Enlist Duo Herbicide Proposal Gets Public’s Attention — DTN

    The EPA will begin examining more than 27,000 comments collected on a proposal to register Dow AgroSciences’ Enlist Duo, an herbicide designed to be used on corn genetically engineered to tolerate 2,4-D. The comment period closed Monday and EPA has indicated it will make a decision on the registration by late summer or early fall, according to the agency’s website.

    The registration being debated is for six states: Iowa, Illinois, Indiana, Ohio, South Dakota and Wisconsin.

    Most of the comments received by EPA and posted at were written anonymously. Most of those commenters asked the agency to not approve the product because of environmental concerns related to agriculture worker exposure, and concerns for food and animal exposure to 2,4-D.

    At the close of the comment period, Food and Water Watch Executive Director Wenonah Hauter said in a statement Tuesday that a coalition of environmental groups including FWW submitted more than 500,000 comments on the proposal. The count on doesn’t include bulk comments.

    Conversely, most of the comments posted in favor of the registration were signed.

    Those supporters were mostly from the ranks of agricultural industry officials, weed scientists and farm organizations on behalf of members.

    By and large the public comments received represented the divide on the issue of weed resistance, split between environmentalists, organic farmers and others on one side, and state and national associations representing production agriculture on the other.


    Larry Steckel, extension weed specialist in the plant sciences department at the University of Tennessee, said in a letter to EPA that based on his research on Enlist Duo used on soybeans and cotton in the past several years, “it is very clear that this herbicide is a much-needed new tool to manage weeds, particularly herbicide-resistant weeds, which yearly are becoming more challenging.”

    He said “many states are quickly becoming infested” with several glyphosate-resistant weeds, particularly Palmer amaranth.

    Tennessee, however, is not among the list of states that Dow included in draft label language.

    A number of state and national agriculture interest groups, in their written comments, expressed concern about the limitations on which states are being considered for registration of Enlist Duo.

    Dale W. Moore, executive director of public policy at the American Farm Bureau Federation said in public comments that AFBF would like to see Enlist Duo registered even in states where weed resistance isn’t yet a problem.

    “We urge EPA to consider expanding this registration to all U.S. corn and soybean production areas,” Moore said. “New data from November 2013 indicate that 86% of corn, soybean and cotton growers in the South have herbicide-resistant or hard-to-control weeds on their farms. The number of farmers impacted by tough weeds in the Midwest has climbed as well, and now tops 61. Delaying the availability of this herbicide can only exacerbate this problem.”

    “Introducing a patchwork of new weed-resistance management requirements one product label at a time will be ineffectual, counterproductive, confusing and most likely impossible for growers to meet,” Moore said.

    A Dow spokesperson, responding to DTN questions regarding the proposed list of states, said Dow is “working with the EPA to expand the list of states in time for the technology’s launch.”


    Several environmental groups questioned the viability of products such as Enlist Duo as part of a weed-resistance strategy, noting that weed resistance to 2,4-D has already been found and that increased use of the herbicide could expand that resistance.

    Commenters also raised the issue of higher levels of drift and other off-target movement, something Dow has said it is addressing with the new formulation of 2-4,D in Enlist Duo

    West Texas Bill Day, who farms organic peanuts, cotton, rye and wine grapes said in a comment to EPA that “2,4-D is still my deadly enemy. Each year, I find vines affected by volatized drift from GMO cotton damaging my grapes. It is a threat to any and all organic crops, vineyards, orchards and vegetable fields. There are other, better, newer chemicals to be used in place of 2,4-D.”

    United Natural Foods, Inc., the largest organic and natural foods distributor in the United States, said in public comments that Enlist Duo poses “a serious threat to organic growers through drift-related crop damage.

    “This problem results in weed resistance and the destruction of organic crops. It also jeopardizes the certification of organic farmland. The threat of 2,4-D is underscored by the fact that this herbicide is already the leading source of drift-related damage to organic crops.”

    The group said expanding the use of 2,4-D would have “an immense impact on the more than 500,000 workers and 18,000 farms that help make up the $35 billion organic industry — the fastest-growing segment of the food sector.”

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