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Response to AgCarm: Yes, the IARC is an ‘outlier’

The Soil & Health Association of New Zealand

Response to AgCarm

Yes, the IARC is an ‘outlier’ and we are the safer for it

An October 1 media release by Agcarm draws attention to the fact that the chemical industry affirms the safety of glyphosate. This is laudable, as the Agcarm represents the chemical industry. However, the release contains many inaccuracies and claims that do not serve the public interest. These, unfortunately, require many paragraphs to unravel and involve a degree of scrutiny around issues that keep ‘popping up’ (such as bacon) the New Zealand media has not, to date, been inclined to address.

Soil and Health agree with Agcarm, that ‘conclusions about our health must be non-biased’, which is why we consider it is essential to comprehensively respond to Agcarm’s article.

Agcarm’s press release leads with an ‘800 studies’ claim cut and pasted directly from glyphosate-based herbicide Roundup owner Bayer’s website In fact, less than 300 unpublished, non-peer-reviewed studies have been used for risk assessment. In contrast, more than 1500 published studies have been produced on glyphosate in the past decade, yet the methods by which regulators claim a scientific study is suitable for inclusion in regulatory risk assessment, result in a ‘vast modern literature on glyphosate effects’ being excluded.

International court cases have drawn attention to the problems and faults of these studies, and the fact that they have time and again, been biased towards protecting the interests of the chemical industry and aggressively pursued independent scientists. These court cases have also informed the world of the predatory campaign that unfolded after the IARC determined that glyphosate and its formulations were probably carcinogenic. They revealed that Monsanto (now owned by Bayer) had:

‘spent millions of dollars on secretive PR campaigns – including $17 million in one year after the IARC evaluation had been published – to finance "ghost-written" studies and editorials aimed at discrediting independent scientists whose work had found dangers with Monsanto’s pesticides.’

Not safe nor effective

Contrary to Agcarm’s claims, a significant body of peer reviewed science demonstrates that glyphosate-based herbicides are not necessarily safe nor effective. The herbicide, and more toxic formulation, probably cause cancer ; appear to act as an endocrine disruptor ; and impact gene function and shape the epigenetic pathway for disease in future generations. Studies are finding that glyphosate causes harm at environmentally relevant levels and propose that current safety standards are not rigorous enough to protect human health. Scientists are concerned that the ingredients in the formulation, which have been hidden by commercial confidentiality agreements, are profoundly toxic. Heavy metals have also been detected in many glyphosate formulations.

Glyphosate’s efficacy is coming into question as many weeds have become resistant to it. This results in chemical applicators throughout New Zealand adding other toxic chemicals to the mix to reduce increasing weed resistance. The chemical mixtures sprayed down our roadside drains and on pavements and in parks are not assessed for mixture toxicity. Superweeds are an enormous problem in the USA because of the heavy applications of glyphosate on genetically engineered corn, sugarbeet, cotton and other crops, a bullet New Zealand has dodged with precautionary legislation that has not so far permitted commercial genetically engineered organisms into the environment.

Contrary to Agcarm’s claim, glyphosate does not necessarily degrade quickly in soil, and this claim has been refuted scientifically. Degradation is impacted by many factors. Glyphosate is commonly detected in soil.

IARC classification – should pregnant mothers and children eat bacon at every meal?

Soil and Health do not consider the IARC’s classification is misleading, contrary to Agcarm’s chief executive Mark Ross’s claim.

Parents may see the common-sense and logic of the IARCs hazard classification. The IARC have drawn attention to risk around coffee, bacon and talcum powder, which, like glyphosate and its toxic formulations, probably cause cancer. Many parents have stopped putting talcum powder on their babies. Not many parents feed their young children bacon or pour them a coffee. Frequent exposures are unsafe. Glyphosate-based herbicides are similarly risky. This is not misleading.

The problem is that parents cannot monitor nor manage how much glyphosate (including the heavy metals and petroleum products in the formulation ) their children consume – their exposure level. This is where the New Zealand public must trust their chemical regulator to act in their interest – and this includes accepting even inconvenient scientific determinations made by the authorities that they have traditionally looked to for guidance – such as the IARC. (Curiously the use of the word ‘trust’ in New Zealand Environmental Protection Authority (NZ EPA) documents has risen exponentially in the last few years.)

Further, the press release indicates Mr Ross may be confused about WHO processes. The Food and Agriculture Organization (FAO) work with the World Health Organisation to form the Joint FAO/WHO Meeting on Pesticide Residues (JMPR). The International Programme on Chemical Safety draw on decisions coming out of the FAO/WHO JMPR meetings as a result of toxicological evaluations, available on the web as INCHEM data.

Therefore, contrary to Agcarm’s article, only two ‘WHO’ agencies undertook toxicology evaluations, the IARC and the JMPR group.

The FAO/WHO JMPR process has not historically assessed full formulation toxicity, certainly the glyphosate evaluations haven’t, and JMPR decisions are based on data selected and supplied by the agrichemical industry. The particular JMPR meeting that evaluated glyphosate was chaired and deputy chaired by two men from the International Life Sciences Institute (ILSI) that had previously received $US500,000 from Monsanto and a $US528,500 donation from the industry group Croplife International, which represents Monsanto, Dow, Syngenta and others. Conflicts of interest were not disclosed.

Our NZ Carcinogenicity Review repeated flaws in the European assessment

The Agcarm press release also draws attention to the European decision on the carcinogenicity of glyphosate by the European Food Safety Authority (EFSA). The August 2016 NZ EPA carcinogenicity review discussed in the press release has been heavily criticised. New Zealand scientists have drawn attention to the flaws in a 2016 New Zealand carcinogenicity review which replicated flaws in the EFSA assessment. The group criticised the use of industry data to support the European and New Zealand assessments, the failure to identify oxidative stress (which can initiate cancer), they voiced the suspicion that industry ‘ghost-wrote’ many studies. The group pointed to the problem of an inadequate ‘weighting’ process that is a laboratory data management process that cannot guarantee studies are of good quality. Using this process the two regulators repeatedly favoured industry data and excluded peer reviewed scientific evidence. A group statement by 94 scientists also criticised the European processes. The NZ EPA have never formally responded to the criticisms from the New Zealand scientists.

The New Zealand public trust their chemical regulator to use best practice and there is a body of public law that supports this. The International Agency for Research on Cancer is the gold standard in cancer assessment. Soil and Health agree with Agcarm - the IARC is an outlier. This is for good reason. The IARC has a process that more accurately serves the public interest to protect human health and it is more transparent.

Conflating the issues

Ross appears to conflate issues. It is important to note that the NZ EPA review was not a risk assessment – it was a carcinogenicity review. Similarly, the NZ EPA has never conducted a risk assessment of glyphosate, it has merely authorised the chemical to be sold, based on data supplied to support authorisations by the chemical industry. Therefore, we do not know at what level glyphosate harms our babies and children and the multiple pathways harm might occur based on the New Zealand environment. Risk has simply never been assessed in New Zealand – the claim that glyphosate is safe as long as it is used according to the label instructions – cannot be scientifically proven from the industry selected data the industry has supplied.

Another conflation is Agcarm comparing the FAO and WHO JMPR assessment with the IARC monograph. The first (industry data-based assessment) looked at different pathways to risk, the second restricted consideration (of public data) to cancer. If a chemical probably causes cancer, it will not cause cancer any less if it is also a neurotoxicant, an endocrine disruptor or a developmental toxicant. Furthermore, the IARC considered more glyphosate cancer studies than any joint FAO and WHO JMPR assessment have ever considered.

That old ‘bacon’ story – a euphemism for ‘it’s really OK’

Risk assessment does not change whether or not a chemical substance is carcinogenic or not – thus the IARC finding that glyphosate-based herbicides are carcinogenic remains true. The level of exposure changes the nature of the risk. There is no New Zealand data researching exposures so there can be no claim that Kiwis, particularly pregnant mothers, babies and children are safe.

Glyphosate is present in urine and blood serum. Children, because they consume more by bodyweight have higher exposures despite being more vulnerable. There are not many mothers that expose their children to bacon or sausages several times a day. Tobacco smoke and alcohol causes cancer, so we keep babies and children away from these substances. Many mothers also limit the amount of cured meat they feed their children, because they are commonly known to probably cause cancer. This is a choice.

Prominent NZ media articles have dismissed the finding of the IARC, intimating that the IARC finding makes glyphosate as risky as processed meat. Glyphosate is sprayed along roadsides and along drains, NZTA spray 4000 litres in the Auckland region alone. Glyphosate is increasingly found in freshwater and it is commonly detected on staple food crops.

However, unlike a mother serving up bacon once or twice a week, when glyphosate is sprayed in parks, splashed onto pavements, sprayed alongside roads and in the ditches that children walk along on the way home from school, there is no choice for parents on how to manage this risk – their children are simply exposed.

Mothers can avoid bacon, but can they avoid toast and breakfast cereal?

Agcarm mention that the Ministry for Primary Industries (MPI) tests residues from commonly used agrichemicals, however New Zealand glyphosate testing appears limited to milk, wheat and peas.

Wheat, oats and barley can be treated with glyphosate ‘pre-harvest’ as the spray acts to ‘dry-down’ or desiccate the crop. Initially glyphosate was ‘only’ sprayed on genetically engineered soy, corn, sugarbeet, and canola crops, increasing glyphosate use exponentially. Then the practice spread to other crops. The WHO/FAO initially authorised the use after conducting trials to establish what expected residue levels would be, so that maximum residue levels (MRLs) could be established slightly above this level. Afterwards, other countries adopted the practice. Permitted residue levels increases are the method by which the practice of desiccation, or pre-harvest spraying of glyphosate on cereal (in particular, wheats, oats and barley) and lupin crops are legally permitted. This is why glyphosate is now in a wide range of common foods, from breakfast cereal to beer.

In a suite of testing of wheat New Zealand’s Ministry for Primary Industries (MPI) detected glyphosate residues on 26 out of the 60 wheat samples and identified one-third of wheat samples above the permitted residue level of 0.1mg/kg. The 0.1mg/kg is an internationally low residue; this is relatively good. This is common practice, and most likely all samples above the 0.1mg/kg will have been desiccated with glyphosate herbicides (and the formulation ingredients). The farmers were following label instructions – which permits application on crops. The response from MPI was to review wording on labels for clarity, and to review the residues information for glyphosate.

The New Zealand national dietary study excludes glyphosate. Many people have asked that glyphosate is included, these requests have been rejected by successive governments. The New Zealand food safety regulator cannot confirm the level of glyphosate in the New Zealand diet is safe.

Despite New Zealand’s MPI refusing to test glyphosate in food, glyphosate is commonly found in Australian cereals, and Australian wheat is our primary source for use in the North Island. When pregnant mothers, babies and children are chronically exposed to glyphosate on a daily basis – the chemical is in biscuits, bread, and breakfast cereal (including cereal for babies) there is no way the chemical can be avoided.

This is why the ‘bacon’ analogy is misleading and unfair. Parents cannot regulate, because unlike bacon, or ham or talcum powder, the glyphosate formulation is invisible and ubiquitous – it is on common food items.

Austria has been the only country to ban glyphosate, it also has the highest proportion of organic farmland in Europe.

The practice of pre-harvest application of glyphosate on cereals has the result that it is not only applicators, farmers and their families who are exposed, city dwellers now are chronically exposed to glyphosate-based herbicides.

Using the peer reviewed, evidence-based science to evaluate pesticides – not secret industry data

Soil and Health agrees that ‘a matter as important as our health must be non-biased’ – however the evidence currently suggests there is inordinate regulatory dependence on industry data.

The evidence also points to the fact that regulators are ignoring the more complex ways humans can become chronically ill – and this is where, the IARC by calling attention to the evidence that glyphosate-based herbicides cause oxidative stress – demonstrates scientific leadership.

The IARC has had a hard time in the New Zealand media, but it is important to understand that the IARC is the gold standard for research on cancer and a trusted agency for New Zealand regulators. AgCarm’s Mr Ross may be unaware that the IARC is the only agency with a requirement that all data selected for IARC processes must be publicly available – the other agencies use data supplied by the chemical industry, whereas IARC will deliberately include published data, frequently from government sources or peer reviewed journals.

The FAO/WHO JMPR process of conducting toxicological evaluations not only ignore formulation toxicity and keeps the details of the toxicity studies hidden, JMPR decisions are not democratically accountable. JMPR decisions exert a tremendous influence internationally because recommendations for daily acceptable exposure levels and maximum residue levels are adopted by national governments. Yet the meetings are largely hidden from the public. The pesticide industry attends en masse, as do agrichemical regulators (who traditionally depend on industry for toxicological data) also attend, but there is no corresponding representation from public health and environmental organisations.

There are chinks in the armour of secrecy that have helped regulators hide decisions away from the public view. A European court case recently decided that the public interest should override corporate claims to confidentiality. It found:

‘emissions into the environment’ was ‘deemed to be in the overriding public interest, compared with the interest in protecting the commercial interests of a particular natural or legal person, with the result that the protection of those commercial interests may not be invoked to preclude the disclosure of that information’.

AgCarm and the chemical industry will demand that the public ignore the published scientific literature, and ignore the findings of IARC, the gold standard in cancer assessment – and trust the conclusions of regulatory authorities.

Of course they should, because the regulatory authorities depend on industry data to supply the data that forms the endpoints that say how much chemicals should be sprayed on our food. The studies that show harm at environmentally relevant levels are kept outside the regulatory environment by the laboratory management system scheme.

This is not evidence-based science, it is protectionism. Recently, applications for funding to support soil-based, lower pesticide use scientific research and knowledge disseminating extension services to farmers have been rejected. Farmers wanting to transition away from chemical intensive agriculture to address issues of carbon sequestration and soil and plant nutrition require support. Interdisciplinary soil and nutrition agricultural research sectors are woefully inadequate in respect to the size of the agricultural industry which has focussed on genetics and patent development. Protection of soil, water and human health is a public good.

Parents cannot control the level of chemicals in food, or in local parks – parents must trust that cross-agency government actions act in the public interest, as the purpose of the Acts that confer statutory powers to these agencies require of them. This imparts a fiduciary responsibility on the NZ EPA, Ministry for the Environment (who oversee the NZ EPA), Ministry for Primary Industries and the Ministry of Health to protect public health and the environment. Civil society must trust that all decision-makers, from Cabinet Ministers, to officials to scientific staff, act as they are legally required to. When trust in governance erodes, so does democracy. A recent paper put it more succinctly:

‘Effective political accountability, in turn, is essential for building and maintaining public trust in the institutions of government and upholding the legitimacy of the democratic system.’

Soil and Health consider that outdated legislation has contributed to a failure to consider formulations and transparently include peer-reviewed scientific literature in assessment. Currently there are substantial data gaps and biases in risk assessment practices in Aotearoa. This has resulted in a substantial body of scientific evidence being ignored or dismissed that demonstrates, that at environmentally friendly levels, our health, our environment and our pets are at risk from lifetime, chronic, daily exposures to glyphosate-based herbicides. We hope that experts in administrative law take a long deep look at this complex and politically controversial issue.

We also recommend that the New Zealand Environmental Protection Authority publicly responds to the criticisms contained in the New Zealand Medical Journal paper , so that a transparent and frank discussion concerning glyphosate, carcinogenicity and risk may ensue.

Jodie Bruning is a National Council member of Soil and Health and a trustee of Physicians and Scientists for Global Responsibility. Bruning is the 2019 recipient of the Robert Anderson Memorial Award, awarded annually by Amnesty International Tauranga Moana for outstanding contributions to human rights, peace and social justice.


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