Firmly Oppose the Increase of Glyphosate Residue Limits; Food Safety Cannot Be Compromised
[20190515 Press Release] Food Safety Cannot Be Compromised; Firmly Oppose the Increase of Glyphosate Residue Tolerance
In response to an application by Hong Kong, China-based Monsanto Far East Ltd., the Food and Drug Administration (FDA) on April 23 announced a pre-notice to add glyphosate residue tolerances for oats, barley, durum wheat, triticale, rye, sorghum, millet, rapeseed, quinoa, and buckwheat, changing the standard from "not detectable" to "no more than 10 ppm" as acceptable. We believe this is an unjustified liberalization. For the sake of consumers, especially children's health, we call on all sectors to take action and urge the FDA to halt before it is too late.
The FDA stated that this addition only raises exposure from 7.9% ADI (Acceptable Daily Intake) to 12.6% ADI, far below the general safety threshold set at 80% ADI. Both the European Food Safety Authority (EFSA) and the U.S. Environmental Protection Agency (EPA) consider the chance of glyphosate causing cancer in humans through dietary intake to be very low. The two U.S. lawsuits in which Monsanto was found liable for glyphosate-related cancer were judicial rulings, not scientific assessment results. Therefore, the aforementioned addition of glyphosate residue tolerances for coarse grains poses no health risk.
However, the FDA's considerations contain several errors. Our responses and views are as follows:
First, there is already ample evidence showing that the EFSA and EPA health risk assessments of glyphosate were subject to corporate interference.
The assessment documents relied upon by European regulatory authorities have been pointed out to contain multiple instances of plagiarism from reports submitted by Monsanto, clearly rendering their conclusions untrustworthy. Moreover, the reference materials used by the agency were mostly manufacturer-provided, unpublished reports, with few independent studies published in journal papers, making its conclusions rather biased.
As for the U.S. EPA's long record of shielding glyphosate for Monsanto, the instances are too numerous to count, including ignoring Monsanto's 1983 report that glyphosate caused renal tubular adenomas in white mice, and revealed records of senior officials communicating collusively with Monsanto. Last month, the U.S. Agency for Toxic Substances and Disease Registry published a new report exceeding 250 pages that further supports the argument that glyphosate may be carcinogenic.
Second, the FDA's view that "the jury finding Monsanto liable has no scientific basis" is a mistaken position.
During court proceedings, both the plaintiff and defendant present experimental evidence to support their positions, and scientists appear as expert witnesses to explain the scientific evidence, after which the jury makes its determination. Claiming that the court's ruling has no scientific basis is unfair.
In setting pesticide residue tolerances, the FDA considers not only ADI (Acceptable Daily Intake) and the average national consumption of each crop type, two factors related to human health, but also the needs of agricultural production and grain importers. These other factors have nothing to do with consumer health. For example, edamame, which our consumers eat less of, is set at 0.2 ppm, while soybeans, which are eaten daily, are set at 10 ppm. This clearly serves the convenience of importing genetically modified soybeans with high glyphosate residues from the Americas, rather than being a consideration for consumer health.
Third, pesticide residue tolerances are considered primarily for acute health risks and do not take into account endocrine-disrupting effects at lower concentrations.
Long-term intake of endocrine disruptors indirectly affects the nervous system, reproductive system, and other chronic diseases, and their effects may also be passed on to future generations.
According to a 2016 report by the European Commission, glyphosate has been classified as a Category 2 endocrine disruptor. Category 1 substances have confirmed effects with understood mechanisms of action, while Category 2 substances also have confirmed effects, though their mechanisms of action remain unclear. From the precautionary principle perspective, even trace intake of glyphosate requires caution.
Fourth, Monsanto has long concealed the toxicity of glyphosate.
Since Monsanto began selling glyphosate herbicide in 1974, it has continuously used advertising to deceive the public by claiming that glyphosate is non-toxic to animals and easily degrades in soil, causing countries around the world to be lax about this herbicide. Only in recent years has the academic community gradually taken its risks seriously, and research reports on glyphosate's health risks have begun to emerge. In the past two years alone, at least 13 published academic papers have pointed out that glyphosate indeed poses health risks:
In animals, papers indicate that glyphosate affects the development and endocrine system of rats during embryonic and postnatal growth periods. Its effects may also occur in the second and third generations. One possible mechanism of glyphosate is altering the gut microbiota composition, namely reducing beneficial bacteria while leaving E. coli unchanged. Glyphosate can alter neurobehavioral patterns in white mice, possibly through changes in gut microbiota.
In humans, epidemiological studies in the United States found that Parkinson's disease patients who were easily exposed to glyphosate herbicides had a higher mortality rate before age 75 compared to those in areas where herbicides were not used. Exposure to glyphosate environments may lead to autism spectrum disorder and intellectual decline in children. Laboratory studies have also found that glyphosate at low concentrations of 5% of the Acceptable Daily Intake has genotoxic effects on human lymphocytes, with chromosome aberration rates and micronucleus rates significantly increasing.
Fifth, this addition is unnecessary.
The FDA sampled imported coarse grain foods between 2014 and 2018. Among them, buckwheat and barley were 100% below detection limits. The most non-compliant detections were in oat products, with a zero-detection rate as high as 84%, and only 16% containing glyphosate, with the highest numbers in 2016 for oatmeal, 5 batches of oat groats, and 11 batches of oat preparations.
When the news came out in 2016, it immediately triggered consumer backlash. When testing was conducted again in 2017, only one batch tested positive for glyphosate. Clearly, the release of the sampling report successfully made importers more vigilant, paying attention to the quality of imported products and reducing consumer concerns. The FDA truly deserves credit for this. Since importers are capable of achieving zero detection, this addition is simply an unnecessary exercise.
Given that most of our coarse grain foods rely on imports, with durum wheat used as pasta ingredients and breakfast oatmeal consumed in considerable quantities, and evidence showing that glyphosate disrupts the endocrine system, total food intake by the human body should be minimized. Maintaining zero detection for coarse grains has little impact on importers. We call on the FDA and the Council of Agriculture to cancel this addition of glyphosate tolerances. In addition to protecting the health of children and general consumers, this would also encourage domestic farmers to produce high-quality coarse grains, implement the Council of Agriculture's coarse grain recultivation policy, and fulfill the intent of the Organic Agriculture Promotion Act passed by the Legislative Yuan.
Therefore, we strongly demand that the FDA respond to the following demands as soon as possible:
1. We call on the FDA to withdraw the pre-notice of this amendment adding glyphosate residue standards.
2. Publicly release the data from the advisory committee's assessment of adding glyphosate pesticide residue tolerance standards.
3. The government should not open the door wide for imported coarse grains containing glyphosate residues.
Organizers: Taiwan GMO-Free Promotion Alliance (Homemakers United Foundation Consumer Cooperative, Homemakers United Foundation Environmental Protection Foundation, Green Citizens' Action Alliance, Professor Guo Hua-ren of NTU Vision Seed Network, Campus Lunch Goes GMO-Free Team)
Press Contact: Chen Ren-he, Chief Executive Officer, Homemakers United Foundation Environmental Protection Foundation (0933-201508)
Chang Yu-ling, Administrative Director, Homemakers United Foundation Environmental Protection Foundation (0921-890916)