Subject: Corrected – Health Canada Proposes to Increase Glyphosate in Food ~ Have Your Say!

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Health Canada Wants to Increase Glyphosate in Food

Have your say by July 20th!


The Issue

Glyphosate is Canada's most-used herbicide, so levels in food are increasing, sometimes exceeding regulatory limits. Health Canada proposes to relax those limits.


Maximum Residue Limits (MRLs) may be more than doubled for oats and bran, lentils and peas, as well as nuts (almonds, pecans and walnuts, mostly coming from the US), or almost quadrupled for 25 types of beans such as chickpeas, kidney beans and pinto beans.


As weeds become resistant and farmers use more glyphosate-based herbicides (GBHs), Health Canada's Pest Management Regulatory Agency (PMRA) proposes to regulate according to the status quo.


Higher herbicide doses harm the environment, contaminate our food and risk our health. This model threatens Organic Agriculture, does not optimize carbon capture in soil or support biodiversity, nor build resilience to face the climate crisis.

 

Whose food will be most affected?


Canadian children. Glyphosate in childrens’ cereals (in oats and bran) are already at alarming levels


Vegetarians, vegans and everyone who gains protein from “conventionally” grown legumes and nuts are at risk of consuming more glyphosate.


Health risks were not evaluated


PMRA provides no health-based justification to increase herbicide contamination. indeed, health effects were not examined. The Proposal and related Evaluation Report obtained from the PMRA aim to adjust the regulation to suit increased use of GBHs.  


Increased legume contamination was based on data presented at a May 2019 Joint Food and Agriculture Organization / World Health Organization (FAO/WHO) meeting.  PMRA provided no scientific information on oats and bran. A dietary risk assessment was referenced, based on a 2005­–2010 US survey, “What We Eat in America.”

HAVE YOUR SAY BY JULY 20th

Tell the PMRA what you think of this proposal – PMRL2021-10.

Email your comments to hc.pmra.publications-arla.sc@canada.ca, or comment online, on “Proposed measures” for PMRL2021-10

Please share your response with:  Info@PreventCancerNow.ca  and  SafeFoodMatters@gmail.com

 

Comments should have a scientific basis and reference the content of PMRL2021-10. 
To get you started, here are some of our concerns.

Concerns

1. Glyphosate is already ubiquitous in agricultural regions.

Higher MRLs will increase contamination on and beyond farms, and we will have even more glyphosate in our food.

Glyphosate is in the soil, air and waterways, drifting in dust and falling in the rain in North America.


2. Glyphosate is a potent chemical – a herbicide, an antibiotic and a chelator – affecting human and environmental health.

As an antibiotic in animals (including humans, other mammals and insects) glyphosate kills bacteria and depletes beneficial gut microbes. Glyphosate caused “anal staining” according to industry-supplied rodent test data held by the PMRA, but they did not find this hallmark of dysbiosis to be “adverse.” Trends of related health effects mirror increasing glyphosate in food.

  • Dysbiosis may escalate to inflammatory bowel disease (IBD is increasing at 6% per year in young children in Canada). Increasing chronic inflammation with dysbiosis is reflected in similar rates of increasing colorectal cancer in our younger adults.

  • Glyphosate is a probable human carcinogen according to the International Agency for Research on Cancer (IARC). Cancer lawsuits are now costing Bayer billions of US dollars, following three successful prosecutions regarding non-Hodgkin lymphoma. Awards were augmented because Monsanto acted with malice, oppression, or fraud in suppressing and contesting the science, influencing regulators.

  • In bees, GBHs perturb the balance of microbes in the gut, possibly exacerbating pollinator decline. Pollinators are essential for legume production.

  • As an antibiotic in the soil, GBHs cause shifts in the soil microbiome, with increased fungi and mycotoxins, including Fusarium spp (e.g., infecting wheat). This contamination can make crops unsalable. Mycotoxins pose many risks to human and animal health, affecting the immune system, nervous system, liver and child development, and causing cancers.

  • As a chelator, glyphosate binds with and may mobilize metals in soil. Toxic metals such as cadmium (which is naturally high in many Prairie soils and Canadian potash fertilizer) is hyper-accumulated in grains and can exceed international MRLs (cadmium is not listed among Canada’s maximum levels for chemical contaminants in food). Cadmium, a known carcinogen, accumulates in bone and can disable essential enzymes, causing widespread disruption of the functioning of the body’s systems, damaging kidneys, impairing child development, promoting chronic disease and causing cancers.

 

3. Increased use of GBHs will further impact Canadian Organic Agriculture.

Organic commodities are already challenged by glyphosate contamination from drift, dust, possible contamination during shipping / handling and other consequences of ubiquitous environmental contamination from non-organic agriculture [2014, COTA Glyphosate Residue report].


This threat to Canadian Organic Agriculture is being averted in ways that do not protect food safety. “Organic” now means that farmers follow prescribed on-farm practices, but recognises that organic food cannot mean “pesticide-free” because of contamination from off-farm sources. The scale of GBH use and associated off-target contamination results in organic commodities losing markets, particularly in the EU and Asia where the MRLs for organic foods are much lower or zero-tolerance.


GBHs are no longer labelled to permit pre-harvest application intended to rapidly kill and dry grains, beans and seeds, because glyphosate accumulates in immature seeds. Nevertheless, such desiccation still occurs because the labels allow GBHs to be used pre-harvest to kill unwanted plants after seeds are sufficiently hardened. Moreover, glyphosate accumulation is inevitable in indeterminant cultivars such as some legumes (like chickpeas and lentils) that continue to grow and develop seeds.


4. GBHs are not a solution to the climate emergency.

No-till agriculture, that is reliant on GBHs, is being advanced as a solution to the climate crisis under the term “Regenerative Agriculture.” The buzz word “regenerative” lacks definition, but is perceived to be synonymous with protecting soil health. The much-emphasized no-till agriculture depends on  substantial use of GBHs to reduce weeds, and results in only short-term, shallow carbon sequestration.  When measuring carbon capture, soils must be tested at a depth of at least one metre, as carbon in the upper 10 to 20 centimeters can come and go. Longer-term storage, that happens at greater depths, is only possible using Organic Regenerative Techniques of farming that protect soil health at all soil depths.


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For more information:

Meg Sears PhD, Prevent Cancer Now

meg@preventcancernow.ca

613 297-6042


Mary Lou McDonald, SafeFoodMatters

SafeFoodMatters@gmail.com

905 467-8531

Prevent Cancer Now works to prevent cancer before it starts,

with research, education, and advocacy

to eliminate preventable contributors to cancer.

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