Subject: Glyphosate Objectors' Concerns Heightened by Health Canada Response

Glyphosate Objectors’ Concerns Are Heightened Following Replies from Health Canada (being released January 14, 2019 online)
 
Responses Dismiss Key Science and Lack Transparency
Canadians at Risk, With no Independent Review of Roundup Herbicide
 
For Immediate Release
 
Ottawa, January 14, 2018 – Today, Health Canada is releasing online, responses to eight objections to re-registration of glyphosate (the active ingredient in Roundup herbicide). Government responses leave objectors more concerned than ever.

Cancer, chronic disease and food quality were inadequately or inaccurately addressed by Health Canada (see Additional Information below).
 
Prevent Cancer Now and other health and environmental groups, university professor and researchers, are disappointed that an independent panel will not scrutinize Canada’s primary pesticide, despite a history of scientific interference and bias (see media release).
 
In briefings by PMRA officials on January 11, 2019, responses to questions from objectors revealed that public health, toxic metals in food and soil quality were summarily dismissed as being outside of the scope of pesticides assessment (see below).
 
Instead of an independent investigation of the re-registration of glyphosate, twenty Pest Management Regulatory Agency (PMRA) staff examined the work of their colleagues, based upon objections submitted in 2017. In briefings, objectors were told of rigorous scientific reviews, but there was no mention of key, current, relevant publicly available research.
 
Glyphosate is the world’s most-used herbicide. Canadian sales data places glyphosate in its own open-ended category – since 2007, more than 25 million kilograms are sold annually.
 
Quotes from Objectors and Experts
 
“Young Canadians are getting sicker, with chronic diseases earlier in life. Glyphosate effects on gut microbes can contribute to bowel, immune, metabolic and neurological conditions that cost society dearly, and the healthcare system billions of dollars. When Health Canada dismisses relevant science as out of scope, the goal to protect human health cannot be met,” said Dr. Meg Sears, Chair of Prevent Cancer Now.
 
“Acting only when extreme effects are seen in animals doesn’t protect human health. Even small effects can result in large impacts across the entire population,” cautioned Dr. David Bowering, former Medical Health Officer, Northern Health, BC.
 
The World Health Organization’s International Agency for Research on Cancer (IARC) found that glyphosate probably causes human cancer. Health Canada responded that the IARC assessment is not relevant because it identified a hypothetical hazard rather than an exposure-associated risk. While IARC does not conduct a formal risk assessment, the panel does examine hazards in human, real-life studies. It is disingenuous to characterize findings of an IARC panel as irrelevant to everyday exposures, particularly when data on Canadians getting cancer was included in the IARC review.
 
“Multiple epidemiologic studies have indicated links between glyphosate and increased susceptibility to development of non-Hodgkin’s lymphoma, myeloma, as well as multidrug resistant bacteria. This is of sufficient concern that it warrants that an independent panel be struck to review the science backing the PMRA’s claim that there is no need to re-review this issue. What level of evidence would be sufficient to trigger a review of the status of glyphosate? Who were the reviewers and what is their expertise? Their clear requirement for “proof of harm” before further review is even more concerning for the Canadian public,” said Dr. Richard van der Jagt, MD, FRCP, a cancer specialist who has many years of cumulative experience treating lymphoma and myeloma patients.
 
“Monsanto’s influence has polluted the scientific literature and improper tactics have been employed by the agro-chemical industry to undermine regulatory decisions world-wide,” stated Kathleen Ruff of Right On Canada. “Ethical, scientific and transparency standards have not been followed, thus destroying public trust.”

When asked, Health Canada responded that it does not have a Code of Scientific Conduct.
 
Mary Lou McDonald of Safe Food Matters asked why some objections were not answered, including the fact that the government’s own data recognizes that labels are not followed. The response was that only objections based in science were responded too. She observed that it was clear from the call [January 11th] that there is no comprehensive scientific approach code adhered to by PMRA, and that the “scientific approach” of PMRA is limited to toxicology studies in the lab, and requires proof that these old, confidential studies were wrong.
 
Prof. Louise Vandelac, Professor at the University of Quebec in Montreal, a researcher at CINBIOSE and director of CREPPA, seriously questions the scientific rigor and transparency of the PMRA . “It claims having consulted sources other than those mentioned in the consultation paper in support of its decision, but without identifying the documents. The PMRA's decision is based mainly on dated and unpublished documents prepared by the agrochemical industry benefiting from the decision. This ethical problem is aggravated by the lack of systematic review of the scientific literature of the last 15 years which shows among others things, the need to perform whole-life analyzes on laboratory animals and to make a scientific assessment of the glyphosate-based commercial formulations, that are up to 1000-fold more toxic than the glyphosate analyzed (Mesnage et al. 2014). The PMRA claims to rely on other agencies such as EFSA in Europe, although registration in Europe was limited to 5 years, not 15 years as it is in Canada. The European report was significantly extracted from a Monsanto document, as revealed by Le Monde (Nov. 26, 2017).”
 
Josette Wier strongly disagreed with Health Canada’s claim to transparency. “This was the worse process I was ever part of. Requests brought no referral to a regulatory framework, the decision took one year and a half to be issued.”
 
Sears noted, “Despite transparency provisions introduced in the Pest Control Products Act (2002), pesticide assessment is opaque. The data evaluation remains confidential. The public sees the final decision, and can take pencil and paper to the Reading Room in Ottawa to copy information from hundreds of industry reports. As of December 31, 2018, Health Canada is required to have established an open Science Integrity Policy. We will see if this will bring more light to data evaluations.”
 
For more information please contact:
 
Meg Sears PhD, Chair Prevent Cancer Now  613 297-6042
 
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Further Information:
The responses from Health Canada’s PMRA did not address or were factually incorrect regarding at least five points raised by objectors:
 
1.    Objectors highlighted an analysis of the confidential animal carcinogenicity dataset by Dr. Christopher Portier highlighted eight tumours that were not counted in any analyses by international authorities, or presumably by the PMRA. The PMRA characterized this as an issue of statistics, rather than under-estimating cancers. At issue is improper use of historical “control” numbers, counting cancers in undosed animals from other studies, eating regular, presumably glyphosate-containing chow.
 
2.    The World Health Organization’s International Agency for Research on Cancer (IARC) classified glyphosate as a probable human carcinogen, in 2015. Dr. Connie Moase indicated during the briefing that IARC does not consider human exposure levels, despite the fact that IARC considered Canadian studies of cancers in workers exposed to glyphosate - example.
 
3.    Glyphosate mobilizes cadmium and other toxic metals, that can then accumulate in grains and other crops. This is well known – In the 1990s then-Environment Canada assembled a database of plants that hyper-accumulate toxic metals, and accumulation in wheat is investigated by Agriculture and Agri-Food Canada. Cadmium is a potent toxin and carcinogen, that is at higher concentrations in some Canadian agricultural regions, and in potash fertilizer. Canada has no standard for cadmium in food, but our grains have been refused at borders for exceeding international standards. Cadmium was not mentioned in the responses, nor apparently further investigated. In the telephone briefing, Health Canada representatives expressed unfounded hypothetical doubt, but the claimed rigorous review overlooked scientific proof of glyphosate actually mobilizing cadmium, and cadmium being lower in organic food, as has been the repeatedly expressed concern.
 
4.    Glyphosate is an antibiotic. Antibiotics disturb the intestinal microbiome, and predispose to inflammatory bowel disease (IBD is increasing 7% annually in young Canadian children), and to colorectal cancer (increasing 7% annually in young Canadian adults). Inspecting confidential test data in the Reading Room revealed that the PMRA assessment dismissed “anal staining” in animal studies – clear signs of intestinal distress – as not “adverse.” Thus, the animal toxicity that would predict Canada’s public health crisis of IBD and colorectal cancer, had been discounted.
 
5.    Differences in food quality when crops are “dessicated” and do not completely mature, were also out of scope. Glyphosate kills some soil microbes, resulting in more crop pathogens. To reduce toxic moulds, and for convenience in harvesting, crops may be “dessicated” by rapid killing with glyphosate before they mature completely and dry naturally. Pesticide application immediately pre-harvest is prohibited in some countries, to prevent the higher residue levels.  Glyphosate accumulates in the seeds of legumes and beans, including chickpeas, and exceeds legal limits, but this magnification of dietary exposure was not considered. Canada Food Inspection Agency data shows that these crops, and grains, have exceeded science-based maximum residue limits. Health Canada explained that an exceedance indicates only that further investigation is warranted, but does not necessarily mean that there is a health risk. In fact, these exceedences warrant a transparent examination of current levels of toxins accumulating in seeds, the levels of consumption by the population, an evaluation of the unaccounted for risks, and rapid action.  
 
Prevent Cancer Now, P.O. Box 86058 Marda Loop, Calgary, Alberta T2T 6B7, Canada
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