1 15 1 https://www.nal.usda.gov/exhibits/speccoll/files/original/c5894808ce7844df8ed2654baa45d766.pdf 45daa154aa30f5d108c4640404d73930 PDF Text Text ItemBNumber 05190 D Author Nolting, Alfred R. NotScannBfl United States of America, Environmental Protection Age Report/Article Title Motion to Intervene Journal/Book Title Year ™™ Month/Day August 23 Color D Number of Images ° DBSCripton Notes ' n r e : 2,4,5-TrichlorophenoxyaceticAcid; I. F. & R Docket No. 295 Friday, March 01, 2002 Page 5190 of 5263 �• - • • "• ••'-.;• ' '\ UNITED STATES OF AMERICA ENVIRONMENTAL PROTECTION AGENCY BEFORE THE ADMINISTRATOR In res 2,4,5-trichloropheno syacetic acid ) I F & R. Docket No. 295 .. Motion to Intervene The Secretary of Agriculture of the United States (hereinafter the Secretary) moves to intervene in the above«rcrjrfr±unscr' • . ,•• ' ' •' •' ,i administrative proceeding which has been instituted pursuant to section 6(b)(2) of the Federal Insecticide, Fungicide, and Rodenticide Act, as amended. The purpose of the hearing is to consider all registered uses of 2,4,5-trichlorophenoxyacetic scid (hereinafter 2,4,5-T)t as well as the use of 2,4S5~T on rice 'wMch was the subject of a cancellation notice on May 1, 1970. T3ae Secretary is charged with broad responsibilities in con™ flection with the total agro-business of the Nation, as well as ' a variety of other responsibilities designed to protect the public health and enhance the public welfare. These responsibilities include considerations relative to the attainment of.adequate quantities of marketable food9 timber, and fiber. lae use of �•••••: )••« -o-.' the herbicide 2,4S5-T is directly relative to the responsibilities ' . of the Secretary, . *-~ ' Concomitant with the foregoing responsibilities, the Secretary is desirous of providing the Administrative Law Judge and the Administrator of the United States Environmental Protection Agency with all available scientific expertise of the Etepartment of Agriculture relevent to the use of 2,4,5-T. The : f • .- -:.'••- Secretary's participation in this administrative proceeding /will jfrelp to insure that a full and'' complete record ls~developed, '' '*"• '. ' • .' ' • ' thereby providing a solid predicate upon which to base the ultimate decision as to the, use of 2,4,5-T. Also, the Secretary was granted permission to intervene in fe&e earlier proposed hearings involving the use of 2,4,5-T on . rice,, Since one of the purposes of this hearing is to consider the use of 2,4,5-T on rice, it trould be incongruous not to permit th& Secretary to intervene in this hearing after such permission wa& granted earlier. Fa have a profound interest in this case. We believe it is imperative to human v?elfare to elicit rational judgments respecting the availability of the chemicals used as tools to assure an . adequate supply of food, fiber, timber and energy for man. The herbicide 2,4,5-T is one such chemical. �•VCi^:% >-'-•/• •• ::"?"^ :" "^ "'"l >V;X'" '- -;; "! * : • 3 . '-'••• In view of the foregoing, we submit that this administrative proceeding demands a comprehensive and systematically objective £act-£inding effort. Only such an endeavor can provide an adequate foundation for a meaningful evaluation that separates objective fact from subjective conjecture, a vital prerequisite for a sagacious conclusion based on a proper assessment of the known risks versus the known benefits from continued use of 2,4,5-T. /• Of and by itself, this concern imputes wide-ranging significance to this case. . • '". - - . But an even more vital facet of this matter causes this , administrative proceeding to assume dimensions that are monumental. Some sensationalistic charges, based on unknown and unquantifiable potential risks,.have been made against the use of 2,4,5-T. . Cburges inundated with emotion are particularly attractive to the most casually informed person; such allegations are often the basis of unwarranted alarm. In our opinion it is therefor needful to judiciously juxtapose emotion-laden claims against known realities ixj order to create an atmosphere that is conducive to the acceptance" of objective judgment. In this regard it is exceedingly tempting— albeit profoundly unwise—to couch questions in a manner that requires an answer implying "absolute" guarantees of "no risk" for and his environment. These assurances cannot be given. And �despite the attraction of such an approach, thoughtful reflection reveals that rhat avenue inevitably leads to meaningless and misleading rhetoric, because it results in the adoption of simplistic expedients for the resolution of complex issues. Oae advocate, Harrison Wellford, has said the "banning of 2>4,5~T is becoming the Dreyfus case of pesticide regulation, * * * At stake is the question of who is to set standards upon ^lich the proposed safety of a. pesticide (or any chemical) is to be judged". . ,, . • '• To the extent that Mr. Wallford's statement accurately characterizes the impact of this proceeding, we intend to devote our most serious concern to the matter. We believe that it is in the best public interest to protect man and his environment; to provide man with the necessities of life; and to enhance the quality of life. We also believe that the provident use of chemicals helps achieve such objectives. Accordingly, in this proceeding we are especially comnitted to the development of a record that will be replete with concrete scientific fact and the articulation of the best available philosophies regarding the . application of such fact to conclusions affecting the well-being of mankind. In return, we fully anticipate a decision that unequivocally enunciates a rule of reason in the debate about the �;• 7?v-:^y- . - '-•-;• ;;</•. • - . . :-^.'-V- '• • - 3 employment of chemical substances and their relation to public health, welfare, and the environment, tj For the foregoing reasons, the Secretary respectfully requests to intervene as a party in this proceeding. . ' . » . • ••: . Respectfully submitted, L. Nolting ^.. **—•-.^v.tg ——.rylj-tf' .-mn-m^r t-ftM-^T^-irrn . . f n .—.u ^r ynjond W. Fuller ton Attorneys for the Secretary of Agriculture � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young. For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 176 Folder The folder containing the original item. 5190 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Nolting, Alfred R. Raymond W. Fullerton Description An account of the resource Corporate Author: United States of America, Environmental Protection Agency (EPA) Date A point or period of time associated with an event in the lifecycle of the resource August 23 1973 Title A name given to the resource Motion to Intervene ao_seriesVIII