A comment here to the federal docket about the registration for Dicamba to be used on Dicamba-Resistant soybeans, as some fruit and vegetable interests express concern about drift issues and impact on vegetable crops in the Midwest.

Comment attachment submitted by Victor L. Shank, President, Central Produce Sales Inc.
Document ID:

EPA-HQ-OPP-2010-0496-0010.1
This is comment on PROPOSED RULE: Pesticide Products; Registration Applications
Docket ID:

EPA-HQ-OPP-2010-0496
Topics:


We would like to submit our comments concerning the registration for Dicamba to be used on Dicamba-Resistant soybeans. We believe this registration should be denied or delayed until new DICAMBA formulations are available. We will address not only our concerns but the interest of our friends, fellow growers, and neighbors. There is a need to manage GMO weed problems and resistant weeds but DICAMBA is not a suitable alternative in vegetable production areas..

The widespread use of dicamba on soybeans is incompatible with the agricultural systems of the Midwest due to the proximity of dicamba sensitive crops and the penetration of housing in the Midwest’s countryside with gardens and small vegetable operations. Specifically our interests are focused on the problems associated with dicamba sensitive crops. The Midwest is the historic and traditional home of the country’s canned vegetable industries as well as fresh market operations serving the local public.

The tendencies for dicamba to volatize and move off-target has been widely researched and the science is clear. Dicamba is prone to volatization and movement into crops and home environments where substantial damage will occur.

In addition to the increased use of dicamba if dicamba resistant soybeans are approved, the use of dicamba in commercial corn will also increase dramatically since the risk of damaging soybeans will be eliminated. So the growth in dicamba usage will not merely be limited to the amount of dicamba soybeans in production, but will rise even further with corn production expansion of use.

This release can be summed up easily; it is narrow sighted and will be the source of contention among growers of all sensitive crops and commercial crop producers who will widely use the product. It is a disregard for the social aspects of rural farm life to put at risk the livelihoods of growers and fruit and vegetable processors whose raw product supply will be in jeopardy. It is not necessary to stoke the fires of consumers who have had their home gardens and landscapes destroyed by drift and volatization of a product when it is well documented that this not only might occur, but WILL occur, particularly when you consider that the primary period of usage will be in June and July, the timing of the perfect weather conditions for high volatility. It is not necessary to pit neighbor against neighbor as crop injuries will result in damages with no ability to positively recover from a responsible party because volatization of a product is not an off-label violation. It is narrow sighted to put into jeopardy an organic producer’s certification for three years because of an off-target movement. There are other solutions for broad leaf weeds missed by the ROUNDUP herbicide programs. The alternative programs are available and can be used to manage missed or resistant weeds without the adverse and disruptive nature of the proposed DICAMBA use pattern.

In addition, it is interesting and yet strange that Monsanto’s attempt to disassociate the risks of this herbicide product from the makers of genetic trait with regard to drift from field. Monsanto has established legal precedent that the pollen that would drift from a field of their GMO crops and cross pollinate other crops gives them the right to sue for patent infringement. They consider that pollen drift is something they have a right of ownership over, but when it will come to herbicide drift and crop injury and damage, they seem content to turn their head and declare that they have no responsibility. It cannot be both ways. Either drift is “owned” by the drifter, or it is not owned. We would suspect that Monsanto will not be volunteering to pay for crop injury and damages resulting from the use of Dicamba Resistant soybeans, yet they are submitting for this use on their GMO crops.

Other companies are researching and developing stacked traits for soybeans to help with the problem of glyphosate resistant weeds. For example, Dow is developing a 2,4 D version of soybeans and is coupling that release and development with a low volatile version of 2,4 D. Good stewardship of this product demands a similar contribution of research and development prior to even the thought of releasing the trait. The standard has been set for product stewardship, this request falls far below that standard.

The potential for extreme crop injuries and loss of raw product supply for our canned vegetables leads us to requesting this registration be denied.