GM Free Cymru

Glyphosate / Roundup: a Plea for Precaution

European Commissioner for Health and Food Safety Mr Vytenis Andriukaitis
European Commissioner for Research, Science and Innovation Mr. Carlos Moedas
European Commission
B – 1049 Brussels


14th April 2015

Dear Commissioners,

Glyphosate and Roundup

We have been following the recent developments concerning GMOs and the industrial chemicals that go with them -- and in particular glyphosate and Roundup. As you will be aware, because those chemicals are responsible for "indirect harm" when used in conjunction with HT GMOs in the places where they are grown, and indeed in the places where they are consumed (through traceable chemical residues in food and feed), they have to be subjected to very careful scrutiny. Public health issues must always trump commercial considerations where demonstrable harm is being discussed and controlled.

You will be aware that on behalf of GM-Free Cymru and other organizations we have brought two Petitions to the EP Petitions Committee in recent times. These are Petitions 813-08 and 436-10; the first relates to "The importance of impartiality within EFSA & the food safety rights of EU citizens" and the second to "Formal protest from scientists against the Commission's draft regulation on implementing rules concerning the applications for authorisation of GM food and feed." In 2013 we accused DG-SANCO and EFSA of overseeing a dramatic reduction in the quality of the science used in the assessment of new GMO varieties (particularly for stacked events); of pandering to political and commercial pressures; and of using EU citizens as "laboratory rats" in a gigantic experiment in which we are fed on potentially dangerous GMO products and chemicals which we did not ask for, which we do not need, and which bring us no nutritional or cost benefits whatsoever. Those Petitions are still alive, and have still not received satisfactory responses from DG-SANCO and EFSA to the points raised in presentations in Brussels. Last year we also entered a formal complaint to the EU Ombudsman relating to the highly biased and impossibly difficult "public consultation process" operated by EFSA in its review of glyphosate safety. The result of that complaint is still not known.

Underlying all of the foregoing is a conviction that the scientific evidence demonstrates actual health harm, on a substantial scale, connected with the growing and consumption of GMO crops and foods and the use of associated chemicals like Roundup. In the last three years a flood of peer-reviewed papers have reinforced this belief and have brought us to make heavy criticism of Prof Anne Glover, who in her time as Chief Scientific Adviser to Mr Barroso repeated the lie (several times) that "If we look at evidence from [more than] 15 years of growing and consuming GMO foods globally, then there is no substantiated case of any adverse impact on human health, animal health or environmental health." We are grateful that she has now gone off to pastures new, where she is likely to do less harm; but her lie is still repeated by others.

We now wish to draw your attention to the following recent developments:

1. A working party of the WHO followed a specialist conference in March with a short paper to The Lancet which declared that glyphosate was now considered to be "a probable human carcinogen." Predictably, this was accompanied by a storm of protest from Monsanto and from the industry-led Glyphosate Task Force, who accused the WHOs Cancer Panel of bias and incompetence and who demanded the retraction of a paper that will probably not be published before 2016! But the WHO authors have not been cowed, and their Report will no doubt contain chapter and verse. What interests us is the fact that a 2A categorisation in the IARC is equivalent to 1B in the European Union, which means that glyphosate cannot receive a new EU authorisation.

2. Following various leads into the archives of the AmericanEnvironmental Protection Agency (EPA), GM-Free Cymru has just published a short report that showed that both Monsanto and the EPA knew of the link between glyphosate and cancer as long ago as 1980, since malignant tumours and other organ damage had been recorded in rat and mouse feeding studies which were, and still are, treated as trade secrets. The revelations confirmed other findings published by Caroline Cox in 1995 and by ISIS in 2014. Our study is here:
We are in no doubt that the "harmless glyphosate myth" started because of a conspiracy involving Monsanto and the EPA in 1981, and that it has been kept alive ever since by American, EU and other regulators around the world for purely commercial reasons. Here again, EFSA and other EU agencies are culpable, since they have turned a blind eye to the accumulating evidence of harm ever since the early days of the European Union.

3. The recent decision by the German (BfR) assessors of glyphosate not to recommend re-approval of the chemical in the EU, but to recommend a careful consideration of the WHO finding that it is "a probable carcinogen", is noteworthy. Frankly, we had expected a recommendation of re-approval, since the BfR report had been written by the industry body called the Glyphosate Task Force; but that would probably have brought the whole re-assessment process into even greater disrepute. We note that BfR recommends that all relevant bodies should discuss "the current disputable issues, with the aim of resolving the discrepancies, before the EU-Commission makes a decision on the further approval of glyphosate."
As you will be aware, the greatest current disputable issue relates to the glyphosate / cancer link, but possibly of even greater importance is the fact that EFSA and the other regulators have refused steadfastly to consider the real impact of Roundup and the other formulations that are actually used by farmers in the field.

Now that a broad-based debate is inevitable, involving many different agencies, there will at last be an opportunity to bring the debate about cancer and other health effects into the open. But we respectfully submit that you cannot exclude Roundup from the debate for a moment longer, in view of the fact that it is MUCH more toxic than glyphosate and should have been banned years ago. We therefore urge you to announce that Roundup toxicity WILL now be considered as part of the review process for glyphosate.

We also ask you to freeze any more EC decisions relating to GMO authorisations indefinitely, given that many of the stacked GMO varieties under consideration are herbicide tolerant to glyphosate and Roundup. Consents for these varieties on 15th April would encourage expanded glyphosate use -- just following the WHO warning that it is a probable carcinogen. Any such consents would inevitably be interpreted as a sign that the EC treats the commercial ambitions of Monsanto and other corporations as more important than public health.

Finally we ask you to insist that Monsanto releases for full public scrutiny the Reports on its early glyphosate animal feeding studies (1979-1985) which have been treated as "trade secrets" by the American EPA simply because that is what Monsanto requested. Those reports contain evidence of cancer, and if Monsanto will not release them into the public domain for expert analysis, we will all know what that means.........

We will be very grateful for your action on the above points, and we look forward to hearing from you.

Yours sincerely,

Dr Brian John
GM-Free Cymru