Perspectives

Dow AgroSciences Statement on Chlorpyrifos and California Proposition 65

Dow AgroSciences strongly disagrees with the California Developmental and Reproductive Toxicity Identification Committee (DART IC) decision to list chlorpyrifos under Proposition 65. Specifically, chlorpyrifos has not been “clearly shown by scientifically valid testing according to generally accepted principles to cause developmental toxicity.” Simply put, the data do not support listing. Chlorpyrifos has been studied extensively by many regulatory agencies around the world, and none have concluded that it causes developmental toxicity within the meaning of Proposition 65.

Chlorpyrifos is a conventional crop protection product designed to control insects such as ants, rootworms and other pests that harm crops. Since entering the market in 1965, chlorpyrifos has become one of the most widely used crop protection solutions in the world. It is authorized for use in about 100 countries – including Australia, Brazil, Canada, China, Italy, Japan, Mexico, New Zealand, Poland, Russia, South Africa, and the United States, where it is registered for the protection of essentially every crop, including alfalfa, almonds, citrus, cotton, walnuts, corn, soybeans, and wheat, among many others.

The toxicological database for chlorpyrifos is one of the more extensive for any regulated chemical. More than 4,000 studies and reports have been conducted that have shown that chlorpyrifos can be used safely to protect our food supply and human health. Strict federal, state and local restrictions govern the use of this important crop protection tool.

At Dow AgroSciences, we strongly believe there is not sufficient evidence to support the State’s decision. This decision may have a significant negative impact on California growers’ ability to produce healthy crops and on the State’s $40 billion agriculture industry. As such, we intend to evaluate all potential actions in response to this decision and vigorously support growers.

For additional information on the registered uses and benefits of chlorpyrifos, please visit www.chlorpyrifos.com.

Dow Statement on Associated Press Story Regarding Chlorpyrifos

The recent Associated Press story regarding government reviews of chlorpyrifos contained a number of misleading and inaccurate statements. Chlorpyrifos is, in fact, one of the most widely used and thoroughly studied pest control products in the world, supported by more than 4,000 studies examining chlorpyrifos in terms of health, safety and the environment. It is approved not only for use in the U.S., but nearly 100 countries. In its preparation of biological evaluations of chlorpyrifos and the other compounds under the Endangered Species Act, EPA did not apply its own standards of data quality, nor did it follow its own procedures. As a result, Dow and other companies submitted concerns and scientific requests through various proper channels. Dow stands by the safety of chlorpyrifos and believes that comprehensive regulatory review of all available data will continue to support the safety of the registered uses of this product.

Dow is providing links to letters sent on behalf of Dow AgroSciences, Adama and FMC in full transparency of the companies’ request. We are advocating that EPA return to applying its own standards of data quality and following its own procedures. Dow will continue to actively participate in policymaking and political processes in compliance with all applicable federal and state laws.

Dow AgroSciences to Work Diligently to Support Renewed U.S. EPA Sulfoxaflor Registrations

On Thursday, November 12, EPA issued a cancellation order for sulfoxaflor-containing products in response to a September 10th Ninth Circuit Court of Appeals ruling “vacating” product registrations. The following is Dow AgroSciences’ comment on that action.

As a result of the extensive data currently available on sulfoxaflor, Dow AgroSciences expects the pollinator protection concerns expressed in a recent Ninth Circuit Court of Appeals decision (September 10) to be readily and thoroughly addressed by EPA through further review of scientific data, supporting pressing grower needs for protection against destructive crop pests with renewed U.S. registrations of sulfoxaflor-containing products.

Four full years of widespread U.S. product use – with additional use in Canada, Australia and other nations – have demonstrated excellent sulfoxaflor performance worldwide with no noted adverse effects on pollinators.

Registrations outside the U.S. of sulfoxaflor-containing products should not be impacted by this decision. U.S. tolerances for sulfoxaflor are similarly unaffected.

As part of its recent action, EPA has issued an existing stocks provision allowing growers to use sulfoxaflor-containing products they have in hand consistent with directions on the pre-existing product label. Dow AgroSciences is, however, disappointed with EPA’s existing stocks provision which effectively removes a critical tool from the American grower by not allowing existing inventories of sulfoxaflor-containing products to be sold and distributed to end-users while EPA considers its next steps.

Dow AgroSciences remains confident in the benefits offered by this new class of insecticides and will work diligently with EPA and States to achieve new registrations for these important products to support the American grower.

Dow AgroSciences notes that contrary to misrepresentations circulated by pesticide opponents, sulfoxaflor is a sulfoximine-class insecticide, not a neonicotinoid, a distinction clearly established by the Insecticide Resistance Action Committee (IRAC) and published in the open scientific literature.

On Thursday, November 12, EPA issued a cancellation order for sulfoxaflor-containing products in response to a September 10th Ninth Circuit Court of Appeals ruling “vacating” product registrations. The following is Dow AgroSciences’ comment on that action.

Background on 2,4-D and IARC - June 12, 2015

One of the World's most widely used and studied herbicides

There are many reasons 2,4-D is one of the most widely used herbicides in the world, protecting agricultural crops, non-crop and aquatic areas, turf grass and environmentally sensitive areas from weeds and invasive species. After 70 years on the market, users trust the herbicide to effectively control a broad spectrum of broadleaf weeds. Given its wide range of weed control and uses, there are more than 1,500 products that have 2,4-D registered as the active ingredient.

Most importantly, based on ongoing and continually updated scientific study, health and safety authorities around the world – including US Environmental Protection Agency, Health Canada, the European Food Safety Authority and the World Health Organization – continue to find that 2,4-D meets modern safety standards. No herbicide has been more thoroughly studied.

Key Facts

  • 2,4-D has been thoroughly evaluated by health and safety regulators in more than 100 countries.
  • Not one health and safety regulator in the world considers 2,4-D to be a human carcinogen.
  • More than 4,000 published studies have been used in these evaluations.
  • Farmers all over the world rely on 2,4-D to maximize crop production, reducing production costs for farmers and food costs for consumers.
  • There are more than 100 prescribed label uses for 2,4-D. It is used to control invasive and noxious weeds in agriculture, forestry, and recreation and for safety along highways, power line corridors and rail lines.
  • For more than 70 years, 2,4-D has been used to protect crops, lawns and turf from invasive weeds.

There is no national regulatory body in the world that considers 2,4-D a carcinogen. Pesticide regulatory authorities have consistently concluded that 2,4-D has not been shown to pose a risk of human cancer.

Health Canada, 2009: “No other international regulatory body considers 2,4-D to be a human carcinogen. Based on all available and relevant data, Health Canada agrees with this position…Health Canada found that 2,4-D does not increase the risk of cancer and can be used safely by homeowners, provided label directions are followed.” http://www.hc-sc.gc.ca/cps-spc/pest/part/protect-proteger/24d/index-eng.php#physicians 

European Food Safety Authority, 2015: “…2,4-D, as currently manufactured, is unlikely to have a genotoxic potential or pose a carcinogenic risk to humans.” http://www.efsa.europa.eu/en/efsajournal/doc/3812.pdf 

EPA, 2014: “While there has been much focus on epidemiology data suggesting a linkage between NHL and farm work, there is insufficient scientific evidence supporting a specific linkage with 2,4-D. Furthermore, this linkage is not supported by data on laboratory animals as discussed in the cancer assessment portion of this response.” http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2014-0195-2414 

For more information, go to www.24D.reviews .

Statement on Landrigan and Benbrook Opinion Piece in NEJM - September 2, 2015

From the exhaustive scientific research to the lengthy approval process, this opinion piece gets the facts wrong, misleading readers, consumers and farmers. Contrary to the claims of the authors, regulatory approvals for Enlist Duo herbicide are based on detailed government health and environmental assessments, including review of recent, published state-of-the-art studies. The U.S. Environmental Protection Agency spent nearly four years on its review and consideration of public input, repeatedly extending the comment period.

In addition to U.S. authorities, governments around the world have approved key ingredients of Enlist Duo (2,4-D and glyphosate) based on their rigorous evaluation of extensive data, affirming their safety when used according to approved labeling. These are two of the most thoroughly studied herbicides in the world, and farmers have used them safely and effectively for decades.

Regulatory evaluations of Enlist Duo’s approval considered all the studies included in this year’s IARC evaluations of glyphosate and 2,4-D and found no basis for concern relative to potential carcinogenicity. It is important to note that IARC only focuses on whether a substance theoretically could cause cancer, not whether it will cause cancer in real-world circumstances. No national regulatory body in the world considers these herbicides a carcinogen.

Regarding labeling, Dow AgroSciences supports the Safe and Accurate Food Labeling Act (HR1599), which would protect consumers from a costly and confusing 50 state patchwork of labeling laws. It would also create a single, unified standard for food to be labeled as “GMO free” as part of a USDA program modeled after the popular USDA Organics program.

Missing from the article is the fact that farmers will have to double current world food production in the next quarter century in order to meet the needs of our planet’s expanding population. Instead of misleading articles, honest dialogue on new crop technologies to meet that need is critically important. Progress would be far easier if facts, science and the rigor of regulatory reviews were fairly and accurately represented by the critics of modern agriculture.

Reference:

Philip J. Landrigan, M.D., and Charles Benbrook, Ph.D.

N Engl J Med 2015; 373:693-695 August 20, 2015  DOI: 10.1056/NEJMp1505660

Dow AgroSciences Responds to Indiana SB 50 - April 2, 2015

Dow AgroSciences believes that Indiana Senate Bill 50 addresses the key concerns with the Religious Freedom Restoration Act (RFRA). We appreciate the speed with which the leadership of the General Assembly has moved to rectify the RFRA. We now urge the Indiana House and Senate to promptly pass this bill and Governor Pence to sign it into law. We have been concerned about the lack of clarity of the RFRA law and how it could have potentially impacted our employees and visitors to the State of Indiana. Dow AgroSciences continues to support a diverse environment for our employees to live and work free from discrimination.