2015 - Total Diet Survey to MPI 6 October 2015

6 October 2015

Ministry for Primary Industries

PO Box 2526

WELLINGTON 6140

2016 New Zealand Total Diet Study Consultation

PSGR urges that the 2016 Total Diet Study and all future studies should include testing for the presence of glyphosate, the active ingredient common to a range of propriety herbicides, including the most widely used internationally, Monsanto’s Roundup.

Increasingly, glyphosate is being detected in the human food chain, in drinking water sources, in soil, air and rain, and of its part alone or in tandem with other chemicals in diseases in humans, animals and crops.[1] [2] [3] [4] It is pervasive through most agricultural regions. Generally, New Zealand Councils use it.

In March 2015, 17 experts from 11 countries met at the International Agency for Research on Cancer, the specialized cancer agency of the World Health Organization. They were to assess the carcinogenicity of the organophosphate pesticides tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate.[5] [6]

Among other effects, the group found:

· Glyphosate has been detected in the blood and urine of agricultural workers, indicating absorption;

· Soil microbes degrade glyphosate to aminomethylphosphoric acid (AMPA);

· Blood AMPA detection after poisonings suggests intestinal microbial metabolism in humans;

· Glyphosate and glyphosate formulations induced DNA and chromosomal damage in mammals, and in human and animal cells in vitro;

· One study reported increases in blood markers of chromosomal damage (micronuclei) in residents of several communities after spraying of glyphosate formulations;

· Glyphosate, glyphosate formulations, and AMPA induced oxidative stress in rodents and in vitro.

The group classified glyphosate as “probably carcinogenic to humans” (Group 2A).

PSGR has called upon New Zealand’s government and regulatory authorities to ban the use of glyphosate-based herbicides, to ban processed or unprocessed glyphosate-resistant transgenic crops, and to ban imported glyphosate-resistant feed.

It has also called for substantive independent safety studies on all agri-chemicals used in New Zealand, in addition to glyphosate-based herbicides, and to rescind approvals and reject future applications for approval for transgenic foods and food additives containing any measure of glyphosate.

Until such time as these measures can be achieved, it is vital authorities be vigilant in locating contaminated foods and food ingredients. That vigilance warrants including ‘glyphosate’ in the list of contaminants tested in the 2016 Zealand Total Diet Study, and all future studies until such time as its use if abolished.

The Western diet is an efficient delivery system for the toxic chemicals used in industrial agriculture. This is because the diet consists primarily of processed foods based on corn, wheat, soy, cottonseed, canola and sugar, all of which are consumed in high quantities. Chemical residues of insecticides, fungicides and herbicides like glyphosate contaminate the entire diet. This is particularly true since the introduction of glyphosate-resistant transgenic food crops which feature strongly in this list.

In 1999, despite not growing transgenic crops at that time, the European Union and the UK increased the acceptable residue limit of glyphosate in respect of soy from 0.1 parts per million to 20 ppm, a 200-fold increase. In 2013, the US EPA increased the acceptable residue levels again. Regulatory authorities have failed to control the use of glyphosate or apply the precautionary principle.[7] In fact, since the introduction of glyphosate-resistant transgenic food crops two decades ago the drive to use it has increased dramatically with chemical and biotechnology industries demanding increased ‘allowable limits’ on glyphosate residue. USDA data show that glyphosate-based herbicide use increased 6504% between 1991 and 2010.

It is estimated 90 percent of transgenic crops grown worldwide are glyphosate resistant[8] and the four main crops are commonly used as food or food ingredients for the human food chain: soy, corn/maize, cottonseed and canola/oilseed rape. Transgenic soy represents 77% of soy production globally. In 2012, the USDA indicated 88 percent of corn/maize grown in country was transgenic.

A large majority of foods come from glyphosate-resistant crops to some extent. In addition, animals fed glyphosate-resistant crops will bio-accumulate glyphosate and/or glyphosate metabolites, adding to the human end-user’s intake.[9]

New Zealand also needs to test all food products containing grains and animal products because of pre-harvest use of glyphosate as a desiccant on crops for human consumption and on hay/silage. For example, around 70% of US wheat and barley crops are desiccated before harvest. Killing the plant in this way leaves considerable glyphosate contamination on the yield. Even US beer brewers are forced to test every delivery of malt barley coming out of North Dakota because the glyphosate level is so high it kills the yeast in the brew mix.[10]

Glyphosate’s pervasiveness extends to organic produce despite the fact that current USDA National Organic Programme standards do not allow the use of the herbicide glyphosate on organic crops. [11] [12]

In 2015, glyphosate is the most widely used herbicide worldwide. Scientific research increasingly points to banning this herbicide as the only logical solution to protect human health. There is a body of scientific opinion that it may be the most toxic chemical ever approved for commercial use despite misleading claims of safety.

Glyphosate destroys the microbiome of humans and plants, which is the root cause of many modern diseases. It has been linked to kidney disease, antibiotic resistant bacteria, inflammatory bowel disease, obesity, depression, ADHD, autism, Alzheimer's disease, Parkinson's disease, ALS, multiple sclerosis, cancer, cachexia, infertility, and developmental malformations.

In 2013, the US EPA again raised the acceptable residue levels. That same year, a study concluded that glyphosate “exerted proliferative effects in human hormone-dependent breast cancer.”[13] An April 2013 study concluded that “glyphosate enhances the damaging effects of other food borne chemical residues and environmental toxins,” and pointed out that glyphosate’s “negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems through a body.”[14]

PSGR urges that the 2016 New Zealand Total Diet Study and all future studies should include testing for the presence of glyphosate until such time as its use is eliminated.

For further information, we refer you to our statements on glyphosate: http://www.psgr.org.nz/glyphosate and http://www.psgr.org.nz/glyphosate-calling-for-a-ban.

Trustees and Members of Physicians and Scientists for Global Responsibility Charitable Trust

Postscript - 2016 Total Diet Survey - Following the above submission to the New Zealand Ministry of Primary Industries requesting that glyphosate be included in the list of contaminants in the 2016 Total Diet Survey testing and for all subsequent Surveys, we have been advised that their decision is not to include it.

The absence of glyphosate on the analytes list was highlighted as an issue raised by many submitters. MPI says it was assessed but not included primarily because there are other, more comprehensive, MPI monitoring programmes that will be targeting glyphosate to determine compliance with regulatory limits.

Reference the IARC review, MPI point out that the review found it “a hazard categorisation only, which does not consider the dose at which glyphosate may be carcinogenic. At this time, there has been no modification to the risk assessment to suggest that exposure to glyphosate at current levels in the diet is a carcinogenic risk. Furthermore, a recently published European Food Safety Authority review on glyphosate, that also considered the IARC outcome, has concluded that glyphosate is unlikely to pose a carcinogenic risk to humans.”

Proposal document http://www.mpi.govt.nz/ news-and-esources/consultations /2016-nz-total-diet-study/.

Further information www.foodsafety.govt.nz/policy-law/food-monitoring-programmes/total-diet-study/.

[1] For example: ‘Glyphosate-Based Herbicides Produce Teratogenic Effects on Vertebrates by Impairing Retinoic Acid Signaling’, Paganelli et al, Chem. Res. oxicol., 2010, 23 (10), pp 1586–1595 DOI: 10.1021/tx1001749, August 9, 2010, http://pubs.acs.org/doi/abs/10.1021/tx1001749. *Roundup and birth defects: Is the public being kept in the dark? Earth Open Source, 2011, http://www.scribd.com/doc/57277946/RoundupandBirthDefectsv5. *‘Differential Effects of Glyphosate and Roundup on Human Placental Cells and Aromatase’, Richard et al Environ Health Perspect. Jun 2005; 113(6): 716–720. Feb 25, 2005. doi: 10.1289/ehp.7728 PMCID: PMC1257596 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1257596/.* ‘Pre- and postnatal toxicity of the commercial glyphosate formulation in Wistar rats’, Dallegrave et al, Arch Toxicol. 2007 Sep;81(9):665-73. Epub 2007 Jul 19. http://www.ncbi.nlm.nih.gov/pubmed/17634926

[2] ‘Pesticides in Mississippi air and rain: a comparison between 1995 and 2007,’ Majewski et al, Environ Toxicol Chem. 2014 Jun;33(6):1283-93. doi: 10.1002/etc.2550. Epub 2014 Apr 4. http://www.ncbi.nlm.nih.gov/pubmed/24549493.

[3] http://www.foeeurope.org/sites/default/files/press_releases/foee_1_introducing_glyphosate.pdf

[4] ‘Detection of Glyphosate Residues in Animals and Humans’, KrÃger et al, 2014, J Environ Anal Toxicol, 4(210), 2161-0525. http://omicsonline.org/open-access/detection-of-glyphosate-residues-in-animals-and-humans-2161-0525.1000210.pdf

[5] ‘Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate’, Guyton et al, published online, 20 March 2015 DOI: http://dx.doi.org/10.1016/S1470-2045(15)70134-8. The assessments will be published as volume 112 of the IARC Monographs (http://monographs.iarc.fr; monographs identifying environmental factors that can increase the risk of human cancer. National health agencies can use this information as scientific support for their actions to prevent exposure to potential carcinogens. Since 1971, more than 900 agents have been evaluated, of which more than 400 have been identified as carcinogenic, probably carcinogenic, or possibly carcinogenic to humans.

[7] http://www.psgr.org.nz/the-precautionary-principle/finish/8-uncategorised/24-the-precautionary-principle

[8] Powles (2008) Glyphosate: a once-in-a-century herbicide, Pest Manag Sci 64: 319-325 http://onlinelibrary.wiley.com/doi/10.1002/ps.1518/abstract

[9] http://extoxnet.orst.edu/tibs/bioaccum.htm, http://www.saferchemicals.org/resources/chemicals/pbts.html

[10] ‘Glyphosate Herbicide Causes Antibiotic Resistant Bacteria, Kidney Disease, and Infertility’ Health Impact News Exclusive. 25 September 2015, http://healthimpactnews.com/2014/glyphosate-herbicide-causes-antibiotic-resistant-bacteria-kidney-disease-and-infertility/

[11] Brian Shilhavy, 12 September 2015, Health Impact News

[12] Food Chemistry, Vol 153, 15 June 2014, pp 207–215, ‘Compositional differences in soybeans on the market: Glyphosate accumulates in Roundup Ready GM soybeans’, Bøhna et al, http://www.sciencedirect.com/science/article/pii/S0308814613019201

[13] Food Chem Toxicol. 2013 Sep;59:129-36. doi: 10.1016/j.fct.2013.05.057. Epub 2013 Jun 10. ‘Glyphosate induces human breast cancer cells growth via estrogen receptors’ Thongprakaisang et al. http://www.ncbi.nlm.nih.gov/pubmed/23756170

[14] Entropy 2013, 15(4), 1416-1463; doi:10.3390/e15041416, ‘Glyphosate’s Suppression of Cytochrome P450 Enzymes and Amino Acid Biosynthesis by the Gut Microbiome: Pathways to Modern Diseases, Samsel and Seneff. http://www.mdpi.com/1099-4300/15/4/1416

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