Following right on the heels of USDA’s decision to deregulate Dow Agroscience’s Enlist corn, Enlist soybeans and Enlist E3 soybean traits The Dr. Oz Show aired a segment on the coming supposed dangers that will accompany the new herbicide formulation called Enlist Duo pending EPA approval.
I received several messages through social media about the show so I set my DVR to record the episode. Upon watching the portion of the show dedicated to this new pesticide I certainly came away with a few thoughts. Surprisingly (given Dr. Oz’s past thoughts on GMO) there was some very good, truthful information concerning the practical implications of herbicide use on farms. Unfortunately, and not surprisingly, there was plenty of fear mongering and ill-informed if not intentionally misleading claims. What I want to do with this post is break down for you my experience watching Dr. Oz.
Dr. Oz began the episode by discussing so-called herbicide resistant superweeds. Dow’s response to this problem claims Oz is to bring to market “an even stronger pesticide” than Roundup to combat these problem weeds. I’m not sure what he means by stronger than Roundup. Enlist Duo is a premixed formulation of glyphosate, the active ingredient in Roundup, and 2,4-D reformulated for improved performance and safety. It is not stronger necessarily, but it is two things instead of one. Two distinctly different modes of action that manage weeds through different mechanisms. Varying modes of action is a great way to mitigate the chance of resistant weeds occurring. Tank mixing multiple pesticides or even pesticides and fertilizers is not a new concept. We fertilize and control weeds in wheat in the same pass.
A quick note on weed resistance. Resistance was around before GMO crops hit the market in the late 1990s. Farmers, gardeners, home owners, and others are trying to kill weeds all the time through various methods. Eventually weeds will wise up and learn to survive. They’ll even adapt to cultural control methods like tillage. I’ve often said that if my farm began to rely solely on tillage for weed control within a few years our worst weed problems would come from those weeds that have methods in place to stay strong in the face of steel working the soil. Multiple practices be they herbicides or other methods are needed for good weed control. I’m not going to argue that resistance is not an issue. It is. And some farmers may act as free riders who won’t steward new technologies properly because they figure all their neighbors are and that will be good enough. There are however ways to manage and limit resistant weeds and pests. Just like crops, weed control methods should be rotated.
OMG Agent Orange
I was wondering how long it would take Dr. Oz to play the Agent Orange card. Took him just a couple of minutes. He’s right in saying 2,4-D was a component in Agent Orange. However, regular 2,4-D and the new formulation in Enlist Duo are not Agent Orange. Anyone who uses this Vietnam War lingo to “inform” you about herbicide use on farms is either misguided or deliberately misleading you. Read “Misuse of a Vietnam Era Tragedy” for more information on the distinctions between defoliating a war zone and crop protection products. Dig into these things like Ellen Malloy did with “What our fields actually need is a heavy application of honesty.”
Have you ever used weed and feed fertilizer in the spring to green up your lawn and get rid of dandelions, or just sprayed something to kill dandelions? If so, then you’ve used 2,4-D at home. If you’ve sprayed to kill weeds in a driveway you’ve more than likely used glyphosate. These are not scary things. They are products any homeowner can grab from the lawn and garden center, read the label, and safely and effectively manage weeds. Just like farmers all across the world do in their fields and pastures on a regular basis. We just have different equipment. And when you killed those lawn weeds, did you notice your lawn didn’t die too? Herbicide resistance isn’t the sole realm of GMOs and “super” weeds. Normal plants like lawn grass are naturally resistant to certain herbicides.
2,4-D has been proven safe time and time again since its first EPA registration in 1948. APHIS, the scientific branch of USDA, has stated when asked if 2,4-D is equivalent to Agent Orange, “No. “Agent Orange” was a mixture of herbicides 2,4,5-T and 2,4-D, kerosene and diesel fuel. Agent Orange contained high levels of dioxin, a contaminant found in 2,4,5-T that causes cancer and other health concerns in people. EPA cancelled all use of 2,4,5-T in 1985 because of theserisks. By contrast, EPA has approved the use of 2,4-D and considers it safe when used according to the EPA-approved labeling.”
Holy smokes! I drive a diesel truck and we have a kerosene heater at the farm shop! Ingredients in Agent Orange on my own farm.
Public Comments on Enlist to EPA
Dr. Oz was correct in stating hundreds of thousands of comments on both sides of the issue were submitted to EPA during a public comment period. I provided one of those comments myself as I did when the comment period was open for USDA. I’d never done something like that before, but this was a cause I believed in. Many of the comments against Enlist were likely form letters. Not all, but a very large number of them.
To clear up why we are dealing with both USDA and EPA you should know what each agency’s responsibilities are. USDA is charged with determining whether or not a new biotech crop trait poses a plant pest risk. If USDA determines this is not the case they are free to deregulate the product. EPA handles the pesticide component. So with the Enlist system USDA was needed to examine the biotech crops, and EPA is there to regulate the use of Enlist Duo herbicide. For the purpose of this post know that technically all herbicides are pesticides, but not all pesticides are herbicides. Got it?
Oz claims if Enlist Duo is approved by EPA an additional 70-170 million pounds of additional pesticides will be used in the United States each year. I’m not sure where that data came from. I’d like to know, but have not been able to find a source. Illinois Farm Girl Katie Pratt came up with the same result.
Let’s look at his other number of 1.1 billion pounds of pesticide applied per year. It isn’t wrong, but it does sound like a big, scary number. In fact that is the latest data from EPA stemming from 2007. Usage actually came down from 1.2B in 2000. This is total use in the United States. Eighty percent is attributed to agriculture, but just for fun let’s attribute all the pesticide to corn and soybean acres. USDA estimated in 2014 that farmers would plant 84.8 million acres of soybeans along with 91.6 million acres of corn. That adds up to 176,400,00 acres total. Divide that into 1.1B pounds of pesticide and we have 6.24lbs of pesticide per acre. That seems a little less scary I think, and we haven’t even accounted for all the other cropland in the United States that can also stake claim to parts of the 1.1B pounds. It comes down to ounces per acre. A pretty standard use rate for glyphosate is 22oz per acre. That would be like me trying to evenly coat the 1 acre my house and yard occupy with less than two 12oz cans of Coke. Or Pepsi or Miller Lite. Whatever wets you whistle. Don’t let a billion pounds scare you.
Zen Honeycutt, Founder of Moms Across America
Her children “had rashes and severe allergies for years.” She said she didn’t know conventional crops had pesticides applied to them. She thought only GMO crops did. I don’t blame her for that. I bet I can find long time friends of mine who think that, or they at least think that organic foods by definition don’t employ pesticides. I don’t know everything about another person’s job, so I can’t expect everyone else to know all about farming.
Anyway she learned somehow that glyphosate kills gut bacteria and she instinctively knew this was the cause of her childrens’ issues. Her family switched to an organic diet to avoid pesticides. Her son was cured of a sudden onset of autistic symptoms within six weeks of this change. I have a hard time buying this. Not that her children had problems that were alleviated, but that the cause was a herbicide. Glyphosate has been blamed at one time or another by various activists groups for just about every malady around. The credibility of Moms Across America has also been questioned.
What about all the people who have never gotten sick since the introduction of biotech crops? What about me being around them everyday along with my family? We’re doing just fine. What about the now trillion meals eaten by livestock without consequence? Wouldn’t farmers have been outraged years ago and quit feeding their livestock feed derived from GMO crops if they were a problem?
Mark Bittman, Food Columnist at the New York Times
Dr. Oz began his conversation with Bittman surprising me by hinting that he thinks there is a place for GMO crops in the world. Good to know. There might be some science in him yet. Bittman’s claim is while there is a good argument for using biotech thus far GMOs have not lived up to the promise of increasing yields and reducing pesticide use. Let me address this issue as I see it from my farm.
I’ve said many times that currently there is no GMO trait on that market with the express intent of increased yield. There is no seed I can go buy that has a biotech gene inserted, deleted, silenced, etc that directly increases yield. Basically right now there is herbicide tolerance and pest resistance on the market. Those things do not increase the yield potential of a plant. They can however protect the potential of a given crop in the right situation. If a farmer has a severe issue with a particular weed, switching from a conventional hybrid to a biotech hybrid that expands the herbicide choices he has to include one that is very effective against his weed will very likely increase his average yield over time because he can now more effectively control the weeds that were robbing his crops of water, sunlight, and nutrients.
On the pest front we are looking toward Bt crops. Bt traits for either below ground pests like corn rootworm, or above ground pests like corn borer will most certainly increase yield when economic infestations of the targeted pest are present. Again, I won’t say they increase the genetic yield potential of a particular variety. They maintain that potential in the face of stress. On our farm we plant Bt corn. Not all our corn is Bt every year. Most of it is although we have recently reduced our purchases of Bt traits due to low pest populations. In 2012 we quit applying soil insecticide at planting. At the same time we quit running starter fertilizer through our planter. We believe Bt traits and seed treatments are effective enough on their own at this time. In some cases the only insecticide we have is the seed treatment. Some of our soybeans aren’t treated at all. It’s a rare event we even spray for other pests during the growing season. On our farm we are using less pesticide than we were in the past.
Ken Ramos, MD, PhD Associate VP, Precision Health Sciences Arizona Health Sciences Center
I appreciate Dr. Oz bringing Dr. Ramos on the show. He provided a view very similar to mine. He spoke about taking advantage of the combination of two modes of action in Enlist Duo, and the proven safety of pesticides over time.
Heather White, Executive Director, Environmental Working Group
As a mom she’s concerned about kids at recess in the “toxic spray zone.” Moms are very concerned about the safety of their kids. Rightly so. Defer to my comments on schools and drift below for commentary on Ms. White.
Marisa Weiss, MD President and Founder, BreastCancer.Org
I’m sure Weiss is an expert in many things I am not, but herbicide drift is not one of those things. Herbicide drift and volatilization are issues every applicator should be trained in managing. In fact they are trained. I carry a pesticide applicator’s permit in my wallet that requires continuing education or retesting to maintain. Off target drift can occur when winds move pesticide away from the intended area of application. Sudden changes in temperature (inversions) or applying in the wrong temperature can cause volatilization, meaning herbicide (2,4-D in particular, an attribute greatly improved upon with Enlist) can up and move off target. These things do happen, but you never hear about the 99.99% of the time everything goes right. It’s not likely you’ll see a story on the local news about the farmer who killed all the weeds in his field and nothing more, but it happens every day.
Weiss paints a scary picture of herbicides drifting onto schools. We just bought a farm behind an elementary school and a bunch of houses. We also farm next to most of the small town of Yeoman, Indiana. Now we don’t own a sprayer so all our pesticides are applied by custom applicators. Do you know what would happen if the kids at that elementary school were outside for recess, and the wind was blowing toward the school? The applicator would probably wait, go to another part of the field, or leave and come back another time. My buddy Jeff grows the same cash crops I do plus an apple orchard. He’s got over 100,000 acres of spraying under his belt from working at an ag retailer before coming back to the family farm. He’ll admit he smoked a neighbor’s tomato field one time spraying at the wrong time. Guess what he’ll tell you he does when the bees are pollinating his orchard or the wind is blowing through the corn into the orchard. Jeff will wait until conditions are right for spraying that pass or two next to the trees. Applicators have to keep records of temperature and wind direction when they are working in case something does go wrong they, and in my case the Indiana State Chemist’s office, can figure out what if anything went wrong if there is a complaint. The newest sprayers log all this stuff automatically and warn the operator of poor application conditions.
Notice there wasn’t one farmer voice represented on the show either for or against Enlist. This happens all too often in similar discussions. The people who are physically dealing with these crops and crop protectants aren’t consulted.
Holy Drift, Dr. Oz!
Oz set up a striking visual for demonstrating herbicide drift using feathers. First he started to fan the feathers with a handheld fan causing a few of them to go off target. The suddenly a huge wind came via a fan off camera and feathers were all over the place. Trust my farmer experience. Applicators will stop applying in these conditions. The middle of the day from 10am-4pm is usually the best time to spray. You don’t want to be out in the early morning or at dusk when temps are changing quickly.
Andrew Kniss at Control Freaks wrote an excellent post entitled “Dear Dr. Oz: We Don’t Spray Feathers.” Please read his post because he explains this so well and so much more thoroughly than I could. He explains, “The dose makes the poison, and that’s a pretty small dose. Now there may be some chemicals for which 10.7 microliters is a dangerous exposure, but for glyphosate and 2,4-D (the active ingredients in Enlist Duo) this amount is certainly within safe limits. It is also important to remember that this droplet represents the amount of total spray solution at 130 feet, not the amount of pesticide. Even with the most concentrated applications, only about 10% of each droplet would actually be pesticide; 90% or more will be just water.”
I’ve actually seen a test plot at Dow where Enlist Duo was applied at several times the label rate into sand. Sand doesn’t hold onto things well. Then the sand was covered in plastic bringing it up to well over 100ºF. Absolutely terrible conditions prime for 2,4-D to move off target. And to make things worse a plot of cotton was next to the sand. Cotton is very susceptible to 2,4-D injury. Not one cotton leaf showed injury in these conditions at an extremely high application rate that was off label for test purposes. Similar results were seen in the lab at a 16X label rate. That’s impressive. Cotton is also going to be an Enlist crop in the future.
The Rubber Stamp of Washington, D.C.
Heather White says Washington just rubber stamps all this GMO stuff that comes through. And it’s at the cost of the children in order to favor Big Ag. Over the last two years I’ve seen the rubber stamp at work in DC. Actually I’ve seen quite the opposite. In July 2012 I was invited by Dow AgroSciences to attend a meeting in Indianapolis concerning the Enlist program. Another farmer I know through social media gave them my name as someone who might be interested in participating since I had been actively talking about biotech online with anyone who cared to listen. My interest was piqued and I accepted the invitation. So since that time I have been an active member of the Enlist Grower Technology Network. I was in the last round of farmers to be added to the group. I think there were about 25 total, but 10-12 of us regularly participate. Heck, one of the guys is a Vietnam vet! Before I joined the group had already been to Washington once. I’ve been twice now. Dow arranged most of the meetings on Capitol Hill and with USDA an EPA. The more experienced farmers arranged meetings of their own while we were in town. This was my first time doing something like this, and I learned a lot in the process (and now have a working relationship to discuss things later like UAVs in ag on my own). Reps from Dow sat in on our meetings with Representatives and Senators, but rarely participated. They excluded themselves from visits with EPA and USDA. Believe what you will, but the farmers directed the conversations in these meetings. I’ve written this post of my own accord. No one asked me to do it. I want to do it so people can be informed on this issue. It’s 1:35am as I type this. I must really want to do it.
Full disclosure. I got an iPad at the end of that first meeting. I gave it to my wife for her birthday that weekend. I’ve been to a Nationwide race in Iowa sponsored by Enlist, but so have hundreds of other farmers and seed dealers and Dow employees. I may have even played two rounds of golf in the last two years on Dow’s dime after meetings with the GTN group. Luckily, the other farmers suck just as much as me on the links. Travel, food, and lodging were paid for our meetings.
Dow submitted Enlist to USDA in 2009. And this is only after several years and billions of dollars of research done by Dow already. Bringing a new biotech product to market isn’t easy.
Finally in September 2014 USDA deregulated the Enlist traits. Five years is far from a rubber stamp. In all that time USDA rarely if ever met a stated deadline in the approval process. During my first visit to Washington the House and Senate Ag committees told us they could do nearly nothing to move the process along. We went in hopes of preventing the USDA from performing an additional Environmental Impact Statement that would keep Enlist out of the hands of American farmers for another 180 days. Elected officials didn’t like hearing that a product made in America couldn’t be used here, but would soon be available to Brazilian and Canadian farms. Max Holtzman from USDA didn’t want to hear a word about the 9th District’s recent ruling on deregulating biotech crops as grounds to not do the EIS. USDA needed more studying. However, when sitting face to face with USDA APHIS scientists who would perform the EIS, an Ohio farmer simply asked “What more information do you need on Enlist to go ahead and deregulate?” The two APHIS men looked at each for a moment in silence until one turned toward the farmer and said, “None.” The EIS happened anyway. USDA knew it was going to get sued upon approval.
Wheels turn slowly in DC. We asked EPA if they would approve the herbicide part of Enlist for use before planting or after harvest. We posed the question because many of us already use glyphosate and 2,4-D on our fields at this time of year, and we’ve all seen how the new formulation in Enlist Duo is safer, less prone to drift and volatilization, and lessens the distinct odor of 2,4-D. It would be a nice product to use even without the crops to go with it in season. EPA wouldn’t budge until USDA performed its duty first.
My second trip to the nation’s capitol in March 2014 did show a marked difference in attitude with the Ag committees. Even USDA said they would be deregulating by July, and despite not meeting any previous deadlines the EIS was finished in good time. July came and went as did August. USDA said in the summer its preferred alternative was to deregulate. Apparently you can’t just decide to deregulate. You go through some bureaucratic nonsense of saying you’d like to and then wait until September to do something you said would be done in July. There should still be enough time to raise the seed for a 2015 launch in the United States. I hope the EPA follows suit soon to approve the herbicide, but there are still spray restrictions to be worked out between EPA and Dow. Some of the EPA proposals on restrictions would make many applications of Enlist Duo impractical. But it is the EPA’s job to keep those recess kids safe.
In almost every meeting our group of farmers from diverse cropping regions raised the concern that USDA was setting a precedent to prolong approvals to such an extent that innovation in biotech would be stifled. As Mark Bittman alluded to on the Dr. Oz show there are many more things in the future of biotechnology that could be of great benefit to the world. Let’s not hinder those advances now. Imagine a world where crops like corn and wheat could provide their own Nitrogen like legumes do. That’s a world-changing thing right there. Instant Nobel Prize to whoever does it first. Will and innovation like that come from biotech? I don’t know, but it could. Don’t quit on this stuff now. It holds too much promise.