Scientific Sanity and 2,4-D!

On February 23, 2009, the U.S. Environmental Protection Agency (EPA) closed the public comment period on a petition submitted by Natural Resources Defense Council (NRDC) seeking to cancel registrations of 2,4-D herbicide and revoke its residue tolerances. The Industry Task Force II on 2,4-D Research Data anticipates that EPA will deny the petition and stand on its major scientific reassessment of 2,4-D and determination of eligibility for continued registration completed in 2005. EPA is also well aware of ongoing studies to further strengthen the database on 2,4-D.

It is not unusual for the NRDC and other interest groups to petition EPA for the cancellation of a pesticide registration. In response to several recent petitions, EPA has published a notice inviting public comments, carefully reviewed those comments and ultimately issued denials of the petitioners’ requests. The EPA’s reviews and responses obviously take time to complete. NRDC's petition to cancel dichlorvos in 2006 resulted in an order denying the petition in 2007. EPA followed a similar time course in response to a petition to revoke tolerances for carbaryl in 2007 by denying the petition in 2008.

For 2,4-D, the Task Force does not take for granted that EPA will deny NRDC’s petition. Rather, the Task Force submitted detailed scientific comments in response to NRDC’s petition, and was pleased that its many friends also urged EPA to deny the petition given EPA's recent thorough and thoughtful review of 2,4-D in the June 2005 Re-registration Eligibility Decision.

During the 2,4-D comment period, over 431 comments were submitted; overwhelmingly supporting EPA’s 2005 re-registration decision. Some 14 comments were negative, but provided no new or compelling evidence for EPA to cancel the product. Thank you to all the foresters, ranchers, farmers, scientists and habitat managers that wrote the Agency, providing real-world information on the value of 2,4-D to their management programs.

The Industry Task Force II on 2,4-D Research Data and the many users of 2,4-D are proud of the more than 300 state-of-the art GLP studies on mammalian toxicity, ecotoxicity, environmental fate and residue that support 2,4-D registrations. EPA’s recent Re-registration Eligibility Decision thoroughly reviewed this data base against the demanding environmental, food and child safety standards of the pesticide laws, FIFRA and FQPA. Other governmental authorities, such as Canada’s PMRA and the EU’s pesticide regulatory authority have also given 2,4-D a clean bill of health. Simply put, few pesticides, indeed few substances of any type, have been so thoroughly tested and so often reviewed by authorities worldwide as the herbicide 2,4-D. The NRDC petition raises no new issues that have not been thoroughly considered by others before.

The Task Force’s comments that carefully respond to the petition’s allegations are posted on the Task Force website at www.24d.org. We are confident that the Agency will deny the petition and re-confirm its 2005 decision that when used according to label directions 2,4-D meets FIFRA and FQPA standards for registration and establishment of residue tolerances.


Jim Gray
Executive Director
Industry Task Force II on 2,4-D Research Data
james.gray@24d.org
1-800-345-5109
www.24d.org