Public Comment – GMO corn petition

REJECT – Bayer / Monsanto’s petition for MON-87429 corn

BAYER gmo pesticides

Comment deadline May 6, 2024

You may submit comments by either of the following methods: • Federal eRulemaking Portal: Go to http://www.regulations.gov. Enter APHIS– 2020–0021 in the Search field. Select the Documents tab, then select the Comment button in the list of documents.  
https://www.regulations.gov/search?filter=APHIS%E2%80%932020%E2%80%930021
Environmental Impact Statements; Availability, etc.: Bayer; Draft Plant Risk Assessment for Determination of Nonregulated Status for Maize Developed Using Genetic Engineering for Dicamba, Glufosinate, etc.

https://www.regulations.gov/document/APHIS-2020-0021-7200      
Federal Register / Vol. 89, No. 57 / Friday, March 22, 2024 / Notices

Summary

We are advising the public that the Animal and Plant Health Inspection Service (APHIS) has prepared a draft environmental impact statement (EIS) and draft plant pest risk assessment (PPRA) evaluating the potential environmental impacts and plant pest risk that may result from the approval of a petition for nonregulated status for maize developed using genetic engineering for dicamba, glufosinate, quizalofop, and 2,4-dichlorophenoxyacetic resistance with tissue-specific glyphosate resistance facilitating the production of hybrid maize seed. We are making the draft EIS and draft PPRA available for public review and comment.

Background

Under the authority of the plant pest provisions of the Plant Protection Act (7 U.S.C. 7701 et seq. ), the regulations in 7 CFR part 340, “Movement of Organisms Modified or Produced Through Genetic Engineering,” regulate, among other things, the importation, interstate movement, or release into the environment of organisms modified or produced through genetic engineering that are plant pests or pose a plausible plant pest risk.

The petition for nonregulated status described in this notice is being evaluated under the version of the regulations effective at the time that it was received. The Animal and Plant Health Inspection Service (APHIS) issued a final rule, published in the Federal Register on May 18, 2020 (85 FR 29790–29838, Docket No. APHIS–2018–0034), (1) revising 7 CFR part 340. However, the final rule was implemented in phases. The new Regulatory Status Review (RSR) process, which replaces the petition for determination of nonregulated status process, became effective on April 5, 2021, for corn, soybean, cotton, potato, tomato, and alfalfa. The RSR process became effective for all crops as of October 1, 2021. However, “[u]ntil RSR is available for a particular crop . . . APHIS will continue to receive petitions for determination of nonregulated status for the crop in accordance with the [legacy] regulations at 7 CFR 340.6” (85 FR 29815). This petition for a determination of nonregulated status is being evaluated in accordance with the regulations at 7 CFR 340.6 (2020) as it was received by APHIS on June 27, 2019…. see more

Public Comment – Jennifer Robin

I Reject Bayer-Monsanto’s petition for MON-87429 corn.

I do not approve of these crops seeds, that require chemicals (dicamba, glufosinate, quizalofop, and 2,4-dichlorophenoxyacetic) being non regulated. They go hand in hand with being drenched with toxic chemicals, directly on the food I, my family, or my pets eat. Cancers are becoming so widespread among the population, I am certain this is related. FDA, You have allowed these industries to poison us for decades. A lot of these practices have already been banned in other countries. There is hardly any processed food available on store shelves that isn’t drenched in cancerous chemicals before becoming a product and because of it, America currently has a 60% chronic illness today.  The FDA’s purpose is to regulate industry and protect citizens. Please do your job as intended and deny this petition.

I do not approve of all these toxic chemicals, used with any GMO seeds, destroying the critical ecosystems. Honey bee’s ability to pollinate. Bird populations are the lowest in history. Waters and lands are being intentionally polluted by the run-off and will take decades to repair. Some species may never recover, some may go extinct directly from the approval of this petition.

I do not want to consume, or purchase corn, or any products that have been drenched with toxic chemicals to speed up the drying process, or to treat the weeds underneath them. I do not want to purchase products that are GMO, and listed registered in the pesticide patent department, designed for the specific purpose of using these toxic, cancerous chemicals.

DICAMBA

U.S. appeals court had blocked dicamba due to EPA understating the risks of drift and you reapproved it anyhow.
https://www.centerforfoodsafety.org/press-releases/5692/farmers-conservationists-challenge-approval-of-monsantos-crop-damaging-dicamba-pesticide
The evidence reveals that government officials—rather than protecting farmers and the public interest—have done whatever Monsanto has demanded to keep this pesticide on the market, forgoing the rigorous analysis and data that the law requires,” said George Kimbrell
https://biologicaldiversity.org/w/news/press-releases/federal-court-halts-spraying-of-monsantos-dicamba-pesticide-across-millions-of-acres-of-cotton-soybeans-2024-02-06 .

While it has been currently banned as of February 2024, existing stock orders are still in use.

So this one has been stopped going forward, but if EPA intentionally ignored the warnings and approved that one, the others may also be suspect.


24-D  

In 2016, There’s a growing body of scientific evidence that the chemical poses a danger to both human health and the environment.
https://www.nrdc.org/stories/24-d-most-dangerous-pesticide-youve-never-heard
“In 2015, the International Agency for Research on Cancer declared 2,4-D a possible human carcinogen, (http://www.iarc.fr/en/media-centre/pr/2015/pdfs/pr236_E.pdf ) based on evidence that it damages human cells and, in a number of studies, caused cancer in laboratory animals.
More conclusive is the proof that 2,4-D falls into a class of compounds called endocrine-disrupting chemicals, compounds that mimic or inhibit the body’s hormones. Laboratory studies suggest that 2,4-D can impede the normal action of estrogen, androgen, and most conclusively, thyroid hormones. Dozens of epidemiological, animal, and laboratory studies have shown a link between 2,4-D and thyroid disorders. “That’s really important when we’re thinking about development,”

Also problematic: 2,4-D sticks around in the environment. Depending on the formulation, it can drift through the air from the fields where it is sprayed or be tracked inside homes by pets or children. By the EPA’s own measure, 2,4-D has already been detected in groundwater and surface water, as well as in drinking water. Australian scientists reported in 2012 that it was found in more than 90 percent of samples taken from agricultural catchments bordering the Great Barrier Reef—bad news for many fish, for whom the herbicide can be toxic. It can also poison small mammals, including dogs who can ingest it after eating grass treated with 2,4-D.”

QUIZALOFOP

https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=91024L28.TXT
Fact sheet is from 1988 – Quizalofop ethyl is practically nontoxic to birds or honey bees; highly toxic to freshwater fish, very highly toxic to invertebrates, moderately toxic to…  with an increase in liver tumors in mice.

1999 – https://oehha.ca.gov/proposition-65/chemicals/quizalofop-ethyl
Listed as Causing Cancer or Reproductive Toxicity · Draft Hazard
“Male Reproductive Toxicity”

GLYPHOSATES

In the footnotes on main page:

(2) Maize is the common botanical term used globally for the CEREAL plant Zea mays. In the United States, maize is also referred to as corn.

Do you recall hearing about the ’roundup’ toxicity in Cheerios recently?
https://www.cbsnews.com/news/cheerios-quaker-oats-infertility-chemicals-in-cereal-ewg

So we know the high levels of toxins ARE in our oats. Unexceptable!

We know the high levels of toxins ARE in soy burgers: Unexceptable!
https://www.momsacrossamerica.com/gmo_impossible_burger_positive_for_carcinogenic_glyphosate

Though the World Health Organization’s International Agency for Research on Cancer concluded in a 2015 report that the glyphosate chemical “is PROBABLY carcinogenic to humans.” 
https://www.iarc.who.int/featured-news/media-centre-iarc-news-glyphosate/

And Robert F. Kennedy, Jr showed us that roundup ‘IS’ a carcinogen in his 13 billion dollar Monsanto lawsuit win. Though food crops were not considered in this lawsuit, if the chemicals can leach into our skin and be deadly and cancerous, one should assume that ‘consuming’ a GMO glyphosate seed that has the glyphosate chemical in its DNA, and then drenched on the crop, and absorbed into the plant from the roots, which then grows into product to be consumed… it too would be affected. But what Mr. Kennedy says relating to glyphosate industry should be considered a major factor here:

“I can tell you the (EPA) Environment Protection Agency is effectively run by the oil industry, the coal industry, and the pesticide industry. When we sued, I was on the trial team that brought the Monsanto cases and we ended up with a $13 billion dollar settlement after winning three trials. But during trials, we uncovered through discovery, email traffic, going back years that showed the head of the pesticide division at the EPA was secretly working for Monsanto, and was running that agency to promote the mercantile ambitions of the business rather than the public interest. He was killing studies, he was fixing, he was ghostwriting studies. And that’s true throughout the agencies.”
https://www.youtube.com/watch?v=AY89a_zXi9s

We know EPA is siding with pesticide companies already, and not doing adequate studies needing to safeguard the people and environments.
Clearly EPA, keeps ignoring glyphosate warnings from experts like WHO in 2015, and Kennedy Jr in 2018, because in 2020, you said…

“In February 2020, after receiving and considering public comments on the glyphosate proposed interim decision, EPA published the interim decision registration review decision (ID) for glyphosate. As part of this action, EPA found that there are no risks of concern to human health when glyphosate is used in accordance with its current label. EPA also found that glyphosate is UNLIKELY to be a human carcinogen.”
https://www.epa.gov/ingredients-used-pesticide…/glyphosate

Somebody isn’t being honest here.

So I have to wonder who is running the EPA right now? Is he also corrupted and in Monsanto’s pocket?

Also, not mentioned, but needs to be considered if these corn crops will also be used with an adjuvant? We know “Sprayed Adjuvants to Herbicides Can Be More Toxic But Are Not Monitored” and the dangers associated to spraying of food and feed crops is already been acknowledged. See Bohn’s study.
https://www.ncbi.nlm.nih.gov/…/pdf/foods-08-00669.pdf

The question is…. Shouldn’t we be taking precautions to keep it from ALL food crops, or at least make these highly REGULATED for safety concerns for the people and ecosystems they destroy?

Who hasn’t seen the damage from industry who isn’t regulated, or is allowed to self regulate?

We must reject this petition!


As noted by multiple others who stated more evidence on this:

“MON-87429 corn is designed as a pesticide delivery system. I understand that USDA does not regulate pesticides, but due to herbicide-tolerant GMO crops’ reliance on their associated herbicides, it is illogical to separate the GMO crops from the herbicides. No GMO farmer would buy the seeds without buying and using the herbicides. Therefore, the GMO crops and herbicides need to be considered as an inseparable system.

Since the introduction of Monsanto’s glyphosate-tolerant GMOs in the 1990s, we have seen the use of this genotoxic carcinogen increase by hundreds of millions of pounds across the U.S.

Since 2016, we have seen that the use of Bayer’s dicamba-tolerant GMOs has caused untold destruction across America. Dicamba drift has decimated millions of acres of non-dicamba-tolerant crops, including non-GMO and organic crops, orchards and vineyards, and has killed off pollinator-important plants, private gardens and valuable trees across the country. There have been hundreds of lawsuits launched against Bayer for damage caused by dicamba drift from GMO crops. The San Francisco Ninth Circuit Court of Appeals even ordered the EPA to vacate their unlawful approval of dicamba-based herbicides manufactured by Bayer and BASF.

Additionally, 2,4-D is also known to be drift-prone and will likely cause further damage as its usage increases with adoption of MON-87429 corn.

A recent study found that glyphosate, dicamba and glufosinate, three of the herbicides that will be sprayed on MON-87429 corn, change the genetic composition of soil microbiomes, potentially contributing to the global antimicrobial resistance problem in agricultural environments.

The EPA approval process is flawed. There is no assessment of the combined toxicity of pesticide mixtures on the soil microbiome, on pollinators, wildlife, birds, biodiversity, or endangered species. A recent study found that pesticide mixtures are more toxic than the individual pesticides. This study of laboratory animals exposed to low concentrations of pesticides revealed metabolic effects on the gut-liver axis, which can potentially be used as biomarkers for the prediction of future negative health outcomes. The study found adverse impacts of the mixture on the host-gut microbiome. The risks of pesticide mixtures must be investigated before considering the approval of MON-8429 GMO corn.

It would be unconscionable for USDA to allow Bayer-Monsanto’s MON-87429 corn to be grown in the U.S. given everything we know about GMO contamination of non-GMO and organic crops, the damage that herbicide drift causes, and the toll of pesticides on human and environmental health. Growing crops genetically engineered to tolerate five different toxic herbicides is madness and USDA must put a stop to this now.”

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