eu version - superweeds: how biotech crops bolster the pesticide industry

8/22/2019 EU Version - Superweeds: How Biotech Crops Bolster the Pesticide Industry

1/19


2/19

About Food & Water Europe

Food & Water Europe is the European program

RI)RRG:DWHU:DWFKDQRQSURWFRQVXPHU

organization based in the United States that works to

HQVXUHWKHIRRGZDWHUDQGVKZHFRQVXPHLVVDIH

accessible and sustainable. So we can all enjoy and

trust in what we eat and drink, we help people take

charge of where their food comes from, keep clean,

DRUGDEOHSXEOLFWDSZDWHURZLQJIUHHO\WRRXU

homes, protect the environmental quality of oceans,

force government to do its job protecting citizens,

and educate about the importance of keeping shared

resources under public control.

Food & Water Europe

Rue dEdimbourg, 26

1050 Bruxelles

Belgium

[email protected]

www.foodandwatereurope.org

Copyright July 2013 by Food & Water Europe.

All rights reserved.

This report can be viewed or downloaded at

www.foodandwatereurope.org.

VER PHOTOS: (TOP LEFT) PALMER AMARANTH IN COTTON FIELD. PHOTO CC-BY-NC JOSEPH L AFOREST, UNIVERSITY OF GEORGIA / BUGWOOD.ORG;OTTOM RIGHT) MARESTAIL PHOTO CC-SA-BY F.D. RICHARDS / FLICKR.COM


3/19

Execuive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Inroducion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Spread o Weed Resisance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Wha he Daa Show: Herbicide-Toleran Crops Increase Herbicide Use. . . . . . . . . . . 6

Agrichemical Trends. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

The Weed Managemen Pipeline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Coss Associaed wih GE Crops and Herbicide-Resisan Weeds . . . . . . . . . . . . . . 9

Farmer Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Human Health Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Conclusion and Recommendaions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Appendix A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Endnoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14


4/19

2 Food & Water Europe foodandwatereurope.org

Geneically engineered (GE) crops usually called

geneically modiied (GM) ouside he U.S. were

irs approved in he Unied Saes in he 1990s, and

since hen he Unied Saes has been he bigges global

adoper o his echnology. GE crops were supposed

o improve yields, lower coss or armers and reduce

agriculures environmenal impac. Ye nearly 20 yearsafer heir inroducion, geneically engineered crops

have no provided he beneis promised by he compa-

nies ha paened hem.

Food & Waer Wach examined U.S. Deparmen o

Agriculure (USDA) and U.S. Environmenal Proecion

Agency (EPA) daa o documen he increased use

o herbicides ha has accompanied he adopion o

herbicide-oleran GE crops. Our analysis looks a he

rapid prolieraion o GE crops and ailiaed pesicides

in he Unied Saes and poins ou he inerdependenrelaionship beween hese wo indusries ha also

uels he crisis o weed resisance. Food & Waer Wach

evaluaed daa rom he Inernaional Survey o Herbi-

cide Resisan Weeds ha reveal burgeoning herbi-

cide-resisan weeds caused by he over-reliance on

glyphosae or broad conrol o weeds. These daa make

i clear ha he problem o herbicide-resisan weeds

will no be solved wih he inensiied use o older, more

oxic herbicides like 2,4-D and dicamba.

Some o Food & Waer Wachs indings include:

Herbicide use on corn, soybeans and coton did all

in he early years o GE crop adopion, dropping by

42 million pounds (15 percen) beween 1998 and

2001. Bu as weeds developed resisance o glypho-

sae, armers applied more herbicides, and oal

herbicide use increased by 81.2 million pounds (26

percen) beween 2001 and 2010.

The oal volume o glyphosae applied o he hree

bigges GE crops corn, coton and soybeans

increased 10-old rom 15 million pounds in 1996 o159 million pounds in 2012.

Toal 2,4-D use declined afer glyphosae was widely

adoped, bu is use has increased since glypho-

sae-resisan crops became widespread, growing 90

percen beween 2000 and 2012. 2,4-D applicaion

on corn could easily increase by nearly hree-ifhs

wihin wo years o 2,4-D-oleran corns inroduc-

ion. And i jus a million dicamba-oleran soybean

acres are planed, i would increase dicamba use 17

imes.

Repors o weeds developing glyphosae resisance

are popping up in more and more saes. In 2008,

glyphosae-resisan waerhemp was repored in

ive saes, bu by 2012 i was repored in 12 saes.

Glyphosae-resisan Palmer amaranh was repored

in eigh saes in 2008 bu 17 by 2012. Resisan

horseweed spread rom 12 saes in 2004 o 21 in

2012.

The Inernaional Survey o Herbicide Resisan

Weeds ound only abou one weed inesaionper year ha was resisan o muliple herbicides

beween 1997 and 2001, bu a decade afer GE

crops were inroduced (2007 o 2011), here were

hree imes as many muliple herbicide-resisan

weed inesaions.

Herbicide-resisan weeds coss o armers can

range rom $12 o $50 an acre, or as much as

$12,000 or an average-sized corn or soybean arm

or $28,000 or an average coton arm.

More bioech indusry-led soluions will only perpe-uae agriculures reliance on chemicals as he end-all-

be-all soluion o weed and insec managemen. Bu

his approach drives he rise o superweeds, poses risks

o human healh and hreaens criical habia or wild-

lie in he process. Food & Waer Wach recommends

ha:

The USDA, EPA and Food and Drug Adminisraion

(FDA) mus work ogeher o horoughly evaluae

he poenially harmul eecs o GE crops and

linked chemicals beore commercializaion, oensure he saey o humans and he environmen.

The USDA should suppor and encourage culiva-

ion bes managemen pracices o preven weed

resisance in he irs place.

The USDA should educae and encourage armers

o adop non-chemical sraegies or long-erm

weed conrol. The USDA mus dedicae research

dollars o developing alernaives or susainable

managemen o herbicide-resisan weeds.

The U.S. governmen mus improve he collecionand disribuion o weed resisance and agriculural

pesicide applicaion daa.

Executive Summary


5/19

Superweeds How Biotech Crops Bolster the Pesticide Industry 3

IntroductionSince he developmen o he chemical indusry afer

World War II, agriculure has become increasingly

relian on herbicides and insecicides ogeher

reerred o as pesicides o conrol weeds and pess.

Farmers have always batled voracious insecs and

weeds ha crowd cropland, and he chemical indusry

promised almos miraculously eecive and labor-saving soluions.

Farmers quickly adoped he new ools, bu he chemicals

ha killed weeds and insecs also posed risks o he

environmen and armworkers and can leave dangerous

residues on ood. Hal o he 877 million pounds o

pesicides used in agriculure are herbicides designed o

kill weeds.1

In he 1970s, he Unied Saes began o ban or phase

ou some o he mos damaging pesicides, like DDT.

Bu many harmul pesicides remain in widespread use.In he 1990s, chemical and seed companies developed

geneically engineered herbicide-oleran crops. These

crops could wihsand being sprayed wih herbicides

ha killed weeds. The mos common herbicide-oleran

GE crops were designed o be used wih Monsanos

herbicide Roundup (known generically as glyphosae).

Monsano promoed Roundup Ready crops as a way o

use a saer and more eecive pesicide ha could reduce

oal pesicide use. Theoreically, armers would make

ewer applicaions wihou resoring o more dangerouspesicides and could reduce he amoun o illage used o

comba weeds on heir arms. Farmers rapidly adoped

Roundup Ready crops (primarily corn, soybeans and

coton).

Bu as weeds became almos universally reaed wih

Roundup, hey evolved a resisance o he pesicide.

Today, some o he mos pervasive and damaging

weeds can wihsand Roundup. As more resilien weeds

have invaded more arm ields and suppressed crop

yields, armers have revered o applying more and

more dangerous pesicides ha Roundup Ready crops

were supposed o le hem avoid.

The GE seed companies have a simple soluion o

Roundup-resisan weeds: inroduce new GE crops ha

are oleran o dieren pesicides. Already he chem-

ical and GE seed companies are esing varieies ha

can wihsand more dangerous pesicides, including

dicamba, 2,4-D and isoxaluole.

The bigges beneiciary rom he weed resisance

epidemic is he crop proecion indusry, including

seed and chemical companies. The global crop proec-

ion marke has ripled rom $26 billion in 2001 o awhopping $64 billion in 2012.2 Herbicides alone accoun

or abou hal o hese sales. 3 The global GE seed

marke has skyrockeed rom $115 million in sales since

is incepion in 1996 o $15 billion in 2012 a 130-old

increase.4 (See Figure 1.)

Monsano he larges bioechnology seed company

in he world in 2011 has generaed seady earnings,

despie is role in creaing he glyphosae-resisan

weed siuaion.5 Monsanos ocus has shifed rom

chemicals o paened seeds, and since 2000, is seedsales have gone up sixold rom $1.6 billion o $9.8

billion in 2012.6

The cycle o herbicide-oleran GE crops has spawned

an agrochemical readmill. Widespread applicaion

SOURCE: Food & Water Watch analysis of CropLife International Annual Reports 2002-2006 and the International Service for the Acquisition of Agri-biotech Applications (ISAAA) Annual Reports

2007-2012.

Figure 1.Global Revenue from Sales of GE Seeds(IN $ BILLION)

1996 1998 2000 2002 2004 2006 2008 2010 2012

$15

$12

$9

$6

$3

$0.1$0.8

$2.0$2.7 $2.7 $3.0

$3.3$3.9

$4.7$5.3

$6.2$6.9

$7.5

$10.5$11.2 $11.2

$14.8


6/19


o Roundup creaes Roundup-resisan weeds ha

encourage armers o increase he applicaion o more

dangerous herbicides and creae incenives or seed

companies o inroduce crops ha are oleran o hese

even more powerul and risky chemicals. Raher han

reducing oal pesicide use, he GE crops have jus

acceleraed he agrochemical arms race, insigaed he

rise o superweeds and hreaened criical habia or

wildlie and public healh.

Spread of Weed ResistanceHerbicides irs became widely available commercially

during he 1950s.7 So ar, chemical companies have

inroduced 21 dieren ypes o herbicide amilies

ha ac hrough dieren mechanisms. 8 Bu he mos

signiican developmen or armers was he approval

o glyphosae in 1976.9 Monsanos Roundup, he brand

name or glyphosae, is a powerul herbicide ha kills a

wide range o plans by inhibiing an enzyme pahwaynecessary or he plans o produce proeins required

or survival.10

Since Roundup Ready crops were inroduced, glypho-

sae has been used more as a pos-emergen herbicide,

sprayed ono weeds afer hey sprou. Because armers

apply Roundup o growing crops o kill emerging weeds,

he weeds ge larger and more diicul o kill beore

hey are sprayed. Inesing weeds can reach sexual

mauriy, and hose ha are herbicide-resisan deposi

heir seeds, propagaing he evoluion o more herbi-cide-resisan weeds.11 The pos-emergen applicaion o

glyphosae, he limied or non-exisen illage used wih

he glyphosae sysem and he ac ha some armers

culivae he same glyphosae-oleran crop or years

a a ime (in one case, as many as 14 years) creaes

he perec scenario or glyphosae-resisan weeds o

hrive.12

In he 1990s, Monsano inroduced geneically engi-

neered crops ha could survive being sprayed by

glyphosae, known as Roundup Ready crops.13 Farmers

were drawn o he ease and versailiy o glyphosae or

weed conrol, and Roundup Ready crops were adoped

a hisoric raes during he 1990s.14 Farmers radiionally

combaed weeds and insecs by roaing heir crops and

varying he pesicides hey used. Because glyphosaewas so eecive, many armers solely planed glypho-

sae-resisan crops and applied glyphosae season

afer season.15 Herbicide-oleran corn and soybean

culivaion increased 100 percen rom abou 45 million

acres in 2000 o 90 million acres in 2012.16 Today, almos

all corn, soybean and coton ields are sprayed wih

glyphosae (76, 96 and 99 percen, respecively; see

Figure 2).17

Ubiquious Roundup applicaion has spawned glypho-

sae-resisan weeds, driving armers o apply more-oxic herbicides and o reduce conservaion illing,

according o a 2010 Naional Research Council repor.18

There are 14 weed species resisan o glyphosae in he

Unied Saes (24 species worldwide), including aggres-

sive weeds like ragweed, horseweed, kochia, Palmer

amaranh and waerhemp.19 The wo mos pervasive

glyphosae-resisan weeds are maresail (horseweed)

and Palmer amaranh (pigweed).20

The indusry currenly esimaes ha 61.2 million acres

o cropland now are inesed wih weeds resisan oglyphosae.21 More han a quarer (27 percen) o U.S.

armers repored more han one species o glypho-

sae-resisan weeds in heir ields in 2012, almos

Figure 2.Percentage of U.S. AcresSprayed With Glyphosate

100%

80%

60%

40%

20%

1990 1995 2000 2005 2010

MARESTAIL PHOTO CC-SA-BY F.D. RICHARDS / FLICKR.COM

RoundupReady crops

introduced

Soybeans Cotton Corn

SOURCE: USDA-NASS Quickstats: Survey, Environmental, Corn, Cotton, Soybean, Application,

Percent Area Planted (Average) (Glyphosate).


7/19


wice as many as in 2011.22 Glyphosae-resisan weeds

ollowed he pah o GE crop adopion. (See Figure 3.)

The irs regions ha adoped Roundup Ready crops

saw he earlies oubreaks o herbicide-resisan weeds.23

Glyphosae-resisan weeds originaed in he Souh and

spread hroughou he bigges U.S. corn and soybean

regions.24 In 2012, a saggering 92 percen o surveyed

Georgia armers repored having glyphosae-resisanweeds.25 In he Midwes, where GE corn and soy

dominae agriculural producion, he weed problem

coninues o worsen. In 2012 in Illinois, wo ou o ive

armers (43 percen) had glyphosae-resisan weeds.26

Food & Waer Wach compared he number o herbi-

cide-resisan weed inesaions beore and afer GE

herbicide-oleran crops were inroduced using daa

rom he Inernaional Survey o Herbicide Resisan

Weeds.27 The weed scienis survey repors herbicide-re-

sisan weed inesaions in a publicly available daa-base.28The volunary inesaion repors in he survey

represen a conservaive esimae, bu he rise in he

small number o repors illuminaes he rapid expansion

o herbicide-resisan weed oubreaks. In 2008, glypho-

sae-resisan waerhemp was repored in ive saes,

bu by 2012 i was in 12 saes. Glyphosae-resisan

Palmer amaranh was repored in eigh saes in 2008

bu 17 by 2012. Resisan horseweed spread rom 12

saes in 2004 o 21 in 2012. (See Figure 4 below and

Appendix A on page 13 or he spread o glyphosae-re-

sisan waerhemp, Palmer amaranh and ragweed.)

Growing weed resisance has increased he oal volume

o pesicides applied o U.S. arms. A Washingon Sae

Universiy sudy by long-ime GE crop and herbicide

researcher Dr. Charles Benbrook ound ha herbicide

use has acually increased by 527 million pounds since

he inroducion o GE crops in 1996, and will only

coninue o rise wih he inroducion o new herbi-

cide-oleran crops.29 A Penn Sae Universiy weed

scienis prediced ha eors o conrol newly resisan

weeds could increase pesicide use 70 percen by 2015. 30

As mixures o herbicides are used on crops, some

weeds are developing muliple resisance meaning

ha hey can survive being sprayed wih wo or

Figure 4.Number of States ReportingGlyphosate-resistant Horseweed in Fields (BYYEAR)

SOURCE: Heap, I. The International Survey of Herbicide Resistant Weeds. Available at www.weedscience.com. Accessed March 18, 2013.

Figure 3.Planted GE Acres and Glyphosate-Resistant Weeds

2000 2002 2004 2006 2008 2010 2012

100,000,000

80,000,000

60,000,000

40,000,000

20,000,000

2000:

Rigid Ryegrass

Horseweed

2004:

Giant Ragweed

Common

Ragweed Italian Ryegrass

2008:

Waterhemp

Palmer Amaranth

Hairy Fleabane

Johnsongrass

Kochia

Junglerice

2012:

Annual Bluegrass

Goosegrass

SOURCE: USDA NASS. Quickstats. Agricultural Survey. Planted Acres (Corn, Cotton, Soybean ); USDA ERS Data Set for Genetically engineered varieties of corn, upland cotton and soybeans in the

United States 2000-2012; Heap, Ian. The International Survey of Herbicide Resistant Weeds. Available at www.weedscience.org/Account/AboutUs.aspx. Accessed April 29, 2013.

Soybeans Cotton Corn


8/19


more herbicides.31 Nearly wo-hirds o weeds wih

glyphosae resisance will develop resisance o oher

herbicides. 32 Prior o he inroducion o Roundup Ready

crops (19911995), he Inernaional Survey o Herbicide

Resisan Weeds ound only abou one weed inesaion

per year (1.2 repors) ha was resisan o muliple

herbicides. A decade afer he GE crops were inroduced

(20072011), he survey ound almos hree imes as

many muliple herbicide-resisan weed inesaions

(3.25 repors annually). Some o he irs saes o

begin o see muliple resisances were Michigan, Ohio

and Illinois all among he irs adopers o GE corn

and soybeans.33 Academic expers expec muliple

resisances in weeds o occur more requenly as he

USDA approves crops engineered o olerae dieren

herbicides. 34

What the Data Show:

Herbicide-Tolerant CropsIncrease Herbicide UseFood & Waer Wach examined he USDA and EPA

herbicide daa and ound ha herbicide use has grown

seadily since he inroducion o GE crops. This anal-

ysis elaboraes on Dr. Benbrooks research by ocusing

on oher herbicides ha will be used in he GE herbi-

cide-oleran crop pipeline and projecing he increased

use under he anicipaed culivaion i he USDA

approves he crops.

Food & Waer Wachs indings conradic he rosyprojecions o he bioech seed companies ha GE

herbicide-oleran crops reduce pesicide use. In 2005,

a represenaive o he Bioechnology Indusry Orga-

nizaion esiied beore a sae legislaure,Bioech-nology-derived crops have conribued o a subsanial

reducion in pesicide volumes used in producion

agriculure.35 Herbicide use on corn, soybeans and

coton did all in he early years o GE crop adopion,

dropping by 42 million pounds (15 percen) beween

1998 and 2001.

36

Buas weeds developed resisanceo glyphosae, armers applied more herbicides. Toal

herbicide use increased by 81.2 million pounds (26

percen) beween 2001 and 2010.37 (See Figure 5.)

Alhough glyphosae represens hal o all herbicides

used on corn, soybean and coton ields, he coninued

growh o oal herbicide use suggess ha glyphosae

is no longer as eecive as i was when i was inro-

duced because o increasing weed resisance.

Agrichemical TrendsAtrazine: Arazine was he mos widely used herbi-

cide on agriculural crops rom 1987 o 1997, unil

glyphosae volume surpassed arazine volume afer he

inroducion o Roundup Ready crops.38 This chemical

is a known endocrine disruper and a very pervasive

polluan in surace and ground waer. 39 In he 1970s,

some o he irs herbicide-oleran weeds were resis-

an o he riazine amily o herbicides, a group ha

includes arazine.40 Ye, insead o changing he para-

digm or weed conrol, he chemical indusry jus added

a new chemical.

Alhough glyphosae has been sprayed on he majoriy

o corn, coton and soybean acres, he shif o glypho-

sae has no reduced arazine use. The percenage o

corn acres sill reaed wih arazine has remained

sable.41 The chemical cycle has now urned ull circle,

and arazine is being suggesed as a supplemen o

conrol glyphosae-resisan weeds, which could cause

a resurgence o arazine use and subsequen waer

conaminaion.42

Glyphosate (Roundup): The noion o glyphosaesinvincibiliy, is widespread adopion and he way i

was applied o ields have aciliaed he evoluion

o resisan weeds.43 The oal volume o glyphosae

applied o he hree bigges GE crops corn, coton

and soybeans increased 10-old rom 15 million

pounds in 1996 o 159 million pounds in2012.44 (See

Figure 6.) Farmers are now resoring o more requen

glyphosae applicaions o cope wih herbicide-resisan

weeds. In 1996, armers ypically applied glyphosae

o heir corn and coton ields once a season, bu by

Figure 5.Total Herbicide Volume Appliedto Corn, Cotton, Soybeans(MILLIONSOFLBSPERYEAR)

350M

300M

250M

200M1994 1998 2002 2006 2010

240,474,000

309,954,000

SOURCE: USDA-NASS. Quickstats. Agricultural Survey, Chemical Applications, Herbicide Use on

Corn, Cotton and Soybeans (Total).


9/19


2010, hal o coton armers applied Roundup wice

each season.45 This happened aser in soybean ields,

where hal o armers made wo Roundup applicaions

a season by 2006 (he laes available daa). Despie

he role played by overuse o Roundup in acceleraing

he chemical readmill, Monsanos Roundup Ready

manager sill considers Roundup he companys amily

jewel.46

2,4-D and Dicamba: The herbicides dicamba and

2,4-D belong o he synheic auxins amily o herbi-

cides, known or heir negaive impacs on arge and

nonarge plan developmen, causing abnormal growh

and deah.47 Since dicamba and 2,4-D are especially

prone o drif, any specialy crops like omaoes,

grapes and poaoes ha are grown near ields

sprayed wih hese herbicides could be damaged by he

herbicide, causing yield losses.48

A 2004 sudy modeled ha 2,4-D and dicamba had 400imes and 75 imes he risk o impacing non-arge

plans, relaive o glyphosae.49 In 2010, an Indiana armer

esiied a a Congressional hearing ha dicamba drif

desroyed over 20 acres o his omaoes.50 An Associaion

o American Pesicide Conrol Oicials survey rom

2002 o 2004 ound ha 2,4-D was he herbicide mos

commonly involved in drif occurrences.51 Alhough Dow

claims ha is new, pricier ormulaion o 2,4-D (designed

or 2,4-D-oleran GE crops) is less prone o drif, many

armers will likely coninue o use he cheaper generic

2,4-D.52

Toal 2,4-D use declined afer glyphosae was widely

adoped, bu is use has increased since glyphosae-re-

sisan crops became widespread, growing 90 percen

(3.9 million pounds) beween 2000 and 2012.53 (See

Figure 7.) Dicamba use slowed down seadily since

1994, bu his decline would rapidly reverse i he USDA

approves dicamba-oleran soybeans.54 The approval o

eiher GE crop ha is engineered o work wih hese

drif-prone herbicides could seriously hreaen nearby

specialy crop growers and any plans and animals

ha are exposed o higher concenraions o hese

dangerous chemicals. Seve Smih, Agriculure Direcor

or Red Gold he larges privaely held U.S. canned

omao processing company sresses ha he wide-

spread use o dicamba herbicide possesses he single

mos serious hrea o he uure o he specialy crop

[rui and vegeable] indusry in he Midwes.55

For every 1 million acres o dicamba-oleran soybeans

planed, here could be an addiional 2 million poundso dicamba applied o crops.56 Even i jus a million

dicamba-oleran soybean acres are planed, ha

would be 17 imes he curren dicamba volume used on

soybeans.57 And i 2,4-D corn were adoped as quickly

as Roundup Ready corn (abou 1 million acres a year

beween 1997 and 2001),58 2,4-D applicaion on corn

could easily increase by nearly hree-ifhs rom 3.5

million pounds o 5.5 million pounds wihin wo years

o 2,4-D-oleran corns inroducion.59

Figure 6.Total Glyphosate Applicationson Corn, Cotton, Soybeans(INMILLIONLBS)

200M

150M

100M

50M

01994 1997 2000 2003 2006 2009 2012

7.4

158.9

SOURCE: Food & Water Watch Analysis of USDA NASS. Quickstats. Agricultural Survey,

Chemical Applications, Glyphosate active ingredient (lbs/year), Number of

Applications per year, Avg. lbs. per application per year.*

*Figures 6 and 7: Missing values were estimated using figures from the closest year of data.

Figure 7.Total 2,4-D Applications onCorn, Cotton, Soybeans(INMILLIONLBS)

10M

8M

6M

4M

2M

01994 1997 2000 2003 2006 2009 2012

7.08.1

SOURCE: Food & Water Watch Analysis of USDA NASS. Quickstats. Agricultural Survey,

Chemical Applications, 2,4-D active ingredient (lbs/year), Number of Applications

per year, Avg. lbs. per application per year.*

4.2


10/19


Gluosinate (Liberty): Gluosinae, he ailiaed

herbicide o Bayers LiberyLink brand o GE corn, coton

and soybeans, has no been used very widely or weed

conrol.60 In 2010, i was sprayed on jus 2 percen o corn

and 7 percen o coton acres, bu is use doubled rom

525,000 pounds in 2000 o 1 million pounds in 2012.61

Gluosinae applicaions will only increase urher i he

USDA approves any o he ive gluosinae-oleran crops

currenly in he pipeline o igh pigweed. 62 Beween

2009 and 2011, gluosinae pounds applied per acre

increased sevenold.63 I armers adop a million acres

o gluosinae-oleran corn, soy and coton per year

(as hey did wih Roundup Ready crops), gluosinae

use could rise ourold o 6.5 million pounds in jus

wo years.64 Currenly, ryegrass is he only weed ha

has developed gluosinae resisance,65 bu more weeds

would likely develop resisance i gluosinae use became

more widespread.

Isoxalutole: Bayer has also sough USDA approvalor corn wih sacked olerance o isoxaluole and

glyphosae-oleran soybeans.66 Already, he volume o

isoxaluole applied o corn has almos doubled since

1999.67 Isoxaluole is a resriced-use herbicide ha can

only be applied o a corn ield beore planing; is use is

discouraged afer crops and weeds are already growing

because i is oxic o some plans even a low levels.68

The increased use o his herbicide sprayed on GE crops

able o wihsand is applicaion posemergence could

increase he risk o harming non-arge plans.69

The Weed Management PipelineAlhough herbicide-resisan weeds emerged rom

he near-universal applicaion o glyphosae on U.S.

arm ields, bioechnology companies are developing

new GE crops, resisan o dieren combinaions o

more-oxic chemicals, including 2,4-D (an Agen Orange

componen) and dicamba.84 The GE seed companies

are rushing o peiion he USDA or promp approval

o new and conroversial varieies. Currenly, nearly

wo-hirds o he GE crops in he pipeline awaiing

USDA approval (13 o 20 varieies) are resisan o new

herbicide mixes, including 2,4-D-oleran corn andsoybeans, dicamba-oleran coton and soybeans, and

glyphosae and isoxaluole-oleran soybeans.85

The USDA is acceleraing is approval process or

GE crops even as he seed companies hurry he new,

:HHGV:RUVW2HQGHUV

Horseweed (Marestail): Horseweed, also known

DVPDUHVWDLOZDVRQHRIWKHUVWZHHGVIRXQGWREH

resistant to glyphosate.

70

In 2012, 21 states reportedhorseweed with glyphosate resistance.71 It is a hardy

weed, thriving even under stressful conditions, and can

produce up to 200,000 seeds per plant.72 Horseweed

in a no-till scenario has been found to reduce soybean

yield by more than 80 percent.73 By 2013, the majority

of horseweed in Alabama appeared to be glypho-

sate-resistant.74 Horseweed is especially problematic in

5RXQGXS5HDG\DOIDOIDHOGVEHFDXVHJO\SKRVDWHUHVLV-

tant horseweed not only can outcompete crops for light

DQGQXWULHQWVEXWLWDOVRLWDWWUDFWVDSHVWWKDWDLFWV

DOIDOIDVSHFLFDOO\WKHWDUQLVKHGSODQWEXJ75

Palmer Amaranth (Pigweed): Palmer amaranth is

a member of the pigweed family and is related to

waterhemp.76 Each large pigweed plant can produce

from 600,000 to 1.6 million seeds, which can travel

up to 1,000 feet. According to a University of Arizona

extension specialist, just 16 pigweed plants for every

10 feet of crop row can generate 6 billion seeds per

acre.77 It outcompetes corn and soybean for sunlight

and nutrients and reduces corn yields by as much as 91

percent and soybean yields by 79 percent, which could

be devastating for farmers.78

Waterhemp7KHUVWJO\SKRVDWHUHVLVWDQWZDWHUKHPSwas reported in the United States in 2005.79 Water-

hemp seeds can persist in soil for up to four years, and

its pollen can travel more than a half-mile in windy

conditions.80 It is one of the most notoriouslybGLFXOWZHHGVWRHUDGLFDWHIURPFRUQDQGVR\EHDQHOGVLQWKH

0LGZHVWVLQFHZDWHUKHPSZDVWKHUVW86ZHHGWR

develop resistance to up to four herbicide families, it is

GLFXOWWRFRPEDWRQFHLWEHFRPHVHVWDEOLVKHG81 Infes-

tations can reduce soybean yields by up to 44 percent

and corn up to 15 percent, as waterhemp can grow up

to 12 feet tall and outcompete crops for sunlight and

nutrients.82

A 2012 Weed Science Society of Americastudy found that waterhemp in Nebraska has become

resistant to 2,4-D.83

TALL WATERHEMP. PHOTO CC-BY JOHN D. BYRD, MISSISSIPPI STATE UNIVERSITY


11/19


unesed varieies o marke. In November 2011, he

USDA unveiled is new sreamlined process or GE crop

approvals o shoren approval imelines by 13 o 15

monhs.86 The USDA claims ha he new sysem will

be more collaboraive, giving he public more noiceand opporuniy or more paricipaion in he process. 87

This collaboraion could be mosly heoreical given he

inense indusry pressure on he USDA o approve GE

crops more quickly.

I he USDA rapidly approves his nex generaion o

GE herbicide-oleran crops, i is likely o only speed

up he agrochemical readmill. These crops will likely

resul in increased herbicide use and he persisence o

weeds resisan o many dieren herbicides, making

hem harder and harder o manage. Formulaing newvarieies o crops o wihsand applicaions o harsher

chemicals coninues o rea one sympom and ignore

he underlying disease.

Costs Associated With GE Crops

and Herbicide-Resistant WeedsFarmer Costs

Farmers apply herbicides or weed conrol because

o heir economic uiliy.97 Yield-depressing weed

inesaions imperil arm earnings, and herbicides are

promoed as a cos-eecive approach o combaing

weeds while coninuing o plan he same crop season

afer season. Bu wih he onslaugh o herbicide

resisance, he indirec coss o herbicide use are under-

mining he economic viabiliy o GE herbicide-oleran

crops. Bioech corn seeds already cos nearly $40 moreper acre han non-GE seeds, and he cos o bioech

corn seeds nearly ripled rom $103 per 80,000 seeds in

1998 o $285 in 2013.98

After herbicide resistance, the second most

prevalent GE trait in corn and cotton is insect

resistance.88 The most common variety contains

a Bacillus thuringiensis (Bt) soil bacterium gene,

in the tissue of the plant, designed to repel

the European corn borer and several cotton

bollworms.89 The amount ofBttoxin expressed

in insect-resistant corn is ac tually 19 times the

amount of conventional insecticide necessary

to target the same pests by applying it to the

surface of the plant.90 Yet, this plant-incorpo-

rated protectant expressed in every cell of

each Btcrop is not counted in the USDA and EPA

measurements of total insecticide use, which

VLJQLFDQWO\XQGHUFRXQWVLQVHFWLFLGHDSSOLFD-

tions.91

Dr. Benbrook reports that stable declines ininsecticide use from the introduction ofBtcrops

are now in jeopardy as insects developed

resistance to the biotech toxin.92 A University

of Missouri entomologist found that corn

rootworms could pass on Btresistance to their

RVSULQJ93 And University of Arizona researchers

found that within seven years ofBtcotton

introduction, cotton bollworms developed Bt

UHVLVWDQFHWKDWWKH\ODWHUSDVVHGRQWRRVSULQJ

meaning that the resistance was dominant and

could evolve rapidly.94 A 2013 National Academy

of Sciences study reported that cotton pestsVKRZHGVLJQLFDQWUHVLVWDQFHWRBtand this

resistance was strengthened by GE crops with

multiple insect-resistant traits, as is common

with stacked Btcorn and cotton varieties.95 This

insect resistance will only be exacerbated by

continued widespread planting, and stacking, of

this GE trait.96

Crop Pests Develop Resistanceto Insect-Resistant GE Crops

PALMER AMARANTH IN COTTON (TEST PLOT). PHOTO UNIVERSITY OFARKANSAS SYSTEM DIVISION OF AGRICULTURE


12/19


Perhaps higher seed coss were jusiiable when

Roundup always worked, bu now ha glyphosae-re-

sisan weeds have spread, he higher cos may no

be worh i. A 2012 naional BASF survey ound ha

73 percen o armers surveyed aced reduced yields

because o herbicide-resisan weed inesaions.99 And

resisance o muliple herbicides in waerhemp could

evenually make soybean producion an unviable opion

in pars o he Midwes.100

Farmers ace signiican coss rom herbicide-resisan

weeds rom reduced yields and increased producion

coss o comba weed inesaions. These coss can

range rom $12 o $50 an acre, or as much as $12,000

or an average sized corn or soybean arm or $28,000

or an average coton arm.101 (See Table 1.) In 2010,

herbicide-resisan weeds cos armers $17 an acre

rom reduced yields.102 In 2012, 92 percen o surveyed

coton armers repored ha heir losses due o weed

conrol were a leas $50 per acre.103 In Tennessee,glyphosae-resisan horseweed has increased soybean

armers producion coss by $12 per acre; and Georgia

and Arkansas coton producers have seen addiional

coss o $19 per acre due o glyphosae-resisan Palmer

amaranh.104

Since U.S. armers have ound herbicide-resisan weeds

in heir ields, hey have changed arming mehods o

conrol hem, resuling in higher weed-conrol coss

and even a reurn o illage and hand hoeing.113 In 2009,

armers in Georgia were orced o weed hal o hesaes 1 million acres o coton due o he spread o

pigweed, cosing $11 million.114

Human Health Costs

Pesticide Exposure: Herbicides are oxic o plans by

naure, and some herbicides have been proven o be

especially hazardous o humans. The herbicide 2,4-D

has been associaed wih healh risks including endo-

crine disrupion in humans.115 Dicamba is a carcinogenic

herbicide ha can drif o nearby communiies.116

Isoxaluole exposure causes developmenal oxiciy andis a probable human carcinogen, leading o liver umors

and carcinomas in male and emale ras.117 The EPA

warns consumers ha acue exposure o arazine can

cause organ ailure, low blood pressure and damage o

adrenal glands, while long-erm exposure can damage

he cardiovascular sysem and cause cancer.118

Chemical Residues in Food: When Monsano

commercialized is Roundup Ready crops, he compa-

nys markeing campaign described glyphosae as being

less oxic o ras han able sal.119 Company-sub-

mited saey sudies highlighed he benign qualiy

o glyphosae, bu some o he independen, peer-re-

viewed research done on glyphosae-oleran crops

has revealed roubling healh implicaions, including

deerioraion o liver and kidney uncion and impaired

embryonic developmen in ras ed GE eed.120 Despie

hese poenial harms, he FDA and USDAs monioring

programs do no es or glyphosae residues on ood

or crops.121 As more Roundup was used o cope wih

glyphosae-resisan weeds, he herbicide residues

increased bu he FDA and USDA merely hikedup he permited residue levels, wih he resul ha

glyphosae-resisan crops did no exceed he allowable

olerance levels.122

The 2,4-D-oleran crops in he pipeline corn and

soybeans could be dangerous o ea because a

meabolie o 2,4-D (2,4-Dichlorophenol or DCP) is

known o cause skin sores, liver damage and some-

imes deah in animals.123 Because o he risks o

his byproduc, scieniss rom he French Naional

Insiue or Agriculural Research sugges ha cropsreaed wih 2,4-D may no be accepable or human

consumpion.124 A 2012 sudy ound ha individuals

wih 2,4-DCP presen in heir urine were more likely o

have a diminished olerance o ood and environmenal

allergens.125

Environment and Wildlie: Monsano has claimed

ha Roundup biodegrades ino naurally occurring

elemens and will no wash or leach in he soil,126

bu glyphosae persiss in he environmen or as long

as a year in soil and on sprayed plans, and or morehan six monhs in waer.127 In 2011, he U.S. Geological

Survey (USGS) ound glyphosae in over 60 percen o

air and rain samples aken during he growing season

Table 1.Farmer Costs ofHerbicide-Resistant Weeds

STUDYAREA

YEARWEED

VARIETY

COSTPER

ACRE

COMPARISON

National105 2010 All $17

3 percent of

value of corn

crop106

Cotton

farmer

survey1072012 All $50

7 percent

of value

of cotton

crop108

Tennessee

soybean

farmers1092005 Horseweed $12

2 percent

of value of

soybean

crop110

Arkansas

andGeorgia

cotton

farmers111

2011Palmer

Amaranth$19

5 percent

of value

of cotton

crop112


13/19


in Mississippi, Iowa and Indiana.128 Anoher USGS

sudy demonsraed he persisence o glyphosae in

surace waers near agriculural areas, including over

hal o Iowa waer samples and every sream examined

in Mississippi over wo years.129

Drif o 2,4-D can damage ecosysems conaining

sensiive organisms. According o he EPA, 2,4-D can

be very highly oxic o slighly oxic o reshwaer andmarine inverebraes.130 In 2011, he Naional Marine

Fisheries Services issued a inal opinion ha concluded

ha regisraion o pesicides conaining 2,4-D is likely

o jeopardize he 28 endangered and hreaened Paciic

salmon species and o adversely modiy he designaed

criical habia o some o hem.131 Isoxaluole is

moderaely oxic o reshwaer aquaic organisms and

highly oxic o some marine aquaic organisms.132

Arazine is oxic o aquaic inverebraes133 and has

been linked o hormonal problems in rogs and ishha can damage heir developmen.134 Arazine was

linked o ish in he Deroi River wih boh male and

emale sex organs135 and has been known o urn rogs

ino bizarre creaures bearing boh male and emale

sex organs.136 In 2007 and 2008, he Naural Resources

Deense Council (NRDC) moniored arazine in 20

Midwesern waersheds. Every sampled waershed had

deecable levels o arazine, and more han hal had

concenraions higher han he 1 par per billion level

ha begins o damage he uncion o aquaic plans.137

The European Union phased ou arazine compleelyby 2007.138

Alhough he USDA is considering approving GE crops

ha are resisan o muliple herbicides, he EPAs

curren surace waer sandards (or healh assess-

mens) do no cover combinaions o muliple herbi-

cides or concenraion peaks during cerain high-use

seasons.139 As a resul, he EPA canno measure or

regulae he eecs o herbicide loading made

prevalen wih sacked GE rais in waerways, wih

uncerain eecs on wildlie and human healh.

Conclusion andRecommendationsGeneically engineered herbicide-oleran crops have

increased he reliance on agrichemicals ha hreaen

he environmen, wildlie, human healh and armer

incomes. The emergence o herbicide-resisan weeds

should cas signiican doub on he bioech seed

companies sraegy o developing new varieies o

crops ha olerae more dangerous and powerulherbicides. The seed and chemical companies have

pu armers on a chemical readmill, and now hey

are increasing he pace. I is ime or a more raional,

sysems-based approach, which includes some o heollowing sraegies and policy changes:

The United States must reorm the approval

process or biotech crops. The USDA, EPA

and FDA should more rigorously evaluate the

potentially harmul efects o GE crops and

linked chemicals beore commercialization,

to ensure the saety o humans and the envi-

ronment. Unil ha policy is designed, he Unied

Saes should enac a moraorium on any new

approvals o GE plans and animals, raher hanspeeding up he approval process.

The USDA should support and encourage

cultivation best management practices to

prevent weed resistance in the irst place.

Conservaion crop roaion, cover crops, illage and

appropriae use o manure ha replaces he no-ill,

herbicide-based sysem can reduce soil erosion,

sequeser more carbon, and improve habia,

biodiversiy and waer qualiy.140 And variey is key.

Farmers should expand rom he commonplace

corn-soy roaion o include addiional crops, like

whea or alala, in he seasonal roaion.141 A long-

erm 2012 USDA, Universiy o Minnesoa and Iowa

Sae Universiy sudy showed ha more diverse

cropping sysems perorm as well and even beter

han less-diverse sysems wih ewer chemical

inpus.142

The USDA should educate and encourage

armers to adopt non-chemical strategies or

long-term weed control. Ausralian armers

developed mehods o desroy weed seeds aharves and maximize crops seeding raes or

increased compeiion agains weedy oes. These

WESTERN CHORUS FROG.PHOTO CC-BY BENNY MAZUR / COMMONS.WIKIMEDIA.ORG


14/19


harves weed seed conrol (HWSC) sysems have

worked o signiicanly igh ryegrass populaions in

Ausralia.143

The USDA must dedicate research dollars

to developing alternatives or sustainably

managing herbicide-resistant weeds. Even

hough he cause o herbicide-resisan weeds is

he overuse o herbicides, governmen and indusryleaders are promoing he increased use o currenly

available herbicides as a soluion.

The U.S. government must improve the collec-

tion and distribution o weed resistance144

and agricultural pesticide application data.

The USDA should collec weed resisance merics

in is annual agriculural surveys and he Census

o Agriculure. The EPA should collec daa on

annual pesicide use raher han relying on privae

consuling irms o collec he daa, as has been he

case or years,145 and make his daa publicly avail-

able. There has been no EPA daa on agriculural

pesicide use made public since 2007.146

In the European Union, Food & Water Europe

calls on politicians and regulators to heed

the warning that GE crops are an escalation

o weed management problems rather than

a solution, and to reject all applications or

Roundup Ready or other herbicide-tolerant GEcrops or import or cultivation. Growing hem

on European soil would harm and se back susain-

able arming, and imporing hem would be a aci

approval o a serious problem, and i is no longer

accepable o urn a blind eye by encouraging he

culivaion o GE herbicide-oleran crops ouside

Europe. The European Union canno claim o oser

susainable arming or susainable developmen i

i is exporing he damage caused by is choices o

oher counries and expecing hose communiies o

pay he price.


15/19


Number of States Reporting Glyphosate-Resistant Weeds in Fields (BYYEAR)

SOURCE: Heap, I. The International Survey of Herbicide Resistant Weeds. Available at www.weedscience.com. Accessed March 18, 2013.

GLYPHOSATE-RESISTANTWATERHEMP

GLYPHOSATE-RESISTANTPALMER AMARANTH

GLYPHOSATE-RESISTANTRAGWEED

Appendix A


16/19


Endnotes1 Food & Water Watch analysis of Grube et al. Environmental Pro-

tection Agency (EPA). Pesticides Industry Sales and Usage: 2006and 2007 Market Estimates. February 2011 at Table 3.1 and Table5.6.

2 Food & Water Watch analysis of CropLife America and CropLifeInternational Annual Reports 2001-2007 and the InternationalService for the Acquisition of Agri-biotech Applications (ISAAA)Annual Reports 20072012.

3 Ibid.4 Ibid.

5 Berry, Ian. Monsanto Chief Cautious on Market Share. The WallStreet Journal. Apr il 6, 2011.

6 Food & Water Watch analysis of Monsanto. Securities and Ex-change Commission. 10K Filings. 2003, 2006, 2009, 2010, 2012;Casale, Carl. Monsanto Biennial Investor Event. Presentation.November 10, 2009.

7 Jeschke, Mark. Crop Insights: Weed Management in the Era of*O\SKRVDWH5HVLVWDQFH'X3RQW3LRQHHU2QOHDQGDYDLODEOHDWhttps://www.pioneer.com/home/site/us/agronomy/weed-mg-mt-and-glyphosate-resis/. Accessed March 4, 2013.

8 Heap, Ian. The International Survey of Herbicide Resistant:HHGVb+HUELFLGH5HVLVWDQW:HHGVE\6LWHRI$FWLRQ$YDLO -DEOHbDWbZZZZHHGVFLHQFHFRP$FFHVVHG0D\

9 Top of the News. Chemical Week. January 28, 1976 at 16.

10 Miller, A. et al. Glyphosate Technical Fact Sheet. National Pesti-cide Information Center. Fact Sheet. September 2010 at 1.

11 Neve, Paul. Simulation modelling to understand the evolutionand management of glyphosate resistance in weeds. Pest Man-agement Science. 2007 at Abstract.

12 Loux, Mark et al. Biology and Management of Horseweed. Pur-due Extension. April 2006 at 8.

13 Gurian-Sherman, Doug. Union of Concerned Scientists. Failure toYield. April 2009 at 15 and 17; Green, Jerry. Evolution of Glypho-sate-Resistance Crop Technology. Weed Science, vol. 57. 2009 at109; 60 Fed. Reg. 36096 (July 13, 1995).

14 Mortensen et al. Navigating a Critical Juncture for SustainableWeed Management. BioScience, vol. 62, no. 1. January 2012 at 75.

15 Ibid. at 76.

16 Food & Water Watch analysis of U.S. Department of Agriculture(USDA), National Agricultural Statistics Ser vice (NASS). Quick-stats: Agricultural Survey, Planted Acres 20002012 for corn andsoybeans; USDA Economic Research Service (ERS). Geneticallyengineered varieties of corn, upland cotton, and soybeans, byState and for the United States, 200012. Data set. Updated July2QOHDQGDYDLODEOHDWKWWSZZZHUVXVGDJRYGD -ta-products/adoption-of-genetically-engineered-crops-in-the-us.aspx#.UUd2M1u4Elg. Accessed May 18, 2013.

17 USDA NASS. Quickstats: Agricultural Survey, Environment, Appli-cation. Latest data for corn is 2010 and for soybeans, 2006.

18 National Research Council of the National Academies. Theimpact of genetically engineered crops on farm sustainability in

the United States. April 13, 2010 at S-3 and S-13. (Pre-PublicationCopy).

19 Food & Water Watch analysis of Heap (2013).

20 Glyphosate-resistant weed problem extends to more species,more farms. Farm Industry News. January 29, 2013.

21 Ibid.

22 Ibid.

23 Food & Water Watch analysis of Heap (2013); USDA ERS (2012).

24 Pocock, John. Weed Revolt Marches On: Glyphosate-ResistantWeed Population Grows Rapidly. Corn & Soybean Digest. January17, 2012; Glyphosate-resistant weed problem extends... (2013).

25 Glyphosate-resistant weed problem extends... (2013).

26 Ibid.

27 Food & Water Watch analysis of Heap (2013); USDA ERS (2012).28 Heap, Ian. The International Survey of Herbicide Resistant Weeds.

$ERXW8V2QOHDQGDYDLODEOHDWZZZZHHGVFLHQFHRUJ$F -count/AboutUs.aspx. Accessed April 29, 2013.

29 Benbrook, Charles M. Impacts of genetically engineered crops onSHVWLFLGHXVHLQWKH86WKHUVWVL[WHHQ\HDUV EnvironmentalSciences Europe, vol. 24, no. 24. 2012 at 1.

30 Gillam, Carey. Analysis: Super weeds pose growing threat to U.S.crops. Reuters. September 20, 2011.


6OLJRM(ULF7KH1H[W6WHSVLQ:HHG&RQWUROCropLife. March 1,2013.


34 Mortensen et al. (2012) at 76, 79, 84.

35 McGrath, Kathleen. Biotechnolog y Industry Organization (BIO).Testimony of the Biotechnology Industry Organization RegardingAssembly Bill 984: Manufacturer Liability. Committee on Agricul-ture. California Assembly. April 29, 2005 at 2.

36 Food & Water Watch analysis of USDA NASS. Quickstats. Agricul-tural Survey, Chemical Use, Applications, Herbicides in lbs. peryear.

37 Food & Water Watch analysis of USDA NASS. Quickstats. Agri-cultural Survey, Planted Acres (Soybean), Chemical Use, Numberof Applications and Average Applications of Active Ingredient (Gly-phosate) in lbs. per acre.

38 Aspelin, Arnold L. and Arthur H. Grube. U.S. Environmental Pro-tection Agency (EPA). Pesticides Industry Sales and Usage: 1996and 1997 Market Estimates. November 1999 at 21; Grube et al.(2011)at 14. EPA. Pesticides Industry Sales and Usage: 2006 and2007 Market Estimates. February 2011 at 14.

(3$$WUD]LQH&KHPLFDO+HDOWK$SULODWWR2QOHand available at http://www.epa.gov/teach/chem_summ/Atra-zine_summary.pdf. Accessed May 3, 2013.

40 Laws, Forrest. Diversity key to glyphosate issue. Southeast FarmPress. January 25, 2010.

41 Food & Water Watch analysis of USDA NASS. Quickstats. Agri-cultural Survey, Planted Acres (Corn, Upland Cotton, Soybean),Chemical Use, Number of Applications

42 Keller, Rich. Recommend protection again resistant weeds withdiversity.Ag Professional. June 13, 2011; Wu, Mae et al. NaturalResources Defense Council (NRDC). Still Poisoning the Well: Atra-zine Continues to Contaminate Surface Water and Drinking Waterin the United States. 2010 at ii.

43 Universit y of Illinois Extension. Know Whats in Your HerbicideBefore You Apply. March 1, 2010.

44 Food & Water Watch analysis of USDA NASS. Quickstats. Agricul-tural Survey, Planted Acres (Corn, Upland Cotton, Soybean Plant-ed Acres), Chemical Use, Number of Applications and AverageApplications of Active Ingredient (Glyphosate) in lbs. per acre.

45 Food & Water Watch analysis of USDA NASS. Quickstats. ChemicalUse (Upland Cotton), Number of Applications (Avg).

46 Burnham, T.J. Glyphosate besieged with concerns of plant dis-ease link, weed resistance. Western Farmer-Stockman. April 2012at 16.

47 Mortensen et al. (2012) at 76.

48 Ibid. at 76 to 77.

49 Peterson, R.K.D. and A.N.G. Hulting. A Comparative Ecological

5LVN$VVHVVPHQWIRU+HUELFLGHV8VHGRQ6SULQJ:KHDW7KH(HFWof Glyphosate When Used Within a Glyphosate-Tolerant WheatSystem. Weed Science, vol. 52, no. 5. 2004 at 839.

50 Roush, Troy. Testimony on Are Superweeds An Outgrowth ofUSDA Biotechnology Policy. Domestic Policy Subcommittee.House Oversight and Government Reform Committee. House ofRepresentatives. July 28, 2010 at 3.

$VVRFLDWLRQRI$PHULFDQ3HVWLFLGH&RQWURO2FLDOV$$3&22005 AAPCO Pesticide Drift Enforcement Survey Report. 2005.2QOHDQGDYDLODEOHDWKWWSDDSFRFHULVSXUGXHHGXGRFVXU -veys/DriftEnforce05Rpt.html. Accessed May 3, 2013.

52 Gillam, Carey. Analysis: Dows New Corn: Time Bomb or Farm-ers Dream? Reuters. April 24, 2012.

53 Food & Water Watch analysis of USDA NASS. Quickstats. Agri-

cultural Survey, Planted Acres (Corn, Upland Cotton, Soybean),Chemical Use, Number of Applications and Average Applicationsof Active Ingredient (2,4-D) in lbs. per acre.


17/19


54 Food & Water Watch analysis of USDA NASS. Quickstat s. Agri-cultural Survey, Planted Acres (Corn, Upland Cotton, Soybean),Chemical Use, Number of Applications and Average Applicationsof Active Ingredient (Dicamba) in lbs. per acre.

55 Smith, Steve. Red Gold. Testimony on deployment of Dicamba-re-sistant soybeans and what it will mean to canned and frozen foodprocessors and specialty crop growers in the Midwest. DomesticPolicy Subcommittee of the Committee on Oversight and Gov-ernment Reform. U.S. House of Representatives. September 30,2010.

56 The manufacturers of Dicamba recommend that a maximum of

2 lbs. of active ingredient be used per acre of corn, cotton andsoybeans each year. Agri Star. Dicamba HD. Specimen Label at2QOHDQGDYDLODEOHDWKWWSZZZFGPVQHW/'DWOG-)pdf.

57 Monsanto data report that in 2008, the volume of dicamba usedon soybeans was 118,000 lbs. Monsanto. Petition for the Deter-mination of Nonregulated Status for Dicamba-Tolerant SoybeanMON 87708. July 6, 2010 at 199. Food & Water Watch analysis ofUSDA NASS data.

58 Average annual increase in Roundup Ready corn from 1997 to2001 was 1 million acres per year. Monsanto. Monsanto Biotech-nology Trait Acreage: Fiscal Years 19962009. October 2009 at 1to 3.

59 In 2010, 2,4-D was applied to 9 percent of total planted corn acres,or approximately 8 million acres. Farmers are currently using

about 0.5 lbs. of 2,4-D per acre of corn, but this corn is not geneti-cally engineered to withstand 2,4 -D. The manufacturer stipulatesthat farmers should not apply more than 3 lbs. per acre. Even ifthe 2,4-D tolerent corn had one lb. of 2,4-D applied per acre, thetotal 2,4-D use would increase by 57 percent from 3.5 million lbs.in 2010 to 5.5 million lbs. in just two years, after a million acres of2,4-D tolerant corn were added each year. Food & Water Watchanalysis of USDA NASS data; Agri Star. 2,4-D Amine 4. SpecimenLabel at 12.

%D\HU&URS6FLHQFH/LEHUW\/DEHODWDQG2QOHDQGavailable at http://www.agrian.com/pdfs/Liberty_280_SL_Label2.pdf. Accessed May 10, 2013.

61 Food & Water Watch analysis of USDA NASS. Quickstat s. Agri-cultural Survey, Planted Acres (Corn, Upland Cotton, Soybean),Chemical Use, Number of Applications and Average Applications

of Active Ingredient (Glufosinate) in lbs. per acre.

62 USDA. Animal and Plant Health Investigation Service (APHIS).3HWLWLRQVIRU'HWHUPLQDWLRQRI1RQUHJXODWHG6WDWXV2QOHDQGavailable at http://www.aphis.usda.gov/biotechnology/petitions_table_pending.shtml. Accessed May 10, 2013; Jeschke (2013).

63 USDA. Dow AgroSciences Petition (09-349-01p) for Determi-nation of Nonregulated Status of Event DAS-68416-4. DraftEnvironmental Assessment. May 2012 at 28.

64 In 2010, glufosinate was applied to 2 percent of total plantedcorn acres, or approximately 1.8 million acres (about 1.9 millionpounds). If farmers adopt 2 million acres of glufosinate-tolerantcorn, 2 million acres of glufosinate-tolerant soy and 2 millionacres of glufosinate-tolerant cotton within two years, the totalamount of glufosinate used would rise by 5.5 million pounds, afourfold increase in total glufosinate use. Food & Water Watchanalysis of USDA NASS data. Bayer CropScience. Liberty. Label.DW2QOHDQGDYDLODEOHDWKWWSZZZDJULDQFRPpdfs/Liberty_280_SL_Label2.pdf; Brabham, Chad B. and William*-RKQVRQ(FDF\RIJQLWHDQG)OH[VWDU7DQN0L[WXUHVRQGiant Ragweed and Common Lambsquarters. Crop Management.December 27, 2010 at Introduction.

65 Heap (2013).

66 USDA APHIS (2013).

67 Food & Water Watch analysis of USDA NASS. Quickstat s, Agri-cultural Survey, Planted Acres (Corn, Upland Cotton, Soybean),Chemical Use, Number of Applications and Average ApplicationsRI$FWLYHQJUHGLHQWVR[DXWROHLQOEVSHUDFUH

68 Wisconsin Department of Agriculture, Trade and ConsumerProtection. Final Environmental Impact Statement for the Use of

3HVWLFLGHV&RQWDLQLQJVR[DXWROHLQ:LVFRQVLQ$XJXVWDW23, Appendix 1.

69 Ibid.


71 Ibid.

72 Loux (2006) at 3,7.

73 Ibid. at 7.

74 Hollis, Paul. Pigweed not the only herbicide resistance issuefacing growers. Southeast Farm Press. February 25, 2013.

75 Loux (2006) at 7.

76 Nordby, Dawn et al. Biology and Management of Waterhemp.Purdue Extension. November 2007 at 3.

77 Blake, Cary. Glyphosate resistance changes Arizona cottonindustry. Western Farm Press. February 22, 2013.

78 Chandi, Aman et al. Inter ference of Selected Palmer Amaranth(Amaranthus palmeri) Biotypes in Soybean (Glycine max). Interna-tional Journal of Agronomy. 2012 at 2.


80 Nordby (2007) at 5,7.

81 Ibid. at 7; Bernards, Mark L. et al. A Waterhemp (Amaranthustuberculatus) Population Resistant to 2,4-D. Weed Science, vol. 60,iss. 3. 2012 at 381, 383; Rathai, Kenna. Quadstack Waterhemp:New Herbicide-Resistant Waterhemp Biotypes Call for New Man-agement Strategies. Corn & Soybean Digest. February 15, 2011.

82 Nordby (2007) at 4 to 6.

83 Bernards (2012) at 379.

84 USDA APHIS (2013); Gillam (2012).85 USDA APHIS (2013).

86 USDA APHIS. [Press release]. APHIS unveils customer-drivenimprovements and solutions. November 10, 2011.

86'$$3+63HWLWLRQ3URFHVVPSURYHPHQWV2QOHDQGDYDLO-able at http://www.aphis.usda.gov/biotechnology/pet_proc_imp.shtml. Accessed March 20, 2013.

88 USDA ERS (2012).

89 Fernandez- Cornejo, Jorge. USDA ERS. The Seed Industry in U.S.Agriculture. (AIB-786). January 2004 at 4.

90 Benbrook (2012) at 7.

91 Ibid. at 6 to 7; 7 U.S.C. 136(u)(1); 40 CFR 174.3. See plant-incorpo-rated protectant.

92 Benbrook (2012) at 1.

93 Wenzel, Wayne. Refuge Angst . Farm Journal. October 5, 2007.

94 Insect shows resistance to Btcrops.Appropriate Technology, vol.35, no. 1. March 2008 at 49.

95 Zook, Martin. Stacked traits may need larger refuges, studyQGVFood Chemical News, vol. 55, iss. 6. April 26, 2013.

96 Gassmann et al. Field-Evolved Resistance to BtMaize by WesternCorn Rootworm. PLoS ONE, vol. 6, iss. 7. July 29, 2011 at 5 to 6.

97 J.K. Norsworthy et al. Reducing the Risks of Herbicide Resistance:Best Management Practices and Recommendations. Weed Sci-ence, vol. 60, Special Issue. 2012 at 32.

98 GE seeds cost $100 more than conventional corn per 80,000seeds, amounting to $40 more per acre for a typical planting of32,000 seeds per acre. USDA NASS. Quickstats. Economics, PricesPaid (Corn), Biotech Seed. Available at http://quickstats.nass.usda.gov/results/3C3963A4-17BB-38C0-A428-542108E75554. Ac-cessed May 3, 2013; South Dakota State University. South DakotaCooperative Extension. Best Management Practices for CornProduction in South Dakota. 2009 at 15; Iowa State UniversityExtension. Corn Planting Guide. September 2001 at 4; U.S. Gen-HUDO$FFRXQWLQJ2FH*$2QIRUPDWLRQRQ3ULFHRI*HQHWLFDOO\0RGLHG6HHGVLQWKH8QLWHG6WDWHVDQG$UJHQWLQD5HSRUWWRWKHChairman, Subcommittee on Risk Management. Research, andSpecialty Crops, Committee on Agriculture, House of Representa-tives. January 2000 at 11.

99 Burt, Ann. BASF. [Press release.] Farmers plan to update weedcontrol management in 2012. April 23, 2012.

100 Tranel, Patrick J. et al. Herbicide Resistances inAmaranthus tuber-culatus: A Call for New Options.Journal of Agricultural and FoodChemistry, vol. 59, iss. 11. November 12, 2010 at 5808 and 5811.

101 Food & Water Watch Analysis of USDA NASS. 2007 Census ofAgriculture. 2007 at Table 33.

102 Rathai (2011).


18/19


103 Robinson, Elton. Resistant weeds changing the way we farm.Southwest Farm Press. February 19, 2013.

104 Mueller, Thomas C. et al. Proact ive Versus Reactive Managementof Glyphosate-Resistant or Tolerant Weeds. Weed Technology,vol. 19, iss. 4. 2005 at 928 to 929; Norsworthy et al. (2012) at 33.

105 Rathai (2011).

106 Average corn yield was 152.8 bushels per acre and farmersreceived $3.83 per bushel, meaning the average acre generated$585 per acre. USDA NASS. Quick stats. Available at http://quick-stats.nass.usda.gov/#A6AF7FC7-FB0F-3A52-8FF9-B39BB209077Cand http://quickstats.nass.usda.gov/results/91F90A64-F6F1-3C80-B0B5-7FD8BA041E2C. Accessed April 30, 2013.

107 Robinson (2013).

108 Average cotton yield was 849 lbs. per acre and farmers received$0.793 per lb., meaning the average acre generated $673 peracre. USDA NASS. Quick stats. Available at ht tp://quickstats.nass.usda.gov/results/EF24C098-C8C0-371F-ADC1-E6B27BC5139B andhttp://quickstats.nass.usda.gov/results/23699B90-253D-3493-BC36-0A14B2BDC7B7. Accessed May 6, 2013.

109 Mueller (2005) at 928 to 929.

110 Average soybean yield was 43.1 bushels per acre and farmersreceived $5.66 per bushel, meaning the average acre generat-ed $244 per acre. USDA NASS. Quick stats. Available at http://quickstats.nass.usda.gov/results/14926CB8-DF59-345D-8431-EAEF594E476E and http://quickstats.nass.usda.gov/results/EE-

D6695A-F353-3099-ACA7-66EF335DAD49. Accessed May 6, 2013.111 Norsworthy et al. (2012) at 33.

112 Average cotton yield was 772 lbs. per acre and farmers received$0.883 per lb., meaning the average acre generated $682 peracre. USDA NASS. Quick stats. ht tp://quickstats.nass.usda.gov/results/FD3C372B-18EA-35C3-9232-A36A12CF3DFF and http://quickstats.nass.usda.gov/results/64BE4D15-E236-3C24-BFF7-945F288EDA80. Accessed May 6, 2013.

113 Robinson (2013).

114 Haire, Brad. Pigweed threatens Georgias cotton industry. South-east Farm Press. July 6, 2010.

0QLI:LVVHPHWDO(HFWRI(QGRFU LQH'LVUXSWRU3HVWLFLGHV$Review. International Journal of Environmental Research and PublicHealth, vol. 8. June 17, 2011 at 2268, 2290 to 2291.

116 Cox, Caroline. Dicamba Factsheet.Journal of Pesticide Reform,vol. 14, no. 1. 1994 at 30 to 35.

117 Wisconsin Department of Agriculture, Trade and ConsumerProtection (2002) at 17 to 20; EPA. Pesticide Fact Sheet, Name of&KHPLFDOVR[DXWROH6HSWHPEHUDWWR2QOHand available at http://www.epa.gov/opp00001/chem_search/reg_actions/registration/fs_PC-123000_15-Sep-98.pdf. AccessedMay 9, 2013.

(3$&RQVXPHU)DFWVKHHWRQ$WUD]LQH2QOHDQGDYDLODEOHDWhttp://www.epa.gov/ogwdw/pdfs/factsheets/soc/atrazine.pdf.Accessed May 2, 2013.

119 Attorney General of the State of New York Bureau of ConsumerFrauds and Protection Bureau Environmental Protection Bureau.In the Matter of Monsanto Company, Respondent. November25, 1996.

GH9HQGRPRLV-RHO6SLURX[HWDO$&RPSDULVRQRIWKH(HFWVof Three GM Corn Varieties on Mammalian Health. Internation-al Journal of Biological Sciences, vol. 5, iss. 7. 2009 at 716 to 718;Malatesta, Manuela et al. Ultrastructural Morphometrical andImmunocytochemical Analyses of Hepatocyte Nuclei from Mice)HGRQ*HQHWLFDOO\0RGLHG6R\EHDQ Cell Structure and Function,vol. 27, 2002 at Abstract; Cisterna, B. et al. Can a genetically-mod-LHGRUJDQLVPFRQWDLQLQJGLHWLQXHQFHHPEU\RGHYHORSPHQW"A preliminary study on pre-implantation mouse embryos.European Journal of Histochemistry. 2008 at 263; Agodi, AntonellaHWDO'HWHFWLRQRIJHQHWLFDOO\PRGLHG'1$VHTXHQFHVLQPLONfrom the Italian market. International Journal of Hygiene and Envi-ronmental Health. January 10, 2006 at Abstract; Mesnage, R. et al.Cytotoxicity on human cells of Cry1Ab and Cry1Ac Bt insecticidaltoxins alone or with a glyphosate-based herbicide.Journal of

Applied Toxicology. 2012 at Abstract.

121 Miller et al. (2010) at 9.

122 76 Fed. Reg. 27268, 27270 (May 11, 2011).

123 Laurent, Franois et al. Metabolism of [14C]-2,4- dichlorophenolin Edible Plants. Pest Management Science, vol. 62. 2006 at 558.

124 Ibid.

125 Jerschow, Elina. Dichlorophenol-containing pesticides and aller-gies: results from the US National Health and Nutrition Exam-ination Survey 20052006.Ann Allergy Asthma Immunol, vol. 109.2012 at 420, 422.

126 Attorney General of the State of New York Bureau of Consumer

Frauds and Protection Bureau Environmental Protection Bureau.(1996).

127 Miller et al. (2010) at 8.

128 Chang, Feng-Chih et al. Occurrence and Fate of the HerbicideGlyphosate and Its Degradate Aminomethylphosphonic Acid inthe Atmosphere. Environmental Toxicology and Chemistry, vol. 30,iss. 3. 2011 at 550 and 554.

129 Coupe et al. Fate and transport of glyphosate and aminometh-ylphosphonic acid in surface waters of agricultural basins. PestManagement Science. 2011 at Results 3.1.

130 EPA. 2,4-D RED Facts. June 30, 2005. Available at http://www.epa.gov/oppsrrd1/REDs/factsheets/24d_fs.htm. Accessed Febru-ary 16, 2012.

131 National Marine Fisheries Services (NMFS). Endangered Species

Act Section 7 Consultation, Biological Opinion, EnvironmentalPrtoection Agency Registration of Pesticides, 2,4-D, Triclopyr BEE,Diuron, Linuron, Captan, and Chlorothalonil. June 30, 2011 at 771to 774.

132 EPA (1998) at 11.

133 EPA. Finalization of Atrazine IRED, and Completion of ToleranceReassessment and Reregistration Eligibility Process. April 6, 2006at 116.

134 Schabath, Gene. Estrogen found in waters alters sex organs ofVKDetroit News. August 14, 2005; Weiss, Rick. Data QualityLaw Is Nemesis of Regulation. Washington Post. August 16, 2004.

135 Schabath (2005).

136 Weiss (2004).

137 Wu (2010) at ii.

138 European Commission. Commission Decision of 10 March 2004concerning the non-inclusion of atrazine in Annex 1 to Council Di-rective 91/414/EEC and the withdrawal of authorisations for plantprotection products containing this active substance. 2FLDO

Journal of the European Union. March 16, 2004 at L78/53L78/54.

139 EPA. EPAs Report on the Environment: 2008. May 2008 at 3 to20.

140 Wallander, Steve. USDA ERS. While Crop Rotations Are Common,Cover Crops Remain Rare.Amber Waves. March 4, 2013.

0DUFRWW\-RVHSKLQH7KRVHEXJVLQQDWLRQVIDUPHOGVDUHJRLQJto outsmart us. StarTribune. November 24, 2012.

142 Davis, Adam S. et al. Increasing Cropping System Diversity Bal-DQFHV3URGXFWLYLW\3URWDELOLW\DQG(QYLURQPHQWDO+HDOWK PLoSONE, vol. 7, iss. 10. October 2012 at 1, 5.

143 Mortensen et al. (2012) at 81; National Academy of Sciences (NAS).National Summit on Strategies to Manage Herbicide-ResistantWeeds: Proceedings of a Workshop. 2012 at 9 to 10.

144 NAS (2012) at 24.

145 EPA. Notice of Intent to Award a Sole Source Purchase Order forAgricultural Pesticide Usage Data. April 10, 2012.

146 EPA. Pesticide Industr y Sales and Usage. Last updated May 9,2QOHDQGDYDLODEOHDWKWWSZZZHSDJRYRSSSHVW -sales/. Accessed May 10, 2013.


19/19

Food & Water Europe

Food & Water Europe

Rue dEdimbourg, 26

1050 Bruxelles

Belgium

[email protected]

www.foodandwatereurope.org

FOOD & WATER EUROPE IS A PROGRAM OF

eu version - superweeds: how biotech crops bolster the pesticide industry

Documents