Information Requests Monitoring System

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Request ID: 192
Request From: Steve Toth
Date Requested: Jan 23, 2009
Request: State Contacts: Please note the following request from EPA for comments on a petition Natural Resources Defense Council (NRDC) requesting that EPA revoke all tolerances and cancel all registrations for 2,4-D. Pass this request to those interested in weed management in your respective states and territories and send comments to EPA (oconnell.cathryn @epa.gov) and the Southern Region IPM Center's Information Requests Monitoring System. Steve Toth ------------------------------------------- 2,4-Dichlorophenoxyacetic Acid (2,4-D), a Herbicide - EPA is seeking comments on a petition Natural Resources Defense Council (NRDC), requesting that EPA revoke all tolerances and cancel all registrations for 2,4-D. Organization: Environmental Protection Agency (EPA) Summary: The petitioner, NRDC, claims that EPA cannot make a finding that there is a reasonable certainty of no harm from dietary residues of 2,4-D and, therefore, that the Agency must revoke all tolerances established under section 408 of FFDCA, as amended by FQPA. As a part of the petition, NRDC claims that the Agency did not consider the full spectrum of potential human health effects associated with 2,4-D in connection with EPA's reassessment of the existing 2,4-D tolerances, and EPA's environmental risk assessment including: 1. Information on the endocrine disrupting effects of 2,4-D. 2. Information on the neurotoxicity related to 2,4-D exposure. 3. Information that products containing 2,4-D are mutagenic. 4. Data showing that dermal absorption of 2,4-D is enhanced by alcohol consumption, sunscreen, and DEET which the EPA's exposure assessment failed to include. 5. Information about adverse developmental effects at doses below those included in EPA's risk assessment for exposure of infants to 2,4- D in breast milk. Source: Federal Register: December 24, 2008 (Volume 73, Number 248) Comments Due By: February 23, 2009 Web site: The Federal Register notice is at http://edocket.access.gpo.gov/2008/E8-30527.htm The NRDC petition is in Docket ID No. EPA-HQ-OPP-2008-0877, available at http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=EPA-HQ-OPP-2008-0877 Risk assessment and related documents for this pesticide can be found under docket ID number EPA-HQ-OPP-2004-0167, available at http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=EPA-HQ-OPP-2004-0167 Contact: Cathryn O'Connell, Special Review and Reregistration Division, Office of Pesticide Programs, Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001; telephone number: (703) 308-0136; fax number: (703) 308-7070; e-mail address: oconnell.cathryn @epa.gov Prepared by: This message was distributed by Cindy Roberts, who may be reached at e-mail: car@fien.com or 202-669-6951 This article (#7609) was distributed by e-mail on December 26, 2008 to those whose names are on the FIEN, LLC Subject Matter Distribution Lists for Crop Protection; Non Governmental Organization Actions Cindy Roberts Food Industry Environmental Network, LLC 1464 Harvard St. NW, Suite 14 Washington, DC 20009-4610 Phone: 202-669-6951 --- E-Mail: CAR@fien.com Food Industry Environmental Network, LLC (FIEN, LLC) - see http://www.fien.com - FIEN, LLC is a regulatory and policy e-mail update service for the agriculture and food industry which is operated as a partnership by Jack Cooper and Cindy Roberts

Responses
Responder: Mark Mossler
State: FL
Date Requested: Jan 26, 2009
Response: This information has been forwarded to the FL/PR/VI network.

Responder: Mark Mossler
State: PR
Date Requested: Jan 26, 2009
Response: This information has been forwarded to the FL/PR/VI network.

Responder: Mark Mossler
State: VI
Date Requested: Jan 26, 2009
Response: This information has been forwarded to the FL/PR/VI network.

Responder: Darrell Hensley
State: TN
Date Requested: Feb 03, 2009
Response: A retrospective call to arms concerning claims having limited supporting data....claiming cancer risks due to the impacts of one salt (cancer risk associated with exposure to the diethanolamine (DEA) salt of 2,4-D).... total exposure calculations show the highest risk among sub-classes to be less than 7% of RFD (chronics)....very low risks.....if we divide the 46 million lbs applied annually by a low estimate (250 million) of the US population that would be .184 lbs/yr or 229 mg/day.....for an average adult that would be 3.27 mg/kg......and that's if we divided up the supply of 2,4-D and made people drink it instead of applying it to their fields.....the lowest no effect level for 2,4-D is 25 mg/kg in female rats.... Looks to me that the endocrine and neurological studies will take the longest time and the most resources to support.....defending the volatility with the 100% respiratory exposure exposure is something they have already done by modeling assumptions that respiratory risk is an ingestion risk at 100%. I am assuming the primary label holder is taking the lead on this one..... Greg Armel, Plant Sciences Dept. University of Tennessee

Responder: Darrell Hensley
State: TN
Date Requested: Feb 04, 2009
Response: In hay and pasture, 2,4-D provides control of plantain. This weed is not controled by other new herbicide chemistries. Neil Rhodes, Plant Sciences.

Responder: Darrell Hensley
State: TN
Date Requested: Feb 04, 2009
Response: If there is a risk (risk has not been fully proven for this product), I see the greatest potential being not in the ag community but in the areas of residential usage by homeowners or renters. These individuals would be least likely to follow safety guidelines (label directions). If commercial applicators use a product in a residential area the area is posted to warn individuals not to enter for 48 hours after treatment, therefore reducing any possible risk drastically. Darrell Hensley

Responder: Darrell Hensley
State: TN
Date Requested: Feb 04, 2009
Response: 2,4-D also control cruciferous weed species in many crops where new products lack control of these weed species Greg Armel, Plant Sciences Dept.

Responder: Darrell Hensley
State: TN
Date Requested: Feb 04, 2009
Response: 2,4-D also control cruciferous weed species in many crops where new products lack control of these weed species Greg Armel, Plant Sciences Dept.

Responder: Darrell Hensley
State: TN
Date Requested: Feb 04, 2009
Response: I just received word from one of our larger retail operators in Tennessee. From their sales figures I added what I believe would be a fair estimate of 2,4-D usage in agriculture production. 360,000 lbs ai for Amine formulation and 760,000 lbs ai for the Ester formulation. These figures do not include sales data for other commercial uses, turf production, or residential type uses. Darrell Hensley, Dept. Entomology and Plant Pathology, UT

Responder: Holly Gatton
State: VA
Date Requested: Feb 05, 2009
Response: None of our state specialists responded to my request for comments.

Responder: Holly Gatton
State: VA
Date Requested: Feb 05, 2009
Response: 2,4-D is registered for use on asparagus, cereals, corn, grasses, grapes, hay, rice, sorghum, soybeans, fallow land, pasture, rangeland, turf, and noncropland. The loss of this herbicide could seriously impact many growers in Virginia.

Responder: Holly Gatton
State: VA
Date Requested: Feb 06, 2009
Response: One of our specialists, Dr. Allen Straw, just got back to me this afternoon and had this to say: "I am not sure how to express the significance of the loss of 2,4-D. It is still used in such a wide variety of crops and provides postemergence broadleaf weed control that is often unsurpassed. Cancellation of 2,4-D would be devastating to fruit growers, beef producers, as well as vegetable and agronomic growers. -Allen" R. Allen Straw Area Specialist Virginia Cooperative Extension SW VA AREC 12326 VPI Farm Rd. Glade Spring, VA 24340 Phone: 276.944.2202 E-mail: astraw@vt.edu

Responder: Mark Matocha
State: TX
Date Requested: Feb 23, 2009
Response: Texas applies more 2,4-D than nearly any state in the nation. The loss of this herbicide would be disastrous to the state, impacting numerous sectors of the population. Perhaps the largest use of this herbicide is for rangeland and pasture weed control. As the number one beef cattle producing state in the U.S., Texas beef cattle producers rely on 2,4-D as a economical and generally environmentally friendly option for effective broadleaf weed control. 2,4-D does not cause great concern for ground or surface water contamination nor is it overly dangerous to wildlife. Additional uses that would be severely negatively impacted include row crops such as wheat, sorghum, corn, and cotton. 2,4-D is a cost-effective tool for broadleaf weed control and an important tool for weed resistance management. This herbicide is also widely used in right-of-way vegetation management and aquatic weed control. The urban population would also feel the effects from the potential loss of this herbicide. 2,4-D is widely used in residential and commercial weed control in turfgrass. The loss of 2,4-D would create an enormous burden to several multi-billion dollar industries in Texas while jeopardizing the sustainability of our food supply.

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