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May 27, 2014

Mr. Michael Walsh

Environmental Protection Agency (EPA)

Office of Pesticide Programs

Biopesticides and Pollution Prevention Division (7511P) / Registration Division (7505P)

1200 Pennsylvania Ave. NW

Washington, D.C. 20460-0001

Dear Mr. Walsh:

We, the undersigned institutional investors, representing $47 billion in assets under management

and led by the Interfaith Center on Corporate Responsibility (ICCR), are writing to express our 

concerns about the use of 2,4-dichlorophenoxyacetic acid (2,4-D) on new genetically engineered 

(GE) corn, cotton and soybean crops designed to survive repeated spraying of the herbicide. We 

are disappointed by the recent news of the Agency’s proposed decision to approve this new 

version of 2,4-D. We ask that, under the proposed new use registrations for 2,4-D-resistant 

crops, EPA incorporate widely accepted estimates for significantly increased use and 

altered use patterns of 2,4-D.

As investors, we are conscious of the long-term risks associated with these products and believe 

it is prudent to await thorough assessment before releasing these products to the market. Without 

adequate understanding of the environmental consequences and health impacts of the 2,4-D 

resistant crops and subsequent increase in herbicide use, we cannot be sure that our companies 

are sufficiently considering potential risks of these products to human health and the 

environment. As a regulator responsible for understanding the effects of herbicide use on 

humans and the environment, the U.S. Environmental Protection Agency (EPA) must carefully

consider its role in determining the use, sale, and labeling of 2,4-D and make a thorough and 

accurate assessment of the potential impacts.

The EPA has reported that 2,4-D is the seventh largest source of dioxins in the United 

States. 2,4-D is a toxic herbicide associated with serious health risks. The 2,4-D resistant crops 

will also, like their predecessors, lead to much greater use of even more dangerous chemicals, the 

development of more herbicide-resistant weeds, destruction and genetic contamination of 

neighboring crops, and severe economic impacts on other farmers.

As shareholders, we engage seed and chemical companies, including Dow AgroSciences, about 

risks and impacts related to herbicide utilization with its seed products on human health and the 

environment. Deregulation of Dow’s 2,4-D resistant crops will drive up use of 2,4-D, an 

antiquated and dangerous herbicide known to drift beyond target crops. Shareholders are aware 

that Dow’s Enlist Duo system utilizes a less volatile form of 2,4-D, however this does not 
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mitigate its inherently dangerous characteristics linked to causing cancer, Parkinson’s disease, 

endocrine disruption, and reproductive problems in humans.

We ask that as you consider Dow’s 2,4-D New Use Registration Applications for the new uses of 

2,4-D choline salt that will be associated with the new 2,4-D resistant crops, you consider the 

mounting evidence about the risks of increased and compounded 2,4-D use. We join more than 

half a million individuals and organizations, including medical doctors and public health 

scientists, farmers, food and health experts, consumers, environmental organizations and many

others in calling on you to undertake a thorough assessment and complete your findings prior to 

undertaking any regulatory changes. 

Noted agricultural scientist Charles Benbrook projects that widespread planting of Dow’s Enlist 

corn alone could trigger as much as a 25-fold increase in use of 2,4-D, from an estimated 4.2 

million pounds at present to over 100 million pounds by 2019. The consequent increase of the 

use of further herbicide resistant crops is troubling for ecosystems and water supplies. As a 

result, Monsanto and other firms that manufacture pesticides are focusing the bulk of their 

Research and Development on new crops engineered with resistances to even more herbicides. 

Monsanto is awaiting approval of soybean seeds that are resistant to dicamba and glyphosate, 

with triple herbicide resistant corn and cotton in the pipeline.

The instructions that the seed companies provide to end-users is dependent on the findings of the 

EPA. Your role in setting the conditions for the herbicide’s use and placement in the labeling 

instructions that a user must follow are critical for protecting the health of farmers and the 

environment. We encourage you to use caution and restraint when establishing these instructions. 

Further, the MSDS sheet for Enlist Duo is alarming: 

 Environmental precautions: Prevent from entering into soil, ditches, sewers, waterways 

and/or groundwater. 

 Personal precautions, protective equipment and emergency procedures: Isolate area. 

Keep unnecessary and unprotected personnel from entering the area.

 Potential Health Effects (extracted from listing)

o Eye Contact: May cause moderate eye irritation. May cause slight corneal injury. 

o Skin Contact: Brief contact may cause slight skin irritation with local redness. 

May cause drying and flaking of the skin. 

o Skin Absorption: Prolonged skin contact is unlikely to result in absorption of 

harmful amounts. 

o Skin Sensitization: Has demonstrated the potential for contact allergy in mice. 

o Inhalation: No adverse effects are anticipated from single exposure to mist. 

Based on the available data, narcotic effects were not observed. Based on the 

available data, respiratory irritation was not observed. 

o Ingestion: Low toxicity if swallowed. Small amounts swallowed incidentally as a 

result of normal handling operations are not likely to cause injury; however, 

swallowing larger amounts may cause injury.

o Effects of Repeated Exposure: For similar active ingredient(s). 2,4-

Dichlorophenoxyacetic acid. In animals, effects have been reported on the 
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following organs: Gastrointestinal tract. Kidney. Liver. Muscles. Observations in 

animals include: Gastrointestinal irritation. Vomiting. For the minor 

component(s): In rare cases, repeated excessive exposure to propylene glycol may

cause central nervous system effects. 

o Birth Defects/Developmental Effects: For similar active ingredient(s). Has been 

toxic to the fetus in laboratory animals at doses toxic to the mother.

How can deregulation of 2,4-D corn, cotton and soy align with EPA’s announced proposed 

changes to the agricultural Worker Protection Standard (WPS) to increase protections from 

pesticide exposure for the nation's 2 million agricultural workers and their families and EPA’s 

commitment to Environmental Justice?

Farmers are deeply concerned that Dow’s Enlist corn, cotton and soy system will threaten their 

crops. 2,4-D is known to drift — directly and through volatilization — which poses a very real 

threat to rural economies and farmers growing crops not engineered to withstand application of 

these potent chemicals. 2,4-D drift is already responsible for more episodes of crop injury than 

any other herbicide, and its vastly increased use promises still more damage to non-2,4-D 

resistant crops like soybeans, cotton, vegetables and fruit.

This chemical is used because Roundup Ready GE crops have caused an epidemic of glyphosateresistant weeds, so another herbicide is needed. Monsanto's RoundUp Ready seed line is

responsible for a dramatic rise in glyphosate-resistant “superweeds,” which have afflicted 

millions of acres of farmland across the Midwest and South. Dow is promoting GE 2,4-D corn, 

cotton and soy as the solution to glyphosate (the ingredient in Roundup) resistant weeds, but GE 

crop systems caused the glyphosate resistant weeds in the first place. Additionally, Enlist Duo 

also utilizes glyphosate.

We ask that, under the proposed new use registrations for 2,4-D-resistant crops, EPA 

incorporate widely accepted estimates for significantly increased use and altered use 

patterns of 2,4-D.

Sincerely, 

Ellen Kennedy

Manager, Environment, Water and Climate 

Change

Calvert Investments

Luan Steinhilber

Director of Shareholder Advocacy

Miller/Howard Investments, Inc.

Kathleen Coll

CHE Trinity Health

William Stoddart

Founder and Principal

Northfork Financial

Shelley Alpern

Director of Social Research & Shareholder 

Advocacy

Clean Yield Asset Management

Julie N.W. Goodridge

President & CEO

NorthStar Asset Management, Inc.
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James A Frazin

President/CEO

Communitas Financial Management

Judy Byron

Director

Northwest Coalition for Responsible Investment

Sally Ann Brickner

Coordinator of Justice, Peace and Ecology

Congregation of Sisters of St. Agnes

Catherine Cartier

President

Progressive Asset Management

Margaret Weber

Corporate Responsibility Director

Congregation of St. Basil

Jo Marie Chrosniak, HM

Coordinator 

Region VI Coalition for Responsible Investment

Joellen Sbrissa, CSJ

SRI Representative

Congregation of St. Joseph

Steve Zielinski

SRI Consultant

Servants of the Paraclete

Susan Vickers

VP Community Health

Dignity Health

Ruth Kuhn, SC

Chair - Corporate Responsibility Committee

Sisters of Charity of Cincinnati

Steve Zielinski

SRI Consultant

Diocese of Springfield, IL

Margaret O'Brien, SC

Congregation Treasurer

Sisters of Charity of New York

Steve Zielinski

SRI Consultant

Dominican Sisters

Sister Barbara Aires

Coordinator of Corporate Responsibility

Sisters of Charity of Saint Elizabeth

Linda Hincken

Chief Financial Officer

Dominican Sisters of Amityville

Sister Patricia Daly, OP

Corporate Responsibility Representative

Sisters of St. Dominic of Caldwell NJ

Valerie Heinonen

Director, Shareholder Advocacy

Dominican Sisters of Hope

Toni Palamar

Province Business Administrator

Sisters of the Good Shepherd-Province of NY

Sr. Donna Graham

OSF Director, JPIC Office

Franciscan Friars (OFM), St. John the Baptist 

Province

Steve Zielinski

SRI Consultant

Sisters of the Presentation

Lura Mack

Director

General Council of the Adrian Dominican 

Sisters

Mary Lardner

Social Justice Committee Chair

Social Justice Committee at UUCSR

Leslie Samuelrich 

President

Green Century Capital Management

Lars M Lewander

Chief Executive Officer

Spring Water Asset Management
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Nadira Narine

Program Director, Strategic Initiatives

Interfaith Center on Corporate Responsibility

Theodore Casparian

Educator

Sustainable Investing 4 All

Cathy Rowan

Corporate Responsibility Coordinator

Maryknoll Sisters

Susan Baker

Vice President, Shareholder Advocacy &

Corporate Engagement

Trillium Asset Management

Marcela Pinilla

Director, Shareholder Advocacy

Mercy Investment Services

Valerie Heinonen

Director, Shareholder Advocacy

Ursuline Sisters of Tildonk

Barbara Jennings

Coordinator

Midwest Coalition for Responsible Investment

Sonia Kowal

Director of Socially Responsible Investing

Zevin Asset Management, LLC