Comment Submissions - Notice of Augmentation of Record and 15-Day Public Comment Period for Exposures to Glyphosate from Consumer Products

Thank you for the opportunity to comment on the two EPA Glyphosate Issue Papers. The EPA based its regulatory decision regarding the carcinogenicity of glyphosate on faulty, ghostwritten research that was bought by Monsanto for use in regulatory decisions. Those ghostwritten research papers are still listed in the EPA Glyphosate Issue Papers. Specifically, Monsanto decided to counter the IARC determination that glyphosate is a probable human carcinogen by hiring a consultant panel of scientists to publish a series of review papers to disprove the IARC findings. Monsanto Chief of Regulatory Science William Heydens said: “We would be keeping the cost down by us doing the writing and they would just edit & sign their names so to speak. Recall that is how we handled Williams Kroes & Munro, 2000.” Indeed, in 2000 Monsanto hired consulting firm Intertek, which paid Williams and Kroes for their willingness to claim authorship. That study is listed in the 2017 Issue Report. Williams GM, Kroes R, Munro IC. Safety evaluation and risk assessment of the herbicide Roundup and its active ingredient, glyphosate, for humans. Regul Toxicol Pharmacol. 2000 Apr;31(2 Pt 1):117-65. doi: 10.1006/rtph.1999.1371. PMID: 10854122. Link to internal Monsanto discussion: https://www.baumhedlundlaw.com/documents/pdf/monsanto-documents/key-documents-pages-203-4.pdf A second study that also has been revealed as ghostwritten by Monsanto is also on the list of research considered by the EPA in these Issue Papers. 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 Mar;45(3):185-208. doi: 10.3109/10408444.2014.1003423. Epub 2015 Feb 26. PMID: 25716480; PMCID: PMC4819582. Link to the proof that it was ghostwritten lies in an internal Monsanto document from an employee review report: https://www.baumhedlundlaw.com/documents/pdf/monsanto-documents/18-monsanto-scientist-admits-to-ghostwriting-cancer-review-paper.pdf Furthermore, the EPA has not appropriately accounted for recent research, including that from members of the Scientific Advisory Panel to the EPA that concluded that exposure to glyphosate-based herbicides is linked with increased risk of developing NHL. They chose to ignore the opinions of the FIFRA mandated SAP assessing the carcinogenicity of glyphosate. See the meta-analysis from SAP scientist Dr. Luoping Zhang: 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 Rev Mutat Res. 2019 Jul-Sep;781:186-206. doi: 10.1016/j.mrrev.2019.02.001. Epub 2019 Feb 10. PMID: 31342895; PMCID: PMC6706269. Therefore, it is critical that California not fold to this labeling, because claiming that the EPA does not believe glyphosate to be a carcinogen is inaccurate. Glyphosate would have been taken off the market years ago without protection from: Ghostwritten research The EPA’s willingness to ignore its own SAP panel The EPA’s refusal to follow their own rules in animal toxicity studies Given the recent decision in the Ninth Circuit of Appeals that the EPA must vacate their finding on risk to human health, it is disingenuous to tell California consumers that the EPA doesn’t believe that glyphosate causes cancer. We know that they in fact are aware of its carcinogenicity, and are opting to let people continue to risk their lives in using this product.