GM Free Cymru

EFSA's glyphosate consultation: designed to help Monsanto

Date Added to website 7th May 2014

This letter outlining our concerns has gone to EFSA, in the context of the glyphosate consultation which ends on 11th May 2014. This follows an earlier exchange of correspondence in which our requests were rebuffed by some anonymous person in the EFSA Pesticides unit. The situation is a truly appalling one, with a "consultation process" which seems to have been specifically designed for the facilitation of Monsanto's commercial ambitions; EFSA says it will only look at technical matters concerning glyphosate as an "active ingredient" in Roundup formulations, and that the consents for proprietary brands like Roundup are the responsibility of member states. So we have another of these absurd situations, with everybody leaving decisions to everybody else, and no actual steps being taken to address the basic issue of danger to the environment and to public health.............. and it is quite possible that permitted levels of glyphosate will be increased yet again, just to keep Monsanto happy. in case you ever doubted it, EFSA is still complacent and corrupt, and seems incapable of appreciating, let alone addressing. the health concerns of the people of Europe.

We believe this issue MUST be aired in public -- so we will treat this letter as an Open Letter.
Public Consultations European Food Safety Authority
Via Carlo Magno 1A 43126 Parma ITALY

7th May 2014

Dear Pesticides Unit

Thank you for your anonymous letter dated 16th April, in response to mine dated 27 March. Why do we not have a name for the person responsible?

We have considered your points, and wish to respond as follows.

Please now register the following formal complaints about the consultation process.

1. The consultation process that you have created (for your own convenience) is the most byzantine we have ever encountered in more than 30 years of involvement in the voluntary sector. It is clearly designed not for the convenience of the general public but for your own "administrative ease" -- and to be as discouraging as possible for concerned individuals and NGOs. Our suspicion is that the system you are using is designed for the convenience of the pesticides and biotechnology industries, both of whom have dedicated and motivated staff who want to see the re-authorisation of glyphosate for their own commercial advantage. The system is therefore biased, and heavily weighted towards those who want to see glyphosate continue in use -- whatever the dangers to the public health and to the environment may be.

2. We wish to protest in the strongest possible terms about your refusal to send the consultation documents (from the German authority) unless the consultee agrees to this extraordinary piece of nonsense: "By sending the request I acknowledge that EFSA has the right to disregard any comments not related to the risk assessment or received after the deadline set for the selected active substance. I also accept that comments have to be submitted electronically to the email address given in the general instruction by using the template." ... and "I agree with the terms as stated above." In our view you have absolutely no right to impose such a condition, which gives you the discretion to disregard anything you consider to be irrelevant, anything submitted after your deadline, and anything submitted in the "wrong" format. A colleague has commented that this is anti-democratic, non-transparent and thoroughly Kafkaesque. We agree with him. Has EFSA learned nothing about communication, public relations and the consultation process over the years?

3. It appears that you have set your face against any consideration of Roundup, and that you will only receive and consider comments relating to "the active substance" -- in this case glyphosate. It is our understanding that you are interpreting the Chemical Regulations very tightly here, and are disregarding the use of glyphosate in association with GMO crops. That is clearly not very sensible, since you are also charged with considering the "indirect effects" of the cultivation of GMOs -- and the use of glyphosate is actually required in conjunction with the planting and harvesting of any RR crop. This is a real issue, and you must not evade it. In our understanding, the revised guidelines for risk assessment of GMOs give the appropriate panel the flexibility to consider glyphosate use with GMOs under the heading of "changes in agricultural practice". The growing of GMOs is a major change, and all of the relevant EU regulations acknowledge this. We do not accept your contention that your hands are tied. The GMO regulations give the panel a degree of freedom to include herbicide use and effects in agriculture, environment and human health, for good scientific reasons, in their risk assessment. The panel can also request proper data on these matters from the developers and the pesticide industry, if such data is not already provided.

4. Again on the matter of Roundup, you are once again seeking to hold to a very narrow interpretation of the rules (Regulation (EC) No 1107/2009 of the European Parliament and the Council, Commission Regulation (EU) No 1141/2010, and Commission Implementing Regulation (EU) No 380/2013), claiming that these put the focus of EFSA evaluations on active substances rather than toxic pesticide formulations. (These are called, euphemistically, "plant protection products" even though they are designed to kill plants as quickly as possible.) You claim that the approval or re-approval of an active substance is a risk management decision (e.g. taken by the Commission and/or Member States) and therefore does not fall under EFSA's remit. We accept that EFSA's role is to evaluate and give advice. You also point out that "plant protection products" such as Roundup are not authorised at an EU level, but that product authorisations are granted by individual Member States. We hope you will agree with us that this absurd division of responsibilities is a recipe for inactivity and a guarantee that virtually nothing will change, whatever your considered evaluation of glyphosate may be. This situation cannot be allowed to prevail, since it is more and more apparent from surveys of the literature that glyphosate and Roundup are highly toxic and harmful to human and animal health. That being the case, we believe that EFSA is perfectly at liberty to pass comment on Roundup, and to make recommendations to Member States, whether or not they have asked for them, in the interests of public health. Indeed, to evade such a course of action would in our view make EFSA culpable of once again adopting a "don't look, don't see" attitude to scientific evidence that the biotechnology / pesticides industries may find inconvenient. Evasion of responsibility would also run against a specific responsibility placed upon you to employ at all times the Precautionary Principle wherever scientific doubt occurs.

We therefore seek reassurances from you on the following matters. Please confirm that:

(a) Comments received by Email or in hard copy, outside the "designated" electronic template, WILL be considered and accepted as valid;

(b) You have no right to withhold the German documents on glyphosate from those who are not prepared to sign the illegal disclaimer referred to above.

(c) You will agree to undertake an assessment of the use of glyphosate in the context of its intended use with GMO / RR crops, as you have full discretion to do.

(d) You will give due consideration to submissions relating to Roundup formulations, since these are the materials actually used in the field by European farmers, and since new evidence points to Roundup being many times more toxic than the supposed "active substance."

We look forward to receiving your confirmation that these four protests will be placed onto the published record, and that action will immediately be taken as requested.

With many thanks


Dr Brian John GM-Free Cymru