Biologist Rod Cumberland sent this letter to all members of the NB Legislative Assembly



Dear NBMLA:



I have just reviewed the 323 page Health Canada re-assessment of glyphosate. It was due in 2014 but was completed April 13, 2015.



Rather than simply take whatever comes out of this process at face value, I believe you need to be informed of the pitfalls of this present review.



It is VERY evident that there are huge problems with this process and I would like to make you aware of them before we blindly assume that this review is unbiased and "scientific". Please allow me to elaborate on my two main shortfalls of this review:



First - There is an obvious lack of relevant research; and

(Without recent and relevant research that CLEARLY reveals numerous health and wildlife hazards associated with glyphosate, the assumptions that it is safe are erroneous).



Second - the inclusion of the economic and social benefits of glyphosate.

This document presumes to use “a science-based approach”, therefore this is no place for economic and social benefits that have little relevance when considering the science behind the impacts and safety of a compound to human health.

The shortcomings of this review are as follows:



1. The Health Canada review of glyphosate has not considered the actual product sprayed and used across Canada with the adjuvants and emulsifiers that make it the effective product it is – If glyphosate was used by itself for the benefits purported in both agriculture and forest based applications, then a review considering the impacts of glyphosate alone may be appropriate. However, the effectiveness of this compound is only possible in formulation. It is therefore the FORMULATION that must be considered in the review of glyphosate because indeed, this is what is sprayed across the country, not glyphosate alone.



2. This review has not included volumes of recent worldwide literature that reveals huge issues with glyphosate in formulation. In any scientific review, literature review or published paper, the strength of the paper is only as relevant as the research upon which it is based. In other words, using outdated and short-term studies on a compound that has been continually modified and that has long term consequences is either knowingly biasing the process and results, or worse, pleading ignorance to the advancement of science and emerging research. Neither is appropriate in this re-evaluation and this process relies on outdated, short-term research when long term and relevant research is readily available that shows markedly different results than they report.



For example, 78% of all industry-supplied research is between 10 and 40 years outdated. Further, the majority of these (a full 80%) are more than 15 years removed from currently published material. I forwarded (and have appended here) over 30 papers published within the past 10 years on glyphosate and glyphosate formulations that suggest markedly different results and reveal glyphosate and its formulations are the cause of many modern human diseases, are carcinogenic and are the cause of cell malformations in numerous types of human and animal cells, but most problematic are its problems associated with gastrointestinal systems and reproductive cells specifically. And the review doesn’t even begin to address all the relevant research on GMO’s and their problems.



Discouragingly, but likely explanatory to the present proposed conclusion is that a mere 9% of the papers used in the review are recent publications. I do not understand on such a controversial topic as glyphosate use and it’s proven health concerns why more effort was not expended to find current research from around the globe to give a much better review of this chemical. It would definitely impact this assessment. This very biased approach is clearly covered in Antoniou et.al 2012.



I would also like to comment on several specific concerns within the document:



a) On page 3 it states that “pesticides are registered for use in Canada only if the level of exposure does not cause any harmful effects”. Therefore, if there is current research that DOES show harmful effects, particularly of a chemical in the state it is sprayed in throughout the country, by their own admission it MUST NOT recommend it for use. I contend that the attached research is clear evidence that the decision must be reversed.



b) Glyphosate formulations pose negligible risk to freshwater fish and amphibians. This conclusion has been proven incorrect by modern research (Annett et.al 2014, Vera et.al 2010). It shows harmful effects and would invoke a nation-wide ban on the use of glyphosate.



c) Under 3.1 it is stated that studies were available to satisfy data requirements, yet it is not specified what these requirements are, nor what studies are applicable, when they were done, etc. to justify these statement. This is poor science and format for a review document with the intent of public review, unless of course the intent is to limit the amount of intelligent and scientific comment.



d) Cardiovascular malformations are mentioned on page 14 as serious side effects in one study (again, no specifics) but regardless, how can it be concluded that glyphosate is safe? Once again, these results disagree with the suggestion that glyphosate “does not cause harmful effects” and would rather corroborate modern research linking glyphosate and its formulations to a huge list of environmental, human and wildlife ill effects (research attached).



e) Dietary exposure can be mitigated by changes in use patterns. This begs two questions – if there are no harmful effects, why suggest mitigation? Next, mitigation is suggested, this implies harmful effects. More Problems are that this document does not suggest how these mitigative steps will be enforced to ensure compliance. Therefore, it is a hollow recommendation that affords NO protection of health.



f) On page 29 “major incidents of human exposure” are reported, however, no qualification is provided for the word “major”. Further, these exposures to “Highly toxic ingredients” or the adjuvants and emulsifiers I suggest MUST be considered. This again highlights that some of their research, along with most modern research, that glyphosate in formulation is HIGHLY TOXIC. Back to point 1 – how can such a review conclude glyphosate does not cause harmful effects unless on the grounds of semantics by separating glyphosate from its formulations, a formulation that is rarely used commercially??



g) On page 30 they reference common incidents in wild animals where these formulations cause death in wildlife. Once again, totally contradicting statements and research that suggests this assessment is incorrect and will jeopardize human, wildlife and environmental health and safety. How could a toxic substance causing death NOT warrant changes in labels at the least, or more responsibly a ban on the product?



h) The statement “Glyphosate is rarely detected in drinking water” proves the weakness and ignorance of the process and data. I include papers that show glyphosate, even at residual levels, shows up in soil, water, human urine, cattle tissue, other cells, etc. Therefore, based on modern research the present suggested evaluation must be reconsidered in light of science.



i) You assume “risk to mammals is low”. Again, research from Montana, Australia, Denmark, Germany and Egypt directly linked malformations in ungulates to the mineral chelating effect that glyphosate has and the resulting mineral deficiencies in their food and systems from the use of glyphosate; More erroneous data, more erroneous conclusions.



j) This review states there is no reproductive risk to glyphosate. Current research again proves this point outdated and erroneous (see attached research).



k) This review states glyphosate has no effect on fish. The appended research proves that herbicides are endocrine disruptors (which glyphosate is) and federal research scientists have proven they cause many problems in fish including high at-sea mortality.



l) Quite disturbing is the assertion on page 42 that one of the benefits of glyphosate is its ability to be more effective when combined with other chemicals. It is hypocritical to in one breath dismiss the impacts of glyphosate in formation because only the compound glyphosate is being reviewed, yet when it’s convenient, this very argument is used to weigh the scales in favour of the compound.



m) The wordsmithing in the section referencing OECD countries not prohibiting ALL uses of glyphosate is correct only grammatically. For the record, there are municipalities within Canada, Provinces within Canada and many countries that have prohibited the use of glyphosate (Columbia and Holland in the past few weeks) due to the health hazards and risks you purport are not present. Interesting play on words, but in no way reflects reality and concerns around this compound. Statements like these drip with bias, and ignorance – whether purposeful or not – to current research.



n) Maximum levels in foods – this raises another point that MUST be considered by Health Canada. In light of emerging research and glyphosates link to modern disease, it is Health Canada’s responsibility to request labels on all foods that have been sprayed at one point or another in the growth process by glyphosate so the public can protect themselves from ingestion of this substance. If the use of this toxic chemical is not revoked, at the very least there must be a means by which the public can make informed decisions on the purchase of these contaminated foods.



o) If the only change from Health Canada’s former review of glyphosate is several labeling changes, how does Health Canada ensure these label instructions are followed? What are the penalties for failure to heed them? Once again, this is a broken system and in NO WAY protects the health and welfare of humans, wildlife or the environment. These are serious deficiencies in this review and therefore, we cannot be expected to take this re-evaluation seriously.



In closing, I was very disappointed with this re-assessment. This appears another bureaucratic process that only provides lip service and opportunity for input just to say it was done. I would hope and expect that the elected politicians of New Brunswick would take these comments seriously and ensure such a biased and ill-informed review in light of applicable and relevant literature of glyphosate’s great risk to public health, wildlife health and the environment would step up and demand a more rigorous approach.



If NB companies, or the BNBDNR, NBAFA or other NB departments stand behind this biased and flawed review, you will be knowingly allowing the poisoning of New Brunswickers.



In all sincerity,

Rod E. Cumberland, CWB