Status of 2,4-D in Sweden and Canada
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Here to Add CommentSubject: Status of 2,4-D in Sweden and Canada
Date:
Thu, 23 May 2002 07:52:57 -0400
From: Stephen Tvedten <steve@getipm.com>
Organization: Get Set Inc. (www.getipm.com)
To: Paul Helliker <phelliker@cdpr.ca.gov>
Director, State of California, Department of Pesticide
Regulation
cc: Christine Whitman whitman.christine@epa.gov
Status of 2,4-D in Sweden and Canada.
In a recent posting on the Municipal Listserve, the status of 2,4-D in Sweden was referenced.
It is not unusual in the ongoing Canadian debate for some to state that 2,4-D has been "banned" in Sweden. We note that Mr. Christie has been very careful in his use of the language concerning the status of 2,4-D in that particular market. Please allow us to fully explain the status of 2,4-D in Sweden and Europe, as well as Canada.
The herbicide 2,4-D, due to the weed spectrum, type of agriculture and climate, never was widely used in Scandinavian countries. 2,4-D's sister compounds, MCPA and MCPP, however, are more broadly used. All three herbicides are members of the phenoxy family of herbicides and have similar toxicology profiles. Due to the high cost of maintaining pesticide registrations in Sweden, the manufacturers decided some time ago to withdraw the registration for the little used 2,4-D, while maintaining the registrations for the more widely used MCPA and MCPP. 2,4-D was not banned in Sweden. This was confirmed to the manufacturers in a letter dated July 26, 1989.
On October 2, 2001, European Commission completed its re-registration of 2,4-D and ruled that the herbicide is acceptable for continued use in the member countries of the EU.
Concerning the status of 2,4-D in Canada. We understand that progress is being made on the re- evaluation of the four turf herbicides (2,4-D, MCPA, MCPP and dicamba). A regulatory decision, based on science-based risk assessment protocols, is expected this year. In addition to the 100x safety factor that is normally built into the risk assessment (100x Margin of Exposure below the no effect level of the most sensitive animal life-time study), the re-evaluation will include an additional 10x factor (resulting in a 1000x Margin of Exposure safety factor) to take into account the unique behavioural patterns of children and other sub-groups. The re-evaluations undertaken by the Pest Management Regulatory Agency are being done so on the basis of the Precautionary Principle.
Typically, the review of pesticide compounds involves the submission of label requirements; a technical chemical analysis of the product; a toxicological analysis (including oncogenicity, multigenerational reproduction, genotoxicity, and neurotoxicity); occupational and bystander exposure studies; metabolism studies; food, feed, and crop residue studies; environmental chemistry and fate data; environmental toxicology studies; value analysis of application; sustainability studies; and comprehensive data summaries.
In evaluating this data, the PMRA reviews multiple lifecycle studies - the data for a single animal feeding study can exceed 4,000 pages. The total data package submitted to the PMRA exceeded 225,000 pages. These studies are completed by a Good Laboratory Practice ("GLP") certified laboratories and independently evaluated by federal government scientists with many years of experience in the analysis of pesticides and their effect on human and animal health and the environment. The PMRA has required more than 20 person years to undertake the re- evaluation of 2,4-D.
A comprehensive explanation of the science-based risk assessment protocols employed by the PMRA may be found at:
http://www.hc-sc.gc.ca/pmra-arla/english/pdf/hlawns/hl-GovtResp-e.pdf
We trust that this information is helpful to those municipal officials tasked with examining this issue. We are also optimistic that those calling for a ban on the use of these products will be supportive of the science-based regulatory decisions of the federal government.
Larry Hammond
Chairman, Technical Committee
Industry Task Force II on 2,4-D Research Data
317-571-9442
Don
Page
Executive Director
Industry Task Force II on 2,4-D Research Data
800-345-5109
I have posted a free pest control book on the web that uses safe and far more effective alternatives, it is entitled: THE BUG STOPS HERE. You can download it for free at: http://www.thebestcontrol.com . All the best. Steve
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