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E-M:/ 2,4-D Up for Public comment

****ALERT**** 2,4-D UP FOR PUBLIC COMMENT; DUE August 23, 2004!
Beyond Pesticides will soon release an Action Alert to provide more details on EPA's draft risk assessment recently released as well as asking for others to send comments to EPA or sign-on to ours. In the meantime, please be aware that comments are due in just three weeks. If anyone would like to join a special ad hoc 2,4-D workgroup and listserv to discuss comments, please contact shoover@beyondpesticides.org. For more information on 2,4-D see our newly revised factsheet at: http://www.beyondpesticides.org/pesticides/factsheets/
2,4-Dichlorophenoxyacetic Acid; Availability of Risk Assessment. (http://www.epa.gov/fedrgstr/EPA-PEST/2004/June/Day-23/p13858.htm) 2,4-D is a broad-spectrum herbicide registered for use in numerous agricultural, forestry, aquatic, and turf applications. It is the most used homeowner product and the most used pesticide by the Industry/Commercial/Government market section. Despite numerous epidemiological and animal studies that support the mounting body of evidence linking 2,4-D to numerous cancers, particularly non-Hodgkin’s lymphoma, EPA is still claiming not enough data is available and listing the herbicide in class D for carcinogenicity. Studies also characterize the chemical as teratogenic (causing birth defects) and an endocrine disruptor, in addition to other health effects. Environmentally, 2,4-D has a high potential to contaminate ground water and has done so in at least five states and Canada. Studies also support its negative impacts on animals, including birds, fish (where it can bioaccumulate), earthworms, and beneficial insects. EPA's risk assessment for short-term post application exposure and one-day toddler post application exposures just meet the Agency's level of concern. The post application exposures to adults exceed EPA's Margin of Exposure (MOE) for both heavy yard work and playing golf. (See explanation of MOE at http://www.beyondpesticides.org/pesticides/factsheets/LowDown%20on%20Dursban.pdf) According to a 1998 study done by The Center for Public Integrity (CPI), since forming an ad hoc group called Industry Task Force II on 2,4-D Research Data, Dow AgroSciences, Rhone-Poulenc Rorer, and other manufacturers of 2,4-D-the nation's most widely used lawn chemical- spent at least $34 million on studies and surveys to present to the EPA (as of 1998). Donald Page, the executive director of the task force, told CPI that re-registration of 2,4-D "is in the bag." EPA’s current risk assessment appears to show very limited risk from 2,4-D usage. Docket ID# OPP-2004-0167. (closes 8/23/04)
Shawnee Hoover
Special Projects Director
Beyond Pesticides/NCAMP
701 E Street, SE
Washington, DC 20003
Tel. 202-543-5450 Fax 202-543-4791