Comment Submissions - Notice of Modification to Proposed Regulation on Safe Harbor Warnings for Glyphosate and Addition of Documents to Rulemaking File

OEHHA’s proposed replacement of “Other authorities, including USEPA, have determined that glyphosate is unlikely to cause cancer, or that the evidence is inconclusive” to this: “US EPA has determined that glyphosate is not likely to be carcinogenic to humans; other authorities have made similar determinations,” is unacceptably incautious. The new language wrongly elevates the credence of US EPA's opinion. It is well known that US EPA is overly dependent on industry studies, usually kept secret from the public, for many of its determinations. Unlike US EPA, IARC relied primarily on a large body of published and peer-reviewed research, not industry studies, for its classification of glyphosate. During scientific advisory panel assembled in Washington DC in December 2016, panel members complained that US EPA officials were not following proper scientific guidelines for how to assess research about glyphosate health impacts. Last year, two independent scientists reviewed 53 industry studies that were made publicly available due to litigation. The review (https://www.global2000.at/sites/global/files/Analyse-Glyphosat-Studien.pdf) found that most of the corporate-sponsored studies used were of poor quality and all but 2 studies failed to meet current internationally accepted scientific standards. If OEHHA's Prop 65 label language counterweights IARC determination with US EPA's opposite conclusion, OEHHA must honestly inform the consumer of the differences in the 2 bodies' sources of data and methodology.