Call to Action
3 days left: Tell the EPA to keep industry-shaped science out of glyphosate safety decisions
The EPA is updating its human health risk assessment for glyphosate and is taking public comments on the studies it plans to use for the scientific review. The deadline for comments is Thursday, September 24th at 11:59pm ET.
The EPA has historically relied on research predominantly provided by the industry it is supposed to regulate, and has not followed their own rules in their safety assessments. If studies shaped by manufacturers are treated as neutral evidence, the result will continue to be a false conclusion that glyphosate is safe. Your comment can help prevent that.
How to comment (Takes just 5 minutes):
- Go to regulations.gov and search for docket EPA-HQ-OPP-2009-0361. Here’s the link: https://www.regulations.gov/docket/EPA-HQ-OPP-2009-0361/document?withinCommentPeriod=true
- Open the glyphosate open literature search notice and click Comment.
- Personalize the message below.
- Submit before the September 24 deadline. Comments are public, so include only what you’re comfortable sharing.
Suggested Comment should include:
I am submitting this comment on the completeness of EPA’s glyphosate open literature search (EPA-HQ-OPP-2009-0361). I ask the EPA to commit to their MAHA promise to use gold-standard science, and on behalf of the American people to exclude papers with evidence of corporate influence and/or with “conflicts of interest” (EO 14303).
Please exclude the papers listed below because there is strong evidence that Monsanto has influenced the research or paper conclusions. In some cases, there is a current or past Monsanto employee directly listed as an author, indicating a conflict of interest.
If you do include these papers, I believe the review will lead to the harm of the American population, potentially including increased rates of cancer, increased hormone disruption, and increased loss of pregnancies due to glyphosate exposure.
Exclude these papers:
Acquavella, J., D. Farmer, and M.R. Cullen. A case-control study of non-Hodgkin lymphoma and exposure to pesticides. Cancer. 1999
Acquavella, J. F., Gustin, C., Alexander, BH, Mandel JS. Implications for epidemiologic research on variation by pesticide in studies of farmers and their families. Scandinavian Journal of Work Environment & Health.2005.
Goldstein DA, Farmer DL, Levine SL, Garnett RP. Mechanism of Toxicity of Commercial Glyphosate Formulatons: How Important is the Surfactant?. Journal of Toxicology. 2005
Mink PJ, Mandel JS, Lundin JI, Sceurman BK. Epidemiologic studies of glyphosate and non-cancer health outcomes: a review. Regul Toxicol Pharmacol. 2011
Mink PJ, Mandel JS, Sceurman BK, Lundin JI. Epidemiologic studies of glyphosate and cancer: a review. Regul Toxicol Pharmacol. 2012
Williams AL, Watson RE, DeSesso JM. Developmental and reproductive outcomes in humans and animals after glyphosate exposure: a critical analysis. J Toxicol Environ Health B Crit Rev. 2012
Kimmel GL, Kimmel CA, Williams AL, DeSesso JM. Evaluation of developmental toxicity studies of glyphosate with attention to cardiovascular development. Crit Rev Toxicol. 2013
Kier LD, Kirkland DJ. Review of genotoxicity studies of glyphosate and glyphosate-based formulations. Crit Rev Toxicol. 2013
Greim H, Saltmiras D, Mostert V, Strupp C. Evaluation of carcinogenic potential of the herbicide glyphosate, drawing on tumor incidence data from fourteen chronic/carcinogenicity rodent studies. Crit Rev Toxicol. 2015
Kier LD. Review of genotoxicity biomonitoring studies of glyphosate-based formulations. Crit Rev Toxicol. 2015
Sorahan T. Multiple myeloma and glyphosate use: a re-analysis of US Agricultural Health Study (AHS) data. Int J Environ Res Public Health. 2015
Chang ET, Delzell E. Systematic review and meta-analysis of glyphosate exposure and risk of lymphohematopoietic cancers. J Environ Sci Health B. 2016
Williams GM, Aardema M, Acquavella J, Berry SC, Brusick D, Burns MM, de Camargo JLV, Garabrant D, Greim HA, Kier LD, Kirkland DJ, Marsh G, Solomon KR, Sorahan T, Roberts A, Weed DL. A review of the carcinogenic potential of glyphosate by four independent expert panels and comparison to the IARC assessment. Crit Rev Toxicol. 2016
Williams, GM; Berry, C; Burns, M; de Camargo, JLV; Greim, H. Glyphosate rodent carcinogenicity bioassay expert panel review (Publication with Expression of Concern See vol 48, pg 914, 2018). Critical Reviews in Toxicology, 2016.
Martens MA, Bleeke MS, Leopold VA, Farmer DR. Toxicology and human health risk assessment of polyethoxylated tallow amine surfactant used in glyphosate formulations. Regul Toxicol Pharmacol. 2019
Acquavella, J. Epidemiologic studies of glyphosate and non-Hodgkin’s lymphoma: A review with consideration of exposure frequency, systemic dose, and study quality. Global Epidemiology. 2023
Chang ET, Odo NU, Acquavella JF. Systematic literature review of the epidemiology of glyphosate and neurological outcomes. Int Arch Occup Environ Health. 2023
The papers listed above are currently included in the spreadsheet provided by EPA and currently marked as “potentially relevant.” EPA should mark these papers “not relevant” before proceeding to the next step in their literature review.
A safety conclusion is only as reliable as the independence of the evidence behind it. Thank you for your consideration.
