Glyphosate and the Politics of Safety

You could call it a convergence of interests.

About a month ago a meeting was held in Truro, Nova Scotia to inform an already jittery public about forest company spraying of VisionMax, a glyphosate-based herbicide on its clearcuts. At the time the Department of Environment had issued 11 permits, including four to Northern Pulp, one to J.D Irving Ltd., two to Wagner Forest NS Ltd., and one to Century Forestry Consultants, totaling about 2,900 ha (about 7,160 acres) to spray on private land. News of it sparked a wave of protest in the form of articles and letters, as well as 10,000 signatures on three online petitions including this one. To date there have been 12 approvals, totaling more than 3,100 hectares in seven counties.

Lenore Zann was at the meeting. She’s an NDP Member of the Legislative Assembly and Colchester County, one of the areas slated for spraying, is in her riding. Zann says the meeting was “staged” by forest industry interests in the province: Forest Nova Scotia (formerly the Nova Scotia Forest Products Association), the Department of Natural Resources (DNR), and the “pro-spray” lobby. The invite to the meeting promised an “interactive session” to “learn more about the science of forest renewal and herbicide use,” but Zann says it was anything but that. “There was no balance on the panel, and anyone ‘interacting’ from the floor was aggressively controlled and our questions largely went unanswered,” she says.^[1]The panelists included Doug Pitt and Dean Thompson, two research scientists at NRCan-Canadian Forest Service, and Len Ritter, a professor Emeritus in Environmental Science at the University of … Continue reading

Even though herbicide spraying of clearcuts has been common practice in the province for the better part of 30 years, and not practiced at all on crown land in the last several, the recent spate of spray permits hit a raw nerve. For one thing they had been issued on the heels of the DNRs five-year progress report on the 2011 Natural Resources Strategy, which many deemed a massive failure in public policy and a betrayal of the public will — citizen-led targets, including a significant reduction in clearcutting, were abandoned.

But news of the spraying also came while concerns over glyphosate’s safety had been on our radar screens for more than a year, ever since the cancer research arm of the World Health Organization classified it as a probable carcinogen.

Quantities Astronomical

Over a period of 40 years, glyphosate has risen to become the most heavily used herbicide in the world. Since 1974, when the compound was first sold to farmers in the US by Monsanto, the Missouri-based agrochemical giant, more than 1.6 billion kilograms of the active ingredient have been applied in the US alone.^[2]Monsanto was the principal manufacturer of polychlorinated biphenyl (PCBs) in the US from the 1930s to the 1970s — its share of global production was about 45 per cent. PCBs were synthetic, … Continue reading Globally the figure is closer to nine billion kg.

To wrap your head around how vast an amount this is, consider this: In just one year—2014 — farmers sprayed enough glyphosate to cover every single hectare of the world’s cultivated cropland with 0.5 kg of the herbicide.

As astronomical as that is, it doesn’t stop there. Both production and use are increasing.

In fact, ever since Monsanto developed “Roundup Ready” seeds in 1996 — genetically engineered so that the crops would survive an application of herbicide — usage soared. Globally, nearly three-quarters of the total volume of glyphosate applied since 1974 has been sprayed since 2004. Another contributing factor is that ever since Monsanto’s US patent expired in 2000, production has increased with the emergence of competition from generic glyphosate producers worldwide. Today, glyphosate is reported to be manufactured by more than 90 companies in 20 countries, including 53 in China alone. China currently exports 35 per cent of the global supply of the herbicide.

For its part, Monsanto has always claimed that glyphosate is benign, environmentally friendly, and safe “when used according to the label instructions.”

But lately these blanket assurances have been called into serious question.

More than the Active Ingredient

Glyphosate is the active ingredient in a number of products sold worldwide under various trade names including Roundup, Visionmax, Rodeo, Wipe Out, and Ground-up. It is reported that in the US alone there are 750 products containing glyphosate.

The way the compound works is by shutting down a biochemical pathway found in plants by interfering with the production of amino acids, needed for the plant to grow. Eventually, the plant dies from starvation.

But glyphosate, the active ingredient, only accounts for about 40 per cent of the herbicide formulation. The rest is water and any combination of more than 2,000 substances, which could be added by the manufacturer but not listed on the label. Health Canada’s media relations advisor, Andre Gagnon, says the public is not informed about what makes up the inerts (known as “formulants” in Canada) because those substances are considered “Confidential Business Information.” But Gagnon says Health Canada knows what they are and they’ve been “deemed safe for the proposed uses before the product is approved for use.”

Independent scientists, however, have been warning for years that glyphosate plus all the other ingredients may be much more dangerous than glyphosate all by itself. In 2013, one controversial study that appeared in the journal Toxicology concluded that the inert ingredients were more toxic than glyphosate alone. And as mentioned above, in 2015 the research arm of the World Health Organization declared glyphosate a probable carcinogen — a subject we’ll return to.

The International Agency for Research on Cancer (IARC) also said that glyphosate-based herbicides often contain multiple active ingredients, and that “herbicide resistance is driving demand for new herbicide formulations.” It noted that inerts such as  polyethoxylated tallowamines (POEAs) were present, which are used to penetrate the waxy surface of many plants. POEAs have been found to cause a host of health problems including nausea, inflammation in the lungs,  and skin and gastrointestinal irritation.

In 2015, Health Canada launched a public consultation process on its proposed decision to continue the registration of glyphosate-based herbicides. In the summary of the consultation it notes:

At high enough concentrations, POEA is toxic to aquatic organisms but is not expected to persist in the environment. While, in general, glyphosate formulations that contain POEA are more toxic to freshwater and marine/estuarine organisms than formulations that do not contain POEA, they do not pose an unacceptable risk to the environment when used as directed on the label.^[3]Pest Management Regulatory Agency, Health Canada. 2015. Proposed Re-evaluation Decision PRVD2015-01, Glyphosate. http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_prvd2015-01/prvd2015-01-eng.php

Around this time other countries were reconsidering glyphosate. In April 2016, the European Parliament adopted a non-binding resolution opposing the European Commission’s proposal to reapprove the weed killer. When the Commission met its members failed to agree with the Parliament; while the Commission cited health concerns, the Commission instead extended the approval for 18 months due to “legal obligations” pending the result of the decision by the European Chemicals Agency on glyphosate’s health risks. However, the extension came with conditions including a ban on the POEA from glyphosate-based products and minimizing the use of glyphosate in public parks and playgrounds.

Earlier this year in the US, the Environmental Protection Agency (EPA) was also involved in a re-registering process and concluded that the herbicide is “not likely to be carcinogenic to humans.” But the next week the report and 13 related documents, including this one were removed from the agency’s website saying their publication had been an error and that the materials would be released at the end of this year. According to an investigative piece that appeared in The Intercept, the documents showed that the safety of the inert ingredients did not factor into the assessment process, and only studies involving the active ingredient were considered.

That Monsanto knew or should have known that the whole was more dangerous than its parts is now the subject of at least four lawsuits against the company in the US, involving people who developed non-Hodgkin lymphoma after using Roundup.

It could be a coincidence that amidst all this action that in April of this year Monsanto reported in a blog post that it will be “transitioning away” from POEA in its products “for commercial reasons.”

As Evidence Builds, so Does the Residue

Health Canada’s Pest Management Regulatory Agency (PMRA) is the federal body that looks after the registration and regulation of pesticides and herbicides in Canada and sets maximum residue levels for individual food-pesticide combinations, for meat, fruit, vegetables, dairy products, grains, and some processed foods. The Canadian Food Inspection Agency is the branch that monitors and enforces residue limits in both domestic and imported foods.

Because glyphosate isn’t considered very toxic by Health Canada, fairly high maximum residue levels (MRL) are now allowed here. But it wasn’t always that way. Prior to 1995, MRLs for glyphosate on all food in Canada was 0.1 ppm (parts per million). Back then Health Canada relied on the use of a General Maximum Residue Limit that was set at that value. It was established under the old Food and Drug Act. But once the PMRA was established in 1995, the department took steps to establish specific MRLs and eventually did under the new Pest Control Products Act.

Today, the MRLs for glyphosate are much higher. Residue on soybeans is allowed to be as high as 20 ppm, cereals such as barley and oats are 10-15 ppm, canola is 20 ppm, sugar beet roots are 10 ppm. When it comes to cereals, something we eat a lot of, the MRL is quite high largely because glyphosate is often sprayed later in the season as what’s called a pre-harvest desiccant — where it is used to speed up the drying of crops in the field so that harvest operations can be completed before bad weather sets in. This practice significantly increases the frequency and levels of residue on harvested grains, requiring registrants to seek significant increases in allowed residue levels.

Some animals headed to the dinner table also feed on crops and grains that have been sprayed with glyphosate, so MRLs have been established for their organs as well: 2 ppm for the kidneys of chickens, horses, sheep, and pigs; and 0.2 ppm for their livers.

How did the new, and much higher MRLs get established?

Basically it works like this: Monsanto submits to the PMRA the rate it says is necessary for the herbicide to work. Monsanto then conducts field trials using its proposed rate, and residue levels are collected on the tested crops. These results are reported back to the PMRA where they are reviewed and MRLs are then established. Gagnon says that the MRLs are only established for the active ingredient, glyphosate in this case.

But since glyphosate residue is in just about everything we eat (unless it’s organic), the residue levels need to be added up to determine our daily exposure to the chemical. Government reviewers do this too: they look at how much of each crop the typical Canadian would normally ingest in a day to establish an acceptable daily intake level. “The dietary risk assessment uses these identified crop residue levels and calculates the potential total human dietary exposure based on Canadian diets, to determine whether risks are acceptable,” says Gagnon. By “acceptable” he means “that the level of dietary exposure is less than or equal to the amount that is considered to be acceptable when consumed daily over a lifetime.”

But what happens if one were to exceed the acceptable daily intake? Gagnon says a wide margin of safety is built in and high-end values are typically used in these assessments so as not to underestimate exposure. He says that even if residue levels were found to exceed the MRL, it doesn’t mean a food poses a health risk to consumers: “Negative health effects in animals resulting from glyphosate exposure occur only at doses more than 100 times higher (and often much higher) than the levels that humans are normally exposed to,” he says, and then adds, “when it is used according to label directions.”

So, Monsanto supplies Health Canada with the field data to establish the residue levels we’re allowed to ingest. But how does Health Canada come to the conclusion that these residue levels are safe?

Industry-sponsored Science and the “Funding Dilemma”

The 1990s were a tumultuous time for Canada’s regulatory bodies. Arguably, the dismantling of Canada’s health watch-dog was the first high profile example of it putting the fox in charge of the hen house.

Over a five-year period between 1993 and 1998, Canada’s governing Liberals (following a track already set by the outgoing Conservatives) cut overall funding to Canada’s Health Protection Branch (HPB) by half. One devastating blow to Health Canada’s already diminished role that appeared more symbolic than fiscal — having saved the feds a mere $6 million at the time — was the dismantling of the entire Bureau of Drug Research, capable of conducting independent lab investigations of pharmaceutical products.

Equipment that wasn’t sent off to universities and colleges was junked and scientists were asked to sort through decades of files and reference material. What wasn’t archived was shredded. The scientists themselves were given buyout packages or positions as drug reviewers. Money was instead being pumped into “health information systems,” or industry clearinghouses where information supplied by drug companies was sent along a health information highway to be processed, rather than independently verified.

Similar cuts were wielded on the agencies responsible for food safety and drug safety, and pesticide regulation.

When the Pest Management Regulatory Agency was created in 1995, staff and resources from four federal departments — Agriculture and Agri-Food Canada, Environment Canada, Natural Resources Canada and Health Canada — were consolidated into a single agency within Health Canada. The mandate of the PMRA has always been a dual and conflicting one: to “minimize the risks” associated with pesticides while at the same time “enabling access to pest management tools.”

According to the rules around the registration of pesticides, the agency first has to conduct a review: it looks at what other regulatory authorities have decided, such as the United States Environmental Protection Agency, the European Union, and other member countries of the OECD. And when it comes to the health studies, the source of the information is the manufacturer: “It must undergo extensive testing, which is the manufacturer’s responsibility to carry out,” says Gagnon. “The onus has always been on the applicant to provide the data required to support a pesticide application.”

Once the manufacturer submits all the data and results to Health Canada with an application for registration, Health Canada follows a set of test guidelines and principles developed by the OECD to assess whether Good Laboratory Practice was adhered to. Health Canada scientists also cross-check the data from different studies, and findings with those from counterparts in other countries. But essentially all the studies they look at are industry-sponsored ones.

Gagnon also says that the decision to register a product is based on the potential social and economic impact of doing so.

But there’s something else Canada’s pesticide regulator gets from the manufacturer: fees.

A few years after the PMRA was established, concerns were already being raised about whether its priorities might be skewed in favour of its revenue-generating activities.

Government critics were calling it a “funding dilemma” and arguing that cost recovery fees, which were collected from companies like Monsanto — registrants wanting their weed and pest killers registered for sale in Canada — were accounting for too much of the agency’s operating budget.

In 2000, a report of the Standing Committee on Environment and Sustainable Development (chaired by Liberal MP Charles Caccia) was released titled “Pesticides: Making the Right Choice for Protection of Health and the Environment.” Among many other things, the report studied the funding issue and relayed that at the time (between 1997, when cost recovery fees were introduced, and 2000) payments from registrants accounted for roughly 30 per cent of the agency’s annual operating budget. The report went so far as to say that cost recovery fees were “a possible disincentive to the registration of safer pesticides.” The Committee recommended that if fees were going to be paid by registrants they should go to the Receiver General of Canada instead of directly to the PMRA:

If this were done, the PMRA might be under less pressure to generate revenues through the registration of pesticides in order to bolster its operating budget and thus might give a higher priority to the non-revenue-generating activities within its mandate, notably programs directed at developing alternatives to pesticides.^[4]House of Commons Standing Committee on Environment and Sustainable Development. 2000. “Pesticides: Making the Right Choice for the Protection of Health and the Environment.” Chapter 17: The … Continue reading

The Committee also recommended increased funding for the PMRA: “We were alarmed by the level of concern among senior scientists in all departments and associated scientific organizations about the government’s declining ability to respond to new demands and emerging issues.”

While it’s difficult to know how many of the Committee’s extensive list of recommendations were taken up, it’s safe to say the funding dilemma remains. According to the PMRA’s most recent annual report (2014-2015) cost recovery still accounts for roughly 30 per cent of its base operating budget, and registrants continue to pay PMRA directly.

The Committee also recommended that the precautionary approach be taken in decision-making, and that the “absolute priority” of the PMRA should be the “protection of human health and the environment”:

The precautionary principle means that appropriate preventive measures are to be taken where there is reason to believe that a pesticide is likely to cause harm, even when there is no conclusive evidence to prove a causal relation between the pesticide and its effects.^[5]Ibid.

When it comes to glyphosate-based herbicides it’s also fair to say the precautionary approach has been abandoned.

Hazard versus Risk  

In 2015, the International Agency for Research on Cancer (IARC) — a specialized research arm of the WHO — declared that glyphosate was a “probable carcinogen.” It reviewed studies that looked at real world exposures of farmers and farm families to glyphosate, as well as at other studies of animals being exposed to glyphosate in lab experiments, and found “limited” evidence glyphosate causes non-Hodgkin lymphoma in humans and “convincing evidence” it caused cancer in lab animals.

In fact, the IARC noted that back in 1985 the US EPA also classified glyphosate as “possibly carcinogenic to humans” but re-evaluated the finding and reversed it in 1991. The IARC also found that glyphosate caused DNA and chromosomal damage in human cells.

What sets the IARC findings apart from others — particularly those referenced by regulatory bodies — is that (in its own words) it reviewed roughly 1,000 “publicly available” studies by “independent experts, free from vested interests.” In other words, unlike the regulatory agencies, the IARC did not rely solely on studies provided by the manufacturers.

After the IARC findings were publicized there was, not surprisingly, a blow back: About seven months later the European Food Safety Authority funded by the EU published a different assessment claiming the opposite: “unlikely to pose a carcinogenic hazard.” And since then the regulatory bodies of several countries, including the US and Canada, have chimed in opposing the IARC findings.

Others have argued that while the IARC finding might be true, it does not mean people should stop using glyphosate. After all, the IARC also categorizes processed meat and alcohol as being “probable carcinogens.” These critics argue that the IARC only assesses whether something is a “hazard,” or could cause cancer in any way. Since it does not look at the levels of human exposure or consumption, it does not assess the “risk,” or the likelihood of someone actually getting cancer from glyphosate.

There is an ongoing debate in regulatory circles around the world about when hazard or risk considerations should be the basis of decision-making. In other words, should something be banned because it has the ability to cause serious harm or should it be banned because there is a “risk” — a real probability that it will actually cause harm, based on exposure levels?

Bisphenol A, or BPA provides a good example. The synthetic chemical used in the making of plastic was developed in 1891. Like many chemicals, it was first developed with pharmaceutical applications in mind — it was originally intended as a synthetic estrogen hormone to help women with fertility issues. But by the early 1950s it found its way into epoxy resins to coat the inside of metal-based food and beverage cans and into plastic containers like baby bottles to make them more heat-resistance and durable. In the early 1990s scientists discovered that the chemical was migrating from the plastic laboratory bottles into the water they contained, starting the controversy over whether humans, and particularly babies were being exposed to a potential endocrine disruptor.

Then in 2006, 38 experts working on endocrine disruption put forth a consensus statement arguing that levels of BPA concentrations could be causing, among other things, reproductive disorders. Two years later it was Health Canada that made the ground-breaking decision to ban BPA from baby bottles, citing the precautionary principle. Following Canada’s lead and the overwhelming international public pressure that ensued, Denmark and Belgium followed suit and similar decisions have been made in some states, counties, and cities in the US. In 2011 the EU banned the use of BPA in baby bottles, and in 2015 France banned it from materials that come in contact with food.

So, BPA is believed to be an endocrine disruptor and therefore a “hazard,” and for many countries this has been enough information to impose a ban. Other regulatory bodies, notably the US EPA, are so far reserving judgement.

Industrial Food and Fibre Production

While Nova Scotia’s Department of Environment doesn’t have the data about how many hectares of glyphosate are sprayed for agricultural purposes because it does not trigger an approval from the department, we do know that agriculture accounts for the lion’s share of glyphosate application.

David Patriquin is a retired Dalhousie University biologist. He says that herbicide tolerant crops — created using genetic engineering — represent the final “victory” of industrial agriculture over weeds. “In more traditional systems, weeds were set back by tillage or outcompeted by crop varieties selected to be competitive, but there were weeds in the understory and on fields after they were harvested,” he says. “These were mostly annual weeds, which flower prolifically and produce a lot of fruit (seeds) which served as significant food sources for insects, birds and mammals.”

Patriquin says the vast fields of herbicide-tolerant GMO corn, canola, and soy that are now planted in Canada are essentially “dead,” completely devoid of any biodiversity. “It must be having an effect, but you don’t see efforts being made here like those in Europe to provide compensatory actions for wildlife.” Many scientists, for instance, have raised the unsettling connection between the disappearance of milkweed in and around farm fields and the precipitous decline in monarch butterflies.

In addition to its farm applications, glyphosate-based herbicides have also become a mainstay of the forest industry, to kill hardwood competition after a clearcut. According to Raymond Plourde, the wilderness coordinator at the Ecology Action Centre (EAC) in Halifax, the spraying of glyphosate is more a “symptom” of industrial forestry than anything else. “Clearcut, plant, spray, and repeat every 40 years,” he says.

In 2010, the EAC published a report on the use of herbicides in Nova Scotia as a “forest management tool,” and found that it was possible to have well stocked stands without using herbicides, but there was something standing in the way: the DNR’s definition of successful forest management.

Jamie Simpson, the Forest Program coordinator at the time and co-author of the study, says that success for the DNR is getting either the planted softwood trees to dominate the stand or to get natural regeneration with softwood species, and herbicides were seen as a way to achieve this goal. According to Simpson, the DNR claim that less than three per cent of non-sprayed plantations meet their criteria of success, but he says this is because their definition of “success” is “very limited.”

“If one defined success as adequate stocking with all commercial species (not just the few chosen by DNR), then the success rates were roughly the same between sprayed and non-sprayed sites,” he says. Simpson’s study also reported that the use of herbicides led to much more “simplified forests” that were “less diverse and more vulnerable to disturbances.”

Patriquin, the retired Dalhousie biologist, agrees. He says the softwood stands that are created with herbicides are not only much less biodiverse, but more flammable and poorly adapted to climate change. He says the forest stands that develop after a glyphosate-sprayed clearcut don’t resemble the mixed Acadian forest that develops normally on Nova Scotia’s landscapes. “I’ve seen an awful lot of even-aged conifer stands with only an occasional red maple or aspen amidst them,” he says.

Earlier this year, a “consensus statement” about glyphosate-based herbicides was published in the journal Environmental Health. The authors, including 10 scientists in the environmental health and medical field, refute the long held view that glyphosate and its formulations are safe. While their focus is on mammalian health risks, they say the natural world is also adversely affected: fish, butterflies, earthworms, and beneficial soil microorganisms are all affected by heavy and repeated uses of glyphosate-based herbicides. “Glyphosate binds strongly to some soils… after repeated applications it can accumulate and become a long-term source of soil and groundwater contamination.”

They also cite evidence to show (contrary to the long-held belief) the weed-killer doesn’t just go after plants but can also adversely affect mammalian biology. The authors provide some sobering recommendations that include a need for more comprehensive epidemiological studies on the effects on human health, especially as human exposures are rising. They also argue that in order to avoid conflicts of interest, scientists independent of the manufacturer should conduct the regulatory tests; that tests should not only be done for glyphosate, the active ingredient, but for the whole product (including the formulants); and that regulatory estimates of tolerable daily intakes for glyphosate in most countries are based on outdated science.

Here in Nova Scotia, and indeed around the world, the questions around glyphosate safety and human health abound. But there are lots of other questions too. What’s it doing to the productivity of the soil that it binds to, and the hidden world of bacteria and fungi living inside the roots of trees? What happens to the beneficial pollinators and all the species (plant and otherwise) that depend on them? Could it be contributing to the spate in toxic algae blooms in the province, like the really bad one affecting the whole of Mattatall Lake for instance?^[6]A recent study indicates that there could be a connection between glyphosate and phosphorus runoff, which is known to contribute to toxic algal blooms and supposedly exists at very high levels in the … Continue reading

These are all legitimate questions, and the blanket assurances and scripted answers we’ve been getting are no longer sufficient.

Editor’s note:  the top photo in this article shows a clearcut that appears to have been sprayed with glyphosate, at Thomson Station in Cumberland County. Photo courtesy Norris Whiston.