The EPA's finding that glyphosate exposure does not cause any health risks is a blatant act of reckless endangerment to public health. Americans should be outraged, not just because our EPA is not protecting us, but because our government is allowing the collapse of democracy by pandering to corporate greed.
Summary
- The EPA assessed risks to humans from exposure to glyphosate from all registered uses and all routes of exposure and did not identify any risks of concern, including cancer.
- The EPA did not review any cumulative health impacts of glyphosate.
- The EPA did reduce the list of crop types with allowable levels of glyphosate residues from 160 to 15, however the crops removed likely did not utilize glyphosate, and the list is not complete.
- The EPA still has not responded to the EWG et al petition about discontinuing the use of glyphosate on oats and wheat as a desiccant or made a determination on residue levels.
- The EPA will do further assessments on the impact of glyphosate on bees and endangered species due to the Center for Biological Diversity mitigation.
- The EPA is limiting the amount of glyphosate used per acre, by category of use, in order to prevent further weed resistance.
- The EPA is requiring additional labeling for aquatic use which warns of fish kill from the lack of oxygen from dead water vegetation (note: not from glyphosate).
- A final decision will be made after a decision about the desiccation of wheat and oats, endangered species review, and an assessment of endocrine disruption. Decisions could be in 2020 for some and August 2021 for others.
A Thorough Assessment of the EPA’s Not-So-Thorough Assessment of Glyphosate
The EPA has been reviewing glyphosate, the declared active chemical ingredient in glyphosate-based herbicides most commonly known as Roundup or Ranger Pro, for over 10 years. During the last 120-day public comment period on glyphosate, the EPA received roughly 283,300 comments. Over 12,000 unique submissions were received from various stakeholders, including glyphosate registrants, grower groups, non-governmental organizations, pesticide industry groups, states, the U.S. Department of Agriculture, and members of the general public.
Glyphosate-based herbicides are the most widely used herbicides in the world. According to the EPA’s own study, between 2012 to 2016 approximately 281 million pounds of glyphosate was applied to 298 million acres annually in agricultural settings, on average. Most glyphosate was applied to genetically modified soybeans (117.4 million lbs applied annually), corn (94.9 million lbs applied annually), and cotton (20 million lbs applied annually). Many citrus fruits (e.g., grapefruit, oranges, lemons), field crops (e.g., soybean, corn, cotton), and tree nuts (e.g., almonds, walnuts, pistachios) have the highest percentage of their acres treated with glyphosate. Approximately 24 million pounds of glyphosate are applied to non-agricultural sites annually, on average. The majority of non-agricultural use is in the homeowner market (5 million lbs applied annually), turf (4.9 million lbs applied annually), forestry (3.6 million lbs applied annually), and roadways (3.3 million lbs applied annually).
HUMAN HEALTH
Despite massive public outcry, letters to the EPA, thousands of calls, protests, petitions, and campaigns regarding the myriad of ways glyphosate has been shown to impact human health the EPA released a statement on January 30, 2020:
The EPA thoroughly assessed risks to humans from exposure to glyphosate from all registered uses and all routes of exposure and did not identify any risks of concern.
The agency concluded that there are no dietary risks of concern for any segment of the population, even with the most conservative assumptions applied in its assessments (e.g., tolerance-level residues, direct application to water, and 100% crop treated). The agency also concluded that there are no residential, non-occupational bystander, aggregate, or occupational risks of concern.
Not only did they not find any human health risks of concern in the industry-funded studies they chose to review (ignoring the 67 studies that the International Agency for Research on Cancer reviewed, 82% of which found glyphosate to be genotoxic), they did not even look:
The EPA has not made a common mechanism of toxicity to humans finding as to glyphosate and any other substance and it does not appear to produce a toxic metabolite produced by other substances. Therefore, it was not appropriate for EPA to assess cumulative risks.
How can the EPA justify this?
They cannot justify cherry picking studies. There is simply no explanation for that..except for pandering to corporate pressure.
It is true, glyphosate is not immediately (acutely) toxic by EPA standards. 51% or more of animals will not die within 96 hours after exposure. But the EPA recklessly neglects to consider long-term, cumulative harm. This presumption is unrealistic because humans are exposed daily, on a long-term basis, to glyphosate in our food and communities.
The additional failure with the EPA’s assessment and their policies is that glyphosate is never used alone. It is used with many co-formulants, such as arsenic and heavy metals, that are up to 1000X more toxic than glyphosate alone. So reviewing glyphosate alone, and approving it alone, is allowing an unfounded approval of glyphosate-based herbicides. The entire policy of approving thousands of chemical products a year based on assessing one common ingredient in the products is faulty, misleading, irresponsible and harmful. This decision is akin to allowing sodium cyanide (poison) for use in our food supply with studies that only reviewed sodium (table salt).
The EPA repeatedly states in its findings:
EPA has thoroughly evaluated potential human health risk associated with exposure to glyphosate and determined that there are no risks to human health from the current registered uses of glyphosate and that glyphosate is not likely to be carcinogenic to humans.
The EPA also wiggled its way out of reviewing independent science by explaining:
The epidemiological literature was also reviewed but most studies were hypothesis-generating in nature. The EPA found there was insufficient evidence to conclude that glyphosate plays a role in any human diseases. Since the last EPA review of the epidemiological literature, two studies regarding the association between glyphosate exposure and non-Hodgkin’s Lymphoma (NHL) were identified for detailed review by the agency; however, these studies did not impact the agency’s assessment. For more information, refer to Glyphosate: Response to Comments on the Proposed Interim Decision Regarding the Human Health Risk Assessment, which is available on the public docket.
Notice how the sentence in red above completely contradicts the sentence before it in blue. The studies they ignore show a 41-50% increased risk of NHL (and Multiple Myeloma) with glyphosate exposure- they are not studies that should be ignored.
GLYPHOSATE RESIDUES ON CROPS
I suppose the EPA felt a concession was made when it removed many food types from the list of glyphosate allowable residue levels “since they will no longer be needed.” However, it is unlikely that glyphosate was being used on these mostly tropical crops. Nor are they the most commonly eaten crops, like soy, corn, sugar, peas, beans, wheat, and oats.
The EPA intends to establish new tolerances for various vegetable and fruit groups and subgroups, as listed in Table 1. Upon establishment of these new crop group tolerances, EPA intends to remove the following individual tolerances, since they will no longer be needed: acerola; aloe vera; ambarella; asparagus; atemoya; avocado; bamboo, shoots; banana; biriba; breadfruit; cactus, fruit; cactus, pads; canistel; cherimoya; custard apple; date, dried fruit; 10 Docket Number EPA-HQ-OPP-2009-0361 www.regulations.gov durian; feijoa; fig; fruit, stone, group 12; guava; ilama; imbe; imbu; jaboticaba; jackfruit; longan; lychee; mamey apple; mango; mangosteen; marmaladebox; noni; nut, tree, group 14; olive; palm heart; papaya; papaya, mountain; passionfruit; pawpaw; persimmon; pineapple; pistachio; pomegranate; pulasan; rambutan; rose apple; sapodilla; sapote, black; sapote, mamey; sapote, white; soursop; Spanish lime; star apple; starfruit; sugar apple; Surinam cherry; tamarind; vegetable, leafy, brassica, group 5; vegetable, leafy, except brassica, group 4; watercress, upland; and wax jambu.
Now the current EPA glyphosate residue level list has been modified from 160 items to the following:
Wheat and oats are mysteriously missing from the list, but not because they are not allowed to have glyphosate residue. Rather, the EPA is still assessing the use of glyphosate as a pre-harvest drying tool. The EWG and several food companies petitioned the EPA to stop the spraying of glyphosate on oats and wheat, as high levels of glyphosate were found in baby and toddler foods like oatmeal and cereals. The EWG et al asserted that children are especially vulnerable to glyphosate and therefore precautions must be taken to protect them. The EPA is still assessing this petition and plans to respond later in 2020. If the EPA did disallow the spraying of glyphosate as a drying agent on all foods, according to Dr. Zach Bush M.D., they could eliminate 50-90% of the exposure to humans to glyphosate through food, and follow the lead of 34 other countries.
The EPA has tragically closed the book on continuing to research the potential impact to human health from glyphosate.
No additional human health data needs have been identified for the glyphosate registration review beyond the human health data required as part of the registration review DCI, which has been satisfied.
IMPACT OF GLYPHOSATE ON BEES
The EPA does believe, however, that additional information is needed on the impact on bees from glyphosate.
Therefore, the agency is currently determining whether additional bee toxicity and exposure data are needed for glyphosate.
IMPACT OF GLYPHOSATE ON ENDANGERED SPECIES
The EPA also recognizes a need to assess the impact of glyphosate on endangered species.
Once the scientific methods necessary to complete risk assessments for listed species and their designated critical habitats are finalized, the agency will complete its endangered species assessment for glyphosate. The draft biological evaluation for glyphosate is anticipated in 2020.
IMPACT OF GLYPHOSATE ON SOIL
The EPA also sees plenty of benefits for glyphosate. Just one of their points:
Since glyphosate controls a broad spectrum of weeds and does not have residual soil activity, it can be used to control emerged weeds prior to planting high value crops such as fruits and vegetables, for which growers sometimes have limited weed control options.
The claim that glyphosate does not have residual soil activity is untrue. Glyphosate has been proven to destroy the microbes in the soil, kill the worms in the soil, and chelate minerals in the soil...essentially, all that creates healthy soil. When glyphosate depletes the soil of organic matter, the soil is less nutrient dense, leading to plants that are less nutrient dense. Such plants are more inclined to be sickly, which attracts pests like grasshoppers. The nutrient-depleted soil is also less able to absorb water, leading to increased crop damage in drought seasons, and increased run off of agro chemicals into waterways. Glyphosate does more than impact the soil, it impacts the crops, water, air, and every living thing it comes in contact with.
WEED RESISTANCE
Some living things are outsmarting glyphosate however, for instance hundreds of plants that are considered weeds have cleverly developed a resistance to glyphosate.
The EPA states:
Currently there are over 250 weed species worldwide with confirmed herbicide resistance. In the United States, there are over 155 weed species with confirmed resistance to one or more herbicides.
To reduce weed resistance in the future, the EPA defined some restrictions on the amount of glyphosate to be used per acre for all of the different uses. For example, up to 8 pounds per acre may be used per year on forestry land. Farming consultant Frank Dean states “These amounts are still far too much and will impact the quality of the soil and crops.”
The USA has 421,302 acres of forestry land, so there is a potential market for Bayer of the sale of over 3.3 million pounds of glyphosate just for the lumber industry. Thanks EPA! Never mind climate change, sell that glyphosate!
CONSERVATION LAND
The EPA touts the glories of glyphosate...including use on (millions of acres) conservation land:
Glyphosate is also important for habitat restoration efforts. It is used to control invasive annual, perennial, and woody plants in riparian habitats and rangeland. Glyphosate use in rights-of-way helps keep roadways and railroad tracks safe by protecting the stability of the surface, maintaining visibility for operators, and allowing for the distribution of goods, services, and utilities (gas and electric). Glyphosate is the most frequently used active ingredient used to control invasive species in the United States.
This means that conservationists have been duped into believing that glyphosate is harmless to our precious nature preserves, parks and wilderness, and they use it to prevent “invasive species.” What they do not realize is that by using glyphosate, they are changing the mineral makeup of the soil. When the soil is depleted of certain minerals, specific plants are more likely to grow...many of them are considered “invasive weeds.” In addition, the birds, pollinators, and butterflies that they work so hard to protect are being impacted by glyphosate. We are losing wildlife species every day...possibly forever.
AQUATIC USE
The EPA also indirectly addresses glyphosate’s impact on fish. They blame the dying weeds on the depleted oxygen in the water which, in turn, kills the fish.
Their new labeling (which is law) for environmental use of aquatic glyphosate herbicides (yes, they can spray it directly IN the water) will read as such:
“Killing aquatic weeds can result in depletion or loss of oxygen in the water due to hazards: for decomposition of dead plant material. This oxygen loss can cause fish suffocation. Consult with labels with your State agency with primary responsibility for regulating pesticides before applying to public both aquatic waters to determine if a permit is required. For terrestrial uses, do not apply directly to water, and terrestrial areas where surface water is present or to intertidal areas below the mean high-water mark uses [Optional text, if applicable: except when applying this product by air over the forest canopy]. Do not contaminate water when cleaning equipment or disposing of equipment wash waters and rinsate.”
Dr. Don Huber, a 50 year plant pathologist and Professor Emeritus of Perdue University responds to the glyphosate aquatic labeling with frustration, "A bunch of contradictory words and highly hypocritical! It is toxic regardless of how it is applied!"
CROP ROTATION
The EPA’s clarification, “For fields being rotated to a non labeled crop, any glyphosate application must be made a minimum of 30 days prior to planting,” means that a farmer can spray glyphosate on a field and 30 days later plant non organic carrots, sweet potatoes, strawberries or peppers, even if these crops are not genetically engineered to withstand glyphosate (non labeled). Regardless of a 1-4 week lag, these crops can still uptake glyphosate into the plant, can weaken the plant, and be ingested by animals and humans. Farming consultants have stated when phosphorus fertilizers are applied to the soil, the interaction with glyphosate has the glyphosate de-absorb from the soil molecules and is made free to be taken up by the plant. So a 1-4 week time makes no difference when it comes to absorption into the crop.
AERIAL APPLICATION
The EPA defined rules on the height of aerial applications for glyphosate (up to 10 feet from the ground in some cases), temperature, and wind speed. They also defined the size of the droplets of spray in order to reduce drift. As if any of these measures will actually prevent harm from glyphosate to an unpredictable bird or bee flying through the air at the time of spraying.
PENDING ASSESSMENTS
Surprisingly, the EPA does acknowledge some potential future changes in environmental use. Due to the case Center for Biological Diversity et al., v. United States Environmental Protection Agency et al., the EPA will need to do additional assessments on the impact to endangered species:
Although the agency is not making a complete endangered species finding at this time, the mitigation described in this document is expected to reduce the extent of environmental exposure and may reduce risk to listed species whose range and/or critical habitat co-occur with the use of glyphosate.
The timeline is defined, and the expectation is that assessments will be determined by the mitigation deadline of August 2021.
A Federal Register Notice will announce the availability of this Interim Registration Review Decision for glyphosate. A final decision on the glyphosate registration review case will occur after: (1) an EDSP FFDCA §408(p) determination, (2) an endangered species determination under the ESA and any needed §7 consultation with the Services, and (3) a resolution of the EWG et al. petition. This document finalizes the agency’s draft supporting documents: Glyphosate Draft Human Health Risk Assessment for Registration Review, and Registration Review—Preliminary Ecological Ris
The EPA does, again, clarify that they are not done with their review. They still (10 years was not enough) need to assess glyphosate for endocrine disruption.
In this ID (Interim Decision), the EPA is making no human health or environmental safety findings associated with the EDSP ( Endocrine Disrupting Screening Program) screening of glyphosate. Before completing this registration review, the agency will make an EDSP FFDCA § 408(p) determination.
STATEMENT FROM CHARLES BENBROOK
Charles Benbrook, a leading scientist and glyphosate expert, who has been an expert witness in the Monsanto trials, made a statement about the EPA’s decision:
I am flabbergasted at this decision. There is NOTHING -- ZERO -- in the EPA decision to reduce worker exposures and risks. How can EPA ignore the thousands of comments highlighting the need for EPA to recover its spine and require Bayer/Monsanto to take out the high-risk surfactants in most glyphosate-based herbicides (GBHs), so the GBHs sold in the USA are as safe as the reformulated products now sold in Europe? And why not require gloves, long sleeve pants, chemical-resistant shoes (aka rubber boots) for applicators using hand-held equipment and spraying a GBH for several hours per day, over many days per year, as part of their job or in keeping up with weeds on their rural property, homestead, or farm?
This irresponsible action by EPA sets the stage for a concerted campaign by many stakeholders to ban all uses of GBHs, and their prime targets will be major food companies, who won't need much of a push to follow in Kellogg's enlightened footsteps.
Note -- Kellogg recently announced a commitment to end pre-harvest applications of GBHs on all crops used in its products. Ending such pre-harvest, desiccation uses will eliminate a significant share of the glyphosate residues now in the US food supply. See more on this story on The Western Producer's website here: https://www.producer.com/2020/01/kelloggs-website-commits-to-phasing-out-glyphosate
Charles Benbrook
Heartland Study Project Coordinator
Benbrook Consulting Services
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