By Steve Smith, Chairman, Save Our Crops Coalition

Many times in life we tend to place “markers” to be able to look back and see where we’ve come from. Today marks one of those occasions where it is appropriate to reminisce about the events and dynamics concerning the introduction of dicamba tolerant soybeans and cotton. It is the 10-year anniversary of being when I was invited to provide Congressional Testimony to the Domestic Policy Subcommittee chaired by Congressman Dennis Kucinich about the upcoming introduction of a new technology that much of the agricultural world was very excited about. Resistant weeds had become and were becoming a serious issue and the idea of a new control mechanism was met with enthusiasm…except from those whose livelihoods would ultimately be negatively affected. Specialty crop producers, organic producers, vineyards, orchards, nurseries and non-GMO crop producers were beginning to realize the threat that was imminent with this new technology.

At the time, I was serving as a member of the Monsanto Dicamba Advisory Council to provide input about the upcoming release to help avoid preventable mistakes. During those meetings the warnings of pending problems were voiced at every opportunity but as it turned out, largely ignored. Seeing the direction that was likely to happen as early as 2012, as expressed at that time, it was quite apparent that further outreach to sound an alarm was necessary. This led to the creation of the Save Our Crops Coalition in December of 2011, a group of like-minded individuals and groups who were at risk from damage the widespread use of dicamba would unleash.

On this ten year anniversary of my testimony, I find myself thinking back on some of the major points expressed at that time.  How did we do? Here is an excerpt of some of the most important parts of the testimony, or you can see the whole transcript here:

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“I am convinced that in all of my years serving the agricultural industry, the widespread use of dicamba herbicide possesses the single most serious threat to the future of the specialty crop industry in the Midwest.

With no fear of soybean injury, the use of dicamba on corn acreage will dramatically increase, raising the overall exposure of sensitive crops to injury. 

In other testimony offered, you may hear that new formulations of dicamba will reduce the risk of volatization. 

We believe those claims to be overly optimistic (referring to claims of volatility not being an issue) as the characteristics of this molecule have been well documented for about 50 years, and even the newest formulations are still proven to move off-target.

Just because we can do something doesn’t mean that we should.  At one time, the conventional wisdom thought it was a good idea to use lead in paint. The theory of dicamba tolerant technology might appear sound on the surface.

If dicamba tolerant soybeans are released onto the market place in the Midwest, they will be used and cause harm to our traditional cropping system.  Anything that has the potential to cause that type of widespread crop damage should have intense discussion and oversight.  When that occurs, the answer will become abundantly clear.  The widespread use of dicamba is incompatible with Midwestern agriculture.

However, the transformation to herbicide applications during the growing season in June and July has put drift prevention at the forefront of concerns to sensitive crop producers of all kinds. 

The risk of off-target movement is not limited to only tomatoes and other fresh market produce.  Growers of non-dicamba tolerant soybeans will be at risk. 

Home gardens and landscaping would be extremely vulnerable to off-target movements because of their proximity to the farming areas of the Midwest.  In an atmosphere of consumers worried about where their food comes from and worries of residues from all crop protectants in the food supply, damage caused by the off-target movement of dicamba would give all of agriculture a black-eye if home gardens or landscaping were damaged.

If the risks of off-target movement of dicamba due to volatization are low and can be effectively controlled through product stewardship and formulations, it only makes sense that those who will profit from the sale of this seed technology and the makers of dicamba should willingly step up to the plate and establish an indemnity fund to cover crop losses and homeowner’s claims for damages.  If they are unwilling to cover potential losses, is this an admission that the safety of this technology is not as safe as we would be led to believe?

The introduction of dicamba tolerant soybeans is a classic case of short-sighted enthusiasm over a new technology blinding us to the reality that is sure to come.  Increased dicamba usage, made possible through the introduction of dicamba tolerant soybeans, is poor public policy and should not be allowed.“

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Ten years later, what has been the outcome?

A lot of water has passed under the bridge since this testimony was given. The Save Our Crops Coalition filed for an Environmental Impact Study in 2012 that effectively delayed the introduction of the technology for nearly three years. Efforts within the EPA were made several times a year to directly express our concerns.

The SOCC reached an agreement with Dow AgroSciences that provided a pathway for the label language about the introduction of the Enlist system that ultimately was the foundation of the changes in label language for all the dicamba products. Foremost among those was the insistence that no application could be made with a sensitive crop downwind from the application site. While modifications to that language has been made through the later iterations of the language, that provision is still a key part of the label restrictions.

Testimony was given on multiple occasions to the Arkansas Plant Board to provide support and encouragement for the restrictions they would later place on the use of dicamba products. 

Direct appeal to the CEO of Monsanto to stop the madness went unheeded and the financial penalties they have suffered are immeasurable at this time because damage continues to occur each year. But it not only involves financial loss for Bayer (formerly Monsanto) but for the thousands of individual farmers who lost income with no compensation and for applicators and insurance providers who have paid millions of dollars in claims for crop losses through the years. And even more recently, much of the early work of the SOCC was used as a foundation for the successful suit and court decision last summer declaring that the registration of dicamba products was to be vacated. Even the initial individual lawsuit concerning the peach farmer in Missouri included SOCC information and direct testimony as a part of the 265 million dollar judgement.  Your support through the years have enabled all of this to occur.

Just this week, the head of the EPA was quoted as saying a new decision about the reregistration of dicamba products will be forthcoming soon. It seems like no matter the evidence, no matter the court decisions, no matter the damages and no matter the evidence that new resistance is already occurring to dicamba, the push continues and is likely to result in a new registration. As you read through the list of predictions, return to the thoughts of ten years ago and imagine the problems that could have and should have been avoided.  The rural acrimony resulting in fights and vandalism, violent shootings, the financial losses, the damage to rural homeowners (of which I was one) the damage to pollinator habitats, the financial cost to state regulatory agencies who have ceased almost all other operations to attend to the reports of crop injury are all the result of a misguided and shortsighted introduction of a technology even the company knew, through released court documents, would result in all of these events.

When the SOCC was started, it was my belief it would be a six month to a year endeavor because we would either win or would lose and life would go on. Being naïve about that thought process would be an understatement as we still find ourselves engaged in the discussions with EPA as recently as two weeks ago. Let’s all hope that there will not be a twenty year anniversary about this subject.

Thanks again for all your encouragement and guidance through these years. The new announcement will be in the news in a short time. Anyone want to be in the predicting business?

Steve Smith

Chairman, Save our Crops Coalition

Could the end really be in sight?  Yesterday, June 3^rd, the Ninth District Court vacated the 2018 Dicamba registration.  I’ve attached the full ruling, but here is an excerpt:

The EPA substantially understated three risks that it acknowledged. The EPA substantially understated the amount of DT seed acreage that had been planted in 2018, and, correspondingly, the amount of dicamba herbicide that had been sprayed on post-emergent crops. Further, the EPA purported to be agnostic as to whether formal complaints of dicamba damage under-reported or over reported the actual damage, when record evidence clearly showed that dicamba damage was substantially under-reported. Finally, the EPA refused to estimate the amount of dicamba damage, characterizing such damage as “potential” and “alleged,” when record evidence showed that dicamba had caused substantial and undisputed damage.

The EPA also entirely failed to acknowledge three other risks. The EPA entirely failed to acknowledge record evidence showing the high likelihood that restrictions on OTT [over the top] dicamba application imposed by the 2018 label would not be followed. The EPA based its registration decision on the premise that the label’s mitigation measures would limit off-field movement of OTT dicamba. These measures became increasingly restrictive with each iteration of OTT dicamba labels. Record evidence shows that the restrictions on the 2016 and 2017 labels had already been difficult if not impossible to follow for even conscientious users; the restrictions on the 2018 label are even more onerous. Further, the EPA entirely failed to acknowledge the substantial risk that the registrations would have anticompetitive economic effects in the soybean and cotton industries. Finally, the EPA entirely failed to acknowledge the risk that OTT dicamba use would tear the social fabric of farming communities.

We therefore vacate the EPA’s October 31, 2018, registration decision and the three registrations premised on that decision. [See the full ruling here]

The ramifications of this ruling will be widely felt in the soybean and cotton growing regions where I’m sure farmers have invested hundreds of thousands of dollars per farm on the higher priced seed and the chemical purchases and anger will be rampant.  But the focus of the anger needs to be put where it belongs…at the feet of the arrogance displayed by Monsanto in developing and releasing a technology that was known to be dangerous to susceptible plants and would move freely from the targeted spray points.  Documents are clear (as revealed in the Bader peach case in Missouri) that they KNEW the dangers and risks and yet progressed with the decision to release and promote the dicamba system. I am not a big fan of judicial activism, but the courts are there for a reason and this was a proper utilization.  Agriculture is better today than it was yesterday.

As I have expressed many times over in the past decade, one of the unintentional consequences of this entire event was the “black-eye of agriculture”.  When we cannot regulate ourselves to limit our farming systems to not damage non-target plants such as rural homeowner landscapes and natural wooded areas, we can expect others to do it for us and we have no one to blame for our situation than ourselves. The long reach of this ruling cannot be accurately predicted and will eventually go far beyond just the registration of dicamba.

On September 30, 2010 I gave this testimony before a Congressional Oversight Committee.  “Increased dicamba usage, made possible through the introduction of dicamba tolerant soybeans, is poor public policy and should not be allowed”. 

Ten years later, the court has agreed and we are all the better for the ruling.  Thanks for all your past support. No doubt there will be appeals and continued battles, but at least the initial skirmish is over.

Sincerely,

Steve Smith

Chairman, Save Our Crops Coalition

Steve Smith, Save Our Crops Coalition Chairman

One down…dozens more to go as the trials associated with dicamba are just beginning.

For those of you who have been watching and reading the news about the Missouri Peach case (here is a good piece by the Midwest Center for Investigative Reporting if you need a refresher), you know that the guilty verdict has reverberated around the dicamba world. 

Bader Farms in Southeastern Missouri is the largest peach orchard in the state. Owner/operator Bill Bader began to witness damage to his trees in the summer of 2015, which drastically worsened in 2016, the very time that dicamba tolerant cotton and dicamba tolerant soybeans were released for sale. 

The usage of dicamba in that area exploded in 2016, for lack of a better term, even though there was no legal product approved for use on those crops. Monsanto had received registration to sell their seed, the genetics were approved by the USDA, but the EPA had yet to approve any dicamba product for in-crop use.  With a wink/wink and a nod/nod, pink stickers were placed on the seed bags to remind everyone that there was no approval to spray any dicamba product during the season. 

It wouldn’t take much of an imagination to guess what happened with those warnings when glyphosate tolerant weeds were really hitting those fields (which by the way was a result of the Monsanto theory of using only glyphosate year after year, thereby selecting for resistant weed types). According to sales figures, the use of existing dicamba formulations increased dramatically as an indication that crops were being sprayed off-label and thus illegally.  (Note- see the extensive coverage of the Dicamba Drift crisis on Hygeia Analytics for more on how this all unfolded).

So much of that was happening, that the phenomenon known as “atmospheric loading” (more on that here) came to pass as highly treated areas had so much dicamba volatilizing from the fields that large areas were injured, and in this case, it included the peach orchard of Bill and Denise Bader.  Thousands of trees were affected and their lifelong dream of a profitable peach operation was in jeopardy.  As the acreage of dicamba tolerant crops increased and the use of in-crop applications were approved and applied, their trees continued to take in sub lethal doses of dicamba and their problems grew worse until viability of their farm was at risk. 

In 2016, the Baders filed a lawsuit as the only hope of saving their farm.  It was impossible to know from which fields the product originated so their only recourse was to claim that Monsanto (now owned by Bayer), originator and registrant of the tolerant seed and then the dicamba manufacturer from 2017 and on, and BASF, the dicamba manufacturer in 2015 and 2016, were responsible for collectively designing and implementing a system that had harmed their trees.  The wheels of justice move quite slowly but were finally put into motion on January 27, 2020 with the start of the trial that they hoped would give them another chance to realize their passions for being quality peach growers.

I had the distinct honor of participating in the trial as the lead-off witness. My job was to begin to lay the foundation of facts regarding the foreseeability of the problems that would follow if the course of dicamba tolerant crops continued and resulted in the widespread usage of dicamba. 

For those of you who have followed this journey through the years, you have witnessed the involvement of the Save Our Crops Coalition in this journey to protect sensitive crops.  The problems that were to come were not a surprise (we warned the EPA of them in 2013, and again in 2016), not to all of you who joined forces to help in the process, nor were they a surprise to Monsanto. 

In 2009, I was named as a member of the Monsanto Dicamba Advisory Council, a group of diverse stakeholders selected to advise Monsanto on the pitfalls or opportunities in releasing such a technology and to advise on how to make the system be successful.  As one of the few participants with specialty crops as a focus, it didn’t take long for me to determine that the pathway being embarked upon was flawed, but I was faithful in the mission of trying to warn, at every opportunity, about those flaws. 

In addition to the dialogue in the official meetings, I was privileged to present Congressional testimony in 2010 outlining the dangers I saw on the pathway ahead if dicamba usage became widespread.  It seems reasonable to recognize the historical accuracy of these two quotes as they are just as true today, ten years later, as they were at the time:

“I am convinced that in all of my years serving the agricultural industry, the widespread use of dicamba herbicide possesses the single most serious threat to the future of the specialty crop industry in the Midwest.”

“The widespread use of dicamba is incompatible with Midwestern agriculture. “

During the trial, I was asked to describe my time on the Dicamba Advisory Council and about my dismissal from that group.  My testimony made it clear that Monsanto was keenly aware of the dangers their new system would be placing upon sensitive plants.  Upon the founding of the Save Our Crops Coalition announced in 2012 and my subsequent removal from the advisory council, continued dialogue occurred where again I faithfully warned them about the problems that were bound to occur. In addition to the dialogue, the Save Our Crops Coalition filed several petitions with the EPA.

One of these petitions urged the EPA to establish an Environmental Impact statement, which was granted and effectively blocked the registration of dicamba products for in-crop use until the crop year of 2017.  All this evidence was important for laying the proper groundwork for the remaining part of the trial, which would last three weeks. My testimony helped establish the fact that Monsanto had been effectively warned of the upcoming problems with dicamba.

The evidence and further testimony of the trial was evidently so clear and convincing, that the jury resisted the defendant’s arguments that the damage sustained to the Bader’s peaches were from other sources and awarded actual damages of $15 million. The following morning, the jury then assessed punitive damages in the amount of $250 million.

One can ascribe many messages as to what this type of award was telling the defendants, but those probably don’t match the statement Bayer/Monsanto made following the verdict: “According to the U.S. Environmental Protection Agency, these tools do not pose any unreasonable risk when used according to their EPA-approved label.”  Hubris is alive and well in St. Louis.

So where does that leave us as we begin the 2020 cropping season?  Unfortunately, we’re in the same vulnerable position.  Dicamba tolerant crops will comprise the vast majority of all soybean acres in 2020 and dicamba will see increasing usage in corn since more and more acres of tolerant beans are safe from the effects of dicamba.  Several states have instituted some additional restrictions on application dates and temperature limitations. 

These will help but are only a small bandage for a gaping wound.  It is critical that all who remain concerned about the damages to sensitive plants remain engaged in working with your state regulatory agencies and in observing evidence of damage and continuing to report those instances.  If the regulatory agencies do not get reports, they will not continue to recognize the severity of the problems that the widespread use of dicamba places on all sensitive plants, including trees, rural landscapes, and pollinator habitats.

The USDA sanctions an advisory board for the Fruit and Vegetable industry.  As a member and chairperson of the Production Subcommittee, and with the cooperative input from others on the board, strong language was included in the recommendations about dicamba.  These recommendations were just released today, February 21, 2020.  You can find those recommendations at this link by scrolling down to the section by the Production Subcommittee, which starts at the bottom of page 3.

I am confident you will find them helpful as we continue to work towards the safety of all sensitive plants and crops.

The Save Our Crops website is still available with historic resources:  www.saveourcrops.org.  We invite you to continue your participation in the theaters that are most available to you.  We will continue to personally dialogue with the EPA and USDA in regards to the regulatory process that is once again up for renewal in 2020.  Maybe all the deniers of dicamba problems will finally recognize that the “emperor is wearing no clothes” when it comes to the problems of widespread use of dicamba so that effective changes can be made to protect sensitive plants.

Thank you for all your past and continued support.

Steve Smith

Chairman, Save Our Crops Coalition

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

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

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

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

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.

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

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