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

We at Moms Across America submit the following comment to OEHHA for consideration regarding the Glyphosate papers, the EPA’s assessment of glyphosate in comparison with IARC’s. Many farmers, scientists, and regulatory agencies are claiming that glyphosate is safe and is an “essential tool”. The EPA continues to claim that they have the science to show that glyphosate is not a carcinogen...but the IARC (International Agency for Research on Cancer) has found that it is a carcinogen. Scientist Charles Benbrook has combed through the studies analyzed by both agencies and has found out exactly why they came to their decisions. In layman’s terms, cherry picking of studies is clearly the reason behind the EPA’s justification. To summarize: The EPA cited 109 total assays not included in the IARC report, 87% of which were regulatory studies commissioned by industry, and all but one was negative. IARC included the results from 67 assays not included in EPA’s analysis, all of which were from peer-reviewed publications, and 82% of which had at least one positive result for genotoxicity. Clearly, choosing to ignore 67 assays that showed genotoxicity is not scientific. It is cherry-picking and pandering to the corporations that pressure them to sway the science in their direction. The discovery process of the Monsanto Trials clearly showed corruption between Jess Rowlands and Monsanto employees. The discovery process also revealed heavy editing by Monsanto toxicologist, Donna Farmer, and the ghostwritten studies. The OEHHA has a duty to the residents of California to review and include independent science, clear evidence of corruption in the EPAs review process, and mountains of data showing that glyphosate is carcinogenic. The fact is that not only is glyphosate not safe for use in any manner, as it is water soluble and contaminates air, water, soil, plant, marine life, and animal life, but is also an increasingly ineffective “tool” for farmers. Over 37 weeds are being reported to be resistant to glyphosate. Glyphosate is destroying the soil, impairing a farmer’s ability to grow healthy crops with sufficient yield, and livestock farmers like Ted Dupenheimer report that switching from GMO grains sprayed with glyphosate to organic, non-GMO grains is “essential for survival.” Too many sows lose their litter to death and birth defects when they eat glyphosate-sprayed grains. Too many cows get sick. Too many chickens and crops with manure from these animals develop antibiotic-resistant bacteria. The immune systems of our livestock, soil, plants, and the human race are being weakened by the use of glyphosate and you have a unique opportunity to act and prevent further devastation. The solution for these farmers is regenerative organic farming; a practice thousands of generations old that sustained more life for longer than the recent toxic chemicals. We urge you to require those remaining herbicides on the market containing glyphosate to be labeled as carcinogenic and as a reproductive effector. We also urge you to phase out the use of glyphosate in the great state of California completely, for any reason, within 12 months. Thank you. Zen Honeycutt Moms Across America