Don't Drift on Me

SOCC Pens Open Letter to Chairman of Monsanto

Below is the open letter Steve Smith, Chairman of the Save Our Crops Coalition sent to Hugh Grant, Chairman and CEO of the Monsanto Company on August 9, 2016:

Dear Mr. Hugh Grant,

When Monsanto’s Xtend soybeans and cotton were approved for planting this season, it was understood that over-the-top applications of dicamba were expressly prohibited until dicamba was labeled for use on these crops. However, over the course of the summer, there has been a flood of reports of drift and/or volatility incidents and crop loss, throughout the country, related to the use of dicamba on Monsanto’s Xtend soybeans and cotton. Even in Monsanto’s own backyard, the Missouri Department of Agriculture’s Bureau of Pesticide Control is conducting investigations of more than 100 complaints in four southeast Missouri counties.

The Save Our Crops Coalition (SOCC) has, since its inception, repeatedly warned of the potential for dicamba to drift and volatilize when applied later in the growing season. Such drift incidents have confirmed what SOCC had already suspected –

  • That unscrupulous applicators will apply non-labeled generic forms of dicamba that are prone to off-target movement if such generic forms cost less, and,
  • That dicamba application later and later in the growing season is especially hazardous given dicamba’s propensity to volatilize and drift as temperatures rise.

Unfortunately, there can be no doubt that Monsanto created this problem by selling Xtend soybeans and cotton, before lower volatility dicamba products were made available to applicators. Our fear is that this single, devastating mistake will be only be compounded by further mistakes that Monsanto seems eager to make.

For instance, Monsanto has still not received residue tolerances for dicamba for crops grown in close proximity to dicamba tolerant crops, prior to registration of its Xtend herbicide. As a result, upon full introduction of the dicamba tolerant cropping system, crops such as tomatoes, grapes, cucumbers, pumpkins and squash will have no dicamba residue tolerances. Thus, as you probably know, if even minute qualities of dicamba are discovered on crops without a tolerance, such crops must be destroyed – causing drastic losses to growers and processors.

Whether Monsanto has a legal duty to the growers and processors whose crops were destroyed is not for me to decide. What I do know is that Monsanto has a moral duty to American agriculture to see that any damage related to the use of its products is mitigated to the fullest extent possible.

At every opportunity, SOCC has presented its case to Monsanto’s usually very capable personnel. Unfortunately, either because of inertia or intransigence, such personnel have found reasons not to deal with the problems that are clearly visible on our horizon. For this reason, I must elevate my concerns to you – the CEO.

SOCC is eager to finally resolve these issues. If you are not aware, SOCC has a history of working constructively with biotechnology providers to address such concerns.   On September 11, 2012, SOCC announced the successful conclusion of discussions with Dow AgroSciences regarding its 2,4-D tolerant cropping system. SOCC’s agreement with Dow was the product of two parties, which had been at loggerheads, attempting to broker a solution that would benefit all of American agriculture.

If we treat these drift incidents and crop losses as an opportunity to begin a dialogue, we believe SOCC and Monsanto can work together to achieve a lasting solution that will deliver on Monsanto’s promise of “a sustainable agriculture.”

Sincerely,

Steve Smith

Chairman, Save Our Crops Coalition

SOCC Petitions EPA to Restrict the Use of Dicamba

Today, the Save Our Crops Coalition (SOCC) petitioned the Environmental Protection Agency (EPA) to conduct a classification review to determine whether pesticides that contain the active ingredient dicamba should be classified as restricted use.

Statement of Steve Smith, Chairman of the Save Our Crops Coalition:

“Dicamba, because of its potential to drift and volatilize, has proven to be one of America’s most dangerous herbicides for non-target plant damage. Food crops, such as tomatoes, are highly susceptible to dicamba exposure, because they are grown in close proximity to dicamba tolerant crops,” said Steve Smith, Chairman of the Save Our Crops Coalition.

“The member growers and processors of SOCC are concerned that, upon introduction of dicamba tolerant crops, unscrupulous applicators will apply non-registered formulations of dicamba on dicamba tolerant crops simply because such formulations are cheaper,” said Smith.

“To be clear — SOCC does not categorically oppose the registration or use of dicamba. However, in light of the fact that older, cheaper, highly volatile formulations of dicamba are likely to be used unlawfully on dicamba tolerant crops, many such formulations should be classified as restricted use. SOCC is simply requesting that EPA restrict the use of dicamba such that it is applied only by certified applicators, and that adequate records of such applications are kept,” said Smith.

“On September 11, 2012, SOCC announced the successful conclusion of discussions with Dow AgroSciences (Dow) regarding its 2,4-D tolerant cropping system. SOCC was impressed by Dow’s commitment to strongly discourage the unlawful use of older, cheaper, highly volatile formulations on herbicide tolerant crops. Unfortunately, SOCC has not been able to reach a similar agreement with Monsanto and BASF,” said Smith.

“BASF claims that its Engenia formulation is 40% less volatile than diglycolamine salt formulations, like Clarity. We appreciate the work that BASF has done to develop new, less volatile chemistries. However, the reality is that BASF and Monsanto still sell older, cheaper, and more volatile formulations of dicamba,” said Smith.

Click Here to View the Petition

SOCC Sets Record Straight Regarding 2,4-D

Today, the Save Our Crops Coalition (SOCC) sent a letter to the Secretary of Agriculture, Thomas Vilsack, explaining the coalition remains concerned regarding the direction of USDA’s proposed environmental impact statement for dicamba tolerant crops.  Following a review of the Draft 2,4-D environmental impact statement, SOCC fears that USDA may fundamentally misunderstand SOCC’s agreement with Dow AgroSciences (Dow).

The statement of Save Our Crops Coalition Chairman, Steve Smith:

SOCC ‘s agreement with Dow was a compromise.  SOCC requested Dow make concessions.  Dow did not agree to every request SOCC made; but, Dow did, in every instance, consider SOCC’s requests, and, oftentimes, Dow obliged.

We believe Dow acted responsibly to address the concerns of its neighbors.  Unfortunately, Monsanto and BASF have, so far, chosen not to act similarly.  SOCC wants to make clear that there remain several points of contention with Monsanto and BASF that are unlikely to be resolved through simply learning more about their products.  Our differences with Monsanto and BASF are especially stark with respect to the use of older, more volatile, forms of dicamba, and product stewardship.  Moreover, unlike 2,4-D, many food crops have no tolerance or exemption for dicamba residues.  Unfortunately, Monsanto and BASF have yet to implement effective measures to protect against non-target plant damage.

The Save Our Crops Coalition intends to file comments reflecting its membership’s views regarding 2,4-D tolerant crops in the appropriate docket.

Click Here to Download the Letter

SOCC Requests USDA Expand the Scope of Dicamba Inquiry

Today, the Save Our Crops Coalition (SOCC) filed comments requesting the US Department of Agriculture (USDA) broaden the scope of an environmental impact statement to include options to address non-target drift damage impacts caused by the use of dicamba on dicamba tolerant crops.

Statement of Steve Smith, Chairman of the Save Our Crops Coalition:

“Consistent with the SOCC mission statement, we do not oppose advances in plant technology.  What we do oppose are quick ‘yes’ or ‘no’ answers to the questions growers have regarding dicamba tolerant crops.  We do not accept a universe of alternatives that includes only wholesale deregulation or wholesale prohibition of these crops.  SOCC requests that USDA expand the scope of its inquiry to consider other alternatives to address the range of issues the SOCC membership faces.”

“It is entirely appropriate that USDA, the stewards of American agriculture, have taken the first step in protecting the millions of acres of American cropland affected by this unprecedented threat.  But this is only a first step.  We believe our agreement with Dow AgroSciences should serve as a roadmap for these agencies to follow to protect growers and others against non-target plant damage.”

Click Here to Download the Comment

USDA to Prepare an Environmental Impact Statement for Dicamba Tolerant Crops

Today, the US Department of Agriculture (USDA) announced its intent to prepare an environmental impact statement (EIS) to consider the environmental impacts of crops genetically engineered for tolerance to the herbicide dicamba. 

Dicamba, because of its potential to drift and volatilize, has proven to be one of America’s most dangerous herbicides for non-target plant damage.  Non-target plant damage associated with herbicide spray drift and volatilization is a major concern for specialty crop growers and processors, and credible estimates project dramatic increases in the amount of dicamba to be applied upon the introduction of dicamba tolerant crops.

On April 18, 2012, the Save Our Crops Coalition (SOCC) petitioned USDA to prepare an EIS to consider the environmental impacts of dicamba tolerant crops.  SOCC is pleased that USDA has now chosen to undertake a comprehensive review of these crops.  SOCC hopes that this process will better inform the decision makers at USDA and EPA about the vastly increased potential for non-target plant damage impacts caused by dicamba spray drift and volatilization.

Statement of the Chairman of the Save Our Crops Coalition, Steve Smith:

We are very pleased that USDA has chosen to prepare an environmental impact statement to consider the plant damage impacts of dicamba tolerant crops.  It’s entirely appropriate that USDA, the stewards of American agriculture, have taken the first step in protecting the millions of acres of American cropland affected by this unprecedented threat.  The interests of the public best served by an informed decision making process.  We appreciate that USDA has acknowledged the need to gather more information about the environmental impacts of dicamba tolerant crops before reaching a decision regarding their widespread use.

SOCC Opposes New Uses of Dicamba and Residue Tolerances For Monsanto’s Dicamba Tolerant Crops

Today, the Save Our Crops Coalition (SOCC) submitted comments to the Environmental Protection Agency (EPA) opposing new uses of dicamba and residue tolerances for dicamba tolerant crops until effective measures are adopted to protect against non-target plant damage.

“Food crops are susceptible to dicamba exposure because they will be grown in close proximity to dicamba tolerant crops. SOCC opposes pending regulatory applications by Monsanto and BASF that would permit the widespread use of dicamba tolerant crops until effective protections are established for nearby food crops,” said Steve Smith, Chairman of the Save Our Crops Coalition.

“In addition to yield reductions caused by direct pesticide damage, farmers also suffer losses when residues of a pesticide are found on a crop for which no tolerance has been established. SOCC believes it is essential to establish the tolerances for susceptible food crops before the introduction of dicamba tolerant crops. Monsanto apparently feels it is sufficient if the tolerances are established after, perhaps years after, introduction of dicamba tolerant crops,” said Smith.

“While Monsanto claims it is evaluating whether to request tolerances for food crops grown in close proximity to dicamba tolerant crops, SOCC believes its member growers deserve more. Monsanto has already requested tolerances for its own dicamba tolerant cotton. SOCC believes that EPA should review tolerances for specialty crops grown in proximity to dicamba tolerant crops according to the same timetable it reviews crops developed by Monsanto,” said Smith.

Click Here to Download the Comment

SOCC Petitions EPA To Establish New Dicamba Tolerance Levels

Today, the Save Our Crops Coalition (SOCC) petitioned the Environmental Protection Agency (EPA) to establish dicamba residue tolerances for a broad range of food crops.

“These food crops are susceptible to dicamba exposure because they will be grown in proximity to dicamba tolerant crops.  SOCC opposes pending regulatory applications by Monsanto and BASF that would allow widespread use of dicamba tolerant crops until effective protections are established for nearby food crops.  Dicamba tolerances should be established before decisions are made regarding these pending regulatory applications,” said Steve Smith, Chairman, of Save Our Crops Coalition.

“In addition to yield reductions caused by direct pesticide damage, farmers also suffer losses when residues of a pesticide are found on a crop for which no tolerance has been established.  Modern testing technologies are so sensitive; trace residues must be recognized as a significant possibility.  If no tolerance has been established for a crop, any residue whatsoever makes sale of the crop illegal, so our farmers and processors must destroy the crop,” said Smith.

“Dicamba is one of America’s most dangerous pesticides for damage to neighboring crops.  It tends to move from where it is sprayed.  We are facing a real threat of dicamba trace residues on various specialty crops.  SOCC is filing this petition to ask EPA to determine whether there are safe levels of dicamba residues.  Without an established safe tolerance by the EPA, dicamba simply should not be approved for widespread use over our major agricultural production areas,” said Smith.

“SOCC is not proposing specific tolerance levels.   We have requested EPA undertake that review and follow the science to assure food safety with appropriate tolerances,” said Smith.

The SOCC petition calls for EPA to establish dicamba tolerances for the following crops:

  • Grape (Vitis spp.)
  • Eggplant (Solanum melongena)
  • Groundcherry (Physalis spp.)
  • Pepino (Solanum muricatum)
  • Pepper (Capsicum spp.) (includes bell pepper, chili pepper, cooking pepper, pimento, sweet pepper)
  • Tomatillo (Physalis ixocarpa)
  • Tomato (Lycopersicon esculentum)
  • Chayote (fruit) (Sechium edule)
  • Chinese waxgourd (Chinese preserving melon) (Benincasa hispida)
  • Citron melon (Citrullus lanatus var. citroides)
  • Cucumber (Cucumis sativus)
  • Gherkin (Cucumis anguria)
  • Gourd, edible (Lagenaria spp.) (includes hyotan, cucuzza); (Luffa acutangula, L. cylindrica) (includes hechima, Chinese okra)
  • Momordica spp. (includes balsam apple, balsam pear, bitter melon, Chinese cucumber)
  • Muskmelon (hybrids and/or cultivars of Cucumis melo) (includes true cantaloupe, cantaloupe, casaba, crenshaw melon, golden pershaw melon, honeydew melon, honey balls, mango melon, Persian melon, pineapple melon, Santa Claus melon, and snake melon)
  • Pumpkin (Cucurbita spp.)
  • Squash, summer (Cucurbita pepo var. melopepo) (includes crookneck squash, scallop squash, straightneck squash, vegetable marrow, zucchini)
  • Squash, winter (Cucurbita maxima; C. moschata) (includes butternut squash, calabaza, hubbard squash); (C. mixta; C. pepo) (includes acorn squash, spaghetti squash)
  • Watermelon (includes hybrids and/or varieties of Citrullus lanatus)

The Save Our Crops Coalition (SOCC) is a grassroots coalition of farm interests focused on preventing injury to non-target plants from exposure to dicamba. Dicamba is likely to be used far more extensively upon the introduction of new crops that are genetically modified to tolerate dicamba.  SOCC is not opposed to plant technology advances, particularly genetic modification. However, SOCC does oppose regulatory actions that would result in herbicide use that causes substantial injury to non-target crops or the habitats necessary for their pollinators.

Click Here to Download the Petition

SOCC Petitions EPA To Amend Generic 2,4-D Labels To Indicate Use on 2,4-D Tolerant Crops is Unlawful

Today, the Save Our Crops Coalition (SOCC) petitioned the Environmental Protection Agency (EPA) to require generic forms of 2,4-D to bear label statements indicating use on 2,4-D tolerant crops is prohibited.

Generic forms of 2,4-D are older formulations of 2,4-D known for their propensity to drift and volatilize. It is currently illegal to use generic forms of 2,4-D on 2,4-D tolerant crops. Dow AgroSciences’ (Dow) has petitioned to use only its advanced low drift and volatility 2,4-D formulation on 2,4-D tolerant crops. SOCC Chairman, Steve Smith, said, “It is not enough that it will be illegal to use generic 2,4-D formulations on 2,4-D tolerant crops. To avoid confusion and accidental violations of the law, the labels need to clearly tell applicators what the legal restrictions are. Illegally using a generic 2,4-D formulation could easily result in wiping out neighboring crops.”

The Save Our Crops Coalition (SOCC) is a grassroots coalition of farm interests focused on preventing injury to non-target plants from exposure to 2,4-D and dicamba. 2,4-D and dicamba are likely to be used far more extensively upon the introduction of new crops that are genetically modified for tolerance to 2,4-D and dicamba. SOCC is not opposed to plant technology advances, particularly genetic modification. However, SOCC does oppose regulatory actions that would result in herbicide use that causes substantial injury to non-target crops or the habitats necessary for their pollinators.

Click Here to Download the Petition

SOCC Requests EPA Prepare an EIS

Today, the Save Our Crops Coalition (SOCC) requested the Environmental Protections Agency (EPA) submit itself to National Environmental Policy Act (NEPA) procedures, and prepare an environmental impact statement that considers herbicide use within the dicamba tolerant cropping system.  SOCC opposes Monsanto and BASF’s efforts to register the new use of dicamba on dicamba tolerant crops, and has also requested EPA withhold registrations until effective measures are in place to mitigate the effects of non-target plant damage. As SOCC explained in a comment to EPA, the registration of dicamba on dicamba tolerant crops, without effective mitigation measures, would significantly increase the risk of unreasonable adverse effects on the environment.

SOCC’s mission is to prevent injury to non-target plants. SOCC has two objectives for dicamba new use registration process:

  1. First, SOCC seeks to encourage the use of only the lowest volatility formulations on dicamba tolerant crops.  Monsanto has requested registration of the older, cheaper, and more drift and volatility prone Clarity dicamba formulation.  SOCC regards additional restrictions on the use of Clarity and generic formulations of dicamba as necessary to protect against drift and volatilization damage to non-target plants.
  2. Second, SOCC seeks to ensure that, should dicamba be used, that it be used in a responsible manner.  SOCC still regards additional mitigation measures to protect against drift and volatilization damage to non-target plants caused by this new pattern of use.

The statement of the SOCC Chairman, Steve Smith:

“Dicamba is one of the nation’s most dangerous herbicides for non-target crop damage.  Monsanto and BASF have not offered sensitive crop growers effective measures to protect against non-target crop damage.  Dow AgroSciences worked with us to deliver solutions to the problems of growers.  We hope Monsanto and BASF will step to the plate and do the same.”

The Save Our Crops Coalition (SOCC) is a grassroots coalition of farm interests organized for the specific purpose of preventing injury to non-target plants from exposure to 2,4-D and dicamba. These herbicides are likely to be used far more extensively upon the introduction of new genetically modified crops tolerant to these herbicides. SOCC is not opposed to plant technology advances, particularly genetic modification.  However, SOCC does oppose regulatory actions that would result in herbicide use that causes substantial injury to non-target crops and to the habitats necessary for their pollinators.

Click Here to Download the Comment

Joint Statement of Dow and SOCC

Dow AgroSciences and the Save Our Crops Coalition (SOCC) are very pleased to announce the successful conclusion of discussions to resolve SOCC concerns regarding the potential for herbicide injury to non-target plants following the introduction of Dow AgroSciences’ new 2,4-D tolerant crops.  Through these discussions, both Dow AgroSciences and SOCC have achieved a better understanding of the each other’s perspective and concerns as well as have agreed to take additional steps to ensure the coexistence of the Enlist™ technology with sensitive crops growers. To this end, each organization agreed to modify positions with respect to pending regulatory matters around 2,4-D tolerant crops.

In light of the commitments made by Dow AgroSciences, SOCC will amend its comments and petitions to the United States Department of Agriculture (USDA) and the Environmental Protection Agency (EPA) to the extent they challenge applications for approval of Dow AgroSciences’ new seed and herbicide products to be commercialized as part of the Enlist™ Weed Control System. SOCC believes that commitments made by Dow AgroSciences represent substantial measures to mitigate potential non-target plant damage impacts from herbicide spray drift and volatilization associated with 2,4-D tolerant crops.

Dow AgroSciences will request an amendment to its label pending before EPA to include additional statements relating to herbicide applications near sensitive crops. Dow AgroSciences also reaffirms its commitments to assist in the investigation, diagnosis and resolution of alleged non-target claims, and in educating growers and applicators in management practices and proper application to reduce off target movement, especially in areas with sensitive crops.

SOCC notes that impressive research findings presented by Dow AgroSciences have been published in refereed journal articles. Specifically, SOCC cites research Dow AgroSciences has made available indicating the reduced drift and volatilization potential of its new herbicide solution for Enlist crops.

Farmers have a long history of wanting to do the right thing for their crops, their land and their neighbors. The willingness of industry segments to discuss and understand each other illustrates the spirit and commitment to success that is typical in American agriculture.

Click Here for a PDF of the Joint Statement to USDA and EPA