March 8, 2019
The Registrar: Genetically Modified Organisms Act
Private Bag X973
The National Family Farm Coalition (NFFC) submits the following comments to respectfully urge the government of South Africa to reject Dow AgroSciences's applications for commercial release of three maize seed varieties genetically engineered to resist the pesticide 2,4-D.
NFFC is a non-profit organization representing 26 grassroots family farm and fishing organizations in 42 of 50 states throughout the United States. Our farmers raise a variety of livestock and crops, from organic produce to commodity grains, both genetically and non-genetically modified.
In 2014, NFFC farmers and concerned partner organizations contacted the U.S. Environmental Protection Agency with several fears around the application of 2,4-D:
- The potential for drift and consequential damage to important food crops - including but not limited to tomatoes, strawberries, grapes, peppers, cabbage, blueberries, squash, carrots, almonds, cherries and dicots (plums, beans, peas) - that are especially sensitive to 2,4-D damage is very high. In addition, ornamental and landscaping plants (including grasses), other broadleaf plants and timber trees, as well as bees and other beneficial insects, would be harmed. This was based on previous incidents, such as a 2012 event in California that involved 2,4-D damage over 15,000 acres from a site 100 miles away (http://westernfarmpress.com/cotton/sjv-phenoxy-drift-cotton-damage-widespread), and a Missouri farmer's loss of grape, tomato, pepper and/or potato plants for at least two consecutive years (http://www.boulderweekly.com/article-13195-market-share-chemical-warfare.html.
- The lack of required testing for water safety for human, livestock and wildlife consumption, as well as for habitat safety for aquatic wildlife, in areas where 2,4-D would be sprayed.
- Risks of new and evolving 2,4-D-resistant weed species, replicating the resistance of hundreds of weeds to various herbicides. Per the International Survey of Herbicide-Resistant Weeds
There are currently [as of March 7, 2019] 499 unique cases (species x site of action) of herbicide-resistant weeds globally, with 255 species (148 dicots and 107 monocots). Weeds have evolved resistance to 23 of the 26 known herbicide sites of action and to 166 different herbicides. Herbicide-resistant weeds have been reported in 92 crops in 70 countries. The website has 2740 registered users and 574 weed scientists have contributed new cases of herbicide-resistant weeds.
- The use of 2,4-D on Enlist Duo crops (soy and corn) would diminish the biodiversity of farms and surrounding communities, the ecological health of rural communities where applied, and overall health of rural communities and farmers nationwide.
USDA estimated that 2,4-D use would increase by 200 to 600 percent, generating significant public health risks and potential harm to non-target organisms. NFFC allies noted that this expected increase in 2,4-D use would have far-reaching negative consequences for the health of children, workers, farmers and other residents of rural communities. The lack of safety testing regarding synergistic or additive effects of various health risks included but were not limited to:
- Inhalation toxicity
- Reproductive and developmental toxicity
- Endocrine disruption and birth defects
- Associations with Non-Hodgkins Lymphoma
- Toxic air contaminant
Since the U.S. government has allowed 2,4-D-resistant crops to be planted, it was learned on March 5, 2019, that:
Kansas State University weed scientists have confirmed a Palmer amaranth population that resists the synthetic auxin (Group 4) herbicides dicamba and 2,4-D. New formulations of dicamba and 2,4-D are used on soybeans in the Roundup Ready Xtend System and the Enlist Weed Control System. ... The KSU scientists note this has left farmers with few postemergence options to manage this weed. Dicamba and 2,4-D (Group 4) have been used for many years to help control Palmer amaranth, but farmers have complained about poor control in recent years.Palmer amaranth that resists 2,4-D and Dicamba confirmed in Kansas by the Fence Post
In addition, NFFC believes that increasingly industrialized agriculture based on chemical pesticides and genetically engineered seeds only exacerbates the corporate consolidation of resources as well as the repercussions of climate change. Heavy reliance on fossil fuels; water and soil depletion and contamination; and loss of wildlife habitat and biodiversity have denigrated socio-economic-environmental systems, thereby increasing poverty, hunger and societal unrest. As you read these comments please know that a broad range of allies in the United States, including family farmers and fishers, people of faith, scientists, economists and legislators, are collaborating on a list of proposals under the umbrella of a Green New Deal to reverse this scenario before floods and hurricanes destroy coastal communities, and drought and tornadoes scorch the Great Plains - often recognized as the 'breadbasket' of the U.S.
Thank you very much for reading and considering these comments.