WASHINGTON, July 2, 2014 – The EPA recently closed the comment period on its proposed decision to register Dow AgroSciences’ Enlist Duo, the new 2,4-D, glyphosate herbicide for use with Enlist corn and soybeans, still pending approval at USDA. Its final decision could be a turning point for U.S. farmers, according to comments from supporters and opponents on the proposal.

More than 25,000 comments were submitted to EPA regarding Dow’s product by June 30.  Dow and several agricultural industry members told the agency that U.S. farmers need the Enlist technology to stay on top of an increasingly competitive global marketplace. However, several activists and researchers said approving the herbicide would cause damage to the environment and human health. 

“The close of the comment period comes as farmers across the countryside contend with persistent pressure from glyphosate-resistant and hard-to-control weeds,” the company said in a statement.  Dow noted that resistant weeds have more than doubled from 2009, affecting an estimated 70 million acres.

Dow points out that EPA stated in its proposed registration of the Enlist herbicide on April 30 that it has a “full and scientifically robust data set on 2,4-D” with respect to human health. Additionally, regulatory agencies in more than 70 countries, including the United Kingdom, Germany, France, Canada, Japan, Australia and the U.S., already allow the use of 2,4-D formulations and have since 2001.

Regarding the Enlist Duo herbicide, Dow said it can now reduce the chances of off-target spray, using “technology optimized for on-target application.”

However, several commentators, including a group of 35 public health scientists and researchers said the use of the chemical "would put public health at risk” and increase the prevalence of 2,4-D resistant weeds. 

"Decades of research have continuously demonstrated the risks of using 2,4-D, a notoriously toxic herbicide,” they stated in a letter sent Monday to EPA Administrator Gina McCarthy. “Allowing large-scale 2,4-D spraying in combination with 2,4-D-tolerant genetically engineered crops would worsen the problem."

In a separate letter, Charles Benbrook, research professor at Washington State University, said the pending decisions by EPA and USDA on herbicide-tolerant crops - like those submitted by Dow - will be the most significant in his 30-year career. 

“These decisions will have a profound impact in determining the contents of the farmer’s weed control toolbox in the decade ahead, and whether farmers increase or begin to reduce reliance on a single tactic (herbicides) by adopting proven, multi-tactic weed management systems that virtually all academic weed management experts are now recommending.”

Benbrook noted that at least eight weeds are resistant to 2,4-D and said the Enlist technology will most likely be effective for only five to seven years.

“Once farmers attempt to spray their way out of the corner they have been backed into by the spread of glyphosate-resistant weeds, they will have exhausted most of the available herbicide chemistry available to them,” he said.

However, Dale Moore, public policy director for the American Farm Bureau Federation, stressed the agricultural industry’s need for the Enlist technology, arguing that the U.S. must move forward with developments like Dow’s to remain internationally competitive.

“Any further, unjustified delay in the registration of this herbicide denies growers an important tool they need to combat weeds and to maximize yields,” Moore said. “It also puts them at a further disadvantage to corn and soybean growers in other nations that have completed or are now completing their registrations of this herbicide.”


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