Crop spraying in the British countryside close to a rural resident's home. Spraying of pesticides, including glyphosate, regularly takes place in the locality of homes and gardens with no protection for those living there. Photo: courtesy of UK Pesticides Campaign.
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No, the UN has not given glyphosate a 'clean bill of health'
17th May 2016
News headlines today suggest that a UN report on glyphosate residues has given the controversial herbicide a clean bill of health, writes Georgina Downs. But that's seriously misleading: the panel concludes that exposure to the chemical in food is unlikely to cause cancer. But that does not apply to those exposed to it occupationally or who live near sprayed fields.
These conclusions relate to exposure through the diet - that is very important ... It is not a general conclusion because anything beyond the diet was not in our mandate. It remains less clear what the situation is with occupational exposure.
Anyone seeking out the latest news on glyphosate will find a number of articles that were published yesterday with headlines such as "UN experts find weed killer glyphosate unlikely to cause cancer" (first issued by Reuters and taken up widely by other news media around the world), and the Guardian's headline of "Glyphosate unlikely to pose risk to humans, UN/WHO study says".
The first line of the Reuters article (and the other publications that took it up) then says "The pesticide glyphosate, sold by Monsanto in its Roundup weed killer product and widely used in agriculture and by gardeners, is unlikely to cause cancer in people, according to a new safety review by United Nations health, agriculture and food experts."
Yet these statements were actually highly misleading to the reader, especially if they did not go on to read the full article to see that the findings of the UN Panel on Pesticides Residues were only in relation to consuming glyphosate residues from food.
The findings were not in relation to glyphosate exposure via the air during and after applications of this weedkiller - and which constitutes exposure for many 'humans' / 'people', especially rural residents living near crops sprayed with glyphosate.
So what actually happened yesterday?
A summary report was published from a Joint Meeting of the Food and Agriculture Organization of the United Nations (FAO) Panel of Experts on Pesticide Residues in Food and the Environment and the World Health Organization (WHO) Core Assessment Group on Pesticide Residues (JMPR) that was held at WHO Headquarters, Geneva (Switzerland), from 9 to 13 May 2016.
The pesticide active ingredients Diazinon, glyphosate and malathion were placed on the agenda by the JMPR Secretariat, based on the recommendation of the last session of JMPR to re-evaluate these compounds given the number of new studies that had become available since their last full assessments.
The UN Panel concluded in relation to all three pesticides that they were "unlikely to pose a carcinogenic risk to humans from exposure through the diet." 
This is clearly only referring to whether these three pesticides, including glyphosate, are likely to pose a carcinogenic risk to consumers from exposure through the diet, and so is not regarding the higher level of exposure for other exposure groups.
The UN Panels findings therefore have no bearing on the cancer risks for the high level of exposure for rural residents and communities living in the locality of where these pesticides are used, as this does not appear to have been considered at all by this Panel in any capacity.
Indeed the Guardian article contains a quote from Harry van der Wulp, a senior policy officer at the FAO, in which he appears to try to stress this critical point where he says:
"These conclusions relate to exposure through the diet - that is very important ... It is not a general conclusion because anything beyond the diet was not in our mandate. It remains less clear what the situation is with occupational exposure" - and this would obviously also apply to the exposures for rural residents.
The only pesticide out of the three of Diazinon, glyphosate and malathion that are still used in agriculture in the UK is glyphosate. 
Glyphosate cancer warnings
Last year the WHO's International Agency for Research on Cancer (IARC) concluded that glyphosate is a "probable human carcinogen". 
Having reviewed the science, IARC concluded that there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma based on studies of exposures, mostly agricultural, in the USA, Canada, and Sweden published since 2001. 
In addition, IARC concluded that there is convincing evidence that glyphosate also can cause cancer in laboratory animals. 
IARC also noted that one study in community residents reported increases in blood markers of chromosomal damage (micronuclei) after glyphosate formulations were sprayed nearby. 
Therefore IARC's conclusions - unlike those of yesterday's UN Panel which was solely in relation to glyphosate residues through the diet - were related to those who are exposed from the actual application of glyphosate, including mainly in relation to agricultural use.
Crucial EU vote on glyphosate
An EU Standing Committee of Member State representatives is due to vote this week on whether glyphosate should be reapproved. 
The UK Pesticides Campaign sent a letter at the end of last week to the Presidents of the European Commission, the European Council and the European Parliament, and which was copied to members of their cabinets, the Health and Environment Commissioners and members of their cabinets, as well as to all representatives on the relevant Standing Committee, along with all 28 EU Health Ministries (and some environment ones). It was also copied to all Members of the European Parliament.
This letter set out that the draft Commission Implementing Regulation renewing the approval of the active substance glyphosate - as submitted to the relevant Standing Committee for a possible vote this week - breaches the EU authorisation Regulation.
The EU law regarding the authorisation of pesticides (formerly Directive 91/414 and now Regulation 1107/2009) contains the absolute requirement that pesticides can only be authorised for use if it has been established that there will be no immediate or delayed harmful effect on human health. This must apply to all the necessary exposure groups, including operators, workers, residents living in the locality of crop fields, as well as other members of the public exposed (eg. such as bystanders).
No risk assessment for residents for any pesticide
As the campaign I run has continued to highlight since 2001 both in the UK, and in Europe, there are major flaws in the existing methods of exposure and risk assessment for pesticides.
Crucially, it is a matter of fact that there is still no actual risk assessment for the real life exposure of residents who live in the locality of crop-sprayed fields - and which obviously includes babies, children, pregnant women, the elderly, and people already ill and/or disabled (and where any interactions or synergistic effects between pesticides and any medication must be accounted for).
None of the following exposure factors and routes - amongst others - that are necessary to include in the calculations for the real life exposure scenario of residents are included in any risk assessment in either the UK approach or the EU:-
exposure to spray drift (droplets) for longer than 15 minutes;
exposure to vapour for longer than 24 hours;
exposure from hand to mouth-object to mouth for longer than 2 hours, and repeatedly; and exposure via the oral route for all other exposure factors;
exposure via the eyes for all exposure factors;
long-term exposure to pesticide particles, droplets and vapours in the air in the days, weeks and months after spraying applications;
exposure to pesticides via precipitation and reactivation;
exposure to pesticides in pollen, dust (including harvest dust);
exposure to pesticides transported from outdoor applications and redistributed into an indoor air environment;
exposure to pesticides via long-range transportation, as studies have shown pesticides found miles away from where they were originally applied;
exposure to the innumerable mixtures and cocktails of pesticides used on crops, as opposed to exposure to just one individual pesticide at any time.
The fact that there is no actual risk assessment across the EU for the real life exposure of rural residents is even further confirmed by two European Commission documents that I have seen that are also to be considered by the EU Standing Committee this week . Those Commission documents show that acute exposure assessments are only currently being considered for operators, and not for residents.
This is despite the fact that EU law - that sets out the data requirements that applicants must submit prior to any pesticides being considered for authorisation - clearly specifies that the risk assessment undertaken for residents has to include both acute and chronic exposures. 
The two aforementioned European Commission documents are therefore again inconsistent with EU law.
The maximum exposure for residents can only be known when all the necessary exposure factors, and routes (ie. inhalation, dermal, oral, and eyes), and all the acute and chronic exposures, and to the mixtures of pesticides exposed to, are included in the exposure calculations, and then added together (summed), otherwise a complete assessment of the overall exposure for rural residents in totality cannot be reached.
No protection for rural residents from pesticides
EU law already recognises that exposure for residents living in the locality of sprayed fields is high, as residents are now specifically defined as a "vulnerable group" in Article 3, para 14, of EU Regulation 1107/2009, which clearly recognises and clearly states that residents are "subject to high pesticide exposure over the long term." 
Yet whilst operators will be in filtered cabs and/or have personal protective equipment when using pesticides, rural residents have no protection at all.
Instead millions of rural citizens across the EU have been put in a massive guinea pig-style experiment from exposure to the innumerable mixtures and cocktails of poisons used on crops and for which many of us residents have had to suffer the serious and devastating - and in some cases fatal - consequences.
Reauthorising glyphosate would breach EU law
If the consideration of the active ingredient glyphosate - and its related products - has followed the same flawed approaches set out above then there will have simply been no proper risk assessment for the real life exposure of residents to glyphosate.
Indeed, it is highly noticeable that there is no reference anywhere of the need to protect residents in the draft Commission Implementing Regulation regarding the renewal of the approval of glyphosate to be voted on by Member States this week. 
This means the draft Commission Implementing Regulation renewing the approval of the active substance glyphosate - as submitted to the relevant Standing Committee for a possible vote this week - would clearly breach the EU Regulation 1107/2009, as it would not have been established before glyphosate is approved * that there will be no immediate or delayed harm to the health of rural residents living in the locality of fields sprayed with glyphosate.
*This is also the case for the original approval of glyphosate, as well as re-approval.
Although Roundup is probably the most well-known glyphosate product there are in fact 476 products currently approved for use in the UK containing glyphosate the majority of which are for use on crops. 
The latest Government statistics on pesticide usage show that in 2014 the total area treated with glyphosate on all crops in Great Britain was 2,241,105 hectares, with the total weight applied being 1,910,524 kg. 
Agricultural use is by far and away the largest sector regarding the use of glyphosate not only here in the UK but also across Europe.
Indeed, the original text of the resolution that MEPs voted on last month in the European Parliament had already recognised that "76 % of the use of glyphosate worldwide is in agriculture" and that "the general population is exposed primarily through residence near sprayed areas." 
Considering the widespread use of glyphosate in agriculture worldwide then it is not surprising that glyphosate has been detected in the air, in water, and in food. 
It is important to stress the fact that farmers cannot control pesticides once they are airborne (either at the time of application or subsequently), and therefore the exposure for residents is not about the misuse, abuse or illegal use of glyphosate - or indeed any pesticides - but about the permitted, approved use of such substances
Establishing no harm to human health and not just cancer
It is also important to stress the fact that establishing there will be no immediate or delayed harm to human health is far wider than just in relation to carcinogenicity. Yet much of the debate over glyphosate in the last year has seemingly been solely in relation to its carcinogenicity with very little being said on the other harm it causes.
For example, glyphosate has been previously linked in certain scientific studies to Parkinson's disease and infertility,  as well as various other health problems.
It has also been reported that dermal exposure to ready-to-use glyphosate formulations can cause irritation and photo-contact dermatitis. Inhalation from spray mist can cause oral or nasal discomfort and tingling and throat irritation. Eye exposure may lead to mild conjunctivitis, and superficial corneal injury is possible if irrigation is delayed or inadequate. 
All of these would constitute acute and/or chronic 'harm' to human health and so again - under Article 4 of EU Regulation 1107/2009 - glyphosate cannot be approved.
The principal aim of pesticide policy, under the EU Regulation, is clearly based on the risk of harm, and not that harm has to have already occurred. Therefore, under EU law residents are not supposed to be exposed to the risk of harm to their health from any pesticide.
The significance of these consequences requires the adoption of a preventative approach to make sure the protection of human health is the overriding priority as under EU law there can be no balancing of interests when it comes to public health.
Recital 24 of the EU Regulation 1107/2009 clearly says, "The provisions governing authorisation must ensure a high standard of protection. In particular, when granting authorisations of plant protection products, the objective of protecting human and animal health and the environment should take priority over the objective of improving plant production.
"Therefore, it should be demonstrated, before plant protection products are placed on the market, that they present a clear benefit for plant production and do not have any harmful effect on human or animal health, including that of vulnerable groups, or any unacceptable effects on the environment."
There are many millions of rural residents across the EU (including babies, children, pregnant women, the elderly, people already ill and/or disabled) who have no protection at all from exposure to glyphosate (or indeed any other pesticide) that is often sprayed in the locality of residents' homes and gardens.
Therefore glyphosate should not be reauthorised at all considering that this matter involves the health and safety of citizens, especially rural residents, across the EU.
All pesticides approved are unlawful
Under EU law no pesticide should ever have been approved for use in the first place for spraying in the locality of residents' homes, schools, children's playgrounds, nurseries, amongst other areas, as EU law is clear that it must be established before a pesticide can be approved for use, on the basis of all the required risk assessments, that there will be no immediate or delayed harm to human health.
This has clearly not been established regarding rural residents and therefore all pesticides that have ever been approved have been done so unlawfully.
This situation is, without a doubt, as I have always correctly stated throughout my campaign, a catastrophic public health and safety failure on a truly scandalous scale.
No more poisons
The only real solution to eliminate the adverse health and environmental impacts of pesticides is to take a preventative approach and avoid exposure altogether with the widespread adoption of truly sustainable non-chemical farming methods.
This would obviously be more in line with the objectives for sustainable crop production, as the reliance on complex chemicals designed to kill plants, insects or other forms of life, cannot be classified as sustainable.
Therefore it is a complete paradigm shift that is needed - to move away from the use of pesticides altogether - as it goes without saying that no toxic chemicals that can harm the health of humans, anywhere in the world, should be used to grow food.
Georgina Downs is a journalist and campaigner. She has lived next to regularly sprayed crop fields for more than 30 years and runs the UK Pesticides Campaign.
1. The Summary Report from the May 2016 Joint FAO/WHO Meeting on Pesticide Residues (JMPR) can be seen at: http://www.who.int/foodsafety/jmprsummary2016.pdf?ua=1
See in particular the following statements in the summary report issued yesterday 16th May:-
"With regard to route of exposure, studies in which chemicals were administered by the oral route were considered to be of most relevance for evaluating low-level dietary exposures."
"An important aspect of the evaluation was whether the genotoxic effect would be likely to occur in humans exposed to low levels of the pesticide present as residues in food."
Regarding glyphosate: "The Meeting concluded that glyphosate is unlikely to be genotoxic at anticipated dietary exposures. Several carcinogenicity studies in mice and rats are available. The Meeting concluded that glyphosate is not carcinogenic in rats but could not exclude the possibility that it is carcinogenic in mice at very high doses. In view of the absence of carcinogenic potential in rodents at human-relevant doses and the absence of genotoxicity by the oral route in mammals, and considering the epidemiological evidence from occupational exposures, the Meeting concluded that glyphosate is unlikely to pose a carcinogenic risk to humans from exposure through the diet."
Regarding Malathion: "The Meeting concluded that there is some evidence that malathion is carcinogenic in rats and mice. However, the formation of nasal adenomas was due to a local irritancy caused by prolonged exposure to high concentrations of malathion absorbed via inhaled food particles. Scenarios of prolonged, direct and excessive exposure of human nasal tissue to malathion or malathion metabolites following ingestion of residues is unlikely, and therefore these tumours would not occur in humans following exposure to malathion in the diet ... Based on consideration of the results of animal bioassays, genotoxicity assays and epidemiological data, the Meeting concluded that malathion and its metabolites are unlikely to pose a carcinogenic risk to humans from exposure via the diet."
Regarding Diazinon: "The Meeting concluded that diazinon is unlikely to pose a carcinogenic risk to humans from exposure through the diet."
2. Malathion was no longer used in agriculture in the UK since 2008. Diazinon was no longer used in agriculture on outdoor crops in the UK since around 1994.
3 - 6. Source: IARC statement dated 20th March 2015.
7. The meeting of the Standing Committee on Plants, Animals, Food and Feed - Section Phytopharmaceuticals - Plant Protection Products - Legislation, takes place on 18th/19th May
8. These two European Commission documents are currently unpublished but are also to be considered by the Standing Committee this week.
9. Commission Regulation (EU) No 284/2013 of 1st March 2013.
10. EU Regulation 1107/2009 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1107
11. There is only some limited reference in the draft Commission Implementing Regulation Annex to Member States paying particular attention to the protection of operators, but no reference for the protection of residents.
12. The pesticide product database is on a secure site and therefore to see the figure of 476 products that are currently approved for use in the UK containing glyphosate, go to https://secure.pesticides.gov.uk/pestreg/ click on number 1 that says "Search for Products by specifying Authorisation features..." etc., then in the form that comes up put glyphosate in the Active column and scroll down and click on Get Results.
13. This is again on a secure site and therefore to see the glyphosate usage figures cited go to https://secure.fera.defra.gov.uk/pusstats/ click on Table Format and then for Survey Year click 2014 and then for Active Substance click glyphosate and then scroll down and click on Submit.
14. Despite this residents were rather perplexed to hear that although MEPs voted last month not to approve glyphosate for various non-agricultural and non-professional uses, as well as for no approval in or close to public parks, playgrounds and public gardens, re-approval was seemingly supported by MEPs for the agricultural use of glyphosate on crops in the locality of residents' own homes and gardens. So called IPM (Integrated Pest Management) referred to in one of the amendments is a red herring and will change nothing significant as it is system that still uses pesticides to some degree whichever definition one goes by. See further http://www.counterpunch.org/2016/04/18/the-ludicrous-european-parliament-vote-on-glyphosate/
15. Source: IARC statement dated 20th March 2015.
17. Toxicol Rev. 2004;23(3):159-6. Glyphosate poisoning. Bradberry SM, Proudfoot AT, Vale JA.
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