Please remember that comments on the EPA’s Draft Biological Evaluation on Glyphosate are due to the EPA this FRIDAY MARCH 12th. We need everyone to submit some words to encourage the EPA to do the right thing and phase out Roundup. The background on the Evaluation can be found in my previous post:
My submission to the EPA follows. Feel free to pull any information you would like from my post. Follow the link to post your comments: https://www.regulations.gov/commenton/EPA-HQ-OPP-2020-0585-0001
GLYPHOSATE GIRL’S COMMENT TO THE EPA
Congratulations on your comprehensive report on the biological effects of glyphosate on endangered species and their habitats – it was not a small piece of work, and the scientists of the EPA should be extremely proud. Hopefully, the team went out and had a cocktail to celebrate! Or perhaps a Zoom happy hour, given the circumstances.
Many commenters have provided you with more than ample evidence of the biological and environmental devastation at the hands of this chemical and, especially, the formulated product Roundup. Hopefully, I can provide some additional useful research and recommendations that can help you evaluate the toxic impact of this chemical.
Reproductive Damage
When looking through my large file of independent, peer-reviewed studies on glyphosate’s harmful impact on a wide variety of species, the most concerning papers are those documenting the multi-generational reproductive harm posed by glyphosate. The damage from glyphosate exposure in F0 isn’t showing up until generations F2 and F3. For those species that are already endangered, this likely generational decline from glyphosate exposure is very worrisome.
What on earth is going to happen with our own grandchildren? Fortunately, other countries who don’t litter their lands with these chemicals will be able to continue a healthier line of human beings. At this rate, Americans will not. We are awaiting our first generation of Roundup grandbabies, and the damage will be irreversible.
Kubsad, D., Nilsson, E.E., King, S.E. et al. Assessment of Glyphosate Induced Epigenetic Transgenerational Inheritance of Pathologies and Sperm Epimutations: Generational Toxicology. Sci Rep 9, 6372 (2019). https://doi.org/10.1038/s41598-019-42860-0
Milesi MM, Lorenz V, Pacini G, Repetti MR, Demonte LD, Varayoud J, Luque EH. Perinatal exposure to a glyphosate-based herbicide impairs female reproductive outcomes and induces second-generation adverse effects in Wistar rats. Arch Toxicol. 2018 Aug;92(8):2629-2643. doi: 10.1007/s00204-018-2236-6. Epub 2018 Jun 9. PMID: 29947892.
J.P. Munoz, T.C. Bleak and G.M. Calaf, Glyphosate and the key characteristics of an endocrine disruptor: A review, Chemosphere, https://doi.org/10.1016/j.chemosphere.2020.128619
Sophie Richard, Safa Moslemi, Herbert Sipahutar, Nora Benachour, and Gilles-Eric Seralini. Differential Effects of Glyphosate and Roundup on Human Placental Cells and Aromatase. Environmental Health Perspectives 113:6 CID: https://doi.org/10.1289/ehp.7728
Glyphosate in Teeth
Last Fall, I sent my daughter’s baby tooth into HRI Labs to check for glyphosate content. Glyphosate was indeed found in her tooth that formed while in my uterus. Every person reading this should be concerned by this fact – Bayer employees, Croplife lobbyists, EPA administration, and all those who need to support this chemical in order to make a living.
Americans all need to consider a path out of this mess in which we find ourselves. Every citizen is impacted, and the reason for the systemic rise in infertility is no great mystery.
Glyphosate and Agricultural Spray Impact
In your Draft BE, you note that the use of glyphosate on the current 896 million acres of US agricultural land does not impact the health of endangered species. I argue that it is actually a primary source of damage. Glyphosate spraying and exposure is pervasive and extensive in our country. For some states, such as Iowa, Kansas, North Dakota, South Dakota, and Nebraska, between 85-91% of the state is primarily conventional farmland that uses glyphosate. Even if we continue to temporarily characterize we homo sapiens as somehow unlike all other mammals for purposes of this evaluation, other non-human species are most certainly impacted by the use of glyphosate on our agricultural land. The runoff into our rivers and tributaries, as well as the presence of glyphosate in rain and air from both direct spraying and as by-products of ethanol burn, wreaks havoc on the environment of endangered species.
Chang, F.‐c., Simcik, M.F. and Capel, P.D. (2011), Occurrence and fate of the herbicide glyphosate and its degradate aminomethylphosphonic acid in the atmosphere. Environmental Toxicology and Chemistry, 30: 548-555. https://doi.org/10.1002/etc.431
Transdermal Exposure
In addition, the transdermal impact of Roundup on these species, particularly with the POEA surfactant, should be acknowledged as a probable contributor to cancer. How horribly sad to think of the animals quietly dying of lymphoma as the government continues to shower their habitats in a carcinogenic endocrine disruptor. I am certain that you are cognizant of the carcinogenicity research, but as a refresher here is a sampling.
Portier, C.J. A comprehensive analysis of the animal carcinogenicity data for glyphosate from chronic exposure rodent carcinogenicity studies. Environ Health 19, 18 (2020). https://doi.org/10.1186/s12940-020-00574-1
George J, Prasad S, Mahmood Z, Shukla Y. Studies on glyphosate-induced carcinogenicity in mouse skin: a proteomic approach. J Proteome. 2010;73(5):951–64. https://doi.org/10.1016/j.jprot.2009.12.008
Zhang L, Rana I, Shaffer RM, Taioli E, Sheppard L. Exposure to glyphosate-based herbicides and risk for non-Hodgkin lymphoma: A meta-analysis and supporting evidence. Mutat Res. 2019 Jul-Sep;781:186-206. doi: 10.1016/j.mrrev.2019.02.001. Epub 2019 Feb 10. PMID: 31342895; PMCID: PMC6706269.
Pollinators
I have memories of visiting the Monarch butterflies on a family trip to Santa Cruz, California thirty years ago. I sat on my dad’s shoulders and marveled at the spectacular showy wings surrounding us. My kids haven’t been able to experience that joy, because the butterflies have largely disappeared. The damage to the milkweed – the caterpillar’s primary food source – from glyphosate spray has been crippling.
The disappearance of bees has been raised with the EPA several times, and must also be addressed.
Stenoien, C., Nail, K.R., Zalucki, J.M., Parry, H., Oberhauser, K.S. and Zalucki, M.P. (2018), Monarchs in decline: a collateral landscape‐level effect of modern agriculture. Insect Science, 25: 528-541. https://doi.org/10.1111/1744-7917.12404
Erick V. S. Motta, Kasie Raymann, Nancy A. Moran, Glyphosate perturbs the gut microbiota of honey bees. Proceedings of the National Academy of Sciences Oct 2018, 115 (41) 10305-10310; DOI: 10.1073/pnas.1803880115
Soil Health
Last year, I took a road trip through our heartland. I met with farmers who allowed me to tour the soil on their fields of Roundup Ready GMO soybeans and corn. This soil is not soil at all – it is a firm, impenetrable, AMPA-laden clay. I looked for earthworms and saw a few dead carcasses. If I were to describe an impending agricultural apocalypse, it would look exactly like our heartland today – dead.
Gaupp-Berghausen, M., Hofer, M., Rewald, B. et al. Glyphosate-based herbicides reduce the activity and reproduction of earthworms and lead to increased soil nutrient concentrations. Sci Rep 5, 12886 (2015). https://doi.org/10.1038/srep12886
Scientists at the USDA have privately acknowledged that this is a tragic state of US agriculture, and ultimately a large threat to our national security and future as a nation. If the situation doesn’t rapidly change, our country will continue to deteriorate into a population laden with chronic disease, insurmountable healthcare costs, and completely infertile, toxic land. The US is also harming the rest of the planet in contributing to climate change by robbing the soil of the ability to be a carbon sink.
Glyphosate and Chronic Disease
I beseech you to acknowledge that humans – like all other mammals – are not immune to the toxic environmental effects of glyphosate. Sadly, my boatload of gut issues, my son’s migraines, my daughter’s rashes, my nephew’s severe food allergies, my mother-in-law’s cancer after using Roundup, and my father-in-law’s excruciating, slow death from a neurodegenerative disorder brought on by decades of herbicide use prove that to be the case. Immeasurable physical and emotional pain have been experienced at the hands of this chemical.
There is now broad scientific consensus of the vital importance of the microbiome and integrity of our gut linings to our overall health and function. We MUST consider what microdosing of POEA surfactant and glyphosate (a patented antibiotic) is doing to both the microbiota and the one-cell layer thick intestinal lining.
Mesnage R, Teixeira M, Mandrioli D, Falcioni L, Ducarmon QR, Zwittink RD, Mazzacuva F, Caldwell A, Halket J, Amiel C, Panoff JM, Belpoggi F, Antoniou MN. Use of Shotgun Metagenomics and Metabolomics to Evaluate the Impact of Glyphosate or Roundup MON 52276 on the Gut Microbiota and Serum Metabolome of Sprague-Dawley Rats. Environ Health Perspect. 2021 Jan;129(1):17005. doi: 10.1289/EHP6990. Epub 2021 Jan 27. PMID: 33502259; PMCID: PMC7839352.
Dechartres J, Pawluski JL, Gueguen MM, Jablaoui A, Maguin E, Rhimi M, Charlier TD. Glyphosate and glyphosate-based herbicide exposure during the peripartum period affects maternal brain plasticity, maternal behaviour and microbiome. J Neuroendocrinol. 2019 Sep;31(9):e12731. doi: 10.1111/jne.12731. Epub 2019 May 26. PMID: 31066122.
Knezevic J, Starchl C, Tmava Berisha A, Amrein K. Thyroid-Gut-Axis: How Does the Microbiota Influence Thyroid Function? Nutrients. 2020 Jun 12;12(6):1769. doi: 10.3390/nu12061769. PMID: 32545596; PMCID: PMC7353203.
Importantly, Monsanto has NEVER had a successful long-term carcinogenicity study on animals using the formulated Roundup product. Why? Because when the test is attempted, the lab animals DIE. As admitted by Monsanto toxicologist Dr. Donna Farmer during the Hardeman v Monsanto trial, the surfactant is too potent for the intestinal lining of the lab animals and therefore they die.
What Farmer inadvertently described is provenly the root cause of most modern chronic inflammatory diseases – gut dysbiosis and increased intestinal permeability. The same chemicals that are cutting through leaf surfaces and delivering glyphosate into the plant cells are destructive to the intestinal mucosa and lining. It is no surprise that autoimmunity is exploding as our bodies try to fight the toxins that are released into our bloodstream through the damaged intestine.
Mesnage R, Benbrook C, Antoniou MN. Insight into the confusion over surfactant co-formulants in glyphosate-based herbicides. Food Chem Toxicol. 2019 Jun;128:137-145. doi: 10.1016/j.fct.2019.03.053. Epub 2019 Apr 3. PMID: 30951798.
Fasano A. All disease begins in the (leaky) gut: role of zonulin-mediated gut permeability in the pathogenesis of some chronic inflammatory diseases. F1000Res. 2020 Jan 31;9:F1000 Faculty Rev-69. doi: 10.12688/f1000research.20510.1. PMID: 32051759; PMCID: PMC6996528.
Vasiluk L, Pinto LJ, Moore MM. Oral bioavailability of glyphosate: studies using two intestinal cell lines. Environ Toxicol Chem. 2005 Jan;24(1):153-60. doi: 10.1897/04-088r.1. PMID: 15683179.
Xu J, Li G, Wang Z, Si L, He S, Cai J, Huang J, Donovan MD. The role of L-type amino acid transporters in the uptake of glyphosate across mammalian epithelial tissues. Chemosphere. 2016 Feb;145:487-94. doi: 10.1016/j.chemosphere.2015.11.062. Epub 2015 Dec 14. PMID: 26701683.
Cost/Benefit
As a former investment banker in leveraged finance at Donaldson, Lufkin and Jenrette and Credit Suisse, and a former employee at NASA, I fully realize that the economic and political stakes surrounding the use of glyphosate are extraordinarily high. Furthermore, the escalation of commitment surrounding US chemical agriculture is not dissimilar to the decisions that led up to the Challenger explosion, in which no one was willing to cut the losses. I know that Bayer, Croplife and members of the JGTF have a lot of money and power to lose if they can’t continue selling Roundup for use on our forests, waters and food. If glyphosate and Roundup Ready GMOs are banned, that leaves a lot of our farmers in a frightening financial state.
I also understand the potential embarrassment to the United States if our chemicals and GMOs are withdrawn, given the immense pressure the State Department and various administrations have placed on other countries to continue using these products despite their strong desire not to do so.
Similar to OIRA’s process, I would propose the following cost-benefit analysis of revamping US agriculture away from chemical farming:
COSTS
- Short term costs to conventional farmers of transitioning out of chemical agriculture
- Less lobbying dollars for political campaigns
- Potential subsidies to conventional farmers to support the change to organic/regen
- Crow-eating on the international stage
BENEFITS
- Healthier US population (Less cancer/chronic disease/food intolerance/microbiome disruption)
- Significantly lower healthcare costs
- Expansion of investment in non-chemical, non-GMO farm technology
- Soil fertility with a nutrient density that will support our population and meet the quality requirements for export (increased magnesium and zinc in our food alone will lower the general hostility and mood disorders in the US today)
- Less glyphosate exposure and cheaper organic food for those in food deserts birthed out of systemic racism.
- A trend upwards in fertility
- Maybe I can eat American wheat again one day – a real pizza, for example.
And, back to the topic at hand, an opportunity to save our beloved endangered species.
Quickly Attainable Solutions
I propose:
- A permanent phase-out of glyphosate and glyphosate-based herbicides (GBHs), including on our agricultural land.
- An immediate ban on the use of highly toxic polyethoxylated tallow amines (POEA) surfactant in the forumated GBH. There are available alternatives, as are sold in Europe.
- An immediate ban on pre-harvest desiccation of our grains with Roundup, thus allowing for lower dietary exposure and greater export to countries with increasingly strict glyphosate restrictions.
- An immediate ban on the use of GBHs in all forests, waterways and other endangered species habitats.
- The recognition that humans are equally impacted by GBHs, just like the endangered species acknowledged by your organization.
- Cooperation with industry to rehabilitate soil health through regenerative *organic* (not just regenerative) farming practices. Please do not be fooled by AgChem’s recent hijacking of the term regenerative – they still fully intend to use chemicals and GMOs.
Ironically, even Germany – home to Bayer, the new owner of Monsanto – is committed to phasing out glyphosate use by 2024 in light of its residual environmental damage and toxicity. I know that the United States is capable of the same if supported by a few brave regulators who are willing to change the status quo and do the right thing.
Thanks again for your work. With excellent, thorough studies like this Biological Evaluation, I feel hopeful that some change may finally come. Please let me know if I can be of any help.
Sincerely,
Kelly Ryerson
