My comment to the USDA on Dow's petition to unleash 2,4-D resistant crops

(Appreciate this look at an issue that was not on my radar. Bleeding Heartland user black desert nomad has posted more details and references in the comments. - promoted by desmoinesdem)

The path to progress has little to do with speed but a heckuva lot to do with direction - an Iowa farmer said once as he described the act of stewarding his farm land to provide for his family and the next generation.  I suggest the the USDA and all interested parties heed this advice in the consideration of the status of 2,4-D Resistant corn and soybeans, and I hope you will decline the petition.  While this is only a single petition it is a strong signal to agriculture to continue on the pesticide-treadmill, whereby efficacy wanes and a new, often more potent, product is rolled out.  And while the USDA and others may chose to take that path - it should be understood they are deciding for everyone and the destructive nature of 2,4-D will impact all farmers. 
The use of herbicide resistant crops inevitably increases the use of the associated chemicals. For example, the volume of glyphosate deployed in  Iowa has grown exponentially since 1996 and today is nearly unfathomable.  The USGS has shown glyphosate is now persistent in Iowa rains and air. These technologies are dealt on a field by field basis but every acre of Iowa gets the treatment through air, water, and transport of crops.  Now on the docket is a chemical that is arguably worse than glyphosate for human and ecosystem health. When 2, 4-D was championed the first time, Iowa's leading apple and grape industries vanished in less than 10 years. Today, Iowa's wine industry is reborn but its fate likely rests on the decision before the USDA.
Veteran farmers that routinely use 2,4-D today for corn production describe that they are very concerned about this pending biotech trait. If/when the herbicide resistant crops are ok'ed, the deployment of 2,4-D will be increased and perhaps more importantly it will be used later in the growing season when volitilization-potential is greatest due to heat and the respiration of mature crops. Dow Agroscience's insistence of lesser volatility in future formulations of 2,4-D is a tough pill to swallow when Iowans see the chemical-burnt windbreaks along field edges. Agrichemical drift is a common issue for rural citizens and the farmers of Iowa growing crops other than the resistant varieties of corn and soybeans.
I am an aspiring farmer and have been actively searching for farmland upon which to begin. Twice recently I have had interest to purchase - but the small (~ 50 acre) parcels have been too narrow to avoid chemical drift - and I have declined in anticipation of the decision on this petition. If 2,4-D resistant crops are approved by you and widely adopted by farmers, Iowa might no longer be a viable place to pursue the production of small grains, vegetables, orchards and pastures as I plan to.  In order to preserve the rights and liberties of Iowa farmers to pursue diverse approaches to agriculture, I ask that you decline Dow Agroscience's petitions 09-233-01p, 09-349-01p, and 11-234-01p.
  • A more daft and reference filled take down of 2,4-D

    Dow Agroscience and Monsanto have both petitioned the U.S. Department of Agriculture (USDA) for deregulation and release of their new generation, GE, herbicide-resistant crops:

    • Dow AgroSciences is developing 2,4-D tolerant corn and soybean, designed to be used in combination with its new Enlist herbicide, which combines 2,4-D and glyphosate;

    • Monsanto is developing dicamba tolerant crops stacked with glyphosate tolerance as part of their new Roundup Ready Xtend program.

    Whereas, GE-Roundup Ready technology "is the principal method of weed control on 90% of the nation's 60 million acres of soybeans, and more than 70% of corn and cotton," (Parker, 2011, pg. 11);

    Whereas, GE herbicide-resistant (HR) technology has resulted in 404 million more pounds of pesticides applied since GE herbicide-resistant (HR) crops were first introduced in 1996 (Clark, 2012);

    Whereas, intensive, wide-scale adoption of GE-Roundup Ready technology "has led to rapid selection of 21 species of glyphosate-resistant weeds," (Parker, 2011, pg.11);

    Whereas, GE, herbicide-resistant technology has failed to provide sustainable weed control through the

    development of herbicide resistant weeds (Ibid.);

    Whereas, "weeds resistant to synthetic auxin herbicides, the class to which dicamba [and 2,4-D] belong, are already numerous, indicating auxin-resistance is prevalent in the plant world" (Freese & Crouch, 2013);

    Whereas, stacking of new herbicide-resistant traits with glyphosate resistance, necessitates the use of combinations of 2,4-D or dicamba with glyphosate (Wright et al. 2010, Seifert-Higgins & Eberwine, 2010);

    Whereas, research indicates that injury resulting from combinations of 2,4-D or dicamba with glyphosate can be more damaging than with either herbicide used alone (Wolfe et al. 2011), "leading to greatly increased herbicide use and inevitably to more off-site movement" (Parker, 2011) and greater drift-related injury to neighboring broadleaf crops;

    Whereas, "environmentally-induced" plant diseases are an "understood outcome" of off-target herbicide spray drift (Walker 1969); "the well-known history of disease syndromes caused by off-site movement of 2,4-D, dicamba and glyphosate is such that many specialty crop growers fear that their crops cannot be grown in a future landscape that will be inundated like never before with all of these active ingredients" (Parker, 2011);

    Whereas, state pesticide control officials listed 2,4-D as the herbicide most often involved in pesticide drift incidents and dicamba as the 3rd most commonly involved, far outpacing the relative use of these herbicides (2,4-D ranks 7th on EPA's list of most commonly applied pesticides; Dicamba did not make the top 25 list) (SOCC, 2013);

    Whereas, exposure to 2,4-D and dicamba has been linked to major health problems (Solomon & Wu, 2008; Cox, 2006) that include cancer, especially non-Hodgkin's lymphoma, (Freese, 2012; Cantor, 1992); 2,4-D exposure has been linked to lower sperm counts, liver disease (Johnston et al., 2008; Leonard et al, 1997) and Parkinson's disease (Tanner et al., 2009); 2,4-D adversely affects the hormonal, reproductive, neurological and immune systems (Freese, 2012). 2,4-D is contaminated with dioxins (EPA, 2005), "highly toxic chemical compounds that bio-accumulate..., potentially leading to dangerous levels of exposure" (Freese, 2012);

    Whereas, Dow's application proposes new uses of 2,4-D choline salt and/or glyphosate on Dow's herbicide-

    resistant crops enable entirely novel post-emergence use of 2,4-D. The new use patterns would be characterized by more frequent application of 2,4-D during a broader application window that extends later into the season (CFS, 2012);

    Whereas, these new use patterns will result in significantly faster evolution of weeds resistant to 2,4-D, dicamba, glyphosate and other herbicides (Ibid.);

    Whereas, these new use patterns will coincide with particularly vulnerable plant growth stages of neighboring

    broadleaf crops and specialty production (Freese, 2012);

    Whereas, these new use patterns would result in an estimated 30-fold increase in the use of 2,4-D by the end of the decade, from "the existing 27 million lbs per year to over 100 million lbs per year" (CFS, 2012, pg. 15) threatening organic, non-GMO, and specialty crop production;

    Therefore, be it resolved that the Northern Plains Sustainable Agriculture Society call for the rejection of the petition to deregulate Dow AgroSciences 2,4-D Ready crops and Monsanto's Dicamba Ready crops.


    Center for Food Safety (CFS), (2012). Comments to EPA on Notice of Receipt of Applications to Register New Uses

    of 2,4-D on Enlist AAD-1 Corn and Soybean. Accessed 1/21/14 at: http://www.centerforfoodsafety...


    Cantor, K.P. (1992). "Pesticides and other agricultural risk factors for non-Hodgkin's lymphoma among men in Iowa and

    Minnesota," Cancer Res. 52: 2447-2455.

    Clark, Brian, 2012. Pesticide Use Rises as Herbicide-resistant Weeds Undermine Performance of Major GE Crops, New

    WSU Study Shows. Accessed 1/21/14 at:


    Cox, C., 2006. "2,4-D Herbicide Factsheet," Journal of Pesticide Reform 25(4), updated April 2006. http:// sheets/factsheets/24d-factsheet.

    Environmental Protection Agency (EPA), 2005. "Reregistration Eligibility Decision for 2,4-D," Environmental Protection

    Agency, EPA 738-R-05-002, June 2005, p. 82-83. Accessed 1/21/14 at:

    Freese, (2012). Going Backwards: Dow's 2,4-D-Resistant Crops and a More Toxic Future. Accessed 1/21/14 at: http://

    Freese, B and M. Crouch (2013). CFS Science Comments on Dicamba Use Registration for Cotton-date corrected copy.

    Accessed 1/21/14 at:!d...

    Johnston, S, G McCusker, TJ Tobinson (1998). "'Golf ball liver': a cause of chronic hepatitis?" Gut 42: 143. Accessed at

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    Leonard, C, CM Burke, C O'Keefe, JS Doyle (1997). "'Golf ball liver': Agent Orange hepatitis," Gut 40: 687-688.

    Accessed 1/21/14 at:

    Parker, Jason Shaw, 2011. New 2,4-D and Dicamba-Tolerant Crops: Managing Risks to Farms and Communities.

    Accessed 8/16/13 at:

    Seifert-Higgins, S.; Eberwine, J. 2010. Dicamba tolerance − a new tool for weed management. Proc. Weed Sci. Soc. Am.

    50: 154.

    Save Our Crops Coalition (SOCC), 2013. Herbicide Drift. Accessed 1/21/14 at:


    Solomon, G, Mae Wu (2008). "Natural Resources Defense Council's Petition to Revoke All Tolerances and Cancel All

    Registrations for the Pesticide 2,4-D," Accessed 1/21/14 at: http://www.beyondpesticides.or...


    Tanner, C.M. et al (2009). "Occupation and Risk of Parkinsonism," Archives of Neurology 66: 1106-1113. Accessed 1/21/

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    Walker, J.C. 1969. Plant Pathology (3rd Ed.). McGraw-Hill Book Company, New York, NY. p 1.

    Wright, T. R.; Lira, J. M.; Walsh, T. A.; Merlo, D. M.; Arnold, N. L.; Ponsamuel, J.; Lin, G.; Pareddy, D. R.; Gerwick, B. C.;

    Cui, C.; Simpson, D. M.; Hoffman, T. K.; Peterson, M. A.; Braxton, L. B.; Krieger, M.; Shan, G.; Tagliani, L. A.; Blewett,

    C.; Gatti, I.; Herman, R. A.; Fonseca, D.; Chambers, R. S.; Hanger, G.; Schult, M. 2010. Improving and preserving high

    performance weed control in herbicide tolerant crops: development of a new family of herbicide tolerant traits. Abstracts,

    239th National Meeting of the American Chemical Society; American Chemical Society: Washington, DC, 78: 202.

    Wolfe, S., Jiang, L., Scurlock, D., Dami, I., Doohan, D. 2011. Response of Grapes to Simulated 2,4-D, Dicamba, and

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  • thanks for this

    The issue was not on my radar. I will bump this up to the front page later today.

    I know organic and chemical-free farmers who have been affected by agrichemical drift and had little recourse.

  • the Des Moines Register

    published a guest editorial against 2,4-D biotech corn and soybeans by Gabrielle Roesch-McNally, a doctoral student at Iowa State University. Excerpt:

    This technology will come at a huge price to Iowa's public health, diverse agricultural production and further exacerbate problems with soil and water quality. 2,4-D is a hazardous chemical, which was part of the defoliant "Agent Orange" that was used in the Vietnam War.

    If this technology is approved, it could have disastrous effects because it will likely be adopted on acres upon acres of corn and soybean ground.

    Many farmers in attendance at the recent Midwest Organic and Sustainable Education Service conference in La Crosse, Wis., were concerned that these 2,4-D corn and soybean seeds would have absolutely catastrophic consequences on human health, vegetable/fruit growers, organic producers and non-GMO conventional producers. [...]

    As we consider the potential effects of 2,4-D corn and soybeans being planted across Iowa, I want to focus on a few key issues that are essential to consider before approving this latest biotechnology.

    First of all, Roundup Ready technology has failed and will continue to fail due to the fact that farmers adopted the technology so quickly and across a very large percentage of the acreage dedicated to corn and soybeans without attention paid either to setting aside refuge or to the broad scale impacts of mass reliance on one herbicide.

    It seems obvious to me that Dow is pursuing its 2,4-D technology because Roundup Ready technology is failing. Roundup is seen as a less potentially harmful herbicide without as much impact to ecological systems and human health.

    While there is some research that would seek to refute this, there is, indeed, much more research illustrating the damaging effects of 2,4-D on human health, on ecological functioning and on organic crops and fruit/vegetable production.

    Many people credit 2,4-D as being the death sentence of the wine industry in the Midwest, and we still see specific herbicide regulation designed specifically around the use of 2,4-D due to its volatile nature and linkages to nerve damage and cancer.

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