Tell USDA To Reject Agent Orange Corn

Dow Chemical is currently requesting an unprecedented USDA approval: a genetically engineered (GE) version of corn that is resistant to 2,4-D, a major component of the highly toxic Agent Orange. Agent Orange was the chemical defoliant used by the U.S. in Vietnam, and it caused lasting ecological damage as well as many serious medical conditions in both Vietnam veterans and the Vietnamese. 

Exposure to 2,4-D has been linked to major health problems that include cancer (especially non-Hodgkin’s lymphoma), lowered sperm counts, liver disease and Parkinson’s disease.  A growing body of evidence from laboratory studies show that 2,4-D causes endocrine disruption, reproductive problems, neurotoxicity and immunosuppression.  Further, industry’s own tests show that 2,4-D is contaminated with dioxins, a group of highly toxic chemical compounds that bioaccumulate, so even a minute amount can accumulate as it goes up the food chain, causing dangerous levels of exposure.  Dioxins in Agent Orange have been linked to many diseases, including birth defects in children of exposed parents; according to EPA, 2,4-D is the seventh largest source of dioxins in the U.S.

USDA approval of Dow’s GE corn will trigger a big increase in 2,4-D use – and our exposure to this toxic herbicide.  Yet USDA has not assessed how much, nor analyzed the resulting impacts on public health, the environment or neighboring farmers (2,4-D is prone to drift and cause damage to nearby crops).  Instead, USDA has once again bowed to the pesticide industry, by giving preliminary approval to still another pesticide-promoting crop that will likely harm people and their children, including farmers, and the environment. USDA claims to be adhering to a scientific process, yet the Agency is blatantly ignoring the science on 2,4-D.

Tell USDA To Do Its Job And Reject 2,4-D Resistant GE Corn
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I am writing to urge you not to approve Dow’s genetically engineered corn (DAS-40278-9) designed to survive repeated spraying of the toxic herbicide 2,4-D (Docket No. APHIS–2010–0103), a major component of Agent Orange, the chemical defoliant used by the U.S. military in Vietnam.

The scientific community has sounded alarms about the dangers of 2,4-D for decades. Numerous studies link 2,4-D exposure to major health problems such as cancer, lowered sperm counts, liver toxicity and Parkinson’s disease. Lab studies show that 2,4-D causes endocrine disruption, reproductive problems, neurotoxicity, and immunosuppression: Further, industry tests show that 2,4-D is contaminated with dioxins. Dioxin contaminants in Agent Orange are thought to be a major cause of many serious medical conditions in both Vietnam veterans and the Vietnamese, including birth defects in the children of exposed parents. EPA has reported that 2,4-D is the seventh largest source of dioxins in the U.S.

Commercial approval of Dow’s corn will trigger a large increase in 2,4-D use, but USDA has not conducted a meaningful review of the consequent harm to native ecosystems, crop injury from 2,4-D drifting onto neighboring fields, or the evolution of weeds resistant to 2,4-D. Despite its short half-life, 2,4-D is frequently detected in surface waters throughout the U.S. and in groundwater in five states and Canada. Even the existing uses of 2,4-D have been found likely to jeopardize protected species, such as Pacific salmon, the California red-legged frog and Alameda whipsnake; USDA’s proposed unrestricted approval of 2,4-D corn would worsen these impacts, as well as place many other similar and endangered species at risk. Yet the agency has refused to account for these adverse impacts. Additionally, Dow plans to sell this GE 2-4,D corn “stacked” with resistance to glyphosate—the active ingredient in Roundup—or other herbicides, yet neither Dow nor USDA has analyzed the potential synergistic or cumulative impacts that these planned combinations pose.

Further, this corn has also been engineered to resist another herbicide (quizalofop) never before used in corn. This will likely cause a massive increase in the use of this herbicide, the increase of which has not been properly evaluated for human health or environmental impacts. Given the numerous inadequacies in the USDA’s Environmental Assessment (EA), an approval of this crop should not be considered without at least a full and rigorous Environmental Impact Statement (EIS).

2,4-D-resistant crops may also pose a new food safety risk in the introduction of 2,4-dichlorophenol (2,4-DCP), a breakdown product of 2,4-D when applied to resistant crops. French scientists who studied the matter concluded that 2,4-D-resistant plants sprayed with 2,4-D may not be acceptable for human consumption due to contamination with 2,4-DCP.

Finally, Dow is hyping 2,4-D corn as the supposed solution to glyphosate-resistant weeds, which themselves were fostered by GE Roundup Ready crop systems. Yet studies already indicate this approach will rapidly generate weeds with resistance to both herbicides. As Dow and other pesticide firms develop new crops resistant to ever more herbicides, weeds will match and exceed them by evolving multiple resistances, and farmers will respond with increasingly toxic herbicidal cocktails. This chemical arms race with weeds means more pesticidal pollution, more disease, higher production costs, and of course increasing profits for firms like Dow that sell both GE seed and pesticide.

At a time when farmers, citizens and government have worked hard to limit our use of, and exposure to, toxic chemicals like 2,4-D and dioxin, approving this crop would take us dramatically backwards, endangering human health and the environment. If USDA wants to adhere to a true scientific process, it should stop ignoring the science that doesn’t suit the interests of the biotechnology industry. I urge you to heed the warnings of the scientific and environmental communities and deny approval of 2,4-D resistant GE corn.
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