“Environmentalists buzzing with excitement!”

Dow herbicide BlogBy Pamela Denholm adapted from Berkshire Organics 12/15/15

This concerns the registration of Dow AgroScience’s Sulfoxaflor, a new herbicide recently approved by the EPA. The Ninth Circuit Court of Appeals overturned the EPA’s approval of the insecticide, citing that the organization violated federal law when it approved the chemical without reliable studies on the impact that it would have on pollinator colonies. The final ruling was that the product must be pulled from shelves, and could not be used in the U.S. unless the EPA obtained the necessary data regarding impacts to honeybees in order to re-approve the insecticide in accordance with law.

Unsurprisingly, this data could not be obtained, and two weeks ago the EPA canceled its registration of Sulfoxaflor As a result, many food activists and farmers have been speculating on whether the ruling and subsequent decision by the EPA might lead to further review of other pesticides and herbicides…and wouldn’t you know, it’s happening already. Last Tuesday, the EPA revoked its approval of another Dow AgroScience product: Enlist Duo. A signature blend of 2, 4-D and glyphosate—both endocrine-disrupting chemicals that the World Health Organization lists as possible and probable carcinogens, respectively—Enlist Duo has been marketed for use with GM corn and soybean varieties as a way to counter the weeds which have evolved to resist glyphosate alone. As you might imagine, the reasons behind the EPA’s revocation of the product are entirely worth exploring. Originally, Dow had assured the EPA that the herbicide cocktail wasn’t really anything new; after all, the two agrichemicals had already been government-approved for some time. Simultaneously, however, Dow was patenting Enlist Duo as a new product which delivers “synergistic” effects of the combined components. In other words, the message changed dramatically depending on the audience: potential investors heard that this new herbicide mix could potentially be a huge money-maker, while the EPA heard that there was nothing new or different about the product—and therefore no new studies needed to be conducted to approve its use.

Upon further investigation, however, the EPA has ruled that the combination of these two herbicides might do a great deal more than just kill weeds. Since agrichemicals are generally safety-tested in isolation, there’s not a lot of industry data on the potential effects of a mixed product. Independent studies, however, show that chemical combinations are often much more toxic than the individual components alone. In short, the EPA sees the synergistic effects of Enlist Duo as being potentially more dangerous than just the sum of its two parts. Dow AgroScience must now comply with the EPA regulations regarding research on these “synergistic effects” in an effort to clear the product’s release in time for the 2016 crop season.

Unfortunately, the EPA generally relies on company-supplied data to make its decisions, which might make this revocation a mere bump in the road for Dow AgroScience. Considering the very recent ruling on Sulfoxaflor, however, we can only hope that the EPA demands independent testing in an effort to keep this very toxic chemical mix off the shelves and out of our nation’s food and water supply
• “EPA Cancels Registration of Dow AgriScience’s Sulfoxaflor Insecticide.” AgriMarketing—16 Nov 2015
• Newman, Jesse. “EPA Seeks to Revoke Approval of Dow Chemical’s Enlist Duo Herbicide.” The Wall Street Journal—25 Nov 2015
• Philpott, Tom. “Another Common Herbicide Linked to Cancer.” Mother Jones—23 June 2015
• Philpott, Tom. “The Government Buried Some Really Important News Right Before Thanksgiving.” Mother Jones—30 Nov 2015

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