Tell EPA: Keep Dow's 2,4-D crops off the market
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, D.C. 20460
RE: Docket # EPA-HQ-OPP-2014-0195
Dear Administrator McCarthy,
We are writing to urge your agency to reject Dow's application for the "new use" of 2,4-D with its Enlist line of genetically engineered seeds. This antiquated, dangerous herbicide is prone to drift off target, damaging neighboring crops and threatening the health of nearby communities.
As you know, 2,4-D is a reproductive toxicant, suspected endocrine disruptor and possible carcinogen. Children are particularly susceptible to its effects. If EPA approves Dow’s new 2,4-D formula, use — and therefore exposures — will go up. Agricultural scientists warn that widespread planting of Enlist corn could trigger as much as a 25-fold increase in use of 2,4-D on corn, from an estimated 4.2 million lbs. at present to over 100 million lbs. by 2019.
Recognizing a potential public health disaster looming on the horizon, 70 physicians, nurses and other health professionals have already urged EPA to reject Dow’s application for new uses of 2,4-D on genetically engineered corn.
American farmers, too, are deeply concerned that Dow’s Enlist corn system will threaten their crops and therefore their livelihoods. Drift from 2,4-D is already responsible for more episodes of crop injury than any other herbicide, and its vastly increased use promises still more damage to crops like non-GE soybeans and cotton, vegetables and fruit.
While Dow says it has developed a new formulation less prone to drifting for miles, the older highly volatile formula is still widely available and its lower cost creates a powerful market incentive to continue its use. And we know from experience that regardless of best practices put forth, pesticide drift is difficult to contain.
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