FLAWED & HAZARDOUS RISK ASSESSMENT OF GLYPHOSATE & MONSANTO's ROUNDUP

THE WHO-FAO Joint Meeting on Pesticides Residues (JMPR) held their meeting this week (9-13 May) in Geneva to determine and set the Acceptable Daily Intake (ADI) of glyphosate/Roundup (i.e. the so-called "safe" amount of glyphosate/Roundup residues allowed on our food, water, etc.)

Monsanto and regulatory agencies in the US (EPA), EU (EFSA) and in Canada (Health Canada) are trying to discredit and dismiss the WHO/International Agency for Research on Cancer (IARC) recent and alarming classification of glyphosate as a "probable" human carcinogen by fraudulently arguing that a health hazard is not a health risk, because - they erroneously argue - a health risk is based on the level of human exposure (i.e. residues of glyphosate/Roundup on our food, water, soil, air, etc.) However, toxicology research has alarmingly found that glyphosate has an inverse dose-toxicity relationship 

(i.e. a low dose = high toxicity)

Please find enclosed a letter I have written to the WHO-FAO Joint Meeting on Pesticide Residues (JMPR) (the arm of the WHO that determines and sets the so-called "safe" levels of pesticides allowed on our food, water, environment, etc.) regarding the scientifically flawed and extremely hazardous Risk Assessment of glyphosate/Roundup and other untested, unregulated toxic/poisonous pesticides copiously sprayed on our food, water, soil, air and environment.

As you will see, we are all literally being poisoned by glyphosate/Roundup and other toxic/poisonous untested and unregulated pesticides copiously sprayed on both GMO and conventional crops and allowed and present as extremely high and lethal residues in our food, water, soil, air, and environment. Thank you for widely sharing this letter to raise public awareness about this deadly issue (pun intended).

28 July, 2015

TO: Joint FAO/WHO Meeting on Pesticide Residues (JMPR)
Geneva, Switzerland
jmpr@who.int

cc:

Ms. Rona Ambrose
Minister of Health
Health Canada
Ottawa, Ontario, Canada

Dr. Richard Aucoin
Executive Director
Pesticide Management Regulatory Agency (PMRA)
Ottawa, Ontario, Canada.

Dr. Christopher Wild
Director
WHO/IARC
Lyon, France
com@iarc.fr

Ms. Adcock Catherine
Expert on JMPR Taskforce
Head of the Toxicological Evaluation Section 2
PMRA, Ottawa, Ontario, Canada

To the Joint FAO/WHO Meeting on Pesticide Residues (JMPR),

I am writing to you with regards to the Risk Assessment of glyphosate and other toxic pesticides copiously sprayed on our food, soil, water, air and environment. As you know, the International Agency for Research on Cancer (IARC) has recently found and classified glyphosate as a “probable” human carcinogen.

However, Health Canada has recently favourably re-evaluated the importation, use and sale of glyphosate and entirely dismissed the credible and alarming findings of the IARC by (erroneously) arguing that a health hazard is not a health risk because a health risk is associated with the level of human exposure (i.e. Acceptable Daily Intake)

Health Canada writes that: "The World Health Organization's (WHO) International Agency for Research on Cancer (IARC) recently assigned a hazard classification for glyphosate as "probably carcinogenic to humans". It is important to note that a hazard classification is not a health risk assessment. The level of human exposure, which determines the actual risk, was not taken into account by WHO (IARC). Pesticides are registered for use in Canada only if the level of exposure to Canadians does not cause any harmful effects, including cancer." Source: http://www.hc-sc.gc.ca/…/…/_prvd2015-01/prvd2015-01-eng.php…

Glyphosate Risk Assessment: Health Hazard vs Health Risk

Personal observations:

1) “The dose makes the poison”

The health hazards vs health risks assessment used by Health Canada/PMRA (and all regulatory agencies) is scientifically flawed and invalid because Health Canada erroneously believes and argues that the “dose makes the poison.” In fact toxicology peer reviewed and published scientific research and evidence (please see copy below) has shown that this belief is in many cases inaccurate and quite often the opposite is true (i.e. linear vs nonmonotonic dose-response curves)
Study links: http://www.ncbi.nlm.nih.gov/pubmed/22419778

2) Active Principle (glyphosate) vs Formulation/product (Roundup)

Health Canada (and all regulatory agencies) only reviews the toxicity of the Active Principle alone (i.e. glyphosate) and not the whole product formulation (i.e Roundup) which contains other highly toxic and synergistic “secret” adjuvants.

However, a recent landmark peer-reviewed and published study (see copy below) has alarmingly found Roundup and other pesticide formulations to be 125 to over 1000 times more toxic than their declared Active Principle. The authors of the study alarmingly found and write:

“We tested the toxicity of 9 pesticides, comparing active principles and their formulations, on three human cell lines[...] Despite its relatively benign reputation, Roundup was among the most toxic herbicides and insecticides tested. Most importantly, 8 formulations out of 9 were up to one thousand times more toxic than their active principles. Our results challenge the relevance of the acceptable daily intake for pesticides because this norm is calculated from the toxicity of the active principle alone. Chronic tests on pesticides may not reflect relevant environmental exposures if only one ingredient of these mixtures is tested alone.”

Study Links: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3955666/

3) Acceptable Daily Intake (ADI)

Health Canada/PMRA (and all regulatory agencies) determines and sets the ADI based exclusively on the Active Principle alone (i.e. glyphosate) and not on the product formulation (i.e. Roundup.) However, the actual product that is approved by Health Canada and used copiously on our food supply, soil, water, air and environment is not only glyphosate (AP) but the whole product formulation (i.e. Roundup.)

In view of the above, I think that it is fair to conclude that both the Risk Assessment and the ADI set by Health Canada/PMRA (and all regulatory agencies) are scientifically flawed and extremely dangerous to both our health and our lives since they expose us to extremely high doses of toxic chemical formulations (i.e. Monsanto's Roundup, Dow's Enlist Duo, etc.) which seriously endangers both our health and our lives.

I therefore hereby request the Joint FAO/WHO Joint Meeting on Pesticide Residues (JMPR) to meticulously study and take into account the above observations while Revisiting the International Estimate of Short-Term Intake (IESTI) in Geneva on 7-9 September for glyphosate/Roundup/Enlist Duo and other highly toxic pesticides copiously sprayed on our food, soil, water, air and environment.
________________________________________________

Note: A coalition of health and environmental organizations have written a letter to the WHO-FAO/JMPR complaining about flagrant conflict of interests among members of the JMPR panel. The following recent investigative article provides a good summary overview of the issue.

WHO-FAO/JMPR DECISION (16 May, 2016): 

The panel has concluded that glyphosate does not cause cancer to humans through exposure of glyphosate/Roundup residues in the food. The JMPR summary report can be read at this link.