sust-mar: Urgent - 2,4-D Deadline April 22nd Action Required /SAMPLE LETTER

From: "Helen Jones" <hjones@chebucto.ns.ca>
To: "Sustainable-Maritimes" <sust-mar@chebucto.ns.ca>
Date: Mon, 18 Apr 2005 00:49:17 -0300
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Subject: Urgent - 2,4-D Deadline April 22nd Action Required


URGENT ACTION REQUIRED BEFORE APRIL 22ND
SAMPLE LETTER PROVIDED 2/3 THE WAY DOWN THIS MESSAGE.
TAKE 2 MINUTES, CHANGE IT TO SUIT YOU, AND SEND IT.

PLEASE RESPOND TO HEALTH CANADA (The Pest Management Regulatory Agency)
BEFORE APRIL 22, 2005


PLEASE FORWARD WIDELY

On Monday, February 21, 2005, the Pest Management Regulatory Agency
(PMRA) published a proposal for public comment regarding the
pesticide 2,4-D for turf.  They also made an announcement that stated
that the pesticide 2,4-D can be used safely on lawns and turf when
label directions are followed. The PMRA is the federal regulatory
body responsible for the regulation of pesticides in Canada, within
Health Canada.

2,4-D is one of the 22 pesticide active ingredients to be
banned from use on all green spaces across the Province of Quebec.

Please write to the PMRA and insist that 2,4-D be banned in Canada
for use on lawns, by 2006 - just as it will be in Quebec.

1.         2,4-D was put on the Quebec list in the first place
because it was found to be a risk by the International Agency for
Research on Cancer.  The new PMRA document did not conclude that
2,4-D is not a carcinogen.  Child cancer merited more study, but this
was considered too difficult.  Animal studies were used.  There is
significant doubt about the PMRA's conclusion, and the Precautionary
Principle should prevail.

2.         The PMRA has stated that 2,4-D is 'safe' IF 'label
directions are followed'. This means that we and our children are at
risk of harm when label directions are not followed (and also likely when
they are).
It is impossible to monitor every usage across Canada. The Precautionary
Principle
would dictate that 2,4-D not be used. We have already seen that most
professional applicators do not protect themselves adequately while
applying pesticides on lawns.

3.         In Canada, it is illegal to advertise that a pesticide is 'safe'.

4.         In the manufacture of 2,4-D, dioxins are formed. Dioxins
are persistent, bioaccumulative and carcinogenic. They harm
neurological development, impair reproduction, disrupt the endocrine
system and alter immune function.  And can be assumed to be present in 2,4-D
products, such as Weed and Feed or any fertilizer or lawn product mentioning
"weed control".

5.         The PMRA relies on the manufacturer's testing of 2,4-D to
monitor dioxins, however since 1983 no such monitoring has been
carried out.  The recent announcement stated that required dioxin
data had not yet been provided by the industry.

6.         No testing is carried out for herbicide related dioxins in
sediments in waterways adjacent to 2,4-D use.

7.         According to Canada's Environmental Protection Act,
dioxins are targeted for virtual elimination.  The PMRA is asking
only for some of the required dioxins to be measured, and ignoring
the main contaminants.

8.         The stink that emanates from storage or use of lawn
pesticides is the smell of the break-down products, which are very
toxic. These chemicals - chlorinated phenols - are not even mentioned
in the review of 2,4-D.

9.         Important gaps in relevant information exist, for example,
reproduction and neurotoxicity studies required by the PMRA were not
submitted, and cancer in children merited study but was not considered.

10.     2,4-D has been found in blood, urine and semen. 2,4-D and has
been linked to neurological impairment and to reproductive risk.

11.     From an environmental point of view, the use of 2,4-D on
lawns is an ecological aberration because it favours monocultures
that are very vulnerable to insect infestations.

For information:
Mrs. Rohini Peris, Coalition for Alternatives to Pesticides (CAP) -
(514) 683-5701
-------------------------------------


Please email your letter to:   pmra_publications@hc-sc.gc.ca

Publications Coordinator

Pest Management Regulatory Agency

2720 Riverside Drive

A.L. 6605C

Ottawa, ON, K1A 0K9

1-800-267-6315

Tel: 613-736-3799

Fax: (613) 736-3758

www.pmra-arla.gc.ca

www.eddenet.ca



-------------------------------------
Sample letter (please feel free to add your own thoughts or change the
letter to suit you)


Publications Coordinator

Pest Management Regulatory Agency

2720 Riverside Drive

A.L. 6605C

Ottawa, ON, K1A 0K9


Madam/Sir,

Reference: PACR2005-01,
Re-evaluation of the Lawn and Turf Uses of (2,4-Dichlorophenoxy)
acetic Acid (2-4,D)

I am writing to you with reference to your re-evaluation of the
pesticide 2,4-D for lawns and turf, and because you have invited the
public to send in written comments.

In 1950 we had fewer than 20 species of insects that showed signs of
pesticide resistance. By 1990, that number jumped to 504. There was
no mention of herbicide resistant weeds in the writing of Silent
Spring, but by the late 1990's weed scientists identified 273 such
species!  The Earth has been polluted by all kinds of chemicals
including pesticides.  All this has been done with the blessing of
"good science", and has resulted in a toxic legacy that we are forced
to leave behind for future generations.

Chemicals have been found in people all over the world. There is no
control group left on this planet that does not have body contamination.
For instance, how do you propose to control the spread
of 2,4-D from lawns to homes?

It is improper that this proposal was published before important
studies had been received, and that as tax paying Canadians we cannot
have access to the studies on which you have based your findings.
These must be made public and the process must be clear and open.

In the laboratory of everyday life we are exposed to thousands of
chemicals, which we eat, breathe, touch and drink.  Laboratory rats,
on the other hand, are experimented on in controlled environments.
Therefore the basis of your evaluation is not relevant to our
everyday exposures. The risk is too high. How do you judge
"acceptable risk"?  It is much like playing God with the lives of
those we love and cherish.

On our lawns, where our children play, we want ecological methods to
maintain grass. The methods are simple, and good for both human
health and the economy. An ecological lawn gives good value to the
community, city, Province and Country.



Rising health care costs must be controlled through Disease
Prevention; not by allowing more chemicals into our environment.  Canada
should follow Sweden's good example and ban 2,4-D from all our greenspaces.
Health Canada must get into the business of Health Protection and not
impose more chemicals on the population. I am not in favour of
registration of 2,4-D for lawn and turf uses.



Thanking you,

Sincerely,

(Your name & address)




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