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EDITORIAL: New Toxins and GMOs Headed Our Way

New Toxins and New GMOs Headed Our Way:

The Next Roundup for the GMO Corral


A new poison may soon be coming to an ecosystem near you.  This is Dow Chemical’s Enlist Duo, a close relative to Monsanto’s aggressively marketed and wildly popular Roundup.  Dow’s powerful herbicide is on the fast track to approval by the Environmental Protection Agency (EPA).[1]

Should Enlist Duo be approved, it will permit the use of yet another powerful plant toxin, and allow the introduction of a new wave of GM food crops.  In short: (1) more poisons in ecosystems and food crops, and (2) more Genetically Modified (GM) produce entering the food chain.

It is rather remarkable and somewhat troubling that the EPA has allowed only a thirty-day window for public comment on its review of the key compound in Dow’s chemical, a substance called “2,4-D Choline salt Herbicide.”  The window closes on May 30, 2014.  Please read the section below about making your comments to the EPA.

We encourage anyone committed to a healthy natural environment to offer a comment before the May 30 deadline.  We especially encourage larger environmental, health, and cultural organizations to motivate memberships to send comments to the EPA.  Sustainable farmers, community garden groups, food co-ops, organic restaurants and markets should all be mobilizing folks to oppose approval of this herbicide, which (we note) is designed for initial use on GM corn and soybean crops.  You can send comments to the EPA here.

GMO -- How it used to be

Analysis and Commentary

The challenge as we see it is not just the toxins in Enlist Duo (which is a major concern), but the related challenge of yet another wave of GM crops being released into our shared environment.  Remember, soy or corn derivatives are found in nearly all processed food, and most soy and corn is already genetically modified.[2] Remember also, the Food and Drug Administration does not require food producers to inform consumers of the presence of GM products in their commodities. Thus, by approving Enlist Duo, the EPA doubles our risks – allowing more herbicides in our ecosystems, our food, and potentially our bodies, and more GM organisms in those same places.  Just as there is no GM label on canned and packaged food, we can assure you that there will be no Enlist Duo label on those products, either.

As of Tuesday afternoon (May 13) the EPA had received only 356 comments regarding their assessment of Enlist Duo.  We suspect that if more people knew about the review process, and the contents of Enlist Duo, there would be far more than 356 responses.  Obviously, it is in the interest of Dow (and any other broad-spectrum plant poison manufacturer) to have a short public review period for the proposed EPA decision to register Enlist Duo.  The EPA has done the American public no favors by allowing only 30 days for public comment.

Besides the innocuously titled “2,4-D Choline salt Herbicide,” Enlist Duo also contains the powerful herbicide, glyphosate –  the same plant-killing toxin found in Monsanto’s Roundup.

In requesting a 90-day extension of the public comment period, George Kimbrell and Bill Freese of the Center for Food Safety remind us that the intent of the new “2,4-D Choline salt Herbicide” is directly related to yet another wave of Genetically Engineered (GE) plants.

2,4-D-resistant crops are among the first of many “next-generation” GE crops engineered for resistance to multiple and more toxic herbicides. As such, they raise numerous, in part novel, human health, environmental and agronomic concerns associated with sharply increased use of and farmer dependence on the linked herbicides. EPA itself acknowledges that: “This is an issue of high public interest and concern so the Agency feels it is important to get feedback from stakeholders before a final decision is reached.”[3]

Like the GM crops developed for use with Roundup (the familiar “Roundup Ready” plants), we can expect to soon find “Enlist Duo Ready”plants in farms and fields around the world – and soon enough the toxin and its “ready” GM plants in every hardware store and garden center in America.

As we see it, these new toxins present a dual concern for public health and environmental sustainability.  First, they introduce harmful herbicides into the environment to kill undesirable vegetation (weeds); but the chief purpose of these plant toxins appears compromised by the resulting proliferation of new “super weeds,” immune to the herbicide.[1]  In short, Roundup Resistant weeds are now getting the better of the Roundup Ready crops.

combine in the field

So, according to the logic of Industrial Agriculture, a more powerful, more toxic herbicide needs to be developed – in this case, Enlist Duo. It will only be a matter of time until there are super weeds immune to Enlist Duo. This will be followed by yet more powerful herbicides, then more resistant vegetation, then even stronger toxins – and so on.  This is neither a natural nor a safe approach to food production.

Like Monsanto before it, Dow will not win in its chemical struggle with Mother Nature.  The big losers, however, will be consumers, ecosystems exposed to the toxins, and, of course, anyone interested in the restoring natural and cultural ecologies. This is the substance of the first concern.

The second concern is somewhat obscured by the first, but it may actually more significant. Beneath the immediate and very obvious challenges posed by this next generation of super-toxins, is the hidden danger of yet another wave of GM plants – and food crops at that.

Enlist Duo is not just a weed killer for unwanted vegetation in your driveway or patio, although it will surely be used there soon enough. The residential retail version most likely will be developed and marketed (just as with Roundup) through massive advertising campaigns, and persuasive commercials appealing to Americans with money to spend on the curb appeal of their private property.

Retail deployment is a concern all its own, but that is a bit further out.  It is in the primary initial deployment of Enlist Duo as an agricultural poison that lurks the second concern.  Here’s why: For Enlist Duo to work properly, it needs to be applied in an industrial agricultural environment where only crops immune to the Enlist Duo poison are being grown.  This is where the second concern suddenly appears at least as (if not more) significant than the first; because the only way to create crops immune to this powerful herbicide is through (you guessed it!) genetic modification.  So, now we are faced with the undesirable and unhealthy situation of having food crops that are (1) unnatural to start with, (2) doused with herbicides designed to kill all forms of vegetation (except them), and then (3) prepared for human consumption in packaging bearing no public information about their synthetic origins and toxic history.

Action is called for and action is urged.

Here is an excerpt from one of the comments sent to the EPA:

As the manager of a small farm and nursery, I strongly oppose granting approval for the use of 2,4-D Choline salt Herbicide.  There are clearly significant problems with other herbicides of this type (e.g., Monsanto’s Roundup), not the least of which is the proliferation of new “super” weeds immune to the toxin, glyphosate. More fundamentally, the use of glyphosate, together with other toxins (such as 2,4 D Choline) will likely be detrimental to human health and life, and will definitely have an adverse impact on any ecosystem into which it is released.  In short, we do not need another dangerous toxin added to our food-production system, and another poison designed to function properly only when used with genetically modified plants. For the good of American consumers and our shared natural environment, please do not approve 2,4-D Choline salt Herbicide, marketed by the Dow Chemical Company as “Enlist Duo.”

We encourage our readers to share their thoughts on this topic with the EPA. Action is called for and action is urged.  Please let others know about this issue. By the time this is published, there will be less than twenty days left for comments. You can leave a comment here.


Additional Sources

[1] For related article, with a number of embedded references, see Nation of Change: “EPA to Give Green Light to Dow’s Latest Toxic Herbicide, ‘Enlist Duo.’”

[2] For related article, with data on GMO (GE) percentages in the food supply and various specific food products, see The Local Grocer: “Are You Eating GMOs.”

[3] For comment submitted to EPA on “2,4-D Choline salt Herbicide” by George Kimbrell and Bill Freese, Center for Food Safety, see

For related article, on recent findings on toxins in Roundup, see Natural Society: “Monsanto’s RoundUp Poison 125 Times More Dangerous than Regulators Admit.”

For related article, on relationship of Roundup to Enlist Duo, see Mother Jones: “Dow and Monsanto Team Up on the Mother of All Herbicide Marketing Plans.”


4 responses to “EDITORIAL: New Toxins and GMOs Headed Our Way”

  1. Ken Dovel Avatar
    Ken Dovel

    I am a 54 year old resident of the state of Florida. Recently I have been told by my doctor of the benefits of naturally grown fruits and vegetables. Could they by making that suggestion have been hinting as to the ill effects of food grown with the use of herbicides and pesticides? I would imagine so. I don’t think we need any more chemicals in or on our food. If My opinion matters at all I vote no as to the introduction of yet another harmful substance to our food supply.

  2. […] pesticide.  We have previously drawn attention to dangerous chemicals produced by Dow,[1] and the approval of Sulfoxaflor appears to be one more instance of the EPA supporting the corporate […]

  3. […] pesticide.  We have previously drawn attention to dangerous chemicals produced by Dow,[1] and the approval of Sulfoxaflor appears to be one more instance of the EPA supporting the corporate […]

  4. […] pesticide.  We have previously drawn attention to dangerous chemicals produced by Dow,[1] and the approval of Sulfoxaflor appears to be one more instance of the EPA supporting the corporate […]

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