February 13, 2018
Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW Washington, DC 20460
RE: Docket ID Number EPA-HQ-OPP-2012-0330
Dear Mr. Bongard:
The National Cotton Council (NCC) appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA) Revised Human Health Risk Assessment for Registration Review of 2,4-D. The NCC urges EPA to recognize the long-term registration of this crop protection product and to recognize the unique mode of action (MOA) it offers for resistance management scenarios. As EPA urges producers to recognize the values of rotating chemical MOA’s for resistance management purposes, EPA must recognize rotation is not possible unless there are multiple MOA’s available. This product serves critical weed resistance management objectives, especially given the level of weed resistance to glyphosate.
The NCC is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from California to Virginia. U.S. cotton producers cultivate between 9 and 12 million acres of cotton with production averaging 12 to 18 million 480-lb bales annually. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 125,000 workers and produce direct business revenue of more than $21 billion. Annual cotton production is valued at more than $5.5 billion at the farm gate, the point at which the producer markets the crop. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 280,000 workers with economic activity of almost $100 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
There are many uses of 2,4-D as the EPA has noted. Historically, cotton plants have been very susceptible to injury from 2,4-D. Dow AgroSciences has developed a genetic trait that provides cotton plants tolerance to 2,4-D. In addition, the company has developed a new formulation of 2,4-D, called Enlist®, as an optional tool available to be applied over the top of the crop, for producer’s weed management programs utilizing the new technology. The addition of this tool does not mandate that all producers utilize this technology, but provides diversity of technology that reduces selection pressure for resistant plants. The diversity of tools must be recognized as a critical component of meaningful resistance management practices.
The NCC appreciates EPA’s continued protection of human health based on scientific data of merit. The NCC compliments EPA on the thorough Revised Human Health Risk Assessment for Registration Review as well as the 2,4-D Toxicology Systematic Literature Review, and Tier II epidemiology reports focusing on non-cancer effects and carcinogenic effects. The NCC appreciates EPA’s acknowledgement that after all scientific data review, “2,4-D has been classified as a Category D chemical, i.e., not classifiable as to human carcinogenicity.” The point is further acknowledged on page 17 of the Revised Human Health Risk Assessment for Registration stating, “Both the rat National Toxicology Program (NTP) carcinogenicity and mouse NTP carcinogenicity studies (1989) on 2,4-DCP are negative for carcinogenicity.” The NCC remains hopeful that responsible media will convey the findings to the public who have been misinformed regarding carcinogenicity of 2,4-D.
Similarly, these reviews have demonstrated vast data that continues to support previous positions with respect to human health safety of 2,4-D and in some cases reduced concerns by acquiring a more complete data set. The NCC believes the EPA has clearly demonstrated the scientific points to ensure human safety with appropriate labeling.
The NCC urges EPA to maintain reliance on valid scientific data as it compiles assessments for registration and registration review of 2,4-D products. The NCC re-emphasizes the importance of multiple herbicide MOA’s, including 2,4-D and encourages the agency to move forward with completion of the registration process without the addition of mitigation measures that are not supported by relevant scientific data.
Thank you for allowing the NCC to comment on EPA’s Revised Human Health Risk Assessment for Registration Review of 2,4-D.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council