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Docket No. APHIS–2013–0042
Regulatory Analysis and Development, PPD
APHIS, Station 3A–03.8
4700 River Road Unit 118
Riverdale, MD 20737–1238

March 5, 2014

The Cornucopia Institute is a 501(c)(3) public interest organization engaged in farm and food policy research and education.  We are proud to represent approximately 10,000 members, who support healthy food and sustainable farms.  Additionally, we believe we have more certified organic farmer members than any other similar organization.  We submit the following comments on Docket # APHIS-2013-0042.  

Cornucopia opposes the approval of genetically engineered (GE) corn and soybeans resistant to broadleaf herbicides, particularly the herbicide 2,4–D.  There are two separate, but equally important, reasons for rejection of this petition.  First, the herbicide itself harms humans and the environment.  Second, the genetically engineered (GE) DNA harms humans, animals, and the environment.

If these crops are planted, use of 2,4-D will increase significantly, which will increase the potential for widespread environmental damage and harm to human health.  It’s been estimated that introduction of this GE corn will increase the use of 2,4-D to more than 103 million pounds applied to U.S. corn fields by 2019, up from about 3 million pounds applied in 2010.

2,4-D Harms the environment

Increase in use of 2,4-D means increased environmental residues in rivers, lakes and oceans, which will harm fish.[1]  The herbicide also harms earthworms, birds, and beneficial insects.[2] [3] [4]

With increased use of 2,4-D, impacts on nearby crops due to drift will increase, because 2,4 D is highly volatile.  Drift from 2,4-D can injure or kill non-target crops grown by neighboring farmers, landscape plants grown by nearby homeowners, and native plants in their natural habitat.

2,4-D Harms human health

Approval of these herbicide resistant crops will increase the exposure of farmworkers to toxic herbicides.  Exposure from sprays of 2,4-D can cause several serious diseases, including cancer, Parkinson’s, and birth defects.  Agent Orange permanently scarred veterans of the Vietnam War when it was sprayed on the forests of that country.  Now, we consider allowing 2,4-D, an ingredient in Agent Orange, to scar the farmworkers when it is sprayed on the crops in this country.  It is irresponsible to promote increased use of this herbicide, with its proven ability to harm human health.

Use of 2,4-D will create resistant weeds

Herbicide resistant crops are not a long-term solution to weed control for farmers.  Development of resistant weeds can be expected, based on the rapid development of glyphosate-resistant weeds after the widespread adoption of glyphosate-resistant GE crops.  This will compromise the ability of landowners to use 2,4-D herbicides to control noxious weeds, but will not provide a long-term solution to weed control for farmers.

Spread of DNA from GE crops cannot be contained

The widespread planting of genetically engineered crops has already raised concerns about how they can coexist with the traditionally-bred crops that have been grown for thousands of years.  Farmers of organic and non-GMO crops have suffered economic losses due to accidental GMO contamination.  There are no regulations or standard practices to ensure that the GE DNA remains in the field where it is planted.  In fact, containment of this GE DNA is impossible.  This fact alone indicates that additional GE crops should not be brought to market.

In addition to its spread to crop plants, the GE DNA can also spread to bacteria on the plant and in the soil.  In the soil environment, the GE DNA can persist in the soil for at least a year,[5] where it can be taken up by natural soil bacteria and be incorporated into their genomes.[6]  This spread would not be detected in the initial field tests of GE crops, because it is rare, and scientists were not specifically looking at this type of environmental contamination.  As GE crops become widespread and are planted repeatedly for many years, the likelihood increases that GE DNA will spread to soil bacteria.

Genetically engineered food has not been proven safe

Genetically engineered food has not been proven safe to eat.  This harm may be due to the ingestion of higher levels of pesticides, or directly caused by the foreign DNA.

Based on results from recent scientific studies, we believe that consumption of GE crops will cause harm to humans and animals that consume them.  In order to determine adverse impacts of eating GE foods, it is necessary to conduct long-term feeding studies.  Independent scientists who have conducted feeding studies over a two-year period, the typical lifespan of lab rats, have raised serious concerns about the health effects of GE crops.  Scientists reported harm to the liver, kidneys, digestive and immune systems, as well as other health problems.[7][8]  The DNA from GE crops can also be transferred directly into animals.  When livestock were fed GE crops, the GE DNA was taken up by the animal’s organs and detected in the meat, milk, and fish that people eat.  [9][10][11][12][13]

Numerous scientists agree that eating GE crops may cause health problems.  In October of 2013, more than 230 scientists signed the following statement: “we strongly reject claims … that there is a “scientific consensus” on GMO safety. …  We feel compelled to issue this statement because the claimed consensus on GMO safety does not exist.”  The statement was issued by ENSSER, the European Network of Scientists for Social and Environmental Responsibility.


The Cornucopia Institute stands with other organizations dedicated to protecting the public’s interest in safe food and a clean environment, including Beyond Pesticides, National Organic Coalition, and Center for Food Safety.

We urge you not to approve deregulation of these herbicide-resistant genetically engineered corn and soybean varieties.

Pamela Coleman, Ph. D.
Farm and Food Policy Analyst
The Cornucopia Institute


[1] 1Wang, Y., C. Jaw and Y. Chen. 1994. Accumulation of 2,4-D and glyphosate in fish and water. Water Air Soil Pollut. 74pp.  397-403.

[2] Roberts, BL and HW Dorough. 1984. Relative toxicity of chemicals to the earthworm. Environmental Toxicology and Chemistry 3:67-78.

[3] Duffard, FL, Traini, and A Evangelista de Duffard. 1981. Embryotoxic and teratogenic effects of phenoxy herbicides. Acta Physiol. Latinoam. 31:39-42; Lutz H and Y Lutz-Ostertag. 1972. The action of different pesticides on the development of bird embryos. Adv. Exp. Med. Biol. 27: 127-150.

[4] Cox, Caroline. 1999. Herbicide Factsheet: 2,4-D: Ecological Effects. Journal of Pesticide Reform 19:3pp14-19.

[5] Lerat S, et al. 2007.  Quantification and persistence of recombinant DNA of Roundup Ready corn and soybean in rotation. J Agric Food Chem. 55(25): 10226-10231.

[6] Pontiroli A,et al. 2007.  Fate of transgenic plant DNA in the environment. Environ Biosafety Res. 6(1-2): 15-35.

[7] Dona A, and Arvanitoyannis IS. 2009.  Health risks of genetically modified foods. Crit Rev Food Sci Nutr. 49(2): 164–175.

[8] Antoniou, M, et al.  2012.  GMO Myths and Truths: An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops.  Earth Open Source, page 42.

[9] Tudisco R, et al. 2010.  Fate of transgenic DNA and evaluation of metabolic effects in goats fed genetically modified soybean and in their offsprings. Animal. 4: 1662–1671.

[10] Ran T, et al. 2009.  Detection of transgenic DNA in tilapias (Oreochromis niloticus, GIFT strain) fed genetically modified soybeans (Roundup Ready). Aquaculture Research. 40: 1350–1357.

[11] Chainark P, et al. 2008.  Availability of genetically modified feed ingredient: investigations of ingested foreign DNA in rainbow trout Oncorhynchus mykiss. Fisheries Science. 74: 380–390.

[12] Sharma R, et al. 2006.  Detection of transgenic and endogenous plant DNA in digesta and tissues of GMO sheep and pigs fed Roundup Ready canola meal. J Agric Food Chem. 54(5): 1699–1709.

[13]Mazza R, et al. 2005. Assessing the transfer of genetically modified DNA from feed to animal tissues. Transgenic Res. 14(5): 775–784.

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