OFS defends one of Oregon’s most commonly used herbicides before EPA

Terry L/ Witt, Director
Oregonians for Food & Shelter
Comments to the EPA on 2,4-D.

OFS is a 29 year old, Board-directed, non-profit coalition of more than 13,000 individuals, organizations and businesses in Oregon that support the efficient production of quality food and wood fiber while protecting human health, personal property and the environment through the integrated (IPM) and responsible use of lawful pest management products, soil nutrients and biotechnology.

OFS also works collectively with other Oregon business and natural resource groups to support the needs and infrastructures of Oregon’s farm, forest and urban communities and their jobs.  The multiplier reach of OFS is more than a quarter million Oregonians involved in one or more natural resource endeavors.

OFS is highly concerned over the NRDC petition filed with the agency to revoke all tolerances and cancel all registrations of 2,4-D.   2,4-D is one of the most widely used and depended upon herbicide in Oregon, ranking second only to glyphosate in pounds used annually.   It is also important to note, that there have been no documented human health or environmental problems dealing with 2,4-D reported to the Oregon Department of Agriculture or the Oregon Pesticide Analytical & Response Center, a multi-agency group specifically designed to handle public concerns about pesticide exposures.

2,4-D is one of the most extensively studied active ingredient available today with more than six decades of use and some three hundred or more agency-reviewed studies addressing human and environmental toxicology to support its continued use.

Oregon is a very unique agricultural state, producing over 220 commodities.   2,4-D is a staple herbicide for broadleaf and aquatic vegetation control, including resistance management, in a long list of Oregon products.  Some of the Oregon uses include:   field and sweet corn; peaches, apples, pears and filberts;  asparagus; spring and winter wheat, rye and barley;  potatoes;  blueberries, cranberries and strawberries;  hops; grasses grown for seed and sod; pasture, rangeland, fallow and conservation grounds;  poplar and cottonwood grown for pulp;  forestry conifer site prep and release;  and in non-group areas such as golf course, cemeteries, turf grass and lawns;  utility and transportation rights-of-ways, and aquatic uses in ditches, irrigation cannels, lakes, ponds and reservoirs.

Several years ago the state of Oregon implemented a pesticide use reporting system that has now generated two years of data on pesticide use by type.   While most believe these data represent only a partial reporting of the actual total (i.e. the numbers are under-reported into the system) they do show the relative importance of 2,4-D as a major herbicide in almost all use categories.   The total of all pesticide (herbicides, insecticides, fumigants, etc.) use reported for 2007 was 34,270,330 pounds of active ingredients.   The number one herbicide total was glyphosate at 2,949,547.   The number two herbicide was 2,4-D at 1,043,474.

The follow 2007 Oregon data does not include pesticides used by homeowners or for non-business purposes:

• 2,4-D was the second most widely used herbicide (480,557 lbs. or about 1/4 of total) in field crops.
• 2,4-D was the second most widely used herbicide (386,365 lbs. or about 1/4 of total) for seed crop production.
• 2,4-D was the third most widely used herbicide in forestry (138,493 lbs.), or 12% of all forestry pesticides.
• 2,4-D was the number one herbicide used on Rights-of-Ways (55,239 lbs.), or 13% of all ROW pesticides used.
• 2,4-D was the second most widely used herbicide (50,660  lbs. or about 1/4 of total) in pasture/forage/hay
• 2,4-D was the number one most widely used herbicide in the public health and regulatory pest category.
• 2,4-D was the second most widely used herbicide (about 1/3 of total) for urban outdoor uses.

OFS hopes the EPA recognizes the financial and practical importance of this herbicide to the agricultural, forestry and urban communities within Oregon and will focus on the SCIENCE not the political whim of an activist group.  With 80% of our agricultural products being shipped outside of Oregon and 40% of that total being exported from the USA, maintaining cost-effective and efficacious tools is a key to continued production of high quality, affordable food and wood fiber for Oregon, the United States and the world.

OFS does not believe the toxicological or environments data reviewed and accepted by the greater scientific community nor more than 60 years of beneficial and safe use supports additional restrictions on 2,4-D.

Terry L/ Witt, Director
Oregonians for Food & Shelter
3415 Commercial Street SE, Suite 100
Salem, Oregon 97302

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