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03
Jul

Tell EPA by End of Today: Don’t Bail Out Genetically Engineered Cotton with a Toxic Pesticide

(Beyond Pesticides, July 3, 2014) It was predictable that genetically engineered (GE) cotton sprayed with the weedkiller glyphosate (Roundup) would create resistant superweeds. Now that it has, Texas GE cotton growers recently requested an emergency use of a chemical cousin to atrazine, the herbicide that is demasculinizing frogs by disrupting the endocrine system– on 3 million acres of cotton fields where the weeds have become resistant to the chemical of choice –glyphosate.

Stop the GE Pesticide Treadmill! Use Beyond Pesticides’ sample comments for guidance.

Help stop the GE treadmill and the use of hazardous pesticides. Join Beyond Pesticides in fighting this predictable “emergency” use because it exemplifies EPA’s practice of allowing increasing dependency on highly toxic pesticides in agricultural systems that are predictably unsustainable, harmful to people and the environment, and for which there are safe alternatives. This situation is the same toxic treadmill and thinking that is ushering in new 2,4-D-tolerant corn to replace Roundup Ready corn. Emergency exemptions and the use of increasingly toxic herbicides must not be the norm for communities and our environment.

Can you help us stop EPA from propping up the failed GE agricultural system? Submit your comment by midnight July 3.

Government does not make commenting easy. So, copy the comment below and then click here to paste it in the comment field or, better, write a comment in your own words. [See Beyond Pesticides' draft comments.]

SAMPLE COMMENT:

I urge EPA to deny the petition from the Texas Department of Agriculture seeking an emergency exemption for the use of the herbicide propazine to control 3 million acres of glyposate-resistant Palmer amaranth. The risks posed by this chemical far outweigh any short-term benefits. Propazine is a toxic herbicide that has been linked to developmental and reproductive toxicity. As part of the triazine family, it has a toxicological profile similar to atrazine, a well-documented hormone disruptor which has also been linked to birth defects, increased risk of breast cancer, and demasculinization of amphibians and other wildlife. Like atrazine, propazine has a strong potential to contaminate groundwater. Its use on 3 million acres of Texas land will undoubtedly increase the levels of this chemical in waterways, a use pattern unaccounted for in previous assessments of propazine. Emergency exemptions under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) cannot be granted without accurate health, ecological, and environmental risk assessments that also take into account the cumulative uses of atrazine and simazine in the state.
According to EPA, under Section 18 of FIFRA an emergency exemption is defined as “an urgent, non-routine situation…” As the agency is aware, glyphosate-resistant weeds, in particular Palmer amaranth, have been documented for several years with increasing frequency and thus must not be considered a “non-routine” or emergency situation. Since 1996, several emergency exemptions for propazine have been requested on sorghum, with roughly half being denied, because EPA must deny a request for emergency exemption if the pesticide does not meet safety standards, or if the emergency criteria are not met. Like these previous denials, EPA must again issue a denial of this latest request.

Sincerely,

—————————————————

Beyond Pesticides, representing  environmental, public health, and organic farm interests, has asked the U.S. Environmental Protection (EPA) to deny an emergency request by Texas cotton growers to use a controversial pesticide on genetically engineered (GE) cotton to control weeds that are now resistant to the chemical they have been using, Roundup (glyphosate). Approximately 90% of cotton grown in Texas is genetically engineered or known as a genetically modified organism (GMO). The request, which comes through the Texas Department of Agriculture, seeks an allowance on 3 million acres for the highly toxic pesticide propazine, not registered for use on cotton.

“In the true sense, this is not an emergency because the weed resistance is predictable since it has been known for many years that GE cotton sprayed with the weedkiller glyphosate (Roundup) would create resistant superweeds,” said Jay Feldman, executive director of Beyond Pesticides, which filed comments opposing emergency status for propazine use. “It is an abuse of the law for EPA to prop up failed GE cropping systems with toxic chemicals when the crop can be grown with organic methods not reliant on toxic pesticides and just as productive and profitable,” he said. Beyond Pesticides opposes 2,4-D tolerant cotton that GE cotton growers are expecting to be available in a year because of the human and environmental hazards, expected increased 2,4-D use, followed by predictable weed resistance.

Propazine is a toxic herbicide in the triazine class of chemicals that has been linked to developmental and reproductive toxicity. Another triazine herbicide, atrazine is linked to birth defects, increases the risk for mammary cancer, and has been shown to demasculinize frogs by disrupting the endocrine system. There is concern that increased use of another member of the toxic triazine chemical family presents unacceptable human and environmental health hazards.

The triazines are highly soluble in water and are the most frequently detected pesticides found at concentrations at or above one or more benchmarks in over half of sites sampled. Increasing propazine use on over 3 million acres in Texas will undoubtedly increase propazine movement into waterways, potentially threatening the safety of Texas’ surface and drinking water.

See Beyond Pesticides’ comments.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

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8 Responses to “Tell EPA by End of Today: Don’t Bail Out Genetically Engineered Cotton with a Toxic Pesticide”

  1. 1
    Gerrie Biegner Says:

    I urge EPA to deny the petition from the Texas Department of Agriculture seeking an emergency exemption for the use of the herbicide propazine to control 3 million acres of glyposate-resistant Palmer amaranth. The risks posed by this chemical far outweigh any short-term benefits. Propazine is a toxic herbicide that has been linked to developmental and reproductive toxicity. As part of the triazine family, it has a toxicological profile similar to atrazine, a well-documented hormone disruptor which has also been linked to birth defects, increased risk of breast cancer, and demasculinization of amphibians and other wildlife. Like atrazine, propazine has a strong potential to contaminate groundwater. Its use on 3 million acres of Texas land will undoubtedly increase the levels of this chemical in waterways, a use pattern unaccounted for in previous assessments of propazine. Emergency exemptions under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) cannot be granted without accurate health, ecological, and environmental risk assessments that also take into account the cumulative uses of atrazine and simazine in the state.
    According to EPA, under Section 18 of FIFRA an emergency exemption is defined as “an urgent, non-routine situation…” As the agency is aware, glyphosate-resistant weeds, in particular Palmer amaranth, have been documented for several years with increasing frequency and thus must not be considered a “non-routine” or emergency situation. Since 1996, several emergency exemptions for propazine have been requested on sorghum, with roughly half being denied, because EPA must deny a request for emergency exemption if the pesticide does not meet safety standards, or if the emergency criteria are not met. Like these previous denials, EPA must again issue a denial of this latest request.

    Sincerely,
    Gerrie Biegner

  2. 2
    Angela Marrow Says:

    I urge EPA to deny the petition from the Texas Department of Agriculture seeking an emergency exemption for the use of the herbicide propazine to control 3 million acres of glyposate-resistant Palmer amaranth. The risks posed by this chemical far outweigh any short-term benefits. Propazine is a toxic herbicide that has been linked to developmental and reproductive toxicity. As part of the triazine family, it has a toxicological profile similar to atrazine, a well-documented hormone disruptor which has also been linked to birth defects, increased risk of breast cancer, and demasculinization of amphibians and other wildlife. Like atrazine, propazine has a strong potential to contaminate groundwater. Its use on 3 million acres of Texas land will undoubtedly increase the levels of this chemical in waterways, a use pattern unaccounted for in previous assessments of propazine. Emergency exemptions under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) cannot be granted without accurate health, ecological, and environmental risk assessments that also take into account the cumulative uses of atrazine and simazine in the state.
    According to EPA, under Section 18 of FIFRA an emergency exemption is defined as “an urgent, non-routine situation…” As the agency is aware, glyphosate-resistant weeds, in particular Palmer amaranth, have been documented for several years with increasing frequency and thus must not be considered a “non-routine” or emergency situation. Since 1996, several emergency exemptions for propazine have been requested on sorghum, with roughly half being denied, because EPA must deny a request for emergency exemption if the pesticide does not meet safety standards, or if the emergency criteria are not met. Like these previous denials, EPA must again issue a denial of this latest request.

    Sincerely,
    Angela Marrow

  3. 3
    Sonya Myers Says:

    I urge EPA to deny the petition from the Texas Department of Agriculture seeking an emergency exemption for the use of the herbicide propazine to control 3 million acres of glyposate-resistant Palmer amaranth. The risks posed by this chemical far outweigh any short-term benefits. Propazine is a toxic herbicide that has been linked to developmental and reproductive toxicity. As part of the triazine family, it has a toxicological profile similar to atrazine, a well-documented hormone disruptor which has also been linked to birth defects, increased risk of breast cancer, and demasculinization of amphibians and other wildlife. Like atrazine, propazine has a strong potential to contaminate groundwater. Its use on 3 million acres of Texas land will undoubtedly increase the levels of this chemical in waterways, a use pattern unaccounted for in previous assessments of propazine. Emergency exemptions under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) cannot be granted without accurate health, ecological, and environmental risk assessments that also take into account the cumulative uses of atrazine and simazine in the state.
    According to EPA, under Section 18 of FIFRA an emergency exemption is defined as “an urgent, non-routine situation…” As the agency is aware, glyphosate-resistant weeds, in particular Palmer amaranth, have been documented for several years with increasing frequency and thus must not be considered a “non-routine” or emergency situation. Since 1996, several emergency exemptions for propazine have been requested on sorghum, with roughly half being denied, because EPA must deny a request for emergency exemption if the pesticide does not meet safety standards, or if the emergency criteria are not met. Like these previous denials, EPA must again issue a denial of this latest request.

  4. 4
    Ardis Macaulay Says:

    I urge EPA to deny the petition from the Texas Department of Agriculture seeking an emergency exemption for the use of the herbicide propazine to control 3 million acres of glyposate-resistant Palmer amaranth. The risks posed by this chemical far outweigh any short-term benefits. Propazine is a toxic herbicide that has been linked to developmental and reproductive toxicity. As part of the triazine family, it has a toxicological profile similar to atrazine, a well-documented hormone disruptor which has also been linked to birth defects, increased risk of breast cancer, and demasculinization of amphibians and other wildlife. Like atrazine, propazine has a strong potential to contaminate groundwater. Its use on 3 million acres of Texas land will undoubtedly increase the levels of this chemical in waterways, a use pattern unaccounted for in previous assessments of propazine. Emergency exemptions under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) cannot be granted without accurate health, ecological, and environmental risk assessments that also take into account the cumulative uses of atrazine and simazine in the state.
    According to EPA, under Section 18 of FIFRA an emergency exemption is defined as “an urgent, non-routine situation…” As the agency is aware, glyphosate-resistant weeds, in particular Palmer amaranth, have been documented for several years with increasing frequency and thus must not be considered a “non-routine” or emergency situation. Since 1996, several emergency exemptions for propazine have been requested on sorghum, with roughly half being denied, because EPA must deny a request for emergency exemption if the pesticide does not meet safety standards, or if the emergency criteria are not met. Like these previous denials, EPA must again issue a denial of this latest request.

    Sincerely,Ardis Macaulay

  5. 5
    Beyond Pesticides Says:

    Hey All,

    Thanks so much for commenting! Please be sure to submit your comments to the docket:http://www.regulations.gov/#!submitComment;D=EPA-HQ-OPP-2014-0419-0001

    -Beyond Pesticides

  6. 6
    P. JACOB Says:

    July 3, 2014
    Environmental Protection Agency
    Docket Center (EPA/DC), (28221T)
    1200 Pennsylvania Ave. NW
    Washington, DC 20460

    0001
    Re: Propazine; Receipt of Application for Emergency Exemption.
    Docket No: EPA

    The EPA is funded by taxpayers and the government is there to serve the people. Please take the time to peruse this aggregate of legitimate articles published on why GMOs and their toxic pesticides destroying our environment and human health should be banned. If your agency doesn’t know IT SHOULD KNOW — All hell is breaking loose around the world with these highly toxic pesticides, and it’s not just the bees

    BAN GMOs NOW: A Special Institute of Science in Society Report http://sco.lt/5KV1Cz

    If you continue to allow this escalating treadmill of biotech crops and their pesticides to control our agriculture we will end up with biological deserts and further poisoning of our water and food supplies. The EPA has a Fiduciary duty to ensure the safety of products entering the marketplace, Does the EPA really want to be left holding the bag on the coming massive “tobacco-like” lawsuits against the biotech, GMO and Pesticide Industry?

    The Ecologist, July 02, 2014
    -â–¶ NEONICOTINOIDS ARE POISONING NOT JUST BEES BUT ENTIRE FARMLAND ECOSYSTEMS The world’s most widely used insecticides have contaminated the environment across the planet so pervasively that global food production is at risk, according to a comprehensive scientific assessment of the chemicals’ impacts. http://ow.ly/yL8b0

    THESE HIGHLY TOXIC PESTICIDES ENTERING OUR ENVIRONMENT AND FOOD SYSTEM GO HAND-IN-GLOVE WITH GENETICALLY MODIFIED FOODS, THAT IS UNCONTROVERSABLE.

    Motley Fool, March 05, 2014
    -â–¶ GMOs AND ECOCIDE: RENOWNED EXPERT SAYS GMOs POSE MORE RISK THAN WE THINK. Genetically modified organisms (GMOs) have the ability to cause “an irreversible termination of life at some scale, which could be the planet.” says Nassim Taleb, distinguished professor of risk engineering at New York University http://www.fool.com/investing/general/2014/03/05/renowned-expert-gmos-pose-more-risk-than-we-think.aspx

    It is time for the EPA, FDA and USDA to cease giving the biotechnology industry a free-hand and free-pass on systemic pesticide products that are destroying both the planetary biosystems and the health of all species that come in contact with their untested, unlabeled, unregulated toxic products that stay in the environment for decades upon decades. @pdjmoo

  7. 7
    Saran Kirschbaum Says:

    No more GMO’s, and deny the petition in Texas for emergency exemption for the use of the herbicide propazine to control 3 million acres of glyposate-resistant Palmer amaranth. What one does today affects tomorrow what isn’t done today affects tomorrow. Do NOT add to the damage that has already been done by these actions.
    When in doubt, use the precautionary principle.
    Always err on the side of public safety over profit.
    Nature did alright without our help. She will do us all in. Time is of the essence. The Agriculture Revolution took thousands of years. The Industrial just 2 centuries. The Environment Revolution if it is to succeed must be compressed into decades.
    You know what has to been done and why, just do it, DENY the petition. Those who wrote it deny the consequences.

  8. 8
    Martha W D Bushnell Says:

    Please do not approve Genetically Engineered Cotton to use a dangerous, toxic pesticide for this will only create soil, water, and agricultural run off more dangerous for animals down stream.

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