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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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