public opposition, the U.S. Environmental Protection Agency (EPA) announced yesterday that it has registered Enlist Duo ®, officially putting the rubber stamp of approval on the sale and use of a new wave of genetically-engineered (GE) 2,4-D tolerant crops.
Developed by Dow AgroSciences, Enlist Duo ® is an herbicide that incorporates a mix of glyphosate and a new formulation of 2,4-D, intended for use on GE Enlist-Duo ®-tolerant corn and soybean crops. While registration of the herbicide was anticipated by most of the public since the U.S. Department of Agriculture (USDA)’s approval of the Enlist Duo ®-tolerant crops in mid-September, the announcement still comes as a disappointing shock, demonstrating the failings of the U.S. pesticide and agricultural regulatory system to put people and the environment before economic incentives and industry bottom lines.
“EPA approval of this herbicide sets a dangerous precedent,” says Jay Feldman, executive director of Beyond Pesticides. “Instead of looking to alternatives, regulators are signaling that the answer to widespread weed resistance is more toxic products that endanger farmworkers and farming communities.”
As Beyond Pesticides noted in its comments submitted to EPA in June of this year, the documented adverse effects of 2,4-D, a chlorophenoxy herbicide, are plentiful and include human health risks of soft tissue sarcoma, non-Hodgkin’s lymphoma, neurotoxicity, kidney/liver damage, and harm to the reproductive system. EPA’s own research suggests that babies born in counties where high rates of chlorophenoxy herbicides are applied to farm fields are significantly more likely to be born with birth defects of the respiratory and circulatory systems, as well as defects of the musculoskeletal system like clubfoot, fused digits, and extra digits. These birth defects are 60-90% more likely in counties with higher 2,4-D application rates. The results also show a higher likelihood of birth defects in babies conceived in the spring, when herbicide application rates peak.
And it doesn’t stop with human risks. Environmental adverse effects also abound, stemming from EPA-acknowledged risk of increased-weed resistance.
There are concerning safety gaps in the human health risk assessment that Dow AgroSciences provided to EPA for Enlist-Duo ®’s registration. These issues are compounded by EPA’s decision to waive the tenfold safety standards under the Food Quality Protection Act (FQPA), as noted in a letter from U.S. Representative Henry Waxman (D-Calif.) to EPA, as well as dismiss the need for new tolerance assessments from aggregate exposures based on outdated data.
For these and other reasons, public opposition to both the clearance of Enlist-Duo ®-tolerant seeds and registration of Enlist Duo ® has been loud and clear. Over the 60-day public comment period for the Enlist Duo ® seeds, which ended back in March, USDA received over 10,000 comments on its draft environmental impact statement and plant pest risk assessments. Of these comments, over 88%, including Beyond Pesticides, were opposed to the non-regulated status of the Enlist varieties. During a recent 30-day “review period” in August for the final environmental impact statement, the agency received 969 submissions. Again the majority did not support deregulation. Additionally the agency received over 240,000 signatures from three non-government organizations opposing the deregulation of the Enlist crops.
Regardless of public opposition and the science to back it, EPA insisted in its announcement yesterday that, “EPA scientists used highly conservative and protective assumptions to evaluate human health and ecological risks for the new uses of 2,4-D in Enlist Duo. The assessments confirm that these uses meet the safety standards for pesticide registration and, as approved, will be protective of the public, agricultural workers, and non-target species, including endangered species.”
Registration only applies to the use of the pesticide six states, (Illinois, Indiana, Iowa, Ohio, South Dakota, and Wisconsin) and further comments are solicited until November 14, 2014 for expansion of the registration to use of the herbicide in Arkansas, Kansas, Louisiana, Minnesota, Missouri, Nebraska, Oklahoma, Tennessee, and North Dakota.
Beyond Pesticides has argued to EPA and USDA that the weed resistance in herbicide-tolerant cropping systems is escalating and not sustainable, contributing to a chemical-dependency treadmill. A 2011 study in the journal Weed Science found at least 21 different species of weeds to be resistant to applications of Monsanto’s Roundup.
Although touted to address this problem of resistance, research reveals weed resistance to 2,4-D is already developing in areas of the western U.S., even without the presence of herbicide-ready crops. Additionally, despite assertions to the contrary, a 2012 report shows that GE crops are responsible for an increase of 404 million pounds of pesticides, or about 7%, in the U.S. over the first 16 years of commercial use of GE crops (1996-2011). USDA’s own analysis finds that approval of 2,4-D-resistant corn and soybeans will lead to an unprecedented 2- to 7-fold increase in agricultural use of the herbicide by 2020, from 26 million to as much as 176 million pounds per year. Even at current use levels, 2,4-D drift is responsible for more episodes of crop injury than any other herbicide. These alarming and ongoing problems point to systematic deficiencies in the current regulatory system and pesticide-use paradigm ””new GE crops will not “solve” resistance issues, but merely push the problems of weed management further down the road.
Join Beyond Pesticides in continuing to fight against the dangerous wave of GE crops and chemicals! Visit our website to learn more about GE crops and how to keep them out of our environment and food!
All unattributed positions and opinions in this piece are those of Beyond Pesticides.