P A N U P S

Pesticide Action Network
North America Updates Service
http://www.panna.org/panna/




April 1, 1997 

Urge EPA to Deny Tolerance Enabling Use of Bromoxynil on Transgenic Cotton 

The U.S. Environmental Protection Agency (EPA) is in the process of deciding whether to renew a tolerance on cotton genetically engineered to tolerate the herbicide bromoxynil (trade name Buctril). According to the Environmental Defense Fund (EDF), new evidence indicates that this chemical  is even more hazardous than previously recognized. EDF feels that EPA should deny renewal of the tolerance for bromoxynil, thus sending a strong signal to industry that the Agency will not permit use of genetically  engineered herbicide-tolerant crops to promote expanded use of hazardous  herbicides. 

Bromoxynil is normally toxic to cotton, a broadleaf plant, and is used on grass-like crops, such as corn, sorghum and small grains, to kill broadleaf  weeds. However, several years ago Rhone-Poulenc, the manufacturer of the herbicide, and Calgene, a small California biotechnology company, teamed up to engineer cotton so that it would tolerate the toxic effects of  bromoxynil, thus making it possible to apply the weed killer to cotton. 

In 1995, EPA approved a conditional registration for bromoxynil on transgenic bromoxynil-tolerant cotton under which the crop was grown commercially in 1995 and 1996. EPA also established a temporary tolerance -- a maximum permissible limit for the residues of bromoxynil in or on cottonseed, which will expire April 1, 1997. Sometime within the next week or so, EPA will decide whether to renew the tolerance. If it is renewed, the herbicide could continue to be applied to transgenic cotton. If not, bromoxynil could not be sold for use on cotton and there would be no reason to market bromoxynil-tolerant cotton. 

Bromoxynil is a toxic chemical with numerous adverse health and environmental effects. A committee of EPA staff has concluded that bromoxynil should retain its classification as Group C, a possible human carcinogen, based on a new study submitted by Rhone- Poulenc showing that bromoxynil causes malignant liver tumors in both female and male mice. Evidence of bromoxynil's mutagenicity and information from a structural analog, 2,4,6-tricholorophenol, a known carcinogen, provided additional support for the carcinogenicity classification. 

In addition, bromoxynil causes birth defects in laboratory mammals (rats, mice, and rabbits) and has been classified by the Agency as a developmental toxicant. In 1989, EPA canceled all registrations of pesticides containing one form of bromoxynil -- bromoxynil butyrate -- because of the risk of developmental toxicity in pesticide handlers. At that time, EPA also imposed new measures, since relaxed somewhat, limiting occupational exposure to avoid cancellation of other bromoxynil formulations (e.g., octanoate). 

Bromoxynil also poses environmental threats -- it is highly toxic to broadleaf plants and fish. Because it is a low-dose herbicide, even a small amount accidentally misapplied or blown from the site of application threatens wildlife habitats near fields. A study in ponds in the prairie-pothole region of Canada demonstrated bromoxynil's toxicity to fish and showed that the herbicide in water is readily converted to a toxic derivative which persists for weeks after spray applications. 

Given the new carcinogenicity data and the record on birth defects, the Agency should not renew the tolerance for bromoxynil on transgenic cotton. Also, this decision is being made by the Agency as it is implementing the new Food Quality Protection Act (FQPA). This far reaching statute requires a new tougher standard of safety, aggregate risk assessments, and special protections for infants and children. The FQPA demands serious consideration of chemicals that pose as many health and environmental hazards as bromoxynil, and may facilitate EPA for the first time to say "no" to expanded use of an herbicide on an herbicide-tolerant crop. 

EDF urges you to write to EPA as soon as possible (a decision is likely within a week) and ask the Agency to deny the renewal of the tolerance for bromoxynil on cotton because 
1) the herbicide presents a significant cancer risk and is a developmental toxicant, and 
2) expanding use of bromoxynil with a bromoxynil-tolerant crop violates the Food Quality Protection Act's safety standard of "reasonable certainty of no harm from aggregate exposure." 

Address your letters to: 
Dr. Lynn Goldman, Assistant Administrator, OPPTS, EPA, 
401 M Street, SW, #642, Washington, DC  20460; fax (202) 260-1847. 

Sources available

Contacts: 
Rebecca Goldburg, Ph.D., Senior Scientist, Environmental Defense Fund, 
257 Park Avenue South, New York, NY 10010;
phone (212) 505-2100; fax  (212) 505-2375; 
email becky@edf.org. 


 
Richard Wolfson,  PhD 
Campaign to Ban Genetically Engineered Food 
Natural Law Party 
500 Wilbrod Street 
Ottawa, ON  Canada  K1N 6N2 
Tel. 613-565-8517  Fax. 613-565-6546 
email:  rwolfson@concentric.net 
NLP Website (in progress):  http://www.natural-law.ca 

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