black desert nomad

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

Mar 10, 2014

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.

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

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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.

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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

Glyphosate Drift. Proceedings of the 66th Annual Meeting of the North Central Weed Science Society, Milwaukee, WI.

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