a four-fold rise - Center for Food Safety

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Center for Food Safety – Science Comments – FG72 Soybean 16 3. Environmental effects of increased herbicide use and changes in herbicide use patterns with approval of FG72 soybean APHIS’ failure to adequately assess the changes in amounts and patterns of use of isoxaflutole and other potential herbicides to which FG72 is resistant needs to be redressed. Without a reasonable projection of herbicide use, environmental, health, economic and agronomic impacts of approval of FG72 soybean cannot be determined. Assessing impacts on endangered species also hinges on realistic projections and descriptions of isoxaflutole and other herbicide use. Isoxaflutole is an extremely potent, broad-‐spectrum herbicide, toxic at very low levels to non-target plants via drift and runoff. It retains herbicidal activity in some soils for over a year, becoming activated after rains. In dry years, dust from isoxaflutole-‐treated fields may pose a hazard to non-‐target plants. Therefore an increase in isoxaflutole use and change in its pattern of use will impact non-‐target crops and wild plants, including endangered plants, with consequences for biodiversity. No other herbicides that have “restricted use” status are used on more than 1% of soybean acres in the U.S. (USDA NASS 2007). a. Injury to plants and other non-‐target organisms via spray drift Injury to organisms from isxoaflutole applications have been recorded in EPA’s Ecological Incident Information System (EIIS), and other databases (US EPA 2011c) at 15. Most of the 460 incidents in the EIIS were of injury to corn itself after direct application. A few incidents involved injury to sugar beet and soybean that were planted in rotation with treated corn via residual soil activity. There were also more than 8000 “minor plant incidents” between from 1999 to 2010 from herbicides containing isoxaflutole, but no more details are provided. Some of these incidents could have resulted from spray drift. With wider use if FG72 soybean is approved, drift events that injure adjacent non-‐resistant crops and wild plants will no doubt occur more frequently. It is likely that crop injury from pesticide drift is significantly under-‐reported: When crops are damaged by off-‐target movement of herbicides, the affected growers may settle their differences without the intervention of government enforcement agencies or courts. However, in the absence of a damage report to a state agency or court settlement, there are no records of their occurrence, due to lack of a centralized herbicide incident reporting system in the United States. For incidents that are more contentious or serious, a likely sequence of events arising from herbicide damage to non-‐target crops may include: 1) a complaint to a state agency over damage cause[d] by an herbicide, 2) an ensuing investigation that may uncover a violation (but which may not resolve the economic loss by the farmer
Center for Food Safety – Science Comments – FG72 Soybean 17 whose crop is affected), and 3) lawsuits that use the investigation as evidence of harm…However, the majority of lawsuits are settled out of court with the stipulation that the plaintiffs not divulge the contents of the settlement to anyone including the government. (Olszyk et al. 2004, p. 225) When only wild plants are harmed, injury may not be noticed or reported at all. Therefore, most information about risks of herbicide exposure for wild plants and ecosystems comes from experimental studies and comparative surveys rather than from incident reports (discussed later in these comments). Glufosinate is a broad-‐spectrum contact herbicide, so non-‐target plants are at risk of injury from drift (Reddy et al. 2011). An EFSA report on glufosinate use in various agricultural scenarios identified drift injury to non-‐target plants as a critical area of concern that “requires risk mitigation measures such as a 5 m buffer zone.” (EFSA 2005, p. 42). As glufosinate use increases with approval of FG72 soybean, due to foreseeable stacking, more injury to non-target plants can be expected. b. Injury to plants and other non-‐target organisms via off-‐site soil movement Due to the widespread drought this summer in much of the U.S., weed scientists are cautioning farmers that label-‐recommended waiting times before planting sensitive crops after isoxaflutole use in corn may be too short (Hartzler and Owen 2013) , a reminder that isoxaflutole and DKN are quite stable in soil the absence of rain. This property of soil retention has prompted concern that such soil containing bound isoxaflutole and/or DKN will move away from treated fields in drought conditions, potentially injuring crops and wild plants at some distance away from the application (US EPA 2002): Based on the observations, EFED recommends that the use of isoxaflutole be limited or disallowed in regions that are subject to frequent drought. It is possible that soil contaminated with isoxaflutole (i.e., soils from which the chemical has not dissipated into surface waters because of inadequate rainfall) could dry out and become airborne. The contaminated dust could land on sensitive crops and cause damage. The recent incident with Oust herbicide in Idaho is an example of this scenario. This incident with Oust in Idaho occurred after the Bureau of Land Management (BLM) applied herbicide containing sulfometron methyl to SW Idaho BLM lands in 1999 and 2000. Nearby crops, including potatoes, sugar beets, grains and other crops sustained severe injury for a few years afterwards, and 135 farmers blamed BLM and DuPont for damages, winning a bellwether case but losing awarded damages on procedural ground (Hull 2011; Paez 2011). Soil contaminated with sulfometuron methyl was swept away in wind erosion after drought. The contaminated soil landed in irrigated fields, releasing the herbicide to be taken up by the sensitive crops.
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a four-fold rise - Center for Food Safety

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