Close relationships between the British Government, the Agrochemical
Industry, the European Food Safety Authority and the European Commission
Contents Page
Genetically Engineered Foods: The Biggest Fraud in the History of Science 1
Glyphosate, destroyer of human health and global biodiversity 3
Commercial formulations of herbicides induce changes in antibiotic response to E.Coli and 5
S.enterica serovar Typhimurium; they are biocides
ADAS recommended pre-harvest spraying of glyphosate on crops and spraying on grassland, 6
but the first papers had been written by Monsanto scientists without declarations of conflict
and without peer-review
The public is unaware that glyphosate (and other pesticide) residues are present in food 8
despite the fact that pre-harvest spraying began in Britain in 1980
Disinformation from Science Media Centre and Glyphosate Task Force 9
The Scandal of Glyphosate Re-assessment in Europe 16
Other independent studies on the toxicity of formulated glyphosate and proof of 18
deterioration of health in the UK and the US
Britain involved with corporations at the expense of the health of the public 24
Open letter from America to the Prime Minister warning the UK against GM crops: November 28
2014
Background on systemic neonicotinoid insecticides: regulation by industry 28
Conflicts of Interest in the EU: the Committees are controlled by industry: ‘professional’ 33
members take turns in rotating around the committees
European Commission, EFSA, UK, WHO and UNEP delay the criteria for defining endocrine 41
disruptors. Is it to protect the Agrochemical Industry and the herbicide
glyphosate/Roundup®?
Other ways in which UK Ministers failed to adhere to the precautionary principle but 46
preferred to support corporations and the economy
UK denies that exposure to environmental chemicals damages foetal brains 48
The Verdict of the Permanent Peoples’ Tribunal concerning the six indicted corporations 50
(BASF, BAYER, DOW CHEMICAL, DUPONT, MONSANTO, SYNGENTA)
Genetically Engineered Foods: The Biggest Fraud in the History of Science1
Governments and leading scientific institutions have systematically misrepresented the facts
about GMOs and the scientific research that casts doubt on their safety
On 4 March 2015 the Organisation Beyond GM facilitated the Press Release of American public
interest attorney Steven Druker’s acclaimed new book, Altered Genes, Twisted Truth How the
Venture to Genetically Engineer Our Food Has Subverted Science, Corrupted Government and
Systematically Deceived the Public.2
His book reveals how governments and leading scientific institutions have systematically
misrepresented the facts about GMOs and the scientific research that casts doubt on their safety. 3
1
Altered Genes, Twisted Truth: Steven M Druker. How the Venture to Genetically Engineer Our Food Has
Subverted Science, Corrupted Government and Systematically Deceived the Public. 2015 Clear River Press.
page 384
2
http://beyond-gm.org/new-book-exposes-systematic-government-and-scientific-fraud-over-gm-food/
3
http://www.gmwatch.org/index.php/news/archive/2015-articles/15973
1
GM Watch reported: “The book features a foreword by the renowned primatologist Dame Jane
Goodall, who will also speak at the conference, hailing it as “without doubt one of the most
important books of the last 50 years.”
The book’s revelations come at a crucial time when the UK is considering the commercial planting of
GM crops following the European Parliament’s decision to allow member states to opt out of the
blockade that has barred them from the EU until now. Based on the evidence presented in the book,
Druker and Goodall will assert that it would be foolhardy to push forward with a technology that is
unacceptably risky and should never have been allowed on the market in the first place. The book is
the result of more than 15 years of intensive research and investigation by Druker, who came to
prominence for initiating a lawsuit against the US Food and Drug Administration (FDA).
Steven Druker initiated a lawsuit against the US Food and Drug Administration (FDA) that forced it
to open its files on GM foods
Those files revealed that GM foods first achieved commercialisation in 1992 only because the FDA:
* Covered up the extensive warnings of its own scientists about their dangers
* Lied about the facts
* And then violated federal food safety law by permitting these foods to be marketed without having
been proven safe through standard testing
“Druker’s well-referenced book points out that if the FDA had actually heeded its own experts’
advice, told the truth, and obeyed the law, the GM food venture would have imploded and never
gained traction anywhere.” There were extensive media resources 4 but the launch failed to be
reported in the newspapers. It is not surprising since many august bodies, scientific journals and
philanthropists in the UK & US are supporting GM.5
Druker challenges UK Royal Society over misleading statements made about GM foods
Open Letter to the UK Royal Society can be read here.6
Extracts: “Because clarifying the facts about GM foods is crucial for developing an intelligent, science-
based policy on the future of agriculture, and because the Royal Society has significantly contributed
to the confusion that currently surrounds this issue, it is imperative that remedial action be promptly
initiated. This is especially so considering that:
The European Commission is about to approve substantial regulatory changes in regard to GM
crops.
The UK is seriously considering allowing them to be commercially planted.
The Society and other proponents of GM foods have inculcated the widespread illusion that there is
an overwhelming scientific consensus that the safety of these products has been established through
rigorous testing…”
Unless you promptly take these steps, it will demonstrate that your commitment to promoting GM
foods is stronger than your commitment to honoring the truth and upholding the integrity of
science. FURTHER, whether or not you own up to your irresponsible actions and take the steps
specified above, I challenge you to read my book and specifically list any inaccurate statements of
fact that you find in it, accompanied by an explanation of why the statement is erroneous and a
reference to the evidence that corroborates your assertion.”
4
http://beyond-gm.org/altered-genes-twisted-truth-media-resources/
5
Royal Society, Wellcome Foundation, Bill & Melinda Gates, Lord David Sainsbury and the Gatsby Foundation,
Rothamsted Research, John Innes Centre, Sainsbury Laboratory, Civil Servants from Defra, NFU, James Hutton
Institute, BIS, Offices of Life Sciences, Centre for Food Security, Food Standards Agency, etc.
6
http://beyond-gm.org/wp-content/uploads/2015/03/DRUKER_OPEN-LETTER-TO-THE-ROYAL-
SOCIETY_Final.pdf
2
Three years ago, a secret meeting was held between the Agricultural Biotechnology Council (ABC),
representing industry, two UK Ministers, two MPs, Civil Servants, Scientists and NFU to discuss the
barriers to introducing Genetically Modified Crops (GM) into Britain and how to overcome them
On 25th October 2012 Dr Helen Wallace Director of Genewatch and Pete Riley Campaign Manager
GM Freeze published a Press Release: 7 Monsanto meets Ministers to push return of GM crops to
Britain. On 26 June 2012, Roundtable discussion on ‘Going for Growth’: Realising the potential of
agricultural technologies in the UK. Attendees 8 included Government Ministers, MPs, Civil Servants
from Defra, the Department of Business, Innovations and Skills, Office of Life Sciences, Director of
the Centre for Food Security, John Innes Centre, Rothamsted Research, James Hutton Institute, the
National Farmers Union and the Agricultural and Horticultural Development Board. Here are the
links to the Agenda 9 and a summary of the meeting.10 The ABC had also communicated with the
Food Standards Agency (FSA). These organisations have colluded with industry.
Glyphosate, destroyer of human health and global biodiversity
World Health Organisation’s International Agency for Research on Cancer (IARC) has
declared glyphosate as a 2A carcinogen (probably carcinogenic in humans)
The IARC reached its decision based on the view of 17 experts from 11 countries, who met
in Lyon, France, to assess the carcinogenicity of 5 organophosphate pesticides. 11
“In male CD-1 mice, glyphosate induced a positive trend in the incidence of a rare tumour,
renal tubule carcinoma. A second study reported a positive trend for haemangiosarcoma in
male mice. Glyphosate increased pancreatic islet-cell adenoma in male rats in two studies. A
glyphosate formulation promoted skin tumours in an initiation-promotion study in mice.
Glyphosate has been detected in the blood and urine of agricultural workers, indicating
absorption. Soil microbes degrade glyphosate to aminomethylphosphoric acid (AMPA). Blood
AMPA detection after poisonings suggests intestinal microbial metabolism in humans.
Glyphosate and glyphosate formulations induced DNA and chromosomal damage in
mammals, and in human and animal cells in vitro. One study reported increases in blood
markers of chromosomal damage (micronuclei) in residents of several communities after
spraying of glyphosate formulations. Bacterial mutagenesis tests were negative. Glyphosate,
glyphosate formulations, and AMPA induced oxidative stress in rodents and in vitro. The
Working Group classified glyphosate as “probably carcinogenic to humans” (Group 2A).”
This is the first influential institute that has taken into account independent science.
However, the IARC Monograph Volume 112 20/03/201512 has no legal power to ban
glyphosate. “The Monographs Programme provides scientific evaluations based on a
comprehensive review of the scientific literature, but it remains the responsibility of
individual governments and other international organizations to recommend regulations,
legislation, or public health intervention.”
7
http://www.genewatch.org/article.shtml?als%5Bcid%5D=569457&als%5Bitemid%5D=571449
8
http://tinyurl.com/9jbce4g
9
http://tinyurl.com/8ahylza
10
http://tinyurl.com/92rrajn
11
http://www.thelancet.com/pdfs/journals/lanonc/PIIS1470-2045(15)70134-8.pdf Carcinogenicity of
tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate.
12
http://www.iarc.fr/en/media-centre/iarcnews/pdf/MonographVolume112.pdf
3
Monsanto, which produces the glyphosate-containing herbicide, Roundup®, strongly
disagreed with the decision. "All labeled uses of glyphosate are safe for human health," said
Phil Miller, a Monsanto spokesman, in a statement.13
In 2011 Earth Open Source challenged the European Commission. “Independent scientific
literature shows glyphosate causes endocrine disruption, damage to DNA, reproductive
and developmental toxicity, neurotoxicity, and cancer as well as birth defects”
The last reassessment in Europe of glyphosate, the most widely used herbicide, was in 2002.14 It was
due to be reassessed in 2012.
In 2011, a multinational paper written by eight experts, the authors challenged the European
Commission about its continued registration of Roundup®. Roundup and Birth Defects: is the public
being kept in the dark? 15 They said: “The European Commission has previously ignored or dismissed
many other findings from the independent scientific literature showing that Roundup® and
glyphosate cause endocrine disruption, damage to DNA, reproductive and developmental toxicity,
neurotoxicity, and cancer, as well as birth defects. Many of these effects are found at very low doses,
comparable to levels of pesticide residues found in food and the environment.”...“This issue is of
particular concern now that Monsanto and other producers of genetically modified seed are trying to
get their glyphosate-tolerant crops approved for cultivation in Europe. If the EU Commission gives its
approval, this will lead to a massive increase in the amount of glyphosate sprayed in the fields of EU
member states, as has already happened in North and South America. Consequently, people’s
exposure to glyphosate will increase.”
“Shortly after the European Commission was notified of the latest research showing that glyphosate
and Roundup® caused birth defects, it quietly passed a directive delaying the review of glyphosate
and 38 other dangerous pesticides until 2015” (including the highly toxic 2,4-D and diquat).
The EU Commissioner for Health, John Dalli, resigned on 12/10/2012 after an anti-fraud inquiry
linked him to an attempt to influence tobacco legislation.16 He denied the allegation.
The same authors challenged the German RMS and the Regulatory Decisions in Europe
Antoniou, M., et al. Teratogenic Effects of Glyphosate-Based Herbicides: Divergence of Regulatory
Decisions from Scientific Evidence. J Environ Anal Toxicol 2012, S:4 17
Abstract: The publication of a study in 2010, showing that a glyphosate herbicide formulation and
glyphosate alone caused malformations in the embryos of Xenopus laevis and chickens through
disruption of the retinoic acid signalling pathway, caused scientific and regulatory controversy.
Debate centred on the effects of the production and consumption of genetically modified Roundup
Ready® soy, which is engineered to tolerate applications of glyphosate herbicide. The study, along
with others indicating teratogenic and reproductive effects from glyphosate herbicide exposure, was
rebutted by the German Federal Office for Consumer Protection and Food Safety, BVL, as well as in
industry-sponsored papers. These rebuttals relied partly on unpublished industry-sponsored studies
commissioned for regulatory purposes, which, it was claimed, showed that glyphosate is not a
teratogen or reproductive toxin. However, examination of the German authorities’ draft assessment
report on the industry studies, which underlies glyphosate’s EU authorisation, revealed further
evidence of glyphosate’s teratogenicity. Many of the malformations found were of the type defined
in the scientific literature as associated with retinoic acid teratogenesis. Nevertheless, the German
13
http://www.usnews.com/news/business/articles/2015/03/20/popular-weed-killer-deemed-probable-
carcinogen-by-un
14
http://ec.europa.eu/food/plant/protection/evaluation/existactive/list1_glyphosate_en.pdf
15
http://earthopensource.org/earth-open-source-reports/roundup-and-birth-defects-is-the-public-being-kept-
in-the-dark/
16
http://europa.eu/rapid/press-release_MEMO-12-788_en.htm
17
http://omicsonline.org/2161-0525/2161-0525-S4-006.php?%2520aid=7453
4
and EU authorities minimized these findings in their assessment and set a potentially unsafe
acceptable daily intake (ADI) level for glyphosate. This paper reviews the evidence on the
teratogenicity and reproductive toxicity of glyphosate herbicides and concludes that a new and
transparent risk assessment needs to be conducted. The new risk assessment must take into account
all the data on the toxicity of glyphosate and its commercial formulations, including data generated
by independent scientists and published in the peer-reviewed scientific literature, as well as the
industry-sponsored studies.
Commercial formulations of herbicides induce changes in antibiotic response
to E.Coli and S.enterica serovar Typhimurium; they are biocides
Four different patents have been filed for glyphosate in the US by Monsanto (and granted)
As a chelator of heavy metals (used to clean boilers) and a wetting agent in 1961 18
As a herbicide in 1968 19
As an antibiotic in 200220
As an anti-protozoal agent in 200321
“Antibiotic-resistant diseases pose an 'apocalyptic' threat to humans.” Vets, farmers and GPs were
blamed for overuse of antibiotics. 22 In 2013, the Chief Medical Officer told MPs that this issue
should be added to the national risk register of civil emergencies. In March 2014 I wrote to inform
her that glyphosate had been patented as an antibiotic. I finally had a reply: “Given the detailed
regulatory regime for plant protection products, this is the most appropriate place for these issues to
be considered.”
When Prof Mark Woolhouse, Professor of Infectious Disease Epidemiology at the University of
Edinburgh, and Dr Jeremy Farrar, Director of the Wellcome Trust, published an article in Nature on
29/04/2014 about the Intergovernmental Panel on Antimicrobial Resistance 23 I wrote to inform
them that glyphosate had been patented as an antibiotic, but received no reply. Here is a scientific
paper that confirms it.
Herbicides dicamba, 2,4-D and glyphosate are biocides which have sub-lethal effects on microbes
Kurenbach, B, et al. Sublethal Exposure to Commercial Formulations of the Herbicides Dicamba, 2,4-
Dichloro- phenoxyacetic Acid, and Glyphosate Cause Changes in Antibiotic Susceptibility in
Escherichia coli and Salmonella enterica serovar Typhimurium. Mbio; Journal for the American
Society of Microbiology. 2015; Vol 6 1-9.24
ABSTRACT Biocides, such as herbicides, are routinely tested for toxicity but not for sublethal effects
on microbes. Many biocides are known to induce an adaptive multiple-antibiotic resistance
phenotype. This can be due to either an increase in the expression of efflux pumps, a reduced
synthesis of outer membrane porins, or both. Exposures of Escherichia coli and Salmonella enterica
serovar Typhimurium to commercial formulations of three herbicides—dicamba (Kamba), 2,4-
dichlorophenoxyacetic acid (2,4-D), and glyphosate (Roundup)—were found to induce a changed
response to antibiotics. Killing curves in the presence and absence of sublethal herbicide
18
http://www.google.com/patents/US3160632
19
http://www.google.com/patents/US3455675
20
http://www.google.com/patents/US7771736
21
http://patft.uspto.gov/netacgi/nph-
Parser?Sect1=PTO1&Sect2=HITOFF&d=PALL&p=1&u=%2Fnetahtml%2FPTO%2Fsrchnum.htm&r=1&f=G&l=50&
s1=7771736.PN.&OS=PN/7771736&RS=PN/7771736
22
http://www.theguardian.com/society/2013/jan/23/antibiotic-resistant-diseases-apocalyptic-threat
23
http://www.nature.com/news/policy-an-intergovernmental-panel-on-antimicrobial-resistance-1.15275
24
http://mbio.asm.org/content/6/2/e00009-15.full.pdf+html
5
concentrations showed that the directions and the magnitudes of responses varied by herbicide,
antibiotic, and species. When induced, MICs of antibiotics of five different classes changed up to 6-
fold. In some cases the MIC increased, and in others it decreased. Herbicide concentrations needed to
invoke the maximal response were above current food maximum residue levels but within application
levels for all herbicides. Compounds that could cause induction had additive effects in combination.
The role of soxS, an inducer of the AcrAB efflux pump, was tested in β-galactosidase assays with
soxS-lacZ fusion strains of E. coli. Dicamba was a moderate inducer of the sox regulon. Growth assays
with Phe-Arg β-naphtylamide (PAβN), an efflux pump inhibitor, confirmed a significant role of efflux
in the increased tolerance of E. coli to chloramphenicol in the presence of dicamba and to kanamycin
in the presence of glyphosate. Pathways of exposure with relevance to the health of humans,
domestic animals, and critical insects are discussed.
IMPORTANCE Increasingly common chemicals used in agriculture, domestic gardens, and public
places can induce a multiple antibiotic resistance phenotype in potential pathogens. The effect occurs
upon simultaneous exposure to antibiotics and is faster than the lethal effect of antibiotics. The
magnitude of the induced response may undermine antibiotic therapy and substantially increase the
probability of spontaneous mutation to higher levels of resistance. The combination of high use of
both herbicides and antibiotics in proximity to farm animals and important insects, such as
honeybees, might also compromise their therapeutic effects and drive greater use of antibiotics. To
address the crisis of antibiotic resistance requires broadening our view of environmental contributors
to the evolution of resistance.
The regulatory regime in which the CMO had such faith failed. The German Rapporteur Member
State recommended re-approval of glyphosate to the European Food Safety Authority (EFSA)
Professor Dr Dr Andreas Hensel President of the Federal Institute of Risk Assessment (BfR) at a Press
release in March 2014 said on behalf of BfR:“These new studies do not suggest that glyphosate has
carcinogenic or embryo-damaging properties or that it is toxic to reproduction in test animals. The
data do not warrant any significant changes in the limit values of the active ingredient... Worldwide,
glyphosate is one of the most common active ingredients in pesticides used to prevent unwanted
plant growth in plant cultivation or to accelerate the ripening process of crops (desiccation).
Glyphosate inhibits an enzyme (5-enolpyruvylshikimate- 3-phosphate synthase) which is essential for
the biosynthesis of certain amino acids. This enzyme is not found in animals and humans.“ 25
This final statement by the German BfR is wrong: glyphosate poisons humans in the same way as it
poisons plants. Humans and animals have exactly the same pathway as in plants; mammals can only
absorb nutrients via the bacteria in their gut; the gut microbiome. The gut microbiome is the
collective genome of organisms inhabiting our body.26 Pesticide scientists and plant scientists have
based their assessment of herbicides on complete ignorance of human physiology. UK public health
experts and physicians in the Wellcome Trust and the Royal Society have failed to question the
accuracy of the assessors‘ knowledge.
ADAS recommended pre-harvest spraying of glyphosate on crops and
spraying on grassland, but the first papers had been written by Monsanto
scientists without declarations of conflict and without peer-review
25
http://www.bfr.bund.de/en/press_information/2014/03/glyphosate__no_more_poisonous_than_previously_
assumed__although_a_critical_view_should_be_taken_of_certain_co_formulants-188898.html
26
http://www.nature.com/nature/journal/v500/n7464/abs/nature12506.html
6
ADAS recommended pre-harvest crop spraying with Roundup® in 198027 and spraying on grassland
in 1985. Researches showed two Monsanto scientists wrote the first papers (without declaring it)
In 1980 UK ADAS28 (at that time the science and advisory branch of Ministry of Agriculture, Fisheries
and Food (MAFF) but now privatised) was recommending that arable farmers use pre-harvest
application of glyphosate on cereal crops. M.G. O’Keeffe, a Monsanto scientist29 wrote three
articles about it, the first at a Crop Protection conference. 30 They do not appear to have been peer-
reviewed. By 1985 ADAS was advocating the use of glyphosate on grassland. They declared it to be
good practice to graze the grass or preserve it as hay or silage after treatment.31 However, the main
author of the paper was another Monsanto scientist, Colin D Stride.32 He later joined Exponent®, a
firm which provides services for industry, governments and for EU regulatory bodies.33
In a 4-month project starting in the UK in January 2007: Pre-harvest glyphosate for weed control and
as a harvest aid in cereals 34 the authors stated in their introduction:
“Concern over residues, as expressed by the Food Safety Authority Report, appears to relate to the
incidence of residues rather than to the levels of the residues. Data from Monsanto and Cessna et al.
(1994 & 2002) suggest that the level of residues is associated with dose but that even the lower
doses used for harvest aid will leave detectable levels at harvest. Hence, any initiative to reduce the
incidence of residues must be to reduce the proportion of the crop sprayed rather than to reduce the
dose of the individual applications.” However, they do not appear to have performed any glyphosate
residue measurements.
The manufacturers succeeded in having glyphosate re-registered in 2002
When glyphosate was being re-assessed in Europe in 2002, the German Rapporteur Member State
received a letter from a British farmer via the UK Pesticides Safety Directorate, written on 4 May
1999, giving first hand evidence of the toxicity of glyphosate to humans and animals, and the
reporting of its toxicity in independent research papers.35 The farmer made a very perceptive
comment: “This is an unsatisfactory and dangerous situation, not just for the victims directly
involved, but for the entire population of the world, since if the manufacturers have their way our
27
http://www.hgca.com/media/185527/is02-pre-harvest-glyphosate-application-to-wheat-and-barley.pdf
28
ADAS is now the UK’s largest independent provider of agricultural and environmental consultancy, rural
development services and policy advice; formerly a branch of Ministry of Agriculture, Fisheries & Food. (MAFF)
29
https://books.google.co.uk/books?id=objYBAAAQBAJ&pg=PA555&lpg=PA555&dq=Monsanto+O%27Keeffe+M
G&source=bl&ots=3k7GWMRWZ3&sig=wg0ZhiNFMTY86cNp_cP3jV4Dz3A&hl=en&sa=X&ei=Twz-
VPmWA8mBU93GgqgP&ved=0CEkQ6AEwBg#v=onepage&q=Monsanto%20O'Keeffe%20MG&f=false Chemical
Manipulation of Crop Growth and Development Proceedings of Previous Easter Schools in Agricultural Science
by J. S. McLaren
30
O'Keeffe MG. The control of Agropyron repens and broad-leaved weeds pre-harvest of wheat and barley
with the isopropylamine salt of glyphosate; 1980. pp. 53–60. Proceedings of British Crop Protection
Conference-Weeds.
31
Stride CD, Edwards RV, Seddon JC. Sward destruction by application of glyphosate before cutting or grazing;
1985. pp. 771–778. British Crop Protection Conference – Weeds 7B–6.
32
http://www.exponent.com/files/Attorney/2f28f368-0f2c-48d0-91c2-
60589cce38f1/Presentation/ceExpertCVUpload/stride,c_full.pdf
33
“Exponent, Inc., a research and scientific consultant firm with clients from industry (including crop protection)
and government” Mr. Stride compiles national and zonal dRR format biological assessment dossiers and dRR
evaluation dossiers to meet the needs of Regulation 1107/2009 for plant protection products for re-registration
at Annex III or new active substances at Annex I. He also provides advice on efficacy and trial programmes;
conducts data gap analyses, identifying potential problems and solutions, drafts efficacy protocols to fit EU
guidelines and good agronomic practice, and can manage efficacy testing programmes including study
monitoring and ensuring reporting standards are high. He also compiles study summaries and tiered dossiers
for Biocides in IUCLID5.
34
http://archive.hgca.com/publications/documents/cropresearch/RR65_Final_Research_Review.pdf
35
http://www.scribd.com/doc/57155451/FULLREPORT-GLYPHOSAT-04#scribd
7
crops will depend on the widespread use of glyphosate.” He was correct. In 2015, 16 years later, the
manufacturers are still having their way and it looks as if glyphosate will soon be re-registered
thanks to collusion between Industry, German RMS, EFSA and the EU Commissioners.
The public is unaware that glyphosate (and other pesticide) residues are
present in food despite the fact that pre-harvest spraying began in 1980
Defra Expert Committee on Pesticide Residues in Food:36 Monsanto is responsible for humans and
animals having glyphosate residues in their bodies: it is in all staple, non-organic foods
The results from monitoring of Pesticide Residues in Food (PRiF) have been published quarterly in
the UK since 2000, but pre-harvest application to crops had already been authorised 20 years
before. Bread and breakfast cereals are staple foods but there are no maximum residue limits
(MRLs) for bread or breakfast cereals. Residues in bread are tested twice a year.
e.g .2002 3rdQuarter: Comments from PRiF: “Residues of chlormequat, 37 glyphosate and pirimiphos-
methyl38 were found (in bread). These pesticides are commonly used on cereal crops, and residues
have been found in other cereal products, therefore these findings are not unexpected. None of the
residues found were of concern for consumer health. “
2011 3rd/4th Quarters for Lentils: Comments: “Sixteen samples of lentils contained glyphosate above
the MRL. A new higher level of glyphosate is expected to come into force in summer 2012. None of
the residues detected in this survey would be above the new proposed MRL.”
When the CRD Head of Regulatory Policy replied on 28/02/2014 to defend the authorisation of
glyphosate, he told me that the capability to detect individual pesticides in food had increased from
150 in 2003 to 393 in 2012. He stated: “In the 2012 Report, although there were a large number of
residues found in bread, none of these were at a level to suggest a risk to consumer health.”
However, he failed to reply to my question as to why EFSA was regularly increasing the Maximum
Residue Limits (MRLs) of glyphosate in foods at the request of Monsanto to accommodate their
practice of desiccation of crops and to protect their imports into Europe.39
The use of glyphosate for desiccation of both barley and wheat was accepted by the brewing and
distilling industries in 200740 therefore it is probable that men will have higher glyphosate residues
because of the consumption of beer and/or whisky. Many foods imported from the US have GM
ingredients and will contain glyphosate (or other herbicide) residues. These include products which
are made from corn or soya, such as energy bars, sugar drinks; and fruit or vegetables. Glyphosate is
used as a ‘ripener’ on sugar cane and is usually sprayed by air 6 weeks before harvest. The US still
does not require labelling of GM. Animals in the UK are fed with imported GM soya and maize.
CRD/PSD Annual Report 2008/200941 Is the CRD a safety agency, or a service agency for industry?
Extracts: "This has been a very busy year in the approvals group. Applications for product approvals
were 9% over business estimates with a total of 1,767 applications received and 1,622 applications
completed this year, 96% of which were completed within published targets. Importantly 100% of
36
http://www.pesticides.gov.uk/guidance/industries/pesticides/advisory-groups/PRiF/about-PRiF
37
Chlormequat, a plant growth regulator was present consistently throughout.
38
pirimiphos-methyl, is an organophosphate insecticide for use in storage. The approval was revoked on
24/03/2011, but it was only finally banned 31/03/2013, presumably to allow stocks to be used up.
39
http://www.efsa.europa.eu/en/efsajournal/pub/2550.htm
40
Notes on the use of Roundup®products on malting, milling and seed crops: Monsanto UK Ltd 2007.
http://www.grainfarmers.co.uk/seeddownloads/Roundup%20on%20seed%20%20milling%20and%20malting.p
df
41
http://www.pesticides.gov.uk/Resources/CRD/Migrated-
Resources/Documents/A/Annual_report_and_accounts_final.pdf
8
‘fast track’ applications identified by industry as high priority to their business needs were completed
within published targets. Achieving this demanding target despite the increase in applications has
required diligent application and commitment of evaluating staff and their managers and represents
a significant achievement. We continue to support growers and we have completed the first stage of
the conversion exercise for the ‘Long Term Arrangements for Extension of Use’ on non-edible crops.
Of the 401 uses requested by growers, the 131 products containing active substances that have
already been fully reviewed in the EU review programme, and included on Annex I of Council
Directive 91/414/EEC have been completed. The remaining product/uses identified by growers will be
automatically included in the on-going re-registration process minimising the impact on industry. We
also assisted in the evaluation of new products by helping companies work towards the completion
of appropriate dossiers through the provision of detailed advice. This advice has covered both
chemical pesticides and biopesticides that we continue to support under our biopesticides scheme.
We submitted completed evaluation reports for 5 new active substances where the UK was the EU
Rapporteur Member State and issued 3 UK provisional authorisations in advance of Annex I inclusion.
In addition we completed 8 ‘partial dossier’ submissions.
About 60% of the CRD budget comes from industry. “Our work is funded from three main income
streams. Firstly, income from industry is generated through fee-paid work, the pesticides levies and
other chargeable events (e.g. training).” Page 9
Detection of glyphosate: One example of this was a project to develop analytical chemistry methods
to allow the detection of glyphosate (a widely used herbicide) and other pesticides in cereal crops
(project PS2538 on Defra‟s Science website EC legislation sets a very low level (0.01mg/kg)) for
pesticide residues in infant food. This level has been very difficult to achieve particularly for the
herbicides, glyphosate, which is widely used as a dessicant [sic] on cereal crops. However, the Food
and Environment Research Agency (Fera) has now developed a method which will allow the routine
analysis of glyphosate in cereal based infant foods down to 0.01 mg/kg within the Pesticide Residues
Committee (PRC) monitoring programme. This is a significant step forward. Page 10
Comment: Thongprakaisang S, et al.42 Glyphosate induces human breast cancer cells growth via
estrogen receptors. Food Chem Toxicol. 2013, 59C: 129-136.
The study found that breast cancer cell proliferation is accelerated by glyphosate in extremely low
concentrations. “The present study used pure glyphosate substance at log intervals from 10 -12 to 10-6
M. These concentrations are in a crucial range which correlated to the potential biological levels at
part per trillion (ppt) to part per billion (ppb) which have been reported in epidemiological studies.”
Disinformation from Science Media Centre and Glyphosate Task Force
Why is the London Science Media Centre hosted by the Wellcome Trust and sponsored by
industry, but not by NGOs or Unions?
Colin Macilwain, a science policy writer from Edinburgh who has worked as a reporter and an editor
from both sides of the Atlantic43 wrote about plans to replicate Britain’s Science Media Centre (SMC)
in the United States, which he said was “fraught with danger.”
Extracts: “The London SMC was set up because UK scientific leaders were upset that
environmentalists had successfully fought the introduction of genetically modified food; they felt that
the UK media were too susceptible to environmental scare stories about new technologies.
Despite the fears of the SMC founders, the British press — led by the BBC, which treats the
Confederation of British Industry with the deference the Vatican gets in Rome — is overwhelmingly
conservative and pro-business in its outlook. It is quite unperturbed by the fact that SMC sponsors
42
http://www.ncbi.nlm.nih.gov/pubmed/23756170
43
http://magz.elibraries.eu/ul/1826/Nature%20Magazine%207389%20-%202012-03-15.pdf
go.nature.com/klnuna World View Nature 15th March 2012
9
include AstraZeneca, BP, Coca-Cola, L'Oreal, Monsanto, Syngenta (as well as Nature Publishing
Group) but not a single environmental non-governmental organization (NGO) or trade union.
Fiona Fox, the SMC's director, says that the centre operates independently of its sponsors and points
out that none (except its host, the Wellcome Trust) accounts individually for more than 5% of its
income. She adds that no NGOs are involved because it was their public-relations skills that the
founders of the SMC sought to match.”
Macilwain goes on to say: “But the perception that the environmental group Friends of the Earth
constitutes a bigger threat to scientific truth-telling than some of the corporate names on the SMC's
sponsorship list is not one the US media would accept.
Some of those considering a US centre share these concerns. They think that their funding model will
have to rely on charitable trusts, not companies or government agencies.”
Glyphosate Facts: Transparency on safety aspects and use of glyphosate containing herbicides in
Europe 44
This website and the website of the European Glyphosate Task Force (GTF) are interlinked.
Glyphosate Facts provides service and advice for farmers.
There is a 12-page paper on the Clarification of Pre-harvest uses of glyphosate: The advantages, best
practices and residue monitoring 45
“Many residue trials have been carried out over many years with pre-harvest uses. The residue data
from these trials are used as the basis for the setting maximum residue levels (MRLs) for crops like
cereals, pulses and oil seed crops where pre-harvest treatments are recommended.” Many studies of
residues in the 2002 reassessment of glyphosate are unpublished.46
The third reference is: How valuable is glyphosate to UK agriculture and the environment? 47
It was not possible to discover the provenance of this paper without purchasing a copy from the
publishers. However, it was worth the expense. The authors came from ADAS, (now a private
company) the branch of MAFF that was the first to recommend pre-harvest application of
glyphosate, from a paper written by O’Keeffe, a Monsanto Scientist. “Sarah K. Cook, Sarah C. Wynn
and James H. Clarke, ADAS UK Ltd, consider the contribution glyphosate makes to cost-effective
agriculture and biodiversity in the UK.” James Clarke is Science and Business Development Manager
for ADAS soils, crops and water. He was an Independent Member of the Advisory Committee on
Pesticides (ACP) as an expert in efficacy and farming systems, from 2003-2007. He was Chairman of
the UK Pesticides Forum.
Pesticides Forum Annual Report 2011 Executive Summary 48
Pesticides Forum Executive Summary in 2011 states that: “the use of pesticides is not adversely
impacting on the health of UK citizens or the environment. This is testimony to the effectiveness of
both statutory and voluntary controls.”
Extracts: “The Pesticide Usage Survey figures are considered by Monsanto to be an underestimate of
the usage of glyphosate in the UK, particularly concerning the amount of glyphosate applied to pre-
planting to crops (P280)… but Monsanto believes that the agricultural use each year is approximately
double this in the UK.” Table 2 Estimated losses to industry due to loss of glyphosate (£M) P281
44
http://www.glyphosate.eu/
45
http://www.glyphosate.eu/system/files/sidebox-files/clarification_of_pre-
harvest_uses_of_glyphsate_en_0.pdf
46
http://ec.europa.eu/food/plant/protection/evaluation/existactive/list1_glyphosate_en.pdf
47
http://www.ingentaconnect.com/content/resinf/opm/2010/00000021/00000006/art00008
48
http://www.pesticides.gov.uk/Resources/CRD/Migrated-Resources/Documents/P/Pesticides-Forum-AR-
2011-revSep12.pdf
10
The authors discuss glyphosate under the following headings: Importance and extent of glyphosate
use in the UK; Calculating the cost of losing glyphosate; Impact on farmer income; Impact on food
cost; Environmental impacts (including increase in greenhouse gas emissions of 25%); Socio-
economic impacts (The use of glyphosate has a monetary impact upon the farmer, but also on the
farmer’s quality of life).
Conclusion: In conclusion, the loss of glyphosate would cause very severe impacts on UK agriculture
and the environment. To ensure it remains available for use in future will need to involve all relevant
stakeholders (farmers, agronomists and policy makers). Farmers and agronomists need to ensure
that they implement best practices to minimise the risks of glyphosate entering water in order to
maximise the benefits that can be gained from this herbicide. There needs to be interaction with
policy makers to find appropriate solutions as necessary.
The Value of Crop Protection by Séan Rickard: Commissioned by the Crop Protection Association
The ADAS paper was published in December 2010, the same month as Prof Séan Rickard’s Report to
defend pesticides from an EU ban. Each document gave apocalyptic warnings to the EU, to UK
farmers and to the public.
‘Séan Rickard, a well-known economist from Cranfield University, wrote the present Government’s
Agricultural manifesto and is currently an Academic Adviser to the government.’ His second report,
The Value of Crop Protection 49(commissioned by the Crop Protection Association and first appeared
on its website on 7th December 2010), examines the economic benefits of Plant Protection Products
PPPs (i.e. pesticides) to the food supply. Prof Rickard warned that if the EU banned pesticides, food
costs could soar up to 40% in the UK and could add £70 billion to the country’s food bill.
Most of the early reports of pre-harvest use of glyphosate came from Monsanto scientists
(O’Keeffe, Stride, Czepō) although this was not obvious from the publications
“Many residue trials have been carried out over many years with pre-harvest uses.”
In Chapter 6 of Monsanto’s document, Agronomic Benefits of Glyphosate in Europe,50 Pre-harvest
weed control in arable crops and grassland there are three references in Hungarian from the
Registration Manager for Monsanto (M. Czepō), two papers from scientists working for Monsanto
(O’Keeffe & Stride) and undisclosed documents from Monsanto (perhaps they were commercially
sensitive?). In Czepō’s PhD Thesis,51 he had many ‘plugs’ for GM crops and glyphosate, without it
being made clear that he worked for Monsanto.
The European Glyphosate Task Force52 monitors articles and supplies data for re-assessment
The European Glyphosate Task Force (GTF) is described as “a consortium of companies joining
resources and efforts in order to renew the European glyphosate registration with a joint
submission.” Their other role appears to be to dismiss out of hand all the articles which have
‘unsubstantiated allegations about glyphosate’. 53
For example, in combination with Monsanto 54 the GTF successfully put pressure on the Sri
Lankan Government to stop restrictions on use of glyphosate in tea planting areas where
nephrotoxic metals were present and where workers were suffering from Chronic Kidney
Disease of unknown aetiology (CKDu).55 The Glyphosate Task Force declared that:
49
http://www.cropprotection.org.uk/media/1903/cpa_the_value_of_crop_protection_rickard_report.pdf
50
http://www.monsanto.com/products/Documents/glyphosate-background-
materials/Agronomic%20benefits%20of%20glyphosate%20in%20Europe.pdf
51
http://193.6.34.234/doktori/2004/Czepo_Mihaly_theses_en.pdf
52
http://www.glyphosatetaskforce.org/
53
http://www.glyphosate.eu/gtf-statements/gtf-responds-unsubstantiated-allegations-about-glyphosate
54
http://www.glyphosate.eu/gtf-statements/restrictions-glyphosate-sri-lanka-not-supported-scientific-
evidence
55
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3945589/
11
“Glyphosate is used extensively in many countries where comparable rates of CKDu are not
evident.” On the contrary, there are many reports of CKDu in agricultural workers all over
the world56 where glyphosate is used, particularly those that harvest tea and in sugar cane
workers (when glyphosate is used for ripening and sprayed by air 6 weeks before harvest) .
The GTF also dismissed an article in The Ecologist 57 (Glyphosate: A converging pattern of
toxicity from farm to clinic to laboratory) which they describe as “sensationalist and that no
credible studies or new data exist to support the claims made by the author… For over forty
years, regulators and public authorities around the world have conducted extensive risk
assessments - all of which have concluded that glyphosate does not pose any unacceptable
risk to the environment or human health.“ 58
The GTF dismissed the article59 about Glyphosate in the urine of Dairy Cows in Denmark as
“no reason to believe that the results are of any scientific merit, as the authors fail to report
any meaningful or relevant data.“ The GTF said: “All credible scientific studies carried out to
date on this issue have concluded that glyphosate is excreted in animals and humans as
unmetabolised parent molecule. There has not been any indication of Glyphosate inducing
kidney damage. Furthermore, it is important to point out that glyphosate and the primary
environmental metabolite, AMPA, have not been reported in the milk of dairy cattle… The
German risk assessment authority, BfR, has published a first assessment of the study on its
website: "In a first assessment of the study the Federal Institute for Risk Assessment (BfR)
concludes that the reported results do not prove a causal link between glyphosate exposure
of the animals and their observed changes of enzyme activities and other laboratory
parameters." 60
The response of the GTF61 to the 2-year feeding study by Prof Séralini “A study conducted by
a French university team led by Gilles-Eric Séralini was presented during a press conference in
September 2012. The scientists claimed to have found negative health effects including
tumor development and a shortened life time in laboratory rats fed a diet containing a
glyphosate containing herbicide and genetically modified NK603 maize. Numerous scientists
have examined the study and expressed their doubts and criticism on its validity. Their
published comments may be viewed under the links provided below. 62(The links are to the
Science Media Centre which publishes advice for journalists and provides an almost identical
service to industry as the Glyphosate Task Force!) In summary, many scientists hold the
opinion that this study does not meet minimum acceptable standards for this type of
scientific research, the findings are not supported by the data presented, and the conclusions
are not relevant for the purpose of safety assessment.”
Séralini’s 2-year feeding study provoked chronic hormone and sex dependent pathologies
in rats; males developed tumours at 4 months and females at 7 months63
“The health effects of a Roundup®-tolerant genetically modified maize (from 11% in the diet),
cultivated with or without Roundup®, and Roundup® alone (from 0.1 ppb in water), were
studied 2 years in rats. In females, all treated groups died 2–3 times more than controls, and
more rapidly. This difference was visible in 3 male groups fed GMOs. All results were
56
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3945755/ Page 14, item 14.
57
http://www.theecologist.org/News/news_analysis/2769439/roundup_a_converging_pattern_of_toxicity_fro
m_farm_to_clinic_to_laboratory.html
58
http://www.glyphosate.eu/gtf-statements/gtf-responds-unsubstantiated-allegations-about-glyphosate
59
http://www.glyphosate.eu/glyphosate-urine-danish-dairy-cows-statement-glyphosate-task-force-0
60
http://dx.doi.org/10.4172/2161-0525.1000186
61
http://www.glyphosate.eu/response-glyphosate-task-force-study-professor-seralini
62
http://www.sciencemediacentre.org/expert-reaction-to-gm-maize-causing-tumours-in-rats/
63
http://dx.doi.org/10.1016/j.fct.2012.08.005
12
hormone and sex dependent, and the pathological profiles were comparable. Females
developed large mammary tumours almost always more often than and before controls, the
pituitary was the second most disabled organ; the sex hormonal balance was modified by
GMO and Roundup® treatments. In treated males, liver congestions and necrosis were 2.5–
5.5 times higher. This pathology was confirmed by optic and transmission electron
microscopy. Marked and severe kidney nephropathies were also generally 1.3–2.3 greater.
Males presented 4 times more large palpable tumors (kidney) than controls which occurred
up to 600 days earlier. Biochemistry data confirmed very significant kidney chronic
deficiencies; for all treatments and both sexes, 76% of the altered parameters were kidney
related. These results can be explained by the non- linear endocrine-disrupting effects of
Roundup®, but also by the overexpression of the transgene in the GMO and its metabolic
consequences.”
Authors’ highlights:
1. A Roundup®-tolerant maize and Roundup® provoked chronic hormone and sex
dependent pathologies.
2. Female mortality was 2–3 times increased mostly due to large mammary tumours and
disabled pituitary.
3. Males had liver congestions, necrosis, severe kidney nephropathies and large palpable
tumours.
4. This may be due to an endocrine disruption linked to Roundup® and a new metabolism
due to the transgene.
5. GMOs and formulated pesticides must be evaluated by long term studies to measure
toxic effects.
A year later, the Editor of Food and Chemical Toxicology retracted the paper after a Monsanto
Scientist, Richard Goodman, had been appointed to the Journal.
What the global scientific community said about the retraction of Séralini’s paper:
Claire Robinson on behalf of GMWatch said: Journal retraction of Séralini study is illicit, unscientific,
and unethical.64 It violates the guidelines for retractions in scientific publishing set out by the
Committee on Publication Ethics (COPE), of which FCT is a member.
COPE guidelines state that the only grounds for a journal to retract a paper are:
Clear evidence that the findings are unreliable due to misconduct (e.g. data fabrication) or
honest error
Plagiarism or redundant publication
Unethical research
Prof Séralini’s paper does not meet any of these criteria and Hayes admits as much. In his letter
informing Prof Séralini of his decision 65 Hayes concedes that an examination of Prof Séralini’s raw
data showed “no evidence of fraud or intentional misrepresentation of the data” and nothing
“incorrect” about the data.
Hayes states that the retraction is solely based on the “inconclusive” nature of the findings on
tumours and mortality, given the relatively low number of rats used and the choice of rat strain,
which Hayes says naturally has a “high incidence of tumours”.
“Crucially, however, inconclusiveness of findings is not a valid ground for retraction. Numerous
published scientific papers contain inconclusive findings, which are often mixed in with findings that
can be presented with more certainty. It is for future researchers to build on the findings and refine
scientific understanding of any uncertainties”.
64
http://www.gmwatch.org/index.php/news/archive/2013/15184
65
http://www.prnewswire.co.uk/news-releases/elsevier-announces-article-retraction-from-journal-food-and-
chemical-toxicology-233754961.html
13
Euronews66 A new editor at the journal, Richard Goodman, is a biologist who formerly worked for
Monsanto – the leading producer of GM foods. French MEP Corinne Lepage said: “If this magazine,
which just hired a former Monsanto employee as an editor, withdraws this study, it’ll mean it never
existed. What we have tried to do, to try and carry out studies of the long-term effects of genetically-
modified foods and pesticides on human health, will be permanently shut off.” * In 2015 Richard
Goodman no longer seems to be an editor.
European Network of Scientists for Social and Environmental Responsibility ENSSER67
“In short, the decision to retract Séralini's paper is a flagrant abuse of science and a blow to its
credibility and independence. It is damaging for the reputation of both the journal Food and Chemical
Toxicology and its publisher Elsevier. It will decrease public trust in science. And it will not succeed in
eliminating critical independent science from public view and scrutiny. Such days and times are
definitively over. Prof. Séralini's findings stand today more than before, as even this secret review
found that there is nothing wrong with the technicalities, conduct or transparency of the data – the
foundations on which independent science rests. The conclusiveness of their data will be decided by
future independent science, not by a secret circle of people.”
Republication of the Séralini study in a new journal: Science speaks for itself
Press release: GMOSeralini.org, 24 June 2014. Séralini and colleagues republished their 2 year study
of GMO maize and Roundup® in rats in Environmental Science Europe by the Springer Group,68
together with its raw data. The team described the attacks they received in 2012 when it was first
published in Journal of Food & Chemical Toxicology, from those with conflicting interests, 69including
the Science Media Centre. Reported around the world, it received minimal publicity in the UK.
The WHO/IARC Report classifying glyphosate as a probable carcinogen (2A)
This is what the GTF70 had to say about the WHO recent classification of glyphosate as a carcinogen.
“Evaluations carried out by regulatory authorities across the world for over forty years have all
confirmed that glyphosate poses no unacceptable risk to humans, animals or the environment. The
Glyphosate Task Force (GTF) therefore does not accept the recent classification of glyphosate by the
International Agency for Research on Cancer (IARC) as a Group 2A carcinogen. The evaluation which
has produced this outcome demonstrates serious deficiencies in terms of methodological approach
and the overall conclusion is inconsistent with the results of all regulatory reviews”
What they fail to mention is that industry has been self-regulating glyphosate for 40 years.
Expert Reaction to the Science Media Centre downplays the significance of the IARC Statement 71
No-one has mentioned that glyphosate reassessment is almost completed. Are they aware?
Prof Andreas Kortenkamp, Professor in Human Toxicology at Brunel University London, said:
The authorities in the EU must now consider whether existing measures are sufficient to protect
consumers and pesticide applicators from cancer risks.
Dr Oliver Jones, Senior Lecturer in Analytical Chemistry at RMIT University in Melbourne:
This sounds scary and IARC evaluations are usually very good, but to me the evidence cited here
appears a bit thin.
66
http://www.euronews.com/2013/11/28/french-researcher-claims-gm-food-lobbyists-pulled-study-from-
journal/
67
http://www.ensser.org/democratising-science-decision-making/ensser-comments-on-the-retraction-of-the-
seralini-et-al-2012-study/
68
http://www.enveurope.com/content/26/1/14
69
http://www.gmoseralini.org/republication-seralini-study-science-speaks/
70
http://www.glyphosate.eu/gtf-statements/statement-gtf-recent-iarc-decision-concerning-glyphosate
71
http://www.sciencemediacentre.org/expert-reaction-to-carcinogenicity-classification-of-five-pesticides-by-
the-international-agency-for-research-on-cancer-iarc/
14
Prof Alan Boobis, Professor of Biochemical Pharmacology at Imperial College London, said:
In my view this report is not a cause for undue alarm. Prof Alan Boobis is Vice-President of the Board
of Directors of the International Life Sciences Institute (ILSI) Europe, Vice Chairman of the Scientific
Advisory Committee of ILSI Europe and a Member of the Board of Trustees. The membership of ILSI
Europe consists of 56 (as of 12 Feb 2015) organisations.72 This list represents Global Corporations
(including the six Agrochemical Giants) with massive resources that are seeking to control the
world’s food supply. ILSI is an industry organisation based in Washington, DC, USA. Under Declared
Interests Prof Boobis states: “I have no consultancies or grants from pesticide companies.” This
might be technically true, but his position on the ILSI Scientific Advisory Committee with many
scientists from corporations must represent conflicts! He was on the Editorial Board of the Journal
of Food and Chemical Toxicology (now Emeritus Editor). In fact he was the first to give expert
reaction to the Science Media Centre calling for withdrawal of Séralini’s paper on the effects of GM
Maize on rats. 73 “However, there are instances where the conclusions of a paper significantly over-
interpret the findings, as was the case here.”
Prof Sir Colin Berry, Emeritus Professor of Pathology at Queen Mary University of London, said:
The weight of evidence is against carcinogenicity.
Prof David Coggon, Professor of Occupational and Environmental Medicine at the University of
Southampton, and Chairman of the UK Committee on Toxicity of Chemicals in Food, Consumer
Products and the Environment (CoT) said: The IARC report does not raise immediate alarms.
However, I would expect regulatory authorities around the world to take note of this new evaluation,
and to consider whether it indicates a need to review their risk assessments for any of the pesticides
that they currently approve. Prof Coggon is Chairman of one of these Regulatory Committees.
Prof Tony Dayan, Emeritus Toxicologist, said:
Detailed analysis of the nature and quality of the evidence overall does not support such a high level
classification, which at the most should be Class IIB.”
The Scandal of Glyphosate Re-assessment in Europe
Glyphosate re-assessment in Europe has been described as ‘fraudulent’ and ‘inadequate’
There are two independent organisations that have raised serious questions about the German
Rapporteur Member State’s re-assessment of glyphosate.
The Institute of Science in Society (I-SIS) Report 07/09/2014
Scandal of Glyphosate Re-assessment in Europe 74
EU rapporteur state Germany recommends re-approval with daily intake increased by 67 %; its
re-assessment was carried out by Monsanto and a consortium of chemical companies in Europe
based almost entirely on studies from industry; it should be rejected outright.
“But BfR and its federal agency partners did not actually review the published toxicology studies.
Instead they relied on a summary provided to them by the Glyphosate Task Force (GTF)”
Testbiotech highlights renewed concern over the risk assessment of glyphosate
Report by German authorities on the most commonly used herbicide criticised as inadequate
Friday, 10. October 2014
In a report published today, Testbiotech is highlighting the ongoing inadequacies in the risk
assessment of the herbicide, glyphosate. 75 The weed killer is sold under brand names such as
Roundup. At the beginning of this year, German authorities published a Renewal Assessment
72
http://www.ilsi.org/Europe/Pages/currentmembers.aspx
73
http://www.sciencemediacentre.org/expert-reaction-to-reports-of-a-request-for-gilles-eric-seralini-to-
withdraw-his-paper-on-the-effects-of-gm-maize-on-rats/
74
http://www.i-sis.org.uk/Scandal_of_Glyphosate_Reassessment_in_Europe.php
75
http://www.testbiotech.org/sites/default/files/Testbiotech_doubts_safety_Glyphosat.pdf
15
Report (RAR) as part of an EU re-evaluation process for the most widely used weed killer.
According to the German authorities, there were no risks to health, and it was even suggested
that the acceptable daily thresholds for long term exposure (ADI) to which consumers could be
exposed might be raised.
In contrast to these findings, the Testbiotech analysis shows that the German assessment report
is untenable in light of new scientific evidence and cites evidence from studies published in 2013
and 2014. Testbiotech concluded that risks associated with glyphosate must be examined much
more closely than has been the case so far.
EFSA’s Reasoned Opinion Panel increases MRLs at the request of industry (Monsanto)
Monsanto Europe asked EFSA to set the import tolerance for glyphosate in lentils “in order to
accommodate the authorised desiccation use of glyphosate in lentils in the US and Canada” from 0.1
mg/kg to 10 mg/kg76 (i.e. 100 times: January 2012). EFSA had granted similarly elevated MRLs for
glyphosate on wheat and GM soya.
Monsanto convicted of fraud with regard to false advertising in 1996
In 1996, the Attorney General of the State of New York, Consumer Frauds and Protection Bureau,
Environmental Protection Bureau successfully brought a case against Monsanto with regard to: False
advertising by Monsanto regarding the safety of Roundup® herbicide (glyphosate). 77
Monsanto’s document: The agronomic benefits of glyphosate in Europe [2010]78
Despite having been convicted of false claims in 1996, Monsanto repeated the same lies in a
document published 2010 entitled “The agronomic benefits of glyphosate in Europe” [28, p.3]: the
same year as glyphosate was granted the patent as an antibiotic.79 “Since its discovery in the early
1970’s the unique herbicidal active ingredient glyphosate has become the world’s most widely used
herbicide because it is efficacious, economical and environmentally benign. These properties have
enabled a plethora of uses which continue to expand to this day providing excellent weed control
both in agricultural and non-crop uses to benefit mankind and the environment.” Further, it states
that glyphosate has an “excellent safety profile to operators, the public and the environment” (italics
added). The document outlined at least 16 use areas (p. 3) from vegetation control on land
throughout agricultural production, on GM Roundup® Ready Crops and on non-agricultural land
“around structures on farms, amenity and industrial areas and on railways” (p. 4).
On page 4, Monsanto makes another fraudulent claim about the use of glyphosate to increase
wildlife and biodiversity: “Increased wildlife and biodiversity: Use of glyphosate instead of
mechanical weed control techniques on non-cropped/amenity land preserves wildlife like small
mammals and birds. Adoption of Conservation agriculture encourages earthworms and other
invertebrates as well as birds. Judicious use of glyphosate to control excessive plant growth and
invasive weeds on or around waterways and lakes encourages wildfowl and much other wildlife.”
An additional claim was made for GM Crops (p. 4): “Use of glyphosate tolerant crops allows later
control of weeds providing early food sources for many invertebrates and birds and thus increases
animal numbers.” This is another lie, as witnessed by Craig Childs’ description below from the US.
Farms in the US where Monsanto’s Roundup® Ready crops are grown are biological deserts
76
http://www.efsa.europa.eu/en/efsajournal/pub/2550.htm
77
http://www.mindfully.org/Pesticide/Monsanto-v-AGNYnov96.htm
78
http://www.monsanto.com/products/Documents/glyphosate-background-
materials/Agronomic%20benefits%20of%20glyphosate%20in%20Europe.pdf
79
http://www.google.com/patents/US7771736
16
Craig Childs, author of Apocalyptic Planet, describes searching for signs of life in 2012 on a farm in
Grundy Count, Iowa, which was growing Monsanto’s GM Bt Roundup® Ready corn: “I had come to a
different type of planetary evolution. I listened and heard nothing, no bird, no click of an insect.” 80
American journalist Robert Krulwich reviewed Apocalyptic Planet: “Yet, 100 years ago, these same
fields, these prairies, were home to 300 species of plants, 60 mammals, 300 birds, hundreds and
hundreds of insects. This soil was the richest, the loamiest in the state. And now, in these patches,
there is almost literally nothing but one kind of living thing. We’ve erased everything else. There’s
something strange about a farm that intentionally creates a biological desert to produce food for one
species: us. It’s efficient, yes. But it’s so efficient that the ants are missing, the bees are missing, and
even the birds stay away. Something’s not right here. Our cornfields are too quiet.” 81
Britain joins forces with Monsanto
On 23/09/2013 the British Government 82 joined forces with Monsanto, EFSA and the EU Commission
to fight civil society in the EU Court to defend the right to import Monsanto’s transgenic soybean
Intacta® which produces an insecticide and is resistant to glyphosate herbicides such as Roundup®.
GM crops to be fast-tracked in UK following EU vote83
However, the UK and Monsanto won’t need legal action. In January 2015 they persuaded the
European Commission to allow countries free votes on GM crops, without any idea about
herbicide/glyphosate residues in our/their food.
Other independent studies on the toxicity of formulated glyphosate and
proof of significant deterioration of health in the UK and the US
Roundup® and AMPA residues in GM Soya: GM Soya is not ‘substantially equivalent’
Prof Thomas Bøhn’s paper from Norway which found that GM soya is not ‘substantially equivalent’
to non-GM has been ignored.84 This paper describes the nutrient and elemental composition,
including residues of herbicides and pesticides, of 31 soy bean batches from Iowa, USA.
In a commentary on the paper Bøhn wrote: “Extreme Levels” of Roundup® in Food Became the
Industry Norm:85 “Roundup® Ready GM-soy accumulates residues of glyphosate and
aminomethylphosphonic acid (AMPA) and GM soy also differs markedly in nutritional composition
compared with soybeans from other agricultural practices. Organic soybean samples also showed a
more healthy nutritional profile (e.g. higher in protein and lower in saturated fatty acids) than both
industrial conventional and GM soybeans. Lack of data on pesticide residues in major crop plants is a
serious gap of knowledge with potential consequences for human and animal health. How is the
public to trust a risk assessment system that has overlooked the most obvious risk factor for herbicide
tolerant GM crops, i.e. high residue levels of herbicides, for nearly 20 years? If it has been due to lack
of understanding, it would be bad. If it is the result of the producer’s power to influence the risk
assessment system, it would be worse.”
80
Craig Childs: Apocalyptic Planet: Chapter 6 Species Vanish. “How shall the heart be reconciled to its feast of
losses?” Stanley Kunitz, American Poet 1905-2006.
http://www.houseofrain.com/bookdetail.cfm?id=1344621970977
81
Robert Krulwich commenting on Craig Childs’ weekend in a field growing Monsanto’s Roundup Ready Corn.
http://www.npr.org/blogs/krulwich/2012/11/29/166156242/cornstalks-everywhere-but-nothing-else-not-
even-a-bee
82
http://www.testbiotech.de/en/node/898
83
http://www.euractiv.com/sections/agriculture-food/gm-crops-be-fast-tracked-uk-following-eu-vote-311313
84
http://www.sciencedirect.com/science/article/pii/S0308814613019201 Compositional differences in
soybeans on the market: glyphosate accumulates in Roundup Ready GM soybeans.
85
http://www.independentsciencenews.org/news/how-extreme-levels-of-roundup-in-food-became-the-
industry-norm/
17
From: Compositional differences in soybeans (Organic, Conventional and GM.) from Iowa, USA. Reproduced by
kind permission of Prof Thomas Bøhn, Genøk, Centre for Biosafety, Norway.
In Europe in 2014: The first study to measure glyphosate residues in Danish dairy cattle and its
impact on blood parameters. Field Investigations of Glyphosate in Urine of Danish Dairy Cows 86
Abstract: In the present study, thirty dairy cows from each of eight Danish dairy farms were investigated for
excretion of glyphosate in urine. Blood serum parameters indicative of cytotoxicity as alkaline phosphatase
(AP), glutamate dehydrogenase (GLDH), glutamate oxaloacetate transaminase (GOT), creatinine kinase CK),
nephrotoxicity, (urea, creatine), cholesterol and the trace elements as manganese (Mn), cobalt (Co), selenium
(Se), copper (Cu) and zinc (Zn) were investigated. All cows excreted glyphosate in their urine but in varying
concentrations. Increased levels of GLDH, GOT and CK in cows from all farms demonstrate a possible effect of
glyphosate on liver and muscle cells. High urea levels in some farms could be due to nephrotoxicity of
glyphosate. Also the unexpected very low levels of Mn and Co were observed in all animals which could be
explained due to a strong mineral chelating effect of glyphosate. In contrast the mean levels of Cu, Zn and Se
were within the normal reference range. In conclusion, this study gives the first documentation to which extent
Danish dairy cattle are exposed to Glyphosate and its impact on blood parameters.
Detection of Glyphosate in Malformed Piglets87
Abstract: Glyphosate residues in different organs and tissues as lungs, liver, kidney, brain, gut wall
and heart of malformed euthanized one-day-old Danish piglets (N= 38) were tested using ELISA. All
organs or tissues had glyphosate in different concentrations. The highest concentrations were seen in
the lungs (Range 0.4-80 µg/ml) and hearts (Range 0.15-80 µg/ml). The lowest concentrations were
detected in muscles (4.4- 6.4 µg/g). The detection of such glyphosate concentrations in these
malformed piglets could be an allusion to the cause of these congenital anomalies. Further
investigations are urgently needed to prove or exclude the role of glyphosate in malformations in
piglets and other animals.
The authors gave an overview of reports of malformations in children of families living a few meters
from where this herbicide was sprayed. The risk of malformation in human embryos is very high
when their mothers are contaminated at 2 to 8 weeks of pregnancy.
How glyphosate damages human metabolism by suppressing metabolic pathways
Samsel A and Seneff S (2013) Glyphosate’s suppression of Cytochrome P450 enzymes and amino
acid biosynthesis by the gut microbiome: Pathways to Modern Diseases.88
86
http://dx.doi.org/10.4172/2161-0525.1000186
87
http://omicsonline.org/open-access/detection-of-glyphosate-in-malformed-piglets-2161-0525.1000230.pdf
88
http://www.mdpi.com/1099-4300/15/4/1416
18
Abstract: Glyphosate, the active ingredient in Roundup®, is the most popular herbicide used
worldwide. The industry asserts it is minimally toxic to humans, but here we argue otherwise.
Residues are found in the main foods of the Western diet, comprised primarily of sugar, corn, soy and
wheat. Glyphosate's inhibition of cytochrome P450 (CYP) enzymes is an overlooked component of its
toxicity to mammals. CYP enzymes play crucial roles in biology, one of which is to detoxify
xenobiotics. Thus, glyphosate enhances the damaging effects of other food borne chemical residues
and environmental toxins. Negative impact on the body is insidious and manifests slowly over time as
inflammation damages cellular systems throughout the body. Here, we show how interference with
CYP enzymes acts synergistically with disruption of the biosynthesis of aromatic amino acids by gut
bacteria, as well as impairment in serum sulfate transport. Consequences are most of the diseases
and conditions associated with a Western diet, which include gastrointestinal disorders, obesity,
diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease. We explain
the documented effects of glyphosate and its ability to induce disease, and we show that glyphosate
is the “textbook example” of exogenous semiotic entropy: the disruption of homeostasis by
environmental toxins.
Glyphosate, pathways to modern diseases II: Celiac sprue and gluten intolerance.89
Samsel A and Seneff S . Glyphosate, pathways to modern diseases II: Celiac sprue and gluten
intolerance
Abstract Celiac disease, and, more generally, gluten intolerance, is a growing problem worldwide, but
especially in North America and Europe, where an estimated 5% of the population now suffers from
it. Symptoms include nausea, diarrhea, skin rashes, macrocytic anemia and depression. It is a
multifactorial disease associated with numerous nutritional deficiencies as well as reproductive
issues and increased risk to thyroid disease, kidney failure and cancer. Here, we propose that
glyphosate, the active ingredient in the herbicide, Roundup®, is the most important causal factor in
this epidemic. Fish exposed to glyphosate develop digestive problems that are reminiscent of celiac
disease. Celiac disease is associated with imbalances in gut bacteria that can be fully explained by
the known effects of glyphosate on gut bacteria. Characteristics of celiac disease point to impairment
in many cytochrome P450 enzymes, which are involved with detoxifying environmental toxins,
activating vitamin D3, catabolizing vitamin A, and maintaining bile acid production and sulfate
supplies to the gut. Glyphosate is known to inhibit cytochrome P450 enzymes. Deficiencies in iron,
cobalt, molybdenum, copper and other rare metals associated with celiac disease can be attributed
to glyphosate's strong ability to chelate these elements. Deficiencies in tryptophan, tyrosine,
methionine and selenomethionine associated with celiac disease match glyphosate's known
depletion of these amino acids. Celiac disease patients have an increased risk to non-Hodgkin's
lymphoma, which has also been implicated in glyphosate exposure. Reproductive issues associated
with celiac disease, such as infertility, miscarriages, and birth defects, can also be explained by
glyphosate. Glyphosate residues in wheat and other crops are likely increasing recently due to the
growing practice of crop desiccation just prior to the harvest. We argue that the practice of
“ripening” sugar cane with glyphosate may explain the recent surge in kidney failure among
agricultural workers in Central America. We conclude with a plea to governments to reconsider
policies regarding the safety of glyphosate residues in foods.
Glyphosate, pathways to modern diseases III: Manganese, neurological diseases, and associated
pathologies90
Samsel A, Seneff S. Glyphosate, pathways to modern diseases III: Manganese, neurological diseases,
and associated pathologies. Surg Neurol Int 2015;6:45.
Abstract Manganese (Mn) is an often overlooked but important nutrient, required in small amounts
for multiple essential functions in the body. A recent study on cows fed genetically modified
89
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3945755/
90
http://www.surgicalneurologyint.com/temp/SurgNeurolInt6145-4381109_121011.pdf
19
Roundup®‑Ready feed revealed a severe depletion of serum Mn. Glyphosate, the active ingredient in
Roundup®, has also been shown to severely deplete Mn levels in plants. Here, we investigate the
impact of Mn on physiology, and its association with gut dysbiosis as well as neuropathologies such
as autism, Alzheimer’s disease (AD), depression, anxiety syndrome, Parkinson’s disease (PD), and
prion diseases. Glutamate overexpression in the brain in association with autism, AD, and other
neurological diseases can be explained by Mn deficiency. Mn superoxide dismutase protects
mitochondria from oxidative damage, and mitochondrial dysfunction is a key feature of autism and
Alzheimer’s. Chondroitin sulfate synthesis depends on Mn, and its deficiency leads to osteoporosis
and osteomalacia. Lactobacillus, depleted in autism, depend critically on Mn for antioxidant
protection. Lactobacillus probiotics can treat anxiety, which is a comorbidity of autism and chronic
fatigue syndrome. Reduced gut Lactobacillus leads to overgrowth of the pathogen, Salmonella, which
is resistant to glyphosate toxicity, and Mn plays a role here as well. Sperm motility depends on Mn,
and this may partially explain increased rates of infertility and birth defects. We further reason that,
under conditions of adequate Mn in the diet, glyphosate, through its disruption of bile acid
homeostasis, ironically promotes toxic accumulation of Mn in the brainstem, leading to conditions
such as PD and prion diseases.
Overweight and obesity in mid-life: Evidence from the 1970 British Cohort Study 91
The Centre for Longitudinal Studies based at the Institute of Education University of London
published their latest report on 9 November 2013.
Their key findings of the cohort at age 42 were that:
The generation born in 1970 is considerably more likely to be overweight or obese than
those born 12 years earlier were at the same age.
Men born in 1970 are far more likely to be overweight than women.
Obesity levels in England are second only to the US and are running a parallel course to the US
Historical and projected overweight rates in OECD countries92
91
Overweight and obesity in mid-life: Evidence from the 1970 British Cohort Study at age 42
92
Healthy Choices OECD Health Ministerial Meeting, Paris, 7-8 October 2010
http://www.oecd.org/health/ministerial/46098333.pdf
20
Some of the UK population has been exposed to glyphosate residues in foods since 1980, even
without growing GM Glyphosate-Tolerant crops. The US has had GM crops since 1996. The third area
with the most overweight adults is Australia, where obesity levels started to rise steeply in 1990 and
by 2000 have overtaken Spain and Canada, both of which have GMs. There are 553 glyphosate
products registered in Australia. Glyphosate use on GM crops is accelerating. GM canola was
registered in 2003, but bans in NSW and Victoria were lifted in 2008. 93 Canola has been registered to
be desiccated since October 2014 94 and sunflowers since 2012.95 However, the Commonwealth
Scientific and Industrial Research Organisation (CSIRO) is promoted as Australia’s pre-eminent public
scientific research body. “Although ostensibly publicly funded, CSIRO has, in reality, been encouraged
to get 30% of its funding from business, with the CSIRO top management encouraging its staff to go
to 40%.” According to John Stocker, CSIRO’s former Chief Executive: “Working with the
transnationals makes a lot of sense, in the context of market access. There are very few Australian
companies that have developed market access in the United States, in Europe and in Japan, the
world’s major marketplaces. Yes, we do find that it is often the best strategy to get into bed with
these companies.” 96
Is glyphosate contributing to the 50% decline in coral (1985-2012) on the Great Barrier Reef?
De’ath, G. et al. analysed surveys of the coral in the GBF over 27 years: 97 “Based on the world’s most
extensive time series data on reef condition (2,258 surveys of 214 reefs over 1985–2012), we show a
major decline in coral cover from28.0%to 13.8% (0.53%y-1), a loss of 50.7% of initial coral cover.”
Mercurio et al. in a paper: Glyphosate persistence in seawater 98quantified the biodegradation of
glyphosate using standard “simulation” flask tests with native bacterial populations and coastal
seawater from the Great Barrier Reef. “Glyphosate has not often been included in regular monitoring
programs as the stand-alone analytical methods are often cost-prohibitive, resulting in a long term
deficiency in global datasets.”… Highlights: “This is the first study of glyphosate persistence in
seawater…Half-lives in “simulation” flask tests ranged from 47 to 315 days…Glyphosate degraded
most rapidly under low light and most slowly in the dark… AMPA, the biodegradation metabolite of
glyphosate was detected in each treatment…This persistence increases the potential for transport
into the marine environment.”
Global burden of disease study 2010 shows declines in the health of the UK and US
Between 1990 and 2010, Britain and the US have slipped down the scale of health compared with
other wealthy nations and the patterns of disease are remarkably similar.
In the US: “However, morbidity and chronic disability now account for nearly half of the US health
burden, and improvements in population health in the United States have not kept pace with
advances in population health in other wealthy nations”.99
In the UK: “The performance of the UK in terms of premature mortality is persistently and
significantly below the mean of EU15+ and requires additional concerted action… premature
mortality from several major causes such as cardiovascular disease and cancers…In terms of
premature mortality worsening ranks are most notable for men and women aged 20-54 years.
93
http://www.sbs.com.au/news/article/2012/11/15/factbox-gm-foods-australia
94
http://www.farmweekly.com.au/news/agriculture/cropping/general-news/new-canola-weed-control-
option/2714416.aspx
95
http://www.australianoilseeds.com/about_aof/news/glyphosate_as_a_desiccant_in_sunflowers
96
http://www.gmwatch.org/latest-listing/1-news-items/13325-csiro-in-bed-with-multinationals
97
http://www.pnas.org/content/109/44/17995.full.pdf+html
98
http://www.sciencedirect.com/science/article/pii/S0025326X14000228
99
http://www.ncbi.nlm.nih.gov/pubmed/23842577 The state of US health, 1990-2010: burden of diseases,
injuries, and risk factors
21
Increases in Alzheimer’s disease, breast cancer, oesophageal cancer, congenital anomalies “and a
growing burden of disability, particularly from mental disorders” are all acknowledged. 100
Substantial increase in neurological deaths 1979-2010
Ten major developed Western countries and 10 smaller Western countries were studied.101 There
was a major reduction in general mortality in all 20 countries, but total neurological deaths rose
substantially between 1980 and 2010 in both sexes in 16 out of 20 western countries; in particular
early onset Parkinson’s, Alzheimer’s and other Dementias, and Motor Neurone Disease. Female
neurological deaths in 9 out of 10 countries were greater than males. The authors thought the
causes were likely to be epigenetic rather than hereditary. “Moreover, looking back 30 or more years
the concept of early dementia or the need for the creation of a Young Parkinson’s Disease Society in
Britain would have seemed a tautology.”
Another paper elucidated the pathological mechanisms by which the herbicide glyphosate could
cause Parkinson’s disease and other neurodegenerative disorders.102
UK cancer survival rates trail 10 years behind other European countries
Cancer survival rates in the UK are still lagging more than two decades behind those achieved in
many European countries, according to new analysis by campaigners on 25th March 2015. 103 The
Concord-2 global study looked at survival rates in 67 countries for patients diagnosed with lung,
breast, colon and stomach cancers in 1995 to 1999, compared with levels in 2005 to 2009.
Genetically-engineered crops, glyphosate and the deterioration of health in the United States of
America. Swanson et al.104
Abstract: A huge increase in the incidence and prevalence of chronic diseases has been reported in
the United States (US) over the last 20 years. Similar increases have been seen globally. The herbicide
glyphosate was introduced in 1974 and its use is accelerating with the advent of herbicide-tolerant
genetically engineered (GE) crops. Evidence is mounting that glyphosate interferes with many
metabolic processes in plants and animals and glyphosate residues have been detected in both.
Glyphosate disrupts the endocrine system and the balance of gut bacteria, it damages DNA and is a
driver of mutations that lead to cancer.
In the present study, US government databases were searched for GE crop data, glyphosate
application data and disease epidemiological data. Correlation analyses were then performed on a
total of 22 diseases in these time-series data sets. The Pearson correlation coefficients are highly
significant (< 10-5) between glyphosate applications and hypertension (R = 0.923), stroke (R = 0.925),
diabetes prevalence (R = 0.971), diabetes incidence (R = 0.935), obesity (R = 0.962), lipoprotein
metabolism disorder (R = 0.973), Alzheimer’s (R = 0.917), senile dementia (R = 0.994), Parkinson's (R
= 0.875), multiple sclerosis (R = 0.828), autism (R = 0.989), inflammatory bowel disease (R = 0.938),
intestinal infections (R = 0.974), end stage renal disease (R = 0.975), acute kidney failure (R = 0.978)
cancers of the thyroid (R = 0.988), liver (R = 0.960), bladder (R = 0.981), pancreas (R = 0.918), kidney
(R = 0.973) and myeloid leukaemia (R = 0.878).
The Pearson correlation coefficients are highly significant (< 10-4) between the percentage of GE corn
and soy planted in the US and hypertension (R = 0.961), stroke (R = 0.983), diabetes prevalence (R =
100
http://www.ncbi.nlm.nih.gov/pubmed/23668584 UK health performance: findings of the Global Burden of
Disease Study 2010
101
http://dx.doi.org/10.1016/j.phe.2012.12.018 Pritchard, C. et al. Changing patterns in mortality from
neurological deaths in the 10 major developed countries 1979-2010 Public Health (2013)
102
http://www.sciencedirect.com/science/journal/08920362
http://www.activistpost.com/2012/04/roundup-herbicide-linked-to-parkinsons.htm
103
http://www.theguardian.com/society/2015/mar/24/uk-cancer-survival-rates-trail-10-years-behind-those-
in-european-countries
104
http://www.organic-systems.org/journal/92/JOS_Volume-9_Number-2_Nov_2014-Swanson-et-al.pdf
22
0.983), diabetes incidence (R = 0.955), obesity (R = 0.962), lipoprotein metabolism disorder (R =
0.955), Alzheimer’s (R = 0.937), Parkinson's (R = 0.952), multiple sclerosis (R = 0.876), hepatitis C (R
= 0.946), end stage renal disease (R = 0.958), acute kidney failure (R = 0.967), cancers of the thyroid
(R = 0.938), liver (R = 0.911), bladder (R = 0.945), pancreas (R = 0.841), kidney (R = 0.940) and
myeloid leukaemia (R = 0.889). The significance and strength of the correlations show that the effects
of glyphosate and GE crops on human health should be further investigated.
In the US glyphosate and GM crops have high correlations with human diseases, including cancers.
Public Health England shares my concern about the prevalence of chronic diseases in the UK such as
obesity, type 2 diabetes, cardiovascular disease and cancer. 105
Devastating Impacts of Glyphosate Use with GMO Seeds in Argentina”106
Published on the I-SIS website on 18/02/2015 by Dr Medardo Ávila-Vázquez, a paediatrician and
neonatologist at the Faculty of Medical Sciences, National University of Córdoba, Argentina.
“Widespread GM soybean cultivation and accompanying pesticide spraying is wreaking havoc on the
health of millions.”
He is the coordinator of the Physicians of Crop-Sprayed Towns, a University Network for
Environment and Health that campaigns against agrochemical spraying and provides medical
treatment to villages suffering from illnesses as a result of agrochemical exposure. Since noticing the
health of his patients deteriorate and patterns of illness change, he has campaigned tirelessly for the
protection of local people, particularly children who are some of the worst affected.
“The model of agricultural production foisted on Argentina by international biotechnology companies
has led to 858 % increase in the amount of pesticides used per year, resulting in a massive
environmental and health impact in the region.”…” Glyphosate is the most commonly used toxic
agrochemical in Argentina, comprising 64 % of total sales, and 200 million litres of glyphosate were
applied during the last crop season.”…” The clinical manifestations that physicians working in the
crop-sprayed towns find in patients are consistent with the results of scientific research on the effects
of various pesticides including glyphosate on experimental animals. Laboratory research by our
Scientists show how glyphosate acts on embryonic development to produce birth defects [8], and
how this poison damages DNA molecules in the cell nucleus, promoting mutant cell lines that will
cause cancer if they cannot be eliminated by the individual [9-11].
Also, a number of scientific papers worldwide show how exposure to toxic agrochemicals significantly
increases the rate of birth defects, miscarriages, cancer, and hormonal disorders in people subjected
to repeated sprayings [12-15].”
Fig 1. The rise in birth defects correlates with the rise in cultivation of GM glyphosate-tolerant
soybeans in Chaco, Argentina. Birth defects per 10 000 live births increased from approx. 15/10,000
live births in 1997 to approx. 82/10,000 live births in 2008.
Cancer Research UK website shows similar trends for certain cancers
The Cancer Research UK (CRUK) website shows similarly increasing trends over time in graphs from
1975 (when glyphosate was introduced) for thyroid cancer, 107 breast cancer,108 prostate cancer,109
malignant melanoma,110 liver cancer,111 myeloma,112 and anal cancer.113
105
Personal communication: email January 2015.
106
http://www.i-sis.org.uk/Devastating_Impacts_of_Glyphosate_Argentina.php
107
http://www.cancerresearchuk.org/cancer-info/cancerstats/types/thyroid/incidence/
108
http://www.cancerresearchuk.org/cancer-info/cancerstats/types/breast/incidence/#trends
109
http://www.cancerresearchuk.org/cancer-info/cancerstats/types/prostate/incidence/uk-prostate-cancer-
incidence-statistics#trends
110
http://www.cancerresearchuk.org/cancer-info/cancerstats/types/skin/incidence/uk-skin-cancer-incidence-
statistics#trends
111
http://www.cancerresearchuk.org/cancer-info/cancerstats/types/liver/incidence/#trends
112
http://www.cancerresearchuk.org/cancer-info/cancerstats/types/myeloma/incidence/#trends
23
Britain involved with corporations at the expense of the health of the public
Obesity crisis: Sugar: spinning a web of influence114
Public health scientists are involved with the food companies being blamed for the obesity crisis
Report by freelance journalist, Jonathan Gornall.
“An investigation by The BMJ has uncovered evidence of the extraordinary extent to which key public
health experts are involved with the sugar industry and related companies responsible for many of
the products blamed for the obesity crisis through research grants, consultancy fees, and other forms
of funding.” There is an interactive infographic, showing the ‘Tangled web: connections between the
sugar industry and UK government advisory bodies. Links represent research funding, consultancy,
and advisory board membership’
Among the main targets in the United Kingdom for an industry facing increasing pressure from
government to reduce the health harms caused by its products are researchers working on nutrition
issues for two key government funded organisations—the Scientific Advisory Committee on Nutrition
(SACN) and the Medical Research Council’s Human Nutrition Research (HNR) unit at Cambridge.
The BMJ has found that for more than a decade funding from industry has flowed to scientists
involved with the research unit. Scientists working on Medical Research Council (MRC) projects have
received research funding from organisations including Coca-Cola, PepsiCo, Nestlé, the Institute of
Brewing and Distilling, Weight Watchers International, NutriLicious (a public relations firm
specialising in conveying “nutrition and health messages” for the food industry), Sainsbury’s, W K
Kellogg Institute, and GlaxoSmithKline.
Others received consultancy fees from Boots, Coca-Cola, Cereal Partners UK, Mars, and Unilever
Foods. They have also sat on advisory boards for Coca-Cola, the Food and Drink Federation, and the
Institute of Grocery Distributors.
Figures obtained through freedom of information requests suggest industry funding of the work of
scientists in the Human Nutrition Research unit alone may have averaged close to £250 000 (€330
000; $380 000) a year for the past decade. Industry funding for the three years from 2010 to 2012
totalled £697 469, peaking at £380 874 in 2010—5% of the unit’s income for the year…Researchers
within the MRC’s units were ‘encouraged to work closely with the private sector, including the food
industries…”
Funding pressures
“For Alan Jackson, chair of SACN from 2001-2009, it is government funding policy that is to blame for
driving scientists into the arms of industry.”
Big food, big pharma: is science for sale115
Editor’s Choice: Elizabeth Loder, acting head of research The BMJ. “We have grown accustomed to
allegations of conflicts of interest, biased research, and manipulative marketing on the part of the
drug industry. Sadly, this is not the only area where there is reason to be concerned about corporate
influences on public policy. Crowcroft and colleagues examine the controversy over the UK
government decision on public funding for a new vaccine (Bexsero) for meningococcal disease.116 .
The problems they outline are all too familiar: “lobbying may have influenced the alteration” of the
original decision. Links between some “vocal clinicians” and the drug industry were not disclosed. The
lack of transparency makes it unsurprising that “conspiracy theories emerged, including the idea of
undue influence of industry.”
113
http://www.cancerresearchuk.org/cancer-info/cancerstats/types/anal-cancer/Incidence/#Trends
114
http://www.bmj.com/content/bmj/350/bmj.h231.full.pdf
115
http://www.bmj.com/content/350/bmj.h795
116
doi:10.1136/bmj.h308
24
Corporate lobbyists find it easier to access the Prime Minister than his own MPs
An Editorial in the British Medical Journal on 11/01/2014 was entitled: A shameful episode.117
The UK government did a sudden U-turn from its agreement that a minimum price on a unit of
alcohol would be introduced across the United Kingdom. The Government had previously said: “The
evidence for substantial health savings and cost savings was clear.”… “Scotland had introduced a
minimum price (though now under legal challenge by the drinks industry) and the UK Prime Minister
had given his personal commitment that England and Wales would follow suit.” Jeremy Browne the
Home Office Minister later said that the government didn’t have “enough concrete evidence.”
However, Jonathan Gornall, in a BMJ investigation, discovered: “the extent and effects of contact
between ministers and interest groups lobbying against the minimum unit price.”
Gornall concluded that the consultation itself was a sham. “While MPs struggled to gain access to
ministers, representatives of alcohol companies and major supermarkets had easy access – made
easier by the well-oiled revolving doors between industry and special advisory posts.”… “Academics
quoted by Gornall express concern about the misuse of the scientific process by the alcohol industry
and its mouthpiece.” They were using tactics reminiscent of the tobacco industry.
Documents released under a freedom of information request showed that between the coalition
taking power in May 2010 and the end of 2013 the Department of Health alone had 130 meetings
with representatives of the industry.118
The extensive investigation shows “beyond doubt that commercial interests are currently in control
of key decisions about the public’s health.”
The UK Government and the GM Industry: colluding to promote GM crops and foods, undermine
consumer choice and ignore environmental harm (published by Genewatch UK, May 2014)119
“This briefing summarises information collected by GeneWatch UK using requests under the Freedom
of Information Act and the Environmental Information Regulations (known as FoIs). It demonstrates
close co-operation between the GM industry and the UK Government, including a joint strategy to
promote GM crops and foods in the press and media.
The documents:
Reveal how foreign multinational GM companies are running the Government's PR strategy on GM
crops by controlling how public and private money will be invested in research;
Show that taxpayers’ money is being spent on PR for the GM industry rather than delivering better
food and farming;
Suggest close co-operation with GM soya importers to pressure retailers to allow meat and dairy
suppliers to use Monsanto’s RoundUp® Ready GM soya for animal feed and prevent consumers from
accessing GM-free fed meat and dairy products;
Highlight the extent to which the GM industry’s role in Government policy is being kept hidden from
the public.”
Syngenta is the powerhouse of the UK government’s agrochemical policy
Dr Peter Campbell Head of Ecotoxicology: Principal Scientific Officer York Pesticides Safety
Directorate (PSD September 1991 – November 1997); now the Chemical Regulations Directorate
(CRD) became Head of Ecological Sciences, Syngenta (October 1997 – September 2007) at Jealott’s
Hill International Research Centre, Bracknell UK.120
Dr Helen Thompson Senior Bee Scientist from the Food & Environment Research Agency (Fera)
defected in 2013, after having done commissions for Syngenta. 121 FoI declarations discovered a
compromising letter from Owen Paterson to Syngenta Switzerland assuring them of his support
117
http://www.bmj.com/content/348/bmj.g110
118
jgornall@mac.com BMJ 2014;348:f7646
119
http://www.genewatch.org/uploads/f03c6d66a9b354535738483c1c3d49e4/FoI_summary_May14.pdf
120
http://uk.linkedin.com/pub/peter-campbell/4/283/6ba
121
http://www.theguardian.com/environment/2013/jul/26/government-bee-scientist-pesticide-firm
25
against the neonicotinoid ban in Europe. 122 Dr Campbell had the power to direct Syngenta funding
wherever he saw fit. In 2009 Syngenta gave £1 million to fund Warwick University and Rothamsted
Research “to help to improve honeybee health”. (Rothamsted had lost funding for its Bee Unit in
2006). Syngenta pioneered Operation Bumblebee in the UK and in 2010 announced expansion of
programmes across Europe; up to €1 million over 5 years. Programmes included “What Operation
Bumblebee can do for your golf course.” Syngenta had representatives on the Advisory Committee
on Pesticides (ACP), the Committee on Toxicity of Chemicals in Foods, Consumer Products and the
Environment (CoT), and Dr Campbell himself was on the Panel to choose the Pollinator Initiative
Projects.123 Syngenta contributed to the Government’s Foresight Future of Farming Report. 124
Syngenta’s parent company AstraZeneca had two representatives on CoT.
Dr James Cresswell received £136,000 from Syngenta to fund his research at Exeter in 2012.125
Syngenta gave scholarships for students at Exeter University in 2012 126 and with the Biotechnology
and Biological Research Council (BBRSC) funded the BEEHAVE honeybee model. 127 Syngenta also
applied to EFSA GMO Panel for GM Roundup®-tolerant maize:128 "The UK Competent Authority and
Syngenta applied for placing on the market of a GM, herbicide tolerant (glyphosate) maize GA21 for
food and feed uses, import, processing and cultivation.”
Syngenta’s parent company is AstraZeneca. AstraZeneca manufactures six different anti-cancer
drugs mainly aimed at breast and prostate cancer. The Corporation has links in Asia, including
Hospitals in China, Japan, Korea, and collaborators in Russia. AstraZeneca’s Oncology Website129 has
the following portentous prediction: “Cancer claims over 7 million lives every year and the number
continues to rise. Deaths are estimated to reach 12 million by 2030.”
Michael Pragnell MA MBA was the founder of Syngenta and CEO of Syngenta AG based in
Switzerland (from its public listing in 2000 to the end of 2007). He was appointed a Trustee of Cancer
Research UK (CRUK) in March 2010 and Chairman in November 2010. CRUK is donating money (£450
million/year) to the Government’s Strategy for UK Life Sciences 130 and AstraZeneca is providing 22
compounds to academic research to develop medicines.
CRUK website on Pesticides and Cancer denies links to pesticides: “For now, the evidence is not
strong enough to give us any clear answers. But for individual pesticides, the evidence was either too
weak to come to a conclusion, or only strong enough to suggest a “possible” effect. The scientific
evidence on pesticides and cancer is still uncertain and more research is needed in this area. 131
Scientist who developed a precursor to Roundup® Ready Canola appointed to Rothamsted132
Professor Maurice Moloney became Director and Chief Executive of Rothamsted Research on 15th
April 2010. According to BBSRC: “Before moving to Calgary, Professor Moloney led the Cell Biology
group at Calgene Inc. in Davis, California, developing the world’s first transgenic oilseeds, which
resulted in RoundUp Ready® Canola and other novel crops. He was previously a Royal Society
122
http://www.guardian.co.uk/environment/interactive/2013/apr/29/environment-secretary-letter-syngenta-
insecticide-ban
123
http://www.bbsrc.ac.uk/funding/opportunities/2009/insect-pollinators-initiative.aspx
124
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/288329/11-546-future-
of-food-and-farming-report.pdf Page 88 Wheat.
125
http://www.theguardian.com/environment/damian-carrington-blog/2012/oct/22/bees-pesticides
126
http://www.exeter.ac.uk/media/universityofexeter/internationalexeter/pdfs/agentsnewsletters/January_201
5.pdf
127
http://www.bbsrc.ac.uk/news/food-security/2014/140304-pr-virtual-bees-unravel-causes-of-decline.aspx
128
http://www.efsa.europa.eu/en/efsajournal/pub/2480.htm
129
http://www.astrazeneca.co.uk/medicines/oncology
130
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/32457/11-1429-strategy-
for-uk-life-sciences.pdf
131
http://www.cancerresearchuk.org/cancer-info/healthyliving/cancercontroversies/pesticides/
132
http://www.rothamsted.ac.uk/news/new-director-rothamsted-research
26
European Postdoctoral Fellow at the University of Lausanne, Switzerland. Professor Moloney is
currently Chief Scientific Officer of SemBioSys Genetics Inc, based in Calgary, Canada. He founded the
company in 1994 and has maintained this role alongside a successful academic career at the
University of Calgary, where he serves as NSERC/Dow AgroSciences Industrial Research Professor of
Plant Biotechnology.”
Prof Moloney was considered in Canada by his colleagues in genetics to be reckless with the
environment. His company SemBioSys focused on producing pharmaceuticals in the oil crops canola
(rapeseed) and safflower. One Canadian geneticist said: “Currently safflower-grown human insulin
has been open field tested in the state of Washington in a sagebrush wild area of the state which is
the habitat for a number of threatened wild species that can be poisoned by ingesting insulin”…“In
Canada and the United States open field tests of crop bio-pharmaceuticals are undertaken with little
or no respect for the environmental consequences of the open field releases… Regulators show
cavalier disregard for the safety of threatened species as well as human beings in proposed release of
the GM pharm crop.” 133
Prof Moloney departed for Australia to work for the Commonwealth Scientific and Industrial
Research Organisation (CSIRO) in December 2013.134
Open letter from America to the Prime Minister warning the UK against GM
crops: November 2014
Living with GMOs: Citizen to Citizen 135 From 57 million citizens in the US to citizens, politicians,
and regulators in the UK and the rest of the EU about the hazards of genetically modified crops
We, the undersigned, are sharing our experience and what we have learned with you so that you
don’t make our mistakes. Signatories include NGOs, groups, academics, scientists, farmers, food
manufactures, and high profile individuals representing some 57 million Americans.
Extracts: “A recent review found that between 1996 and 2011, farmers who planted Roundup Ready
crops used 24% more herbicide than non-GMO farmers planting the same crops. This pesticide
treadmill means that in the last decade in the US at least 14 new glyphosate-resistant weed species
have emerged, and over half of US farms are plagued with herbicide-resistant weeds.” They outlined
eight independent papers describing Environmental Harm and six about the Threat to Human
Health. “Americans are reaping the detrimental impacts of this risky and unproven agricultural
technology. EU countries should take note: there are no benefits from GM crops great enough to
offset these impacts. Officials who continue to ignore this fact are guilty of a gross dereliction of
duty.
We strongly urge you to resist the approval of genetically modified crops, to refuse to plant those
crops that have been approved, to reject the import and/or sale of GM-containing animal feeds and
foods intended for human consumption, and to speak out against the corporate influence over
politics, regulation and science.”
The Open letter from America was passed from the Prime Minister’s Office to Defra. Did Defra draft
the Minister’s letter without telling him it was from 57 million citizens?
Extracts from the reply from Lord de Mauley, Defra Minister, “to Directors of Beyond GM.”
It was clear that the Minister hadn’t read the letter, or realised that it was an Open letter from 57
million citizens from the US, but relied on signing Defra’s letter of denial 136
Extract: “However, to pick up on your point on contamination, cross-pollination is, again, a normal
process between compatible plant species and there is nothing different about GM crops in this
133
http://www.i-sis.org.uk/gmSaffloweHumanPro-Insulin.php h
134
http://www.bbsrc.ac.uk/news/people-skills-training/2013/130808-pr-new-post-for-prof-maloney.aspx
135
http://www.theletterfromamerica.org/
136
http://beyond-gm.org/wp-content/uploads/2015/01/BGM_Defra-letter_151214.pdf
27
respect”...“The UK Government regards safety as paramount and we will only agree to planting of
GM crops or the marketing of GM foods if it is clear that people and the environment will not be
harmed.”
Background on systemic neonicotinoid insecticides: regulation by industry
Society of Environmental Toxicology and Chemistry (SETAC); headed by industry
Dr Peter Campbell of Syngenta is currently the World President of SETAC. SETAC is a society
controlled by industry and the US EPA. In 2011, SETAC held a Workshop on Pesticide Risk
Assessment for Pollinators January 15-21, 2011, at Pellston, Florida. It was by invitation only; ‘world
experts’ of whom many were from industry (Helen Thompson, now working for Syngenta, and Mark
Clook CRD were present from the UK). David Fischer from Bayer CropScience and Thomas Moriarty
from the US EPA Office of Pesticide Programs and Team Leader, US EPA Bee Unit wrote the
Executive Summary. 137
The Summary shows that the pesticides industry and all of the environmental protection agencies
were aware of the following, which up until then, they had consistently denied:
That the systemic neonicotinoid pesticides are harmful to bees.
That the tests and protocols that had allowed registration of the systemic pesticides were
not adapted to assess potential hazard and risk from this type of pesticide.
Despite knowing all this, the Protection Agencies had allowed the pesticides industry to keep
neonicotinoids on the market while they carried out further research.
That many of the projects suggested for the future have already been done by independent
scientists. These were merely delaying tactics.
Admission on Page 12 “Many who are familiar with pesticide risk assessment recognize that the
methodology and testing scheme for foliar application products (where exposure may be primarily
through surface contact) is not adapted to assess potential hazard and risk from systemic pesticides”.
European Commission denied our claim that the registration of clothianidin was illegal
One of our complaints to the European Ombudsman (1089/2012/BEH) was that clothianidin had
been registered illegally, since its half-life in a range of soils was an average of 545 days with a
maximum of 1386 days (Source: Footprint Database). According to the Directive on Plant Protection
Products (EC) 1107/2009;138 Annex II, page 43, persistence in the soil, approval should not be given if
the half-life in soil is greater than 120 days (‘based on half-life data collected under appropriate
conditions, which shall be described by the applicant’).
Michael Flüh, replied on behalf of Commissioner John Dalli, "The allegation as regards the illegality
of the registration of clothianidin is strongly rejected. The assessment of clothianidin, carried out by a
Rapporteur Member State (RMS) and peer reviewed by experts from all Member States concluded
that safe uses of this substance exist."
Conditional139 registration of clothianidin in the US
On May 30, 2003, Daniel C Kenny of the US EPA Registration Division granted conditional registration
for clothianidin to be used for seed treatment on corn and canola (oil seed rape) to Bayer
137
http://c.ymcdn.com/sites/www.setac.org/resource/resmgr/publications_and_resources/executivesummarypo
llinators_.pdf?hhSearchTerms=SETAC+and+Pellston+and+Workshop
138
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:309:0001:0050:EN:PDF
139
‘Conditional’ means that they are allowed to sell it on condition that they fulfil all the data gaps within a
year
28
Corporation. 140 In the 19-page document, the EPA scientists (as opposed to the Registration
Division) had assessed the risks as: “Clothianidin is highly toxic to honey bees on an acute contact
basis. It has the potential for toxic chronic exposure to honey bees, as well as other non-target
pollinators, through the translocation of clothianidin residues in nectar and pollen. In honey bees, the
effects of this toxic chronic exposure may include lethal and/or sub-lethal effects in the larvae and
reproductive effects in the queen. The fate and disposition of clothianidin in the environment suggest
a compound that is a systemic insecticide that is persistent and mobile, stable to hydrolysis, and has
potential to leach into ground water, as well as run-off to surface waters. There is evidence of effects
on the rat immune system and juvenile rats appear to be more susceptible to these effects.”
Summary of Data Gaps. Page 18. There were gaps in Toxicology; Residue Chemistry; Environmental
Fate Data and Ecological Effects Data. These included: Additional studies on Developmental
Immunotoxicity and Mutagenicity. Data on aerobic aquatic metabolism and a Seed leaching study.
Whole sediment acute toxicity to freshwater invertebrates. Field test for pollinators. There is no
evidence that the data gaps were filled in.
Bayer uses the action of neonicotinoid suppression of the immune system to kill colonial insects
such as termites (Premise 200SC) 141and ants (Baythion I Myrelokkedaase Denmark)
“Premise 200SC plus Nature causes termites to succumb to disease and death by naturally occurring
organisms”… “Imidacloprid binds to nicotinergic acetylcholine receptors at the nervous system…they
stop feeding, grooming and become disorientated”…”Low doses of Premise 200SC such as the edge
of the Treated Zone, disorientate the termites and cause them to cease their natural grooming
behaviour. Grooming is important for termites to protect them against pathogenic soil fungi. When
termites stop grooming, the naturally occurring fungi in the soil attack and kill the termites. Premise
200 SC makes fungi 10,000 times more dangerous to termites. Nature assists Premise in giving
unsurpassed control. This control is Premise 200SC plus Nature.”
Honey bees groom each other. Buzz about Bees website states: A natural defence against Varroa
mites for bees is grooming. Bees also groom in defence against diseases and fungi.142
17/04/2012 EU Ombudsman investigates whether the European Commission should do more to
combat increased bee mortality143
This followed a complaint from the Austrian Ombudsman Board, alleging that the Commission has
failed to take into account new scientific evidence arguing in favour of restricting the use of the
(neonicotinoid) insecticides. The Ombudsman had asked the Commission to submit an opinion by
30 June 2012.
EFSA Scientific Opinion on the science behind the development of a risk assessment of Plant
Protection Products on bees (Apis mellifera, Bombus spp. and solitary bees) 23 May 2012144
The trade-offs: Farmers Page 10 There is a trade-off between plant protection and protecting the
ecosystem services, pollination, hive products and biodiversity. From a farmer’s point of view plant
protection may be more important than hive products. While for beekeepers, hive products are of
greater importance. Society may give a high value to protection of biodiversity (to ensure delivery of
other ecosystem services such as aesthetic values, cultural services and genetic resources).
Risk Managers Page 131 The final decision on protection goals needs to be taken by risk managers.
There is a trade-off between plant protection and the protection of bees. The effects on pollinators
need to be weighed against increase in crop yields due to better protection of crops against pests.
140
http://www.epa.gov/opprd001/factsheets/clothianidin.pdf
141
http://www.elitepest.com.sg/brochure/Premise_200SC.pdf
142
http://www.buzzaboutbees.net/honey-bee-health.html
143
http://www.ombudsman.europa.eu/en/press/release.faces/en/11428/html.bookmark
144
http://www.efsa.europa.eu/en/efsajournal/pub/2668.htm
29
Big money, economics and politics take priority over human health and biodiversity.
Syngenta had access to EFSA’s press release announcing a ban on three neonicotinoid insecticides
before its publication. Bayer and Syngenta threaten to sue EFSA145
Corporate Europe Observatory reports: “Private letters reveal Syngenta and Bayer’s furious lobbying
against EU measures.”
There is a long correspondence between Syngenta, Bayer and EFSA. Bayer commissioned…’an
independent panel of bee scientists’…in fact it was Exponent® Inc. which specializes in defending
products from regulation. Exponent® came to the conclusion that “EFSA risk assessments use
unrealistic exposure values, make inappropriate comparisons to toxicity threshold levels, fail to
consider critical bee behaviour, and inappropriately discount monitoring and field studies”, and
therefore “overstates the risks to honey bees”. 146 Syngenta had access to EFSA’s press release before
its publication. The Corporation could not persuade EFSA’s Executive Director, Catherine Geslain-
Lanéelle, to alter the wording of the Press Release. Syngenta sent an extremely aggressive letter to
the agency, claiming that the press release was “incorrect in a major and highly relevant aspect but
EFSA also moves out of its area of responsibility and mandate”. Syngenta even threatened to take
legal action and set a deadline: “we ask you to formally confirm that you will rectify the press release
by 11 o’clock. Otherwise you will appreciate that we will consider our legal options.” 147
EFSA Press Release: finally recommends bans of three neonicotinoids on flowering crops148
16 January 2013
“EFSA scientists have identified a number of risks posed to bees by three neonicotinoid insecticides.
The Authority was asked by the European Commission to assess the risks associated with the use of
clothianidin, imidacloprid and thiamethoxam as seed treatment or as granules, with particular
regard to: their acute and chronic effects on bee colony survival and development; their effects on
bee larvae and bee behaviour; and the risks posed by sub-lethal dose of the three substances. In
some cases EFSA was unable to finalise the assessments due to shortcomings in the available data.”
EFSA Chief of Pesticide Risk Assessment had discovered the data gaps
Herman Fontier, Head of the Pesticide Risk Assessment Peer Review (PRAPeR) Unit came to
London to give evidence to the Environmental Audit Committee on 06/02/2013149
Q522 Caroline Nokes MP: “Last week, Bayer told the Committee that your imidacloprid risk
assessment at EFSA had not taken into account all of the available research, including studies that
had been referenced in earlier draft reports. Their feeling was that EFSA had not given sufficient
weight to real-world higher-tier field trials, which showed that imidacloprid was safe. How would you
respond to that criticism?”
Herman Fontier: “I am aware of this allegation made by Bayer; that leaves me a little puzzled,
because we have indeed requested applicants to submit all the available data and they have done so,
I thought. They had submitted a data package, which we have evaluated from the first to the last
study “.
On questioning by the Chairman, Herman Fontier said: “The British Government is completely free to
ignore recommendations from European safety regulators that controversial nerve-agent pesticides
145
http://corporateeurope.org/agribusiness/2013/04/pesticides-against-pollinators
146
http://corporateeurope.org/sites/default/files/letter_interexchange_between_syngenta_bayer_and_efsa.pdf
147
http://corporateeurope.org/sites/default/files/letter_and_fax_interexchange_between_syngenta_ashurst_la
wers_and_efsa.pdf
148
http://www.efsa.europa.eu/en/press/news/130116.htm
149
http://www.publications.parliament.uk/pa/cm201213/cmselect/cmenvaud/668/668.pdf
30
should not be used on crops visited by bees. It was merely a risk assessment – and it was up to
individual EU member states whether or not to act on it.
Environment Correspondent for The Independent reported: “In Britain the Environment Secretary,
Owen Paterson, has already indicated that the Government is likely to ignore the recommendation
and is opposed to an immediate ban on three neonicotinoids highlighted by the EFSA report,
imidacloprid, clothianidin and thiamethoxam, made by the giant agribusiness companies Bayer and
Syngenta. Mr Paterson’s Department for Environment, Food and Rural Affairs (Defra) is carrying out
its own research into neonicotinoids and bees.” 150
Were the changes of staff at EFSA significant? Did industry threats to sue frighten the EC?151
Catherine Geslain-Lanéelle EFSA CEO resigned on 24 July 2013. In July EFSA had issued new
guidelines for two-year whole food feeding studies…but they were for future establishment of
protocols and it sounded optional; “the decision on a case by case basis”. 152
Herman Fontier Head of EFSA’s Pesticides Unit disappeared. When earlier he came to give testimony
to the Parliamentary Environmental Audit Committee153 he had challenged an allegation by Bayer
(and on BBC Radio 4.). By September 2013 he had been replaced by Luc Mohimont as Acting Head.
José Vincente Tarazona was appointed as definitive Head of EFSA’s Pesticide Unit by February 4th
2014. Were the departures precipitated by a flurry of threatened or actual legal actions by the
pesticides companies? Syngenta took legal action against the European Commission’s decision to
suspend the use of thiamethoxam on bee attractive crops which they claimed was on the basis of a
flawed process, an inaccurate and incomplete assessment by the European Food Safety Authority?154
Bayer’s action against the 2-year moratorium on clothianidin and imidacloprid which they described
as ‘unjustified’, saying it went beyond the commission’s existing regulatory framework.155 The
German chemical giant also said the commission failed to take into account other factors that are
contributing to bee die-offs, including, it says, loss of habitats, extreme environmental and climatic
factors and lack of genetic diversity.
EFSA’s rejection of Fera’s Bumblebee Study for which the British Government had been eagerly
awaiting. Discussion by the UK Advisory Committee on Pesticides156
The ACP with Prof Ian Boyd, Defra Chief Scientist, found the results difficult to interpret because the
control bees had been contaminated by another neonicotinoid. Defra went to re-do the statistics.
EFSA’s opinion of the UK study
Evaluation of the FERA study on bumble bees and consideration of its potential impact on the EFSA
conclusions on neonicotinoids:157 “The current assessment concluded that, due to the weaknesses of
the study design and methodology, the study did not allow it to draw any conclusion on the effects of
neonicotinoids on exposed bumble bee colonies, and confirmed that the outcome of the conclusions
drawn for the three neonicotinoid insecticides remains unchanged.”
150
http://www.independent.co.uk/environment/green-living/government-to-ignore-european-ban-on-
neonicotinoid-pesticides-8483916.html
151
On 24 July 2013 Catherine Geslain-Lanéelle, Executive Director of the European Food Safety Authority
(EFSA), today announced that she is resigning to take up a new post as Director General for agricultural, agri-
food and territorial policies in the French Ministry of Agriculture, Food and Forestry on 1 September 2013
152
http://www.efsa.europa.eu/en/efsajournal/doc/3347.pdf
153
http://www.publications.parliament.uk/pa/cm201213/cmselect/cmenvaud/668/668.pdf
154
http://www.syngenta.com/global/corporate/en/news-center/news-releases/pages/130827.aspx
155
http://www.ibtimes.com/bayer-cropscience-fights-europes-pesticide-ban-petition-blasts-bee-killing-
chemical-giant-1403820
156
http://www.pesticides.gov.uk/guidance/industries/pesticides/advisory-groups/acp/ACP-News/ACP-359-29-
January-2013-Detailed-Record-of-Discussion
157
http://www.efsa.europa.eu/en/efsajournal/pub/3242.htm
31
A Pan-European field experiment has been designed and will be delivered during 2014-2015
Defra has volunteered CEH researchers to design, and oversee, the delivery of the trial of systemic
neonicotinoid pesticides.158 CEH said: “This research is co-funded by Bayer CropScience AG and
Syngenta Crop Protection, but controls are in place to ensure the experimental design and the
reporting of its research (whatever the outcome) is independent.”
Syngenta and Bayer are part funding, and inevitably have control, over the design of the Pan-
European Pollinator Study by the Centre for Ecology and Hydrology (CEH) in 2015
Syngenta and Bayer consistently deny that neonicotinoid insecticides are harming bees. Joan Walley
MP, Chair of the Environmental Audit Committee (EAC), wrote to Professor Bailey CEH to ask to be
sent the correspondence with industry. The EAC wished to be reassured that CEH had control over
the Study. 159
In fact, Syngenta and Bayer are controlling the study. According to experts, the study will not meet
the protection goals defined by the European Food Standards Agency (EFSA).
Firstly, bumblebees and solitary bees are not included in the study (wild pollinators are more
important for pollination of crops than managed honey bees. Bumblebees are more
sensitive to imidacloprid than honey bees.) 160, 161
Secondly, the CEH study is designed to detect a 20% detrimental effect on bee colony sizes,
while EFSA requires 7%.
Finally, although it was recommended by the CEH that the experiment should run for at least
three years, to allow for inter-annual variability due to weather and other factors, Syngenta
and Bayer have said that they will only fund one year. Meanwhile, the Government has
privatised Fera, the Food and Environment Research Agency.162
Conflicts of Interest in the EU: the Committees are controlled by industry;
‘professional’ members rotate around the Committees
European Food Safety Authority (EFSA), founded in 2002, has been accused of conflicts of interest
EFSA has been regularly challenged by four independent organisations, Corporate Europe
Observatory, Earth Open Source (UK), Testbiotech (Germany) and Criigen (France).
In 2011 Earth Open Source published an 18-page document: Europe’s pesticide and food safety
regulators – Who do they work for?163 “Some prominent EFSA regulators have conflicts of interest,
holding positions in organisations that are funded by the same companies whose products they are
supposed to regulate. This report shows that over a period of many years, influential EFSA managers
and regulators have been heavily involved with a US-based organisation called the International Life
Sciences Institute (ILSI), which is funded by multinational pesticide, chemical, GM seed, and food
companies.” Angelo Moretti resigned in 2011 from EFSA after he had failed to declare conflicts of
interest because he had shares in a company that helped companies needing to comply with EU
Regulations. “ILSI has also taken control of the environmental risk assessment for GM crops. It has
set up a body called the Center for Environmental Risk Assessment (CERA) to ‘develop and apply
158
http://www.ceh.ac.uk/science/impacts-neonicotinoids-honeybees-largescale-field-experiment.html
159
http://www.parliament.uk/documents/commons-committees/environmental-audit/Chair-Neonicotinoids-
research.pdf
160
http://www.sciencemag.org/content/336/6079/351 Treated colonies had a significantly reduced growth
rate and suffered an 85% reduction in production of new queens compared with control colonies.
161
http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0079872
162
https://www.gov.uk/government/news/food-and-environment-research-agency-new-145m-investment
163
http://earthopensource.org/files/pdfs/Europes-pesticide-and-food-safety-
regulators/Eu_pesticidefoodsafety.pdf
32
sound science’ to the environmental risk assessment of agricultural biotechnologies”. But Earth Open
Source’s investigation revealed much more about Moretti and many other regulators.
In 2012 Corporate Europe Observatory/Earth Open Source wrote a Report: Conflicts on the menu: A
decade of industry influence at the European Food Safety Authority (EFSA).164 Holland, N., Robinson,
C., and Harbinson, R. (2012). Brussels, Belgium, Corporate Europe Observatory and Earth Open
Source.
The Editors of the Journal of Epidemiology and Community Health (owned by the British Medical
Journal) read the above Report and commissioned a paper based on the information. It was
published online in 2013. Conflicts of interest at the European Food Safety Authority erode public
confidence.165 Claire Robinson, Nina Holland, David Leloup, Hans Muilerman.
“EFSA experts involved in assessing the risks of GM foods have attracted criticism. In 2010, 12 out of
21 experts on the GMO Panel…had conflicts of interest as defined by the Organisation for Economic
Cooperation and Development (OECD.)”… “Chair of EFSA’s Management Board Diána Bánáti had a
longstanding relationship with the industry-funded ILSI. In May 2012 she had to resign from EFSA and
re-joined ILSI as Executive Director. Suzy Renkens Scientific Coordinator of EFSA’s GMO Panel was
criticised by the European Ombudsman over her failure to deal with conflicts of interest. She left EFSA
in 2008 and stepped straight into a job with Syngenta. “
Harry Kuiper was Chair of the GMO Panel from 2003 to 2012. He had been at the forefront of the
criticism of Dr Arpad Pusztai’s paper in 1998 on rats fed GM potatoes which was published in the
Lancet.166 “He had been involved in the risk assessment of every GM food submitted to EFSA since the
Agency was set up. Throughout his term of office he retained links with ILSI…Even the design of
EFSA’s GMO risk assessment standards was influenced by an ILSI Task Force headed by a Monsanto
employee.”
International Life Sciences Institute (ILSI): Is it a private club for Corporations?
The membership of ILSI Europe consists of 56 (as of 12 Feb 2015) organisations.167 This list
represents Global Corporations (including the six Agrochemical Giants) with massive resources that
are seeking to control the world’s food supply. ILSI is an industry organisation based in Washington,
DC, USA. It claims to be “a non-profit, worldwide organization whose mission is to provide science
that improves human health and well-being and safeguards the environment” and allegedly has
charity status.
The IUPAC (International Union of Pure & Applied Chemistry); Subcommittee on Crop Protection
Chemistry. 168 There are currently 28 people on the IUPAC Subcommittee including Dr Caroline
Harris and Dr Gijs Kleter from Wageningen University. Dr Kleter wrote papers with Harry Kuiper in
2002 and 2007 and is now Vice-Chairman of EFSA GMO Panel.
Dr Caroline Harris is also a member of the supposedly independent UK Advisory Committee on
Pesticides (ACP). She is Corporate Vice-President of Exponent Inc. 169 She worked for 15 years for the
UK Pesticides Safety Directorate (PSD) and will have known Dr Peter Campbell when he was Head of
Ecotoxicology in the PSD. Both went through the revolving doors to high positions in Industry. Dr
Harris went straight from PSD into Exponent Inc.
164
http://corporateeurope.org/efsa/2012/02/conflicts-menu
165
http://jech.bmj.com/content/67/9/717
166
http://download.thelancet.com/pdfs/journals/lancet/PIIS0140673605767088.pdf
167
http://www.ilsi.org/Europe/Pages/currentmembers.aspx
168
http://www.iupac.org/home/about/members-and-committees/db/division-
committee.html?tx_wfqbe_pi1%5bpublicid%5d=604
169
“Exponent, Inc., a research and scientific consultant firm with clients from industry (including crop
protection) and government” http://www.exponent.com/caroline_harris/
33
In 2013, in a commentary by Sue Davies, Chair of EFSA Management Board, she denied complaints
about Conflicts of Interest170
“I therefore read with interest, the latest report from Corporate Europe Observatory on alleged
conflicts of interest at EFSA (with reference to the GMO Panel). The fact that EFSA makes its experts’
Declarations of Interest publicly available online allows interested parties to scrutinise for themselves
how the Authority selects its scientific experts. The Management Board is confident that the policy
EFSA has in place to ensure independence in its scientific work is robust. The Board is also satisfied
that EFSA is implementing its own rules effectively as they apply to the selection of experts and the
assessment of Declarations of Interest.”
Harry Kuiper, Chairman of the GMO Panel from its inception in 2003, finally steps down in 2012
after being accused of a close relationship with ILSI
Harry Kuiper left as Chairman of the GMO panel in 2012 because Corporate Europe Observatory,
Christoph Then of Testbiotech, CRIIGEN and Earth Open Source had all complained about Conflicts of
Interest in EFSA because of Kuiper’s links with ILSI.
Rothamsted Research. Dr Jonathan Napier, the Programme Leader from Rothamsted Research, was
present at the secret meeting with industry. In 1941 the herbicide 2,4-D was discovered in the UK
(Rothamsted Research) and the US at the same time. It was commercialized in 1946 (US 1948) and is
still on the list of herbicides registered in the UK and the US. In Australia in 2013 an urgent review
was underway after a Four Corners investigation found elevated levels of dangerous dioxins in a
generic version of 2,4-D, one of Australia's most widely used herbicides (imported from China).
Dioxins are one of the most deadly chemical compounds in the world, but Australian authorities do
not routinely test for them. 171 GMOs are now being made to be resistant to glyphosate, glufosinate
and 2,4-D, all very toxic herbicides.172 The US Environmental Protection Agency’s (EPA) gave
unconditional registration on 15/10/2014 of Dow Chemical’s Enlist Duo herbicide, a new blend of
2,4-D and glyphosate intended for use on Dow’s patented 2,4-D resistant (Enlist) genetically
engineered corn and soybeans.173
Current membership of the GMO panel: Has it improved since Harry Kuiper left?
Chairman: Prof Joe Perry: Registered conflicts of interest. 174 He retired as a Rothamsted employee in
June 2006. Indeed, apart from his name and email address there was little to indicate that he had
been there. He seems to have ‘disappeared’ to become ‘Rothamsted’s man in Europe.’ From July
2006 he has been permanently employed on various GMO Committees, until he took over from
Harry Kuiper in 2012 as Chairman of the GMO Panel.
Prof Perry states at the bottom of Page 2: In terms of time, over 98% of my working time consists of
advisory work as an expert on the GMO panel of EFSA, which is ongoing since 2006. For this I receive
only expenses.” Prof Perry has done at least four papers with colleagues from EFSA on GM crops
without declaring his position on the GMO Panel.175
In 2003 he was lead author in the Farm Scale evaluation (3 years only) of GM Herbicide-tolerant
crops.176 In 2012 he was lead author in a paper in the Journal of Applied Ecology 177 “Estimating the
170
http://www.efsa.europa.eu/en/press/news/131024a.htm
171
http://mobile.abc.net.au/news/2013-07-22/four-corners-dangerous-dioxins/4833848
172
https://www.testbiotech.org/sites/default/files/Risks%20of%20herbicide%202_4-D_0.pdf
173
http://sustainablepulse.com/2014/10/16/us-center-food-safety-slams-epa-approval-enlist-duo-
herbicide/#.VOw-L_msWII
174
http://www.efsa.europa.eu/en/gmo/gmomembers.htm
175
http://link.springer.com/search?facet-author=%22Joe+N.+Perry%22
176
http://onlinelibrary.wiley.com/doi/10.1046/j.1365-2664.2003.00786.x/full
177
http://onlinelibrary.wiley.com/doi/10.1111/j.1365-2664.2011.02083.x/pdf
34
effects of Cry1F Bt‐maize pollen on non‐target Lepidoptera using a mathematical model of
exposure.”
“A 14-parameter mathematical model integrating small- and large-scale exposure was used to
estimate the larval mortality of hypothetical species with a range of sensitivities, and under a range
of simulated mitigation measures consisting of non-Bt maize strips of different widths placed around
the field edge” Synthesis and applications. Mitigation measures of risks of Bt-maize to sensitive
larvae of non-target lepidopteran species can be effective, but depend on host-plant densities which
are in turn affected by weed-management regimes.
In EFSA’s Scientific Opinion published 09/11/2012, Updating the risk assessment conclusions and risk
management recommendations on the genetically modified insect resistant maize 1507 178
variations of Perry’s mathematical model have been referenced on four occasions. “Perry et al.,
2010, 2011, 2012 referred to in EFSA, 2011d), the EFSA GMO Panel concluded that: “there is a risk to
certain highly sensitive non-target lepidopteran species where high proportions of their populations
are exposed over successive years to high levels of maize 1507 pollen deposited on their host-plants”
(EFSA, 2011d, 2012b).”
If you find the paper on mathematical modelling difficult to understand, then listen to Prof Perry
explaining The Risks of GMOs to a Weekend Residential Conference of Christians in Science.179 At
the beginning of his recorded lecture180 he says: “I don’t know anything about the science of GMs.”
This becomes very clear as he struggles to explain it to a lay audience. If you fast forward to 20.27
min, he then tries to expound the risk to a non-target species of moth. He finally comes up with a
recommended distance between a Bt crop and a theoretical Nature Reserve of 30 metres to mitigate
the risks to a non-target unknown species of moth.
US populations of a ‘real’ lepidopteran, the migrant monarch butterfly, have declined by 90%:
The results of mathematic modelling appear to bear no relationship to what happens in the field
In the last 20 years, the population of monarch butterflies in the eastern US has declined by 90
percent. 181 With the introduction of genetically-modified crops like Roundup®-Ready corn and soy
that are resistant to traditional herbicides, farmers have begun to spray more and more Roundup®—
the Monsanto-made chemical—over wider and wider areas, resulting in the loss of milkweed, the
only plant upon which they lay eggs and their larvae feed.
In February 2015 the US Center for Food Safety produced an 88-page Report: Monarchs in peril;
Herbicide-Resistant Crops and the decline of Monarch Butterflies in North America 182 “Unlike many
other weed killers, once absorbed it (glyphosate) is translocated (moved internally) to root tissue,
where it kills milkweed at the root and so prevents regeneration. The increasingly common practice
of growing Roundup Ready crops continuously on the same fields means that milkweed is exposed to
glyphosate every year, with no opportunity to recover. In 1999, common milkweed was found in half
of corn and soybean fields, but only 8% of them a decade later.”
First Vice-Chairman of the GMO Panel: Dr Gijs A. Kleter, Wageningen University. Dr Kleter is Harry
Kuiper’s protégé; he is a member of the IUPAC Sub-Committee on Crop Protection Chemistry and is
the lead author for a number of multi-author publications. Dr Caroline Harris has a 28-year history of
working for industry. She has written 26 papers, eight of which are with Dr Kleter as first author.
Some of the GMO papers have 16 authors.
178
http://www.efsa.europa.eu/en/efsajournal/doc/2933.pdf
179
http://www.cis.org.uk/conferences/past-conferences/residential-2012/
180
http://www.cis.org.uk/upload/conferences/Residential2012/Joe_Perry.mp3
181
http://www.newsweek.com/monarch-butterflies-have-declined-90-conservationists-seek-extra-protection-
267094
182
http://www.centerforfoodsafety.org/files/cfs-monarch-report_2-4-15_design_05341.pdf
35
Second Vice-Chairman of the GMO Panel: Prof Patrick du Jardin: Gembloux Agro-Bio Tech; Plant
Biology Unit; University of Liège; Gembloux, Belgium.
In January 2012 Prof du Jardin was second author of a paper whose first author, Nancy Podevin an
EFSA employee, found a hidden viral gene in GMO crops.183 In fact, this paper isn’t among Prof du
Jardin’s selected scientific publications in his Biography for EFSA. Is he anxious to avoid it being
discussed? Or has he been threatened by industry? There are at least two independent scientists
who have suggested that there are serious questions to be answered about human safety by those
in Europe authorising GM.
Jonathan Latham, PhD, Editor of Independent Science News has written a Synopsis and he and
Allison Wilson have published a pdf.184
Synopsis: A scientific paper published in late 2012 shows that US and EU GMO regulators have for
many years been inadvertently approving transgenic events containing an unsuspected viral gene. As
a result, 54 different transgenic events commercialized internationally contain a substantial segment
of the multifunctional Gene VI from Cauliflower Mosaic Virus (CaMV) within them. Among these are
some of the most widely grown GMOs, including Roundup® Ready Soybean (40-3-2) and MON810
Maize. The oversight occurred because regulators failed to appreciate that Gene VI overlaps the
commonly used CaMV 35S gene regulatory sequence.
The authors of the paper, working for the European Food Safety Authority, concluded that functions
of Gene VI were potential sources of harmful consequences. They further concluded that, if
expressed, the fragments of Gene VI are substantial enough for them to be functional (Podevin and
du Jardin (2012) GM Crops and Food 3: 1-5).
This discovery has multiple ramifications for biotechnology. Foremost, there is the immediate
question of GMO safety and whether the 54 events should be recalled, but secondly, the failure
implicates regulators and the industry in a circle of mutual incompetence and complacency.
The discovery will also strengthen the argument for GMO labelling: if regulators and industry cannot
protect the public then why should they not be allowed to protect themselves?
In Norway, on 24.01.2013 GenØk185 published a similar assessment at the request of the Norwegian
Directorate for Nature Management. 186
EFSA’s statement on the membership of the Scientific Committee for Emerging Risks (2015)187
“In view of the strategic role of the Scientific Committee, its members are prominent scientists with
recognised scientific excellence, competences spreading across disciplines, seniority and prior
experience with scientific bodies. The Committee’s expertise encompasses all the scientific areas
within EFSA’s remit:
Human health risk assessment, food consumption and exposure assessment, environmental
risk assessment, animal health risk assessment, toxicology, microbiology, human nutrition,
epidemiology, animal health, animal welfare, human medicine, veterinary medicine, food
hygiene, food technology, chemistry, biology, biochemistry, life sciences.”
183
Possible consequences of the overlap between the CaMV 35S promoter regions in plant transformation
vectors used and the viral gene VI in transgenic plants.
http://www.tandfonline.com/doi/full/10.4161/gmcr.21406#.VOi3Cnxybcs
184
http://www.independentsciencenews.org/commentaries/regulators-discover-a-hidden-viral-gene-in-
commercial-gmo-crops/
185
GenØk – Centre for Biosafety is a non-commercial foundation located in the research environment at the
University of Tromsø and Forskningsparken (the Science Park). GenØks vision is safer use of biotechnologies.
186
http://genok.com/arkiv/723/
187
http://www.efsa.europa.eu/en/scer/scmembers.htm
36
The Chairman is Prof Anthony Richard Hardy. He states in 2015 that he is an ‘Individual Scientist’ and
has spent 14 years on committees. Although he says he has been working at the University of York,
his email address cannot be found on the website. In fact it transpires that he was working at the
Central Science laboratory (CSL) at Sand Hutton, York. 188 The CSL is the UK's foremost public sector
laboratory in the fields of agriculture, food and the environment and is an Executive Agency
‘responsible for the delivery of science in support of Government objectives’. He did not admit that he
also worked for ADAS before that.189ADAS recommended pre-harvest spraying of glyphosate (to dry
them) on cereal crops in 1980. Since 1965, the MAFF Pesticides Survey Group has surveyed the use
of pesticides in major agricultural and horticultural crops every 4-5 years. One of Professor Hardy’s
publications: The impact of the commercial agricultural use of organophosphorus and carbamate
pesticides on British wildlife190at a conference in Cambridge in 1984, the lead author said:
“Herbicides and fungicides are the most widely used pesticides, but, from their intrinsic toxicity,
insecticides have greater potential direct effects on non-target wildlife.” Monsanto has completely
deceived them by declaring glyphosate to be harmless. The 1975-1979 quantity of herbicides was
11,145.4 tonnes (compared with 2,336.1 tonnes of fungicides and 1,606.8 tonnes total insecticides).
Prof Hardy was also Chairman of the Scientific Panel at a meeting on Endocrine Disrupting Chemicals
in Parma in 2013 when the group decided that they would delay identification of EDCs. 191 Prof
Hardy has been on the Environmental Panel of the Advisory Committee on Pesticides for 15 years.192
Members are responsible for providing advice to the ACP on issues related to the environmental fate
and behaviour and eco-toxicological effects of pesticides.
Why do the current Chair of the EFSA Panel on Genetically Modified Organisms (GMO) which deals
with genetically modified organisms and genetically modified food and feed, 193 the Scientific
Committee and Emerging Risks (SCER) 194 and Contaminants in the Food Chain (CONTAM) 195 come
from the UK?
Professor Joe Perry, Chairman GMO Panel formerly worked at Rothamsted Research.
Professor Anthony Richard Hardy, Chairman of SCER, formerly worked for the CSL and ADAS.
Dr Diane Benford, Chairman of CONTAM, currently works for the UK Food Standards Agency.
Prof Huw Jones is another member from Rothamsted Research on the GMO Panel.
Is it part of the plan with industry set up on 26/06/2012 to facilitate getting GM crops into Britain?
EFSA’s Reasoned Opinion Panel increases MRLs at the request of industry (Monsanto in this case,
to 100 times the previously authorised MRL)
Monsanto Europe asked EFSA to set the import tolerance for glyphosate in lentils “in order to
accommodate the authorised desiccation use of glyphosate in lentils in the US and Canada” from 0.1
mg/kg to 10 mg/kg196 (i.e. 100 times: January 2012). EFSA had granted similarly elevated MRLs for
glyphosate on wheat and GM soya.
Conflicts of interest of Anne Glover CSA to the European Parliament
188
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2679592/
189
http://digitalcommons.unl.edu/cgi/viewcontent.cgi?article=1038&context=vpc14
190
http://nora.nerc.ac.uk/5980/1/13.pdf page 75.
191
http://www.efsa.europa.eu/en/topics/topic/eas.htm
192
http://www.pesticides.gov.uk/guidance/industries/pesticides/advisory-groups/acp/acp-environmental-
panel/?wbc_purpose=ba
193
http://www.efsa.europa.eu/en/gmo/gmomembers.htm
194
http://www.efsa.europa.eu/en/scer/scmembers.htm
195
http://www.efsa.europa.eu/en/contam/contammembers.htm
196
http://www.efsa.europa.eu/en/efsajournal/pub/2550.htm
37
Professor Glover, former Chief Scientific Advisor to President Barroso, in an interview with
EurActiv197 said: “There is no substantiated case of any adverse impact on human health, animal
health or environmental health, so that’s pretty robust evidence, and I would be confident in saying
that there is no more risk in eating GMO food than eating conventionally farmed food.” She said the
precautionary principle no longer applies as a result. “The evidence with which I work is independent;
the evidence with which I work does not change according to political philosophy. And that should
give people a lot of confidence.” She is not independent. According to Glover's declaration, as
reported by Damerval,198 “Professor Glover is a shareholder in a biotech company and set up the firm
Remedios, which was names Scotland’s “Best New Biotechnology Company” for Biotech Scotland by
its industry peers.199She will be a leading speaker at a conference in Africa to persuade them to grow
GM crops. She sits on the board of Science Business, alongside representatives of Microsoft, Sanofi
and BP; members include biotechnology companies.”
Glover said that discomfort around the subject of GM crops in the 1980s and 1990s was “a
generation ago, we’ve moved on and the challenges are completely different.” Corinne Lepage MEP
for France (and former French Minister of the Environment) says Anne Glover is wrong. 200 “However,
regarding the environmental impact of GMOs, the evidence is overwhelming and completely
concrete. Not only is the dissemination of GMOs to non-GM plants proven, but the damage caused
by regrowth elsewhere, which requires the use of ever more toxic pesticides, has already become a
reality.” Corinne Lepage goes on to say: “Glover has as such taken on a heavy amount of personal
responsibility, going so far as to say the precautionary principle is no longer applicable. If in the
coming years, evidence on the toxicity of GMOs comes to light, European citizens would be entitled to
ask her for an explanation.”
Science Media Centre: expert reaction to the re-publication of Séralini Study on Roundup-tolerant
GM maize. 201 Prof Perry rejected it, but did not declare his interest as Chair of EFSA’s GMO Panel!
Professor Joe N. Perry, Visiting Professor of Biometry, University of Greenwich, said:
“This paper appears to be based on the same data as Seralini’s previous 2012 paper, with no real
new information and only minor rephrasing and a few new references. Therefore, I doubt whether
my conclusions would differ from those of the vast majority of independent members of the scientific
community, who concluded in 2012 that there was insufficient evidence to justify the claims of
CRIIGEN and Giles-Eric Seralini. However, I do welcome Seralini’s promise to publish his raw data and
my hope is that all organisations involved in GM risk assessment will, wherever possible in the future,
publish in full their raw data in the spirit of full transparency and openness.”
Declared interests
None declared
Non-declaration of interests over GMs in June 2014
Why did Professor Perry pretend that he was an independent member of the scientific community
and fail to mention his position as Chairman of the EFSA GMO Panel? For the same reasons as Times
Journalist, Matt Ridley wrote an article: Eat up your GM crops. They are good for you.202 He said he
was a farmer and did not declare an interest. However, he is not plain Matt Ridley, but the 5 th
Viscount Ridley, Chairman of Northern Rock 2004-2007, the first Bank to be bailed out by the
197
http://www.euractiv.com/innovation-enterprise/commission-science-supremo-endor-news-514072
198
Francois Damerval is Chief of Staff to Corinne Lepage, the French MEP.
199
http://foodvitalpublicservice.wordpress.com/2014/02/13/the-biotech-industry-retreats-from-europe-but-
is-courting-africa/
200
http://www.euractiv.com/cap/gmos-anne-glover-wrong-analysis-514185
201
http://www.sciencemediacentre.org/expert-reaction-to-republication-of-seralini-study-on-roundup-
tolerant-gm-maize/
202
http://www.thetimes.co.uk/tto/opinion/columnists/article4127014.ece
38
Government. He is also the brother-in-law of Owen Paterson the previous Environment Secretary
who was found to be having secret correspondence with Syngenta, and was pressing for GM.
Examples of EFSA GMO Panel ‘adopting’ GM without considering environmental consequences
"The UK Competent Authority and Syngenta had applied for placing on the market of a GM, herbicide
tolerant (glyphosate) maize GA21 for food and feed uses, import, processing and cultivation.” 203 It
was adopted by the EFSA on 16 December 2011. Although the EFSA GMO Panel had said that there
were no effects on human or animal health or the environment in the Abstract, in the full document,
they admitted to the problems of reduction in farmland biodiversity, selection of weed communities
and selection of glyphosate-resistant weeds, and destruction of food webs and the ecological
functions they provide. Nevertheless, EFSA adopted it, but covered itself by saying "The magnitude
of these potential adverse environmental effects will depend on a series of factors including the
specific herbicide and cultivation management applied at farm level, the crop rotation...etc. and
recommended “case-specific monitoring.”
EFSA GMO Panel adopted GM crops on the grounds that they were safe for human health and the
environment
This is despite the many papers that show that super weeds are massively destructive to the
environment in the US 204 and that over a period of 30 years there has been uncontrolled spread and
contamination globally by many Genetically-Engineered (GE) plants that are herbicide resistant. 205
Conflicts of interest not declared: GMO Panel Chairman is joint author of a Review with EFSA of
spread of feral GM herbicide-tolerant OSR: “concerns are not scientifically justified” 206
This paper dismisses concerns of escape of GE organisms into the environment. It “concludes that
feral GM herbicide-tolerant oilseed rape in Europe should not be routinely managed, and certainly
not in semi-natural habitats, as the benefits of such action would not outweigh the negative effects
of management.”
Uncontrolled spread of GE crops: Testbiotech Report on the spread of GE Oil Seed Rape207
GE plants have been grown for 30 years and commercially for 20 years. This independent Report
provides a global overview of the uncontrolled escape of GE oil seed rape (OSR) in various regions of
the world (US, Canada, Japan, Australia, Switzerland and Germany). In Switzerland where no imports
of GE OSR have been allowed since 2008: “Transgenic OSR was able to survive along rail tracks for
long periods because extensive glyphosate spraying of these areas offer them selective advantages.”
In Japan: “plants that proved to be resistant to glyphosate or glufosinate were found at ports and
along transportation routes to industry plants where OSR is processed.”
Transgene Escape: Global atlas of uncontrolled spread of genetically engineered plants 208
This Report, also from Testbiotech (Germany) makes several recommendations. Most importantly,
measures should be put in place immediately to stop any further uncontrolled spread of genetically
engineered plants into the environment as far as possible. Comprehensive regulation should be
established to strengthen the Precautionary Principle and the release of genetically engineered
organisms should not be allowed if they cannot be retrieved.
European Network of Scientists for Social and Environmental Responsibility ENSSER
203
http://www.efsa.europa.eu/en/efsajournal/pub/2480.htm
204
http://www.enveurope.com/content/24/1/24
205
http://www.testbiotech.org/sites/default/files/Testbiotech_Transgene_Escape.pdf
206
http://nora.nerc.ac.uk/15307/1/N015307PP.pdf
207
www.testbiotech.de/node/891
208
http://www.testbiotech.org/sites/default/files/Testbiotech_Transgene_Escape.pdf
39
“No scientific consensus on GMO safety” statement published in peer-reviewed journal209
A statement signed by over 300 scientists and legal experts to the effect that there is “No
consensus” on the safety of genetically modified (GM) crops and foods has been published in a peer-
reviewed open access journal, Environmental Sciences Europe in 2015. It now belongs to the body of
open peer-reviewed scientific literature and stands as a citable publication.
Open Letter from Industry (2013) urges EU officials to abandon ‘the precautionary principle’
However, many pesticide lobbyists in Europe, in common with Prof Anne Glover, are calling for the
‘precautionary principle’ to be abandoned and be replaced by the ‘innovation principle’ where risk-
taking is acceptable (when it is for the benefit of businesses). Twelve of the largest corporations in
Europe (the majority of which are Agrochemical Corporations) submitted an Open Letter to the
President of the European Commission, Mr Jose Manuel Barroso, Mr Herman Van Rompuy,
President of the European Council and Mr Martin Schulz, President of the European Parliament
urging them to adopt an “Innovation Principle” to be taken into full consideration during policy and
legislative processes in order to “stimulate economic recovery.”210
The European Commission, EFSA, WHO and UNEP delay the criteria for
defining endocrine disruptors. Is it to protect the Agrochemical Industry and
the herbicide glyphosate/Roundup®?
Delay since 1999 in identifying and banning endocrine disruptors in Europe
The Community strategy on endocrine disrupters is from 1999, but no real action has resulted from it.
There appear to be many individuals and bodies fighting to delay the ban on agricultural pesticides
that have been causing endocrine disruption in humans and animals for the last 30 or so years: low
semen quality in men, genital malformations, adverse pregnancy outcomes and birth defects,
neurobehavioural disorders related to thyroid function, increasing incidence of endocrine-related
cancers (breast, endometrial, ovary, prostate, testicular and thyroid cancers), early breast
development in girls and the prevalence of obesity and Type 2 diabetes.
European Commission was challenged about its continued registration of Roundup®
In 2011, a paper written by eight multinational experts, the authors challenged the European
Commission about its continued registration of Roundup®. Roundup and Birth Defects: is the public
being kept in the dark? 211 “The European Commission has previously ignored or dismissed many
other findings from the independent scientific literature showing that Roundup® and glyphosate
cause endocrine disruption, damage to DNA, reproductive and developmental toxicity, neurotoxicity,
and cancer, as well as birth defects. Many of these effects are found at very low doses, comparable
to levels of pesticide residues found in food and the environment.”...
“This issue is of particular concern now that Monsanto and other producers of genetically modified
seed are trying to get their glyphosate-tolerant crops approved for cultivation in Europe. If the EU
Commission gives its approval, this will lead to a massive increase in the amount of glyphosate
sprayed in the fields of EU member states, as has already happened in North and South America.
Consequently, people’s exposure to glyphosate will increase.”
The review of glyphosate was due to take place in 2012. Soon after the Commission was notified of
the latest research showing that glyphosate and Roundup® caused birth defects, it quietly passed a
directive delaying the review of glyphosate and 38 other dangerous pesticides until 2015.
209
http://www.enveurope.com/content/pdf/s12302-014-0034-1.pdf
210
http://www.scienceindustries.ch/_file/13682/erf-communication-innovation-principle.pdf
211
http://earthopensource.org/earth-open-source-reports/roundup-and-birth-defects-is-the-public-being-
kept-in-the-dark/
40
The EU Commissioner for Health, John Dalli, resigned on 12/10/2012 after an anti-fraud inquiry
linked him to an attempt to influence tobacco legislation. 212 He denied the allegation.
Independent scientists have shown that glyphosate is an endocrine disruptor
Gasnier, C. et al, Glyphosate-based herbicides are toxic and endocrine disruptors in human cell lines.
Toxicology doi:10.1016/j.tox.2009.06.006213
“All parameters were disrupted at sub-agricultural doses with all formulations within 24h. These
effects were more dependent on the formulation than on the glyphosate concentration. First, we
observed a human cell endocrine disruption from 0.5 ppm on the androgen receptor in MDA-MB453-
kb2 cells for the most active formulation (R400), then from 2 ppm the transcriptional activities on
both estrogen receptors were also inhibited on HepG2. Aromatase transcription and activity were
disrupted from 10 ppm. Cytotoxic effects started at 10 ppm with Alamar Blue assay (the most
sensitive), and DNA damages at 5 ppm. A real cell impact of glyphosate-based herbicides residues in
food, feed or in the environment has thus to be considered, and their classifications as
carcinogens/mutagens/reprotoxics is discussed.
Fiona Young et al, Endocrine disruption and cytotoxicity of glyphosate and Roundup in human JAr
cells in vitro. Integrative Pharmacology, Toxicology and Genotoxicology 214
Conclusions Glyphosate alone is less toxic than glyphosate in a Roundup® formulation; both
glyphosate and Roundup® caused cell death which resulted in decreased progesterone levels in vitro,
and endocrine disruption did not precede cytotoxicity. A 24h exposure to a concentration of
Glyphosate (in Roundup®) similar to that recommended as an acceptable level for Australian drinking
water caused significant cytotoxicity in vitro, which supports a call for in vivo studies to characterise
the toxicity of Roundup®.
Endocrine Disrupting Chemicals (EDC) – 2012 Commissioned by WHO and UNEP
An assessment of the State of Science of Endocrine Disruptors was prepared for the United Nations
Environment Program and the World Health Organization by a group of approximately 50 expert
scientists led by Professor Åke Bergman, University of Stockholm.215
The authors outlined the current evidence of: 1) a high incidence, and increasing trends, of many
endocrine-related disorders in humans; 2) observations of endocrine-related effects in wildlife
populations; 3) identification of chemicals with endocrine disrupting properties linked to disease
outcomes in laboratory studies.
“Endocrine-related disorders in humans are manifest by:
Increases in low semen quality in young men (up to 40%)
Incidence of genital malformations has increased over time
Adverse pregnancy outcomes and birth defects has increased in many countries
Neurobehavioural disorders related to thyroid dysfunction has increased
Endocrine-related cancers (breast, endometrial, ovary, prostate, testicular and thyroid
cancers) have been increasing over the past 40–50 years
Earlier onset of breast development in young girls which leads to breast cancer
The prevalence of obesity and type 2 diabetes is increasing. The WHO estimates that 1.5
billion adults worldwide are overweight or obese and that the number with type 2 diabetes
increased from 153 million to 347 million between 1980 and 2008”
The conclusion was: “It is essential to evaluate associations between EDC exposures and health
outcomes by further developing methods for which proof of concept is currently under development.”
212
http://europa.eu/rapid/press-release_MEMO-12-788_en.htm
213
http://www.ncbi.nlm.nih.gov/pubmed/19539684
214
http://www.gmoevidence.com/wp-content/uploads/2015/03/IPTG-1-104.pdf
215
http://unep.org/pdf/9789241505031_eng.pdf
41
An Editorial in the Lancet216 concluded: “there is currently no widely agreed system for assessing the
strength of associations between exposure to chemicals (including EDCs) and adverse health
outcomes.”
Why didn’t glyphosate even appear on the list of candidates for Endocrine Disrupting Chemicals?
There is plenty of evidence from independent scientists. In addition, the evidence produced in the
Report that atrazine was also an EDC was overwhelming; why was atrazine not named as one? The
reason is that atrazine is still used extensively in many countries, including the US and Australia and
Syngenta relentlessly pursues anyone who says it is harmful.217 Although atrazine was banned in the
EU in 2004, it was still used in Britain 4 years after it had been banned in Europe.218 At that stage
illegal levels of atrazine >0.1µg/l were found in more than 25% of groundwater monitoring sites in
the UK.219 The Environment Agency Groundwater Database had recorded a maximum concentration
of atrazine of 13.04µg/l. That is 130 times the EU legal limit for groundwater (2004/248/EC).220
Was heavy contamination of groundwater with atrazine linked to a gastroschisis cluster in Kent?
In April 2012, The Daily Mail and Mail on Sunday revealed that nine babies born over 12 years in one
street in Kent had the same major congenital anomaly, gastroschisis. 221 Gastroschisis is a major
congenital defect in the abdominal wall, almost always to the right of the navel, through which the
abdominal contents freely protrude. An investigation was carried out which reported on 10 July
2013.222 The Public Health investigation did not find evidence of higher rates of gastroschisis than
could be considered normal in the Waterdales Road area. Syngenta said: “There is no proven link
between atrazine and these defects. Atrazine does not cause developmental abnormalities.”
Atrazine does appear to be linked with developmental abnormalities
However, gastroschisis had been reported in association with atrazine in the US in 2010.223 The
investigators discovered this report, but for some reason had dismissed it. In May 2013, 3 months
before the Report was published a Case-control study of maternal residential atrazine exposure and
male genital malformations in their offspring was undertaken in Texas. 224
Extracts from Abstract: “Exposure to endocrine disrupting chemicals has been associated with risk for
male genital malformations. However, residential prenatal exposure to atrazine, an endocrine
disrupting pesticide, has not been evaluated…Previous literature from animal and epidemiological
studies supports our findings. Our results provide further evidence of a suspected teratogenic role of
atrazine.”
Just after the Report was published (in December 2013) The incidence of abdominal wall defects is
related to surface water atrazine and nitrate in Indiana225 and a further paper confirmed the link;
Maternal residential atrazine exposure and gastroschisis by maternal age.226
216
http://www.thelancet.com/journals/lancet/article/PIIS0140-6736(13)60564-4/fulltext
217
www.newyorker.com/reporting/2014/02/10/140210fa_fact_aviv
218
https://secure.fera.defra.gov.uk/pusstats/index.cfm Atrazine
219
http://www.pesticides.gov.uk/Resources/CRD/Migrated-
Resources/Documents/P/Pesticides_Forum_Oct_2008_WFD.pdf
220
http://nora.nerc.ac.uk/14557/1/OR11013.pdf A British Geological Survey Report (2011): ‘Emerging
contaminants in groundwater’ which has remained unpublished.
221
http://www.dailymail.co.uk/news/article-2142106/One-street-Nine-babies-born-horrific-rare-deformity-
And-troubling-question--mothers-poisoned-weedkiller.html
222
Report into possible cluster of Gastroschisis in Northfleet: Meradin Peachey, Director of Public Health, Kent
County Council (Formerly Director of Public Health Kent and Medway) 10 July 2013
223
http://www.ncbi.nlm.nih.gov/pubmed/20207240 Agricultural-related chemical exposures, season of
conception, and risk of gastroschisis in Washington State.
224
http://www.ncbi.nlm.nih.gov/pubmed/23494929
225
http://www.ncbi.nlm.nih.gov/pubmed/17560200
226
http://www.ncbi.nlm.nih.gov/pubmed/23184502
42
Glyphosate Studies in Emerging Contaminants: degradation product four times the parent and
may be problematic
According to the British Geological Survey (BGS) Report on Emerging Contaminants in Groundwater
(2011) page 35: “Glyphosate is now the most widely used herbicide in the world, with dramatic
increases in agricultural use since the introduction of glyphosate resistant crops. Microbial
degradation produces aminomethyl phosphonic acid (AMPA) (Kolpin et al., 2000) and it has been
anticipated that AMPA may be problematic. The high water solubility of both the parent and the
metabolite has meant that their analysis has been difficult. Although AMPA has a DT50 of about 151
days and is therefore persistent it also has a relatively high Koc of 8087 and would not be classified
as vulnerable to leaching by the simple method described above. Similarly for parent compounds
which have non-agricultural applications, there will be routes to groundwater which would not be
identified, such as routes which do not pass through the soil zone. Kolpin (2006) showed AMPA to be
detected in wastewater-impacted surface waters about four times as frequently as the parent.”
Endocrine Disrupting Chemicals: Owen Paterson former UK Environment Minister in a secret
letter to Syngenta about neonicotinoids (April 2013) in which EDCs were mentioned227
“You raise the point that this issue is one of several that impact on the availability of pesticides in
agriculture. We are well aware of this point and you will know that amongst other things, the UK has
been arguing hard for a proportionate approach to regulating Endocrine Disrupting Chemicals.”
A letter had been sent to Prof Anne Glover Chief Scientific Adviser to the European President
Barroso to protest about the Draft Regulation on endocrine active chemicals 18/06/2013 228
Soon after Owen Paterson’s comments to Syngenta about “the UK arguing hard about a
proportionate approach to regulating EDCs” more lobbyists weigh in with delaying tactics. Seventy
three individuals writing under the umbrella of the Royal Society of Chemistry complained that the
European Commission was ignoring scientific principles in the setting of a regulatory framework for
endocrine disrupting chemicals. A significant number of signatories had conflicts of interest. Twenty
were/or had been, on EFSA Panels, Diane Benford is Chairman of EFSA CONTAMIN and she and
David Gott work for the UK Food Standards Authority (FSA) and Alan Boobis served on EFSA, and is
current Vice-President of ILSI Europe and a member of the Board of Trustees of ILSI.
EFSA Committee works on Endocrine Disruptors, March 2013, but continues to procrastinate
Prof Anthony Hardy Chairman of EFSA Scientific Committee and Emerging Risks made a video
statement at the end.229 The Committee agreed unanimously with the WHO definition (2012).
Scientific knowledge of this area is still growing and, therefore, understanding of what is an
endocrine active substance continues to be the subject of scientific debate…EFSA’s experts concluded
that available or soon to be available internationally agreed testing methods can identify
interference of chemical substances with the most important endocrine pathways in mammals and
fish known to be sensitive to endocrine disruption.
EFSA concluded that a risk assessment approach which considers both the likelihood of exposure
together with potential adverse effects of endocrine active substances makes best use of available
information to regulate their use.
New attack on EU policy regarding endocrine disruption: Health DG SANCO prepares an escape
route for pesticides 20/05/2014
227
http://www.guardian.co.uk/environment/interactive/2013/apr/29/environment-secretary-letter-syngenta-
insecticide-ban
228
http://www.rsc.org/suppdata/tx/c3/c3tx90013d/c3tx90013d.pdf
229
http://www.efsa.europa.eu/en/topics/topic/eas.htm
43
Pesticides Action Network Europe puts out a Press Release:230“Commission health service DG
SANCO is on its way to develop an escape route for endocrine disrupting pesticides that will be
banned in future. This is done behind closed doors with EU member states and Food Authority EFSA.
Sweden fiercely protested against this initiative because they feel the pesticide Regulation is misused
and doesn’t allow for a general derogation. Food Authority EFSA is also active in the SANCO working
group, lobbying to revise the legislation on endocrines back to traditional risk assessment and
encouraging SANCO to use an escape route.”
“It also appears from documents released by Commission to PAN Europe (on the PAN website [2])
that EFSA has an active role in the SANCO working group. A representative of the EFSA Scientific
Committee writes to Barroso’s advisors that they keep on opposing the pesticide legislation and aim
to return to traditional risk assessment. This is in line with pesticide industry’s efforts. The
representative also complains about the pesticide legislation having no "control route" or "socio-
economic route" to save endocrine disrupting pesticides from a ban and keep them on the market.
The person suggests that the 'negligible exposure' option will be a good option to fill this gap.”
Sweden decides to sue the EU Commission for delay on identifying hormone disrupting chemicals
On May 22 2014, Agence France Presse: Sweden said it would sue the European Commission over a
delay in identifying harmful chemicals in everyday products, which it blamed on chemical industry
lobbying.231
“This delay is due to the European chemical lobby, which put pressure again on different
Commissioners,” Swedish Environment Minister Lena Ek told AFP.
The Commission was due to set criteria by December 2013 to identify endocrine disrupting
chemicals (EDCs) in thousands of products — including disinfectants, pesticides and toiletries —
which have been linked to cancers, birth defects and development disorders in children. “Hormone
disrupters are becoming a huge problem,” said Ek, explaining that Sweden and Denmark had written
to the Commission to demand action but to little avail.
“In some places in Sweden we see double sexed fish. We have scientific reports on how this affects
fertility of young boys and girls, and other serious effects.”
Commission delays further by consulting the public on criteria to identify Endocrine Disruptors 232
The Commissioners launch a consultation on 29 September 2014 with closing date 15 January 2015.
Protecting public health from Endocrine Disrupting Chemicals: the EDC-Free Campaign
Letter to the new EU Commissioner, President Juncker, in response to the launch of a public
consultation: 20 November 2014:233
We write as 19 health and environmental organisations, doc tors, scientists and concerned
professionals across Europe to urge you to ensure that the Commission takes clear action to minimize
our multiple daily exposures to harmful hormone-disrupting chemicals. This would ensure that the EU
creates lasting benefits for productivity and health budgets by reversing chronic diseases related to
endocrine disrupting chemicals (EDCs).
The EU pesticides regulation required the European Commission to come up with EDC criteria by
the end of 2013. EU Council joins EDC court case234
230
http://www.pan-europe.info/News/PR/140520.html
231
http://www.capitalfm.co.ke/business/2014/05/sweden-to-sue-eu-for-delay-on-hormone-disrupting-
chemicals/
232
http://europa.eu/rapid/press-release_IP-14-1057_en.htm?locale=en
233
http://www.env-health.org/IMG/pdf/letter_edc_free_coalition_to_president_juncker.pdf
234
http://env-health.org/news/latest-news/article/eu-council-joints-edc-court-case
44
The EU Council of Ministers is now supporting a court case against the EU Commission regarding the
delay in delivering the criteria for EDCs. The European Parliament is also set to join. The lawsuit was
started by Sweden last year.
Letter to Vytenis Andriukaitis Commissioner for Health & Safety from 11 MEPs: economic impacts
on industry are taking precedence over human health and the environment235
On 20/01/2015 “Endocrine disrupting chemicals cause adverse health effects in an intact organism.
This is particularly relevant during pregnancy, where it can affect developmental processes of the
foetus in an irreversible manner. Cancer, infertility, diabetes, obesity and behavioural disorders have
all been linked to exposure to endocrine disrupters”…” Back in 2009, the European Parliament and
the Council adopted the Regulation (EC) No 2009/1107 on plant protection products. It included so
called cut-off criteria for endocrine disrupters: active substances in pesticides should no longer be
authorized if they were endocrine disrupters, unless there was a serious danger which cannot be
contained by other available means, including non-chemical methods… firstly, concrete interim
criteria for endocrine disrupters were adopted, and secondly, the legislator gave a mandate to the
Commission to come up with permanent criteria by the end of 2013.
“Moreover, it makes the decision about what should be the appropriate definition for endocrine
disrupters depend on the socio-economic impact on the industry and the substitutability of these
substances when used as pesticides and biocides. However, such economic considerations are totally
irrelevant when it comes to the question of what is an endocrine disruptor. “
Member states and European Parliament join Swedish court case on EDC criteria236
Wednesday, 28 January 2015
Health and Environment Alliance reports: “The European Council has voted to join Sweden's legal
case against the European Commission over its delays in proposing criteria for endocrine disrupting
chemicals (EDCs). Also the European Parliament is supporting the case.”
Estimating Burden and Disease Costs of Exposure to Endocrine-Disrupting Chemicals in the
European Union237
Rapidly increasing evidence has documented that endocrine-disrupting chemicals (EDCs) contribute
substantially to disease and disability.
Expert panels achieved consensus at least for probable (>20%) EDC causation for IQ loss and
associated intellectual disability, autism, attention-deficit hyperactivity disorder, childhood obesity,
adult obesity, adult diabetes, cryptorchidism, male infertility, and mortality associated with reduced
testosterone.
Conclusions
EDC exposures in the EU are likely to contribute substantially to disease and dysfunction across the
life course with costs in the hundreds of billions of Euros per year. These estimates represent only
those EDCs with the highest probability of causation; a broader analysis would have produced
greater estimates of burden of disease and costs.”
Other ways in which UK Ministers failed to adhere to the precautionary
principle but preferred to support corporations and the economy
Mad Cow Disease 1980s-2000; how reassurances by Ministers undermined precaution
235
http://www.michele-rivasi.eu/au-parlement/lettre-au-commissaire-europeen-a-la-sante-sur-les-criteres-
de-definition-des-perturbateurs-endocriniens/
236
http://env-health.org/news/latest-news/article/eu-council-joints-edc-court-case
237
http://dx.doi.org/10.1210/jc.2014-4324
45
From the European Environment Agency Report 2001: The Precautionary Principle: Late lessons
from Early Warnings. 238
The first case of Bovine Spongiform Encephalopathy (BSE) in cows was officially recognised in
November 1986. “The pathological characteristics of the new cattle disease closely resembled
scrapie, a transmissible spongiform encephalopathy (TSE) that is endemic in the UK sheep
population…Policy-makers were repeatedly told, both by the scientific experts on whom they claimed
to rely, and by the wider scientific community, that it was impossible to be certain that consuming
meat, milk and dairy products from animals with BSE posed no risk.
Ministers and senior policymakers insisted otherwise in public. On 7 June 1990, for example, the
Agriculture Minister told the House of Commons that there was ‘... clear scientific evidence that
British beef is perfectly safe’ (Hansard, 1990, column 906).”
By 1995 there was evidence that BSE may cause Creutzfeldt-Jakob disease (CJD) in young people. In
1996 experiments start to see whether cattle fed on rations deliberately infected with scrapie would
get BSE. The BSE crisis (1996) occurred after a new variant of CJD emerged in the United Kingdom,
and consuming BSE contaminated food was considered the most probable cause.
“Most of the deceit about BSE was perpetrated by the UK government, and only a few other
governments also employed deception to cloud its risks.” 239
Mark Purdey, a farmer who died from a brain tumour aged 52, had another theory. 240 “His life
changed one day in 1984 when a Ministry of Agriculture (MAFF, as it then was) official told him he
had to comply with a warble fly eradication order and treat his herd of Jersey cows with an
organophosphate (OP) pesticide. Purdey refused, arguing that the suggested dose was far too high
and in any case his natural treatment for warble fly was perfectly effective. The battle lines with the
agricultural bureaucracy were drawn; before they had a chance to prosecute him, Purdey took MAFF
to court and shook administrative complacency by winning his case. Purdey also noted that no home-
reared cattle on fully converted organic farms had contracted BSE. He believed that the onset of the
disease was associated with the over-use of chemicals on the cattle.” Samsel and Seneff, in their
paper: Glyphosate, pathways to modern diseases III: Manganese, neurological diseases, and
associated pathologies, agree that there may be link between glyphosate and prion diseases such as
BSE.241 Monsanto scientists were recommending pre-harvest glyphosate use in 1980. By 1985 ADAS
was promoting the use of glyphosate on grassland; they declared it to be good practice to graze the
grass or preserve it as hay or silage after treatment. 242 The compulsory treatment of warble fly with
OP Pesticides was 1978-1981. The cattle that contracted BSE were born 1986-1988. Humans started
to develop new variant CJD in 1995. It could have been a combination of chemicals.
Successive British Governments supported the pesticides industry against the public. Defra denied
a link between organophosphate use as a sheep dip in the 1980s and neurological problems in
farmers: OPs are still registered by Defra. Aviation Authorities and Physicians denied Pilots/Crew
and Gulf War Veterans symptoms connected with OP exposure.
In 2012, Mackenzie Ross, S.J. et al. Reviewed 14 studies (looking at 1600 participants) and showed a
relationship between low level exposure to organophosphates (OPs) and impaired neuro-
behavioural functioning. OPs target memory, information processing speed, the ability to plan and
238
http://www.eea.europa.eu/publications/environmental_issue_report_2001_22 Chapter 15 page 384
Patrick van Zwanenberg and Erik Millstone. ‘Mad cow disease’ 1980s–2000: how reassurances undermined
precaution. The Precautionary Principle. Late lessons from early warnings.
239
Altered Genes, Twisted Truth Steven M Druker. How the Venture to Genetically Engineer Our Food Has
Subverted Science, Corrupted Government and Systematically Deceived the Public. Page 385
240
http://www.theguardian.com/news/2006/nov/21/guardianobituaries.bse
241
http://www.surgicalneurologyint.com/temp/SurgNeurolInt6145-4381109_121011.pdf
242
Stride CD, Edwards RV, Seddon JC. Sward destruction by application of glyphosate before cutting or grazing;
1985. pp. 771–778. British Crop Protection Conference – Weeds 7B–6.
46
have abstract thoughts. 243 These findings have implications for working practice and for other
occupational groups exposed to organophosphates such as Aviation Workers and Gulf War Veterans.
When this paper was discussed on Radio 4 Farming Today in 2012, Defra denied a connection and
said it continued to authorise the OP insecticides chlorpyrifos and dimethoate.
Chemical Concern published 23/02/2015: Incriminating sheep dip poisoning: Health & Safety
Executive Report (1990) – officially destroyed –but has now been revealed 244
Farmer Tom Rigby, Sheep Dip Sufferers’ Support Group, requested a FoI. He said: “The information I
want is HSE advice given to the government minister just before he decided to abandon compulsory
dipping and the science behind and date of a government order that Ministry of Agriculture, Fisheries
and Food inspectors must not go within 14ft of a sheep dip.” The HSE responded to the FoI request
by telling Mr Rigby: “The information you requested is no longer held by the Health & Safety
Executive, having been destroyed in accordance with HSE’s corporate retention policy”. A ‘well-
wisher’ sent a copy to Mr Rigby.
Re-approval of aspartame by CoT and the FSA
The UK is the RMS for aspartame. In December 2013 CoT re-approved Monsanto’s chemical
sweetener aspartame. 245As a result of unpublished British research (Hull University), CoT had
decided there is no need to ban or control the sale or consumption of the sweetener, aspartame, to
protect the health of the public. On December 10 th 2013 EFSA completed “full risk assessment on
aspartame and concludes it is safe at current levels of exposure.” 246
Prof Erik Millstone of Sussex University had written on multiple occasions to EFSA about the toxicity
of aspartame, beginning in June 2011. He wrote a 67-page document on 20th February 2013 247 in
response to the EFSA draft report: “The draft report on the safety of aspartame, issued by the
European Food Safety Authority’s ANS panel on 8 January 2013, is deeply flawed.” He detailed the
history of aspartame in the US and the fact that for 16 years it was considered too toxic to be
licenced because it was neurotoxic and carcinogenic. On page 15 is an indictment 248 against GD
Searle, the original owners, before Monsanto bought the company.
Ralph D Walton MD, Professor at the Center for Behavioural Medicine, North Eastern Ohio
University College of Medicine has published a review of studies. 249 He did research for 60 minutes
on scientific peer-reviewed studies and funding; 92 per cent of the studies showed problems
with aspartame, but Walton said if you remove 6 studies because the FDA had something to do with
it and their controversy, and 1 pro-industry summary, one hundred per cent of independent
scientific peer-reviewed studies showed the toxicity of aspartame. Aspartame is an addictive, excite-
neurotoxic, carcinogenic, genetically engineered drug and adjuvant that damages the mitochondria
and interacts with drugs and vaccines.
243
http://oro.open.ac.uk/36218/1/Mackenzie%20Ross%20et%20al%202012a.pdf
244
https://politicalcleanup.wordpress.com/2015/02/23/secret-state-14-incriminating-sheep-dip-poisoning-
hse-report-officially-destroyed-has-now-been-revealed/
245
http://www.food.gov.uk/news-updates/news/2013/5894/aspartame
246
http://www.efsa.europa.eu/en/press/news/131210.htm
247
https://www.sussex.ac.uk/webteam/gateway/file.php?name=em-letter-to-efsa-on-aspartame-
20feb2013.pdf&site=25
248
In his role as FDA Chief Counsel, Richard Merrill was therefore satisfied that the FDA had gathered sufficient
evidence for G D Searle to be indicted for: “…violations of the federal Food, Drugs and Cosmetics Act…and the
False Reports to the Government Act…and for concealing material facts and making false statements in reports
of animal studies conducted to establish the safety of…the food additive Aspartame.”
249
http://ww.dorway.com/peerrev.html
47
UK denies that exposure to environmental chemicals damages foetal brains
UK Committee on Carcinogenicity of Chemicals in Foods, Consumer Products and the Environment
(COC) assesses and gives advice on carcinogenic risk to humans.
Meeting July 2006250 ITEM 5: Age related differences in susceptibility to carcinogenesis (CC/06/8)
Members did not support the conclusion that most of the lifetime risk associated with genotoxic
carcinogens arose from pre-adult exposure.
ITEM 8: 'Tissue Organ Field Theory' of carcinogenesis (CC/06/10)
58. A paper by Newby and Howard (2006) claimed that it is feasible that chemical environmental
contaminants could be major factors in cancer aetiology… Overall, Members agreed that the paper
reported interesting ideas but that there were insufficient data to support the hypothesis.
UK refused to acknowledge that exposure to pesticides during pregnancy is harmful
Defra Minister, the Defra Chief Scientist and Dave Bench Chief Scientist CRD gave evidence at the
Environmental Audit Committee Inquiry Insects and Insecticides. When questioned by Dr Matthew
Offord MP (Q359) about removing amateur applications of pesticides, they all agreed that it wasn’t
necessary to ban domestic use.251 Could it be because Bayer had just re-launched their garden
products campaign?252 When the Royal College of Obstetricians and Gynaecologists published their
advice to avoid chemical exposure during pregnancy,253 there was a barrage of press coverage
quoting those who dismissed the advice as ridiculous. This included the CMO at the Department of
Health254 and Tracey Brown from Sense About Science. 255
The Faroes Statement: Human Health Effects of Developmental Exposure to Chemicals in Our
Environment256
In 2007 twenty five experts in environmental health from eleven countries (including from the UK)
met on the Faroes and contributed to this statement. “The periods of embryonic, foetal and infant
development are remarkably susceptible to environmental hazards. Toxic exposures to chemical
pollutants during these windows of increased susceptibility can cause disease and disability in
infants, children and across the entire span of human life. Among the effects of toxic exposures
recognized in the past have been spontaneous abortion, congenital malformations, lowered
250
http://webarchive.nationalarchives.gov.uk/20131103234051/http://www.iacoc.org.uk/meetings/Minutes13.0
7.2006.htm
251
Lord de Mauley: The products for use in gardens have very clear instructions for use. No product is
approved for garden use if the correct use would require either training or protective clothing. The levels of
toxicity for products that are approved for garden use are generally considerably lower than for professional
use. So we think that the level of control is appropriate.
http://www.publications.parliament.uk/pa/cm201213/cmselect/cmenvaud/668/668.pdf
252
http://www.gardenforum.co.uk/tradeforum/peoplenews/?artid=2382
253
http://www.rcog.org.uk/womens-health/clinical-guidance/chemical-exposures-during-pregnancy-scientific-
impact-paper-37
254
http://www.theguardian.com/lifeandstyle/2013/jun/07/pregnancy-advice-royal-college-health-chief
255
In 2009 this registered Charity, Sense About Science, published a document to educate the general public
called “Making sense of GM”. Eight of the 28 main authors were members of the John Innes Centre. Three
were FRS and another two Fellows’ contributions were acknowledged. The author of the introduction was Prof
Jonathan Jones FRS (The Sainsbury Laboratory, John Innes Centre). Once again Prof Jones failed to declare his
links with Monsanto: [In a statement to the Observer (18/07/2010), Prof Jones insisted: "It is not true to
suggest I have attempted to hide my role as co-founder and science advisory board member of Mendel
Biotechnology, which has contracts with Monsanto, Bayer and BP. The information that I am co-founder… of
Mendel has been in the public domain on the Mendel website for at least 10 years."]
256
http://www.ncbi.nlm.nih.gov/pubmed/18226057
48
birthweight and other adverse effects. These outcomes may be readily apparent. However, even
subtle changes caused by chemical exposures during early development may lead to important
functional deficits and increased risks of disease later in life. The timing of exposure during early life
has therefore become a crucial factor to be considered in toxicological assessments.”
Chemical brain drain: insidious and pervasive257
“Today, one out of every six children suffers from some form of neurodevelopmental abnormality.
The causes are mostly unknown. Some environmental chemicals are known to cause brain damage
and many are suspected of it, but few have been tested for such effects.
The brain’s development is uniquely sensitive to toxic chemicals and even small deficits may
negatively impact our academic achievements, economic success, risk of delinquency, and quality of
life. Chemicals such as mercury, polychlorinated biphenyls (PCBs) arsenic and certain pesticides pose
an insidious threat to the next generation’s brains. When chemicals in the environment affect
development of the child’s brain, he or she is at risk for mental retardation, cerebral palsy, autism,
ADHD, and a range of learning disabilities and other deficits that will remain for a lifetime.
The chemical brain drain can be halted to protect the next generation’s brain power. First, we need
to control all of the 200 industrial chemicals that have already been proven to affect brain functions
in adults, as their effects on the developing brain are likely even worse. We must also demand
routine testing for brain toxicity, stricter regulation of emissions of brain-toxic chemicals, and
required disclosure on the part of industries who unleash these hazardous chemicals into products
and the environment. Decisions can still be made to protect the brains of future generations – and
some decisions appear to be seriously overdue. This site aims at furthering information on chemical
risks to brain development and ways to protect the next generation against chemical brain drain.”
ONLY ONE CHANCE How Environmental Pollution Impairs Brain Development - and How to Protect
the Brains of the Next Generation by Professor Philippe Grandjean: Oxford University Press.258
Review by THEO COLBORN, PHD, President, TEDX (the Endocrine Disruptor Exchange)
“This book is a huge gift to humankind from an eminent scientist. Grandjean tells the truth about
how we have been ruining the brain power of each new generation and asks if there are still enough
intelligent people in the world today to reverse the problem. I cannot rid myself of the idea that too
many brains have been drained and society is beyond the point of no return. We must learn from the
follies and scandals that Grandjean reveals and stop the chemical brain drain before it is too late.”
Violent Behavior: A Solution in Plain Sight
Why is there an increasing incidence in unsociable behaviour, disorder, aggression, gun crime, and
brutality in the UK? This paper by Sylvia Onusic, PhD, CNS, LDN, seeks reasons for the increase in
violent behaviour in America, especially among teenagers. She identifies malnutrition, vitamin and
micronutrient deficiency as potent causes of aberrant behaviour, crime and the spectrum of autistic
diseases. She says: “Some children have been corrected by a proper diet free of junk food.” 259
These are precisely the effects of exposure to glyphosate.
257
http://braindrain.dk/ www.chemicalbraindrain.info
258
http://www.env-health.org/news/latest-news/article/book-review-only-one-chance-by
259
http://www.westonaprice.org/environmental-toxins/violent-behavior-a-solution-in-plain-sight/pdf
49
The Verdict of the Permanent Peoples’ Tribunal (PPT) concerning the six
indicted corporations (BASF, BAYER, DOW CHEMICAL, DUPONT, MONSANTO,
SYNGENTA) 260
Findings in the Final Report from the PPT (Page 28)
The PPT Session was held in Bangalore, India between December 3 and 6, 2011. In accordance with
the program (Attachment 2), witnesses, technical witnesses and survivors made oral presentation of
specific cases and submitted supporting documents. As established in its Statute, the Tribunal
notified the legal representatives of the transnational corporations headquartered in Germany
(Bayer and BASF), Switzerland (Syngenta) and the United States (Monsanto, DuPont, Dow Chemical
Company).
The Tribunal makes the following declaration of responsibility for the six indicted Trans National
Corporations and three Governments in particular and further also declares the responsibilities of all
States, international organizations, UN Specialist Agencies, all other institutions of global
governance.
CONCERNING THE INDICTED SIX CORPORATIONS (BASF, BAYER, DOW CHEMICAL, DUPONT,
MONSANTO, SYNGENTA)
The Tribunal finds on all evidence presented before it, the six TNCs prima facie responsible
for gross, widespread and systematic violations of the right to health and life, economic,
social and cultural rights, as well as of civil and political rights, and women and children’s
rights.
The Tribunal further finds that their systematic acts of corporate governance have caused
avoidable catastrophic risks, increasing the prospects of extinction of biodiversity, including
species whose continued existence is necessary for reproduction of human life.
Rosemary Mason MB ChB FRCA 26/03/2015
"Corporate totalitarianism … rules through dispensability and corruption. It treats communities,
people, countries, ecosystems and species as disposable and dispensable."
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