Comments to EPA on Glyphosate:
Proposed Interim Registration Review Decision
Rural Coalition and Alianza Naciónal de Campesinas
Agricultural Missions, Inc.
BioRegional Strategies, Inc.
Concerned Citizens of Tillery
Cottage House, Inc.
Hempstead Project Heart
La Mujer Obrera
Organización en California de Lideres Campesinas, Inc.
Mississippi Association of Cooperatives
National Latino Farmers and Ranchers Trade Association
North Carolina Association of Black Lawyers Land Loss Prevention Project
Oklahoma Black Historical Research Project
Rural Advancement Fund of the National Sharecroppers Fund
and
NRDC:
https://www.nrdc.org/sites/default/files/nrdc-glyphosate-cancer-comments-20190903.pdf
Introduction
The Rural Coalition, Alianza Naciónal de Campesinas, etal are submitting these comments on the issuance of an interim or final decision on the registration of glyphosate under Docket ID No. EPA-HQ-OPP-2009-0361. We urge the Administrator of the U.S. Environmental Protection Agency to exercise its immediate authority to cancel the registration of Glyphosate pursuant to 7 U.S.C. 136 (c)(8).
The foundation of our request rests upon applicable statutes and regulations which permit the cancelation of an herbicide registration where there is a finding of “adverse risk to man or the environment.” Since glyphosate was first registered for use in the U.S. 45 years ago, our members and partners have experienced substantial negative health, ecological, and agronomic consequences of the herbicide. As allies with the mission of protecting the health and safety of the environment and farmers and farmworkers, we strongly believe that the more prudent decision is cancelation rather than reregistration.
7 U.S.C. 136 (c) (8) states in relevant part:
Notwithstanding any other provision of this subchapter, the Administrator may not initiate a public interim administrative review process to develop a risk-benefit evaluation of the ingredients of a herbicide or any of its uses prior to initiating a formal action to cancel, suspend, or deny registration of such herbicide, required under this subchapter, unless such interim administrative process is based on a validated test or other significant evidence raising prudent concerns of unreasonable adverse risk to man or the environment. 7 U.S.C. 136 (c) (8).
There is significant evidence in the form of peer reviewed scientific studies and case law demonstrating the significant and unreasonable adverse impacts of glyphosate on BOTH man AND the environment. As such we support a formal action to deny a re-registration of the chemical
Human and Environmental Concerns
There is no question that the research on glyphosate has become highly politicized. However, for our member organizations, which include farmworker and farmer organizations, this is not a political issue. To a farmworker facing significant exposure to glyphosate, this is a family health issue where exposure may result in diseases such ranging from cancer to pulmonary, kidney or celiac disease and autism. It is important to note that glyphosate does not kill on the spot. It is the cumulative effects that matter. It isn’t until glyphosate starts building up in the body over months and years, when symptoms start to arise. As shown below, this has been the personal experience of many of our members. Furthermore, this remains an under-reported and under-acknowledged set of impacts of glyphosate use.
As the recent immigration debate has revealed, farmworkers play a major economic role in the viability of America’s agricultural industry. Farmworker justice and human health demand that EPA administers its herbicide registration program by making human safety paramount. 7 U.S.C. 136 (c) (8) provides the Administrator of the Environmental Protection Agency with the authority to demand validated testing or other significant evidence where there is a concern for adverse risks to man and the environment. We believe such evidence exists and should be brought forward and considered by EPA in its consideration of this registration and the registration of similar classes of herbicides.
A. Farmworker Health Examples
Our farmworker leaders in California report there are high incidences of disease for workers exposed to herbicides like glyphosate-but not only of cancers. Thus, a finding that a particular herbicide does not cause cancer—a finding which evidence shows in not well founded—is not a sufficient finding to dismiss that there are significant human health impacts of an herbicide or any other product.
With respect to Round-Up, our farmworker – and farmer--members report cases ranging from leukemia, to fibrosis and to pulmonary cancer, lymphatic cancer and skin cancer after regular use of the herbicide. They also see a high incidence of kidney disease - noting that it is through the kidneys and liver that we process all the toxics. Round-up and other chemicals get into the water supply, including drinking water on farms. One farmworker woman leader reported a miscarriage (at 6 months), and that another woman also long exposed to glyphosate, experienced permanent blindness related to diabetes.
The workers also reported that producers frequent do not observe reentry requirements with farmworkers often required to reenter the field while their exposure to herbicides and pesticides exceeds required limits. They further noted that glyphosate is also transmitted in the wind, affecting the health of nearby residents. For example, in Oxnard, CA, the high school is close to the fields and the ocean breezes blow the herbicide right towards the school, affecting children who are even more vulnerable to the impacts of exposure.
Farmworkers also reported that pesticide-related workplace illnesses are often deliberately misdiagnosed – workers are told they have allergies when in fact there are experiencing other serious and life-affecting illnesses which are not treated. Moreover, these impacts are not reported in any routine manner to help workers and regulators discern immediate and long-term impacts of the use of such chemicals. Farmworkers point out the need for vastly improved reporting registries and requirements and the availability of independent medical personnel with appropriate training near to agricultural workplaces.
EPA should, in fact, modify its review process for registration and renewal of registrations of all chemicals in this class, and take into consideration additional data that should be routinely collected on human health impacts of these chemicals, particularly on farmworkers, farmers and all others most directly exposed to them.
Our members also emphasize the importance of requiring the destruction of all herbicides that are banned or not approved in the US. This is because chemical companies pass on the banned herbicide for sale or distribution to Mexico and many other countries, including those in Central America.
B. Food System Concerns
Glyphosate is used not just with row crops like corn, soybeans and wheat, but also as a range of fruits, nuts and veggies, including spinach.
As with small grains, glyphosate is used as a desiccant prior to crop harvest. In order to efficiently harvest small grains, glyphosate is sprayed directly on oats, wheat etc. to kill any weeds or grain plants that are not quite ripe. This helps dry down the plant to make harvest easier. The problem with this practice is that glyphosate is sprayed directly on a crop, a crop which may be processed shortly after harvest. We have also learned that glyphosate is also used as a desiccant in fruit production also before harvest. There is no chance for rain to wash the chemical off, so in effect glyphosate is going directly into the food system. The General Account Office has cautioned that more effective residue studies are needed in order to trace the appearance of the chemical. For example, an October 2014 GAO study recommended that the Food and Drug Administration and the U.S. Department of Agriculture should strengthen Pesticide Residue Monitoring Programs and Further Disclose Monitoring Limitations. The 2014 GAO study found that the Food and Drug Administration takes relatively few targeted samples to test for pesticides residue and detects what is likely to be a small percentage of the foods that have violative levels of residue. The GAO study also found that FDA does not disclose in its annual monitoring reports that it does not test for some commonly used pesticides that have established tolerances for many commodities.
“Notably, glyphosate use is also seen with a variety of crops not engineered to be sprayed directly. Looking at the period ending in 2003 compared to 2011, glyphosate use in wheat production was pegged at 8.6 million pounds, up from 8.1 million pounds; use in almonds was pegged at 2.1 million pounds; grape use was pegged at 1.5 million pounds, up from 1.4 million pounds, and rice use was estimated at 800,000 pounds, compared to 700,000 pounds in 2011.”
Families including those of our members and allies are increasing efforts to build better long-term health strategies by eating healthier. With the prevalence of glyphosate, our efforts are significantly hampered because healthy food are on the list of agricultural products sprayed with glyphosate. For example, glyphosate applications make frequent contacts with healthy foods such as cherries, avocados, apples, lemons, oranges, grapefruit, peanuts and walnuts. Federal agencies such as the U.S. Food and Drug Administration, in 2016, initiated testing for glyphosate residues based on a credible concern for human health. The FDA concern is more reason for the EPA administration to exercise its herbicide cancelation authority under 7 U.S.C. 136 (c) (8) until proper data and use restrictions are more fully analyzed. Any such concern identified for consumers by FDA would also first affect farmworkers, and also farmers and their families. Farmworkers, farmers, consumers and their families should also be afforded such action and protection.
C. Agricultural Viability Concerns
Growing evidence overwhelmingly supports the emerging understanding that rampant glyphosate use has led to significant resistance in weed species, causing a treadmill effect where greater and greater amounts of herbicides are required. This undermines the long-term viability of farms that have become dependent on glyphosate.
The continued use of glyphosate does not increase farm gate income for small and medium sized family farms. Glyphosate is a component of production agriculture likely to help keep farm gate prices low at a time when equity and wealth is being eroded due to trade disruptions and increased input costs.
Farmers also cannot depend on glyphosate and related herbicides to continue to work into the future Our farmer members noted that there are many other ways to address weeds, including proper management and care of the soil, using weeds as indicators to learn how to improve soil quality and nutrition, and water retention capacity, and spacing rows to allow mechanical cultivation to remove weeds.
In fact, there are also increasing suggestions that the use of glyphosate and other similar herbicides in fact may contribute to plant diseases- especially in orchards expected to produce over many years. As USDA invests heavily in research to find antibiotic or GMO cultivar solutions to citrus greening disease- affecting oranges across the state of Florida, for example, one researcher has found evidence that in fact the disease itself could be related to the overuse of herbicides including glyphosate. “The disease is generally assumed to be caused by a bacterium called Candidatus Liberibacter asiaticus, which is thought to be spread by an insect called the Asian citrus psyllid. Trees that succumb to the disease produce fruits that are green, misshapen, and bitter. They’re unsuitable for sale as fresh fruit or for juice. Most affected trees die within a few years.
But Frank Dean is not convinced that the bacterium is the cause of citrus greening. He believes that the disease is actually a metabolic and nutritional problem in plants caused by the overuse of pesticides, especially glyphosate herbicides, which are used in non-organic citrus orchards to kill weeds and grass around trees.”
The decreased efficacy of glyphosate and other related classes of herbicides – also observed by our members—are causes for renewed concern by farmers and worthy of more research by EPA. “Citrus greening disease has devastated millions of acres of citrus crops throughout the United States and elsewhere. In an effort to combat the disease, the Environmental Protection Agency (EPA) proposes to expand the mass spraying of the antibiotic streptomycin as a pesticide on citrus groves. The EPA has already approved the use of another antibiotic, oxytetracycline, for this purpose.”
There is ample evidence in the field of human medicine over the urgent need to address the increasing issues of antibiotic resistance. In the case of citrus greening disease, it would be worth at least considering other alternatives, such as the impact of removing herbicides like glyphosate altogether, before using antibiotics or searching for genetically modified resistance in the face of conditions like citrus greening.
Farmers will not benefit in the long or short term from the use of chemical agents of ever decreasing efficacy and higher cost, especially when the countervailing human and ecological costs are fully assessed. Investing in movement towards organic, agroecological and biodynamic methods of production are likely to have greater positive benefits throughout the food system, starting at the farmgate, in the long term. The sooner these are initiated, the better for human and ecological health alike.