beyond pesticides

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March 14, 2005

Public Information and Records Integrity Branch (PIRIB) (7502C)
Office of Pesticide Programs (OPP)
Environmental Protection Agency
1200 Pennsylvania Avenue, NW.
Washington, DC 20460-0001

Subject: Docket No. OPP–2004–0167, Revised Risk Assessment for 2,4-Dichlorophenoxyacetic acid (2,4-D)


Thank you for the opportunity to comment on risk reduction measures for the herbicide 2,4-D. [INSERT HERE WHAT YOU OR YOUR AGENCY/ORGANIZATION DOES RELEVANT TO THIS ISSUE: E.G. WATER QUALITY, CONSUMER/LANDSCAPER EDUCATION, NATURAL LAWN CARE, PROFESSIONAL HORTICULTURE, HAZARDOUS WASTE REDUCTION, PUBLIC HEALTH, ETC.]

We are concerned about 2,4-D because of its widespread use on residential landscapes, frequent detections in surface water, and exposures to children. Much of this residential use of 2,4-D is completely unnecessary because it is intended for purely aesthetic purposes and because it is applied as a broadcast treatment of combined herbicide and fertilizer, commonly known as weed and feed. Use of weed and feed violates integrated pest management (IPM) principles because an herbicide/fertilizer combination ties together two decisionmaking processes that should be separate and because it can only be used as a broadcast treatment. These two characteristics guarantee overuse and inappropriate use. Our agency does not recommend the use of weed and feed, and [ADD IF TRUE] we do not use weed and feed in our own operations. In fact, we expend considerable effort educating consumers and landscapers about weed control techniques that are more compatible with integrated pest management.

Unnecessary and inappropriate use of 2,4-D in weed and feed products increases risks to children who play on turf and is certainly responsible for the widespread pollution of surface water across the United States. We believe that canceling the registration of weed and feed products is the single most effective action EPA could take to reduce urban use of 2,4-D and reduce both human and environmental exposures.

[TALKING POINTS FOR ELABORATION. INCLUDE THE ONES YOU WANT, AND EXPAND OR MODIFY AS DESIRED.]
• 2,4-D widespread water pollutant
2,4-D has a high potential to leach and run off from soils and has been detected in ground water in at least five states and Canada.(1) Studies by the U.S. Geological Survey also show 2,4-D to be the herbicide most frequently detected in streams and shallow ground water throughout the country from home and garden use.(2) Measurements in King County, Washington in 1996 documented 2,4-D in 100% of streams sampled during spring storm events.(3) We are particularly concerned by the number of pollutants detected, some of which (such as MCPP) are structurally similar to 2,4-D. When multiple pollutants are present, it is inappropriate and scientifically indefensible to compare chemicals to toxicity criteria one at a time, neglecting possible additive or synergistic toxicity. Given the frequent occurrence of lawn pesticides in surface water, we think that additional reductions in use are necessary.

• Most 2,4-D use in urban areas is in the form of weed and feed products
EPA data show that twice as much 2,4-D is used by homeowners in weed and feed products than in products without fertilizer.(4) Even higher numbers have been seen locally. [INCLUDE ANY LOCAL DATA YOU HAVE HERE] King County (Seattle) obtained data on pesticides sold at large home and garden centers in the county.(5) These data indicate that approximately three-quarters of all of the 2,4-D sold in these stores was in weed and feed products.

• Weed and feed application is counter to IPM principles
EPA has spent considerable time, energy, and funds to promote the widescale adoption of IPM.(6) Use of weed and feed is not supportive of IPM because it requires a broadcast treatment over the entire lawn area, which spreads the herbicide everywhere instead of just where weeds are present. This practice is in direct opposition to selective spot treatment for weed control or healthy lawn maintenance practices that get to the source of the problem rather than just treat the symptom. Typically, weeds cover a small fraction of lawn area, and any herbicide applied to weed-free areas is wasted. Even if a lawn contains as much as 50% weeds, then half of the herbicide is unnecessary and contributes to runoff and health risk without providing any benefit. Homeowners who use weed and feed regularly are overusing far higher percentages of the herbicide because weed cover with frequent use will be much less than 50%. In IPM, spot treatment of weeds is preferred to broadcast treatment, especially when weed cover is low. There are very few situations in which weed and feed use can be considered consistent with IPM.

Given EPA’s stated acceptance and promotion of IPM and pesticide use reduction, the re-registration of weed and feed—a product whose use rarely qualifies as IPM—is inconsistent and undermines real progress towards pesticide reduction goals. Our agency [NAME] recommends against weed and feed use. We spend considerable time and money educating the public about healthy and appropriate lawn care. The registration and availability of weed and feed undercuts our message (and EPA’s own message about IPM) and makes it extremely difficult to move consumers to more responsible lawn management, including non-chemical weed control and, as a last resort, spot treatment with herbicides.

• Consumers use weed and feed inappropriately
The maximum number of allowed broadcast applications of 2,4-D on turf is two per year. However, many cooperative extension agencies recommend that lawns be fertilized more than twice per year, sometimes up to four times per year.(7) Users are likely to apply weed and feed more than twice a year for two main reasons. First, surveys suggest that a substantial number of consumers do not recognize that weed and feed is a pesticide. For example, the Green Gardening Program in Seattle/King County asked audiences at gardening slideshow presentations if they thought weed and feed products were pesticides. They were also asked if they thought herbicides were pesticides. In general, these audiences were relatively well informed about gardening. Yet, twenty percent of respondents did not believe that herbicides or weed and feed were pesticides, while 13% and 16%, respectively, were unsure.(8)

Second, people generally do not read and follow label instructions and are even less likely to do so if they do not recognize the product contains a potentially hazardous pesticide. Adding to numerous EPA studies, a recent survey showed only 53% of households read and follow the label carefully when using pesticides and fertilizers.(9) EPA acknowledges that homeowners often purposely overuse a product by thinking that more is better. Over-application of a pesticide increases human health risks and the problems of runoff. Cancellation of weed and feed registration will force consumers to make more responsible weed management choices.

• Risks to children
EPA’s preliminary risk assessment of 2,4-D indicated that aggregate risks to toddlers from contact with treated lawns may exceed agency guidelines. The revised risk assessment indicates that the earlier calculations were overestimates, but still does not provide a proper aggregate risk assessment summing exposures from food, water, and residential risks including track-in. Cancer risks were not included because, despite numerous independent studies by the National Cancer Institute and others, EPA cannot determine whether or not 2,4-D is a carcinogen. There are a number of studies linking 2,4-D exposure to childhood cancers including leukemia, non-Hodgkin’s lymphoma, and brain cancers, to name a few. There is no doubt that exposure to 2,4-D is increased in households that use it regularly as a lawn and garden herbicide. Furthermore, exposure to 2,4-D extends to the indoor environment through tracking it into the home, significantly exposing young children by ingestion of contaminated dust, penetration through the skin, and inhalation of the 2,4-D re-suspended into indoor air. Whatever the risks may be, the indisputable fact is that if weed and feed were not registered for residential use, the risks to children from 2,4-D exposure and the pervasiveness of 2,4-D in our waterways would be drastically reduced.

Thank you for this opportunity to offer our input regarding the Revised Risk Assessment for the 2,4-D Reregistration Eligibility Decision.

Sincerely,

Your name
Position, Agency
Contact Information

(1) Extension Toxicology Network. 1996. Pesticide Information Profile, 2,4-D.

(2) U.S. Geological Survey (USGS). 1998. Pesticides in Surface and Ground Water of the United States: Summary of Results of the National Water Quality Assessment Program. http://ca.water.usgs.gov/pnsp/allsum/

(3) Voss FD, Ebbert JC, Davis DA, Frahm AM, and Perry GH. 1999. Pesticides detected in urban streams during rainstorms and relations to retail sales of pesticides in King County, Washington. USGS fact sheet 097-99. U.S. Geological Survey. National Water-Quality Assessment Program.
(4) USEPA OPP. Overview of the 2,4-D Risk Assessments. June 18, 2004, Page 2.

(5) Vista Information Service, Division of CCI Triad. 1998-2003. Annual reports for King County Department of Natural Resources. Livermore, CA.

(6) US EPA. Integrated Pest Management in Schools (http://www.epa.gov/pesticides/ipm/); Integrated Pest Management and Food Production (http://www.epa.gov/pesticides/factsheets/ipm.htm); Controlling Pests Around the Home (http://www.epa.gov/pesticides/controlling/home.htm).

(7) Robson, M. 1993. September–Good Time for Lawn Improvement. Regional Gardening Column, September 13, 1998. http://gardening.wsu.edu/column/09-13-98.htm; Miltner, E. 1999. Improve Your Lawn, Environment and Conserve Water. Regional Gardening Column, April 11, 1999. Improve Your Lawn, http://gardening.wsu.edu/column/04-11-99.htm.

(8) Green Gardening Program Final Report 2003. Seattle Tilth Association, Washington Toxics Coalition, and WSU Cooperative Ext. King County.

(9) 2004 Environmental Lawn and Garden Survey. The National Gardening Association and Organic Gardening Magazine. http://www.garden.org/articles/articles.php?q=show&id=2244.

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