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February 23, 2012


2,4-D Task Force II Response to NRDC Law Suit Filed on February 23, 2012


The Industry Task Force II on 2,4-D Research Data is disappointed that the Natural Resources Defense Council ("NRDC") has sued EPA today claiming that the Agency has taken too long in responding to its November, 2008 petition to cancel 2,4-D registrations and tolerances.

2,4-D is not only among the most thoroughly tested pesticides, it is among the most thoroughly reviewed. Since 1988 the Task Force has submitted to EPA over 250 mammalian and environmental toxicology, environmental fate and residue studies. In 2005, EPA concluded its seventeen year comprehensive review and assessment of 2,4-D. It reported in its 304 page Reregistration Eligibility Decision for 2,4-D ("RED") that the short and long-term effects of using 2,4-D were "not of concern" when users followed product label instructions.

EPA has not taken too long to respond to NRDC's Petition. NRDC's 2008 Petition to EPA and its law suit alleged that 2,4-D disrupts the human endocrine system. Yet since November, 2008, the Task Force has submitted to EPA a state-of-the-art reproduction study in rats and, in response to an October 2009 testing order of EPA, eleven endocrine assays in various organisms or equivalent information that address the very endpoint of concern to NRDC. EPA is reviewing this body of test data now. The results of the study and assays demonstrate that 2,4-D is not an endocrine disruptor.

Finally, to address FIFRA's requirement that EPA periodically and systematically review the safety of pesticides every fifteen years, EPA, even though it completed its comprehensive safety assessment of 2,4-D in 2005, will start another updated review of 2,4-D, approximately 12 months from now, March, 2013.

In summary, 2,4-D continues to meet FIFRA's standards for registration. Registrants are conducting and EPA is assessing state-of-the-art studies to address the very questions raised in NRDC's November, 2008 Petition. EPA will start a public and transparent review of 2,4-D within the next 12 months.

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