(Beyond Pesticides, February 18, 2009) The Environmental Protection Agency (EPA) is accepting through February 23, 2009 public comments on a petition to cancel all registrations for the herbicide 2,4-D and to revoke all of its tolerances. The petition was filed by the Natural Resources Defense Council (NRDC) in November and published by EPA on December 24, 2008. As the most commonly used â€śhome and gardenâ€ť chemical, millions of U.S. households especially vulnerable children and pets, are exposed to this toxic chemical.
Beyond Pesticides fully supports the cancellation of this dangerous pesticide which has been associated with a host of adverse human impacts, such as non-Hodgkinâ€™s lymphoma, endocrine disruption, reproductive and developmental effects, as well as water contamination and toxicity to aquatic organisms. The highly toxic chemical can be replaced by cost-competitive and effective management practices widely used in organic agriculture and lawn care.
As long as 2,4-D remains on the market, the public will continue to be exposed to, and suffer the effects of this chemical whose health impacts have long been ignored by EPA. Public health and environmental advocates believe it is time that EPA put science and the health of the public and the environment first and ban this dangerous chemical.
2,4-D is one of the most widely used herbicide for the control of broadleaf weeds in commercial agriculture and residential landscapes in the U.S. About 46 million pounds of 2,4-D are used annually, with 16 million pounds used in non-agricultural settings, such as golf courses, playing fields, and residential lawns. 2,4-D was considered eligible for reregistration by the EPA in 2005 with the publication of its Reregistration Eligibility Decision (RED) document. However, according to advocates, extensive important scientific evidence pointing to the dangers of 2,4-D have been ignored by the agency during its risk assessment process. These include scientific observations that 2,4-D is an endocrine disruptor with predicted human health risks ranging from changes in estrogen and testosterone levels, thyroid problems, prostate cancer and reproductive abnormalities. EPA has yet to finalize a screening program to assess endocrine disruption for pesticides. According to EPAâ€™s RED document for 2,4-D, current data â€śdemonstrate effects on the thyroid and gonads following exposure to 2,4-D, there is concern regarding its endocrine disruption potential.â€ť Despite this finding, the agency found 2,4-D eligible for reregistration, a fact that advocates say illustrates EPAâ€™s flawed risk assessment process.
Along with numerous health effects that continue to be ignored, EPA removed the additional (10X) safety factor instituted to protect children from pesticide exposure. The removal of this extra safeguard for children means that children playing on lawns and fields continue to be exposed to a chemical that has known and uncertain toxicological effects from which they are not adequately protected. In fact, there are several data gaps and uncertainties in the toxicological database for 2,4-D such as, according to the RED, concern for developmental and neurotoxic effects. 2,4-D is also commonly formulated with other toxic herbicides such as dicamba and mecoprop-p (MCPP). The agency has not evaluated the cumulative effects of these chemicals, even though they are growth regulators and have the same mode of action. As such, exposures and risks posed from this combination(s) of chemicals have gone unchecked.
2,4-D is one of the oldest registered herbicides in the US. Its association with a host of human effects, including cancer, promoted a Special Review of the chemical in 1986. A few years later in a unique move, several large pesticides companies with a common interest in keeping 2,4-D on the market formed the Industry Task Force II on 2,4-D Research Data. In 2007, EPA decided not to initate a special review after all. 2,4-D, once part of the deadly duo of chemicals that made up Agent Orange, can also be contaminated with several forms of dioxin, including 2,3,7,8-TCDD, a known carcinogen. Studies have also documented that once tracked indoors from lawns, 2,4-D can stay indoors (on carpets) for up to a year. 2,4-D is also absorbed by the body more easily in the presence of sunscreen, DEET and in the consumption of alcohol.
TAKE ACTION: Tell EPA that it is time to put science and the health of the public and the environment first! Tell the agency that 2,4-D is too dangerous to remain on the market. If you would like to sign on to Beyond Pesticides’ comments, email Nichelle Harriott at firstname.lastname@example.org by February 22. Or submit your own comments in support of this petition at www.regulation.gov, using docket number EPA-HQ-OPP-2008-0877, no later than February 23, 2009. Follow the on-line instructions for submitting comments. You can also send your comments via mail to Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001.