INDUSTRY TASK FORCE II ON

2,4-D RESEARCH DATA

Phone: 816-246-9469 Information Line: 1-800-345-5109 9317 E Pleasant Avenue Kansas City, MO 64138

June 1, 2011

Mr. Peter Robinson Chief Executive Officer David Suzuki Foundation 219 2211 West 4th Avenue Vancouver, BC V6K 4S2Canada Via email: probinson@davidsuzuki.org

Dear Mr. Robinson, I am writing with regard to the news release Environmental groups claim victory for municipal, provincial pesticide bans, issued on May 30, 2011. To introduce myself, I am a self-employed agricultural consultant who serves as Executive Director of the 2,4-D Task Force. The Task Force is a group of companies which, as provided by law, has jointly funded more than 300 new research studies required by United States Environmental Protection Agency and requested by Health Canadas Pest Management Regulatory Agency (PMRA) under the American and Canadian pesticide re-registration/reevaluation programs. In reviewing www.davidsuzuki.org I was pleased to see that we share a common objective: We work with government, business and individuals to conserve our environment by providing science-based education, advocacy and policy work, and acting as a catalyst for the social change that today's situation demands. Both our organizations want to work with government and their community of stakeholders to ensure policy decisions are based on the foundation of scientific evidence. With this shared objective, it perplexed me when reading the following statements in the above-noted news release: The pesticide 2, 4-D is a chlorophenoxy herbicide, a group of chemicals that the International Agency for Research on Cancer a branch of the World Health Organization classifies as possible human carcinogens. Exposure to this herbicide is also associated with a number of other serious health risks, including effects on the hormone system. But Quebec is not saying that 2, 4-D is safe said Lisa Gue of the David Suzuki Foundation. This is still a toxic chemical and we disagree with regulators that a potentially cancer-causing pesticide does not pose an unacceptable risk to human health or the environment.

While these statements may reflect the opinion of the David Suzuki Foundation, they are not supported by the evidence considered by the governments and Canada and Quebec in reaching the settlement with Dow AgroSciences.
e-mail: james.gray@24d.org 2,4-D Web Page: www.24d.org

As you will note in the settlement agreement which was made public by the Government of Canada, the Government of Quebec recognizes that 2,4-D does not pose an unacceptable safety risk to human health when used according to label instructions. Section 3 a) of the settlement agreement states: ... the Government of Quebec agrees that products containing 2,4-D do not pose an unacceptable risk to human health or the environment, provided that the instructions on their label are followed, as concluded by Health Canadas Pest Management Regulatory Agency (PMRA) in its May 16, 2008, decision on the re-evaluation of 2,4-D. With regard to the IARC classification, in 2005-06 the PMRA considered this matter in conducting the re-evaluation of 2,4-D and concluded: The International Agency for Research on Cancer is the only international regulatory organization that has not revisited the issue of 2,4-D in its entirety. More recent re-evaluations by the European Union, the United States Environmental Protection Agency, New Zealand and the World Health Organization do not classify 2,4-D as human carcinogen. Over the course of several years, the PMRA thoroughly and rigorously examined the toxicological and epidemiological data pertaining to 2,4-D and determined that 2,4-D does not present risks of concern. In its final decision document released in 2008, the agency stated: Health Canada found that 2,4-D does not increase the risk of cancer and can be used safely by homeowners, provided label directions are followed. No other international regulatory body considers 2,4-D to be a human carcinogen. Based on all available and relevant data, Health Canada agrees with this position.

The Task Force welcomes informed public debate on important matters of health policy such as the appropriate and beneficial use of pesticides. We are optimistic that the above information will allow the David Suzuki Foundation to appropriately re-examine this matter taking into consideration our shared objective in having government decisions based on scientific evidence. In so doing, we would encourage your organization to more accurately reflect the simple fact that several agencies around the world mandated with protecting human health have considered the current and relevant scientific evidence relating to 2,4-D and all have determined it may be safely used according to label instructions. I very much appreciate the opportunity of engaging in meaningful dialogue with you. Thank you for your consideration. Sincerely,

James W. Gray Executive Director Industry Task Force II on 2,4-D Research Data