Response to the NRCD Petition 

Conclusion

Data quality considerations and balanced reviews are critical. 2,4-D is an old product and there are numerous published papers in the literature that can be ‘cherry picked’ to allege 2,4-D effects. Emphasis must be placed on high quality, studies that have been conducted using validated protocols, standardized guidelines, and Good Laboratory Practice Standards. Peer-reviewed, replicated studies from the scientific literature can also be of value. However, open literature cited in the NRDC petition are of questionable utility due to limitations in experimental design, limited documentation, lack of dose response, excessive doses (above renal saturation threshold), absence of positive controls and misleading conclusions, especially as re-interpreted by NRDC.

The petition should be denied.

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