Sample Comment to the EPA to BAN Glyphosate

Here is our comment to the EPA:

Following are 12 reason why the license of glyphosate must be revoked.

Scientific studies to back up every statement can be found at www.momsacrossamerica.org/data

1. Babies, toddlers, and young children have kidneys and livers which are underdeveloped and do not have the ability to detox toxins the way adults do. Their bodies are incapable of eliminating toxins and therefore are particularly susceptible. The American Academy of Pediatrics (AAP) has stated that children, especially, should avoid pesticides because, "prenatal and early childhood exposure to pesticides is associated with pediatric cancers, decreased cognitive function and behavioral problems."”
2. Glyphosate does not wash, dry or cook off, and has been shown to bioaccumulate in the bone marrow, tendons and muscle tissue. Bioaccumulation of low levels over time will result in levels which we cannot predict or determine; therefore there is no scientific basis to state that the low levels are not dangerous, as they can accumulate to high levels in an unforeseeable amount of time.
3. "There is no current reliable way to determine the incidence of pesticide exposure and illness in US children." -AAP Children are exposed through food, air, contact with grass and pets. How much they are being exposed to daily from all these possibilities is simply not something that we have been able to determine. Therefore no one is capable of assessing what levels are safe from any one modality of exposure because an additional low level from other modalities could add up to a high level of exposure.
4. Ultra-low levels of glyphosate herbicides have been proven to cause non-alcoholic liver disease in a long term animal study by Michael Antoniou, Giles Eric Seralini et al.  The levels the rats were exposed to, per kg of body weight, were far lower than what is allowed in our food supply. According to the Mayo Clinic 100 million, or 1 out of 3 Americans now have liver disease. These diagnosis are in some as young as 8 years old.
5. Ultra-low levels of glyphosate have been shown to be  endocrine and hormone disrupting. Changes to hormones can lead to birth defects, miscarriage, autoimmune disease, cancer, mental and chronic illness.
6. The  EPA Allowable Daily Intake Levels (ADIs) of glyphosate exposure were set for a 175-pound man, not a pregnant mother, infant, or child.
7. Glyphosate alone has been shown to be chronically toxic causing organ and cell damage. Glyphosate herbicides  final formulations, have been shown to be acutely toxic, causing immediate damage at low levels.
8. The detection of glyphosate at low levels could mean the presence of the other toxic ingredients in glyphosate herbicides on our food. Until studies are done, one must practice the Precautionary Principle.The label on glyphosate herbicides does not specify the pesticide class or “other”/ “inert” ingredients that may have significant acute toxicity and can account for up to 54% of the product.
9. Regarding the label and low-level exposure: “Chronic toxicity information is not included, and labels are predominantly available in English. There is significant use of illegal pesticides (especially in immigrant communities), off-label use, and overuse, underscoring the importance of education, monitoring, and enforcement.” - AAP. Exposure to low levels of glyphosate herbicides can occur through pregnant wives or children hugging the father who is a pesticide applicator.  The chronic health impacts such as rashes which can, years later, result in non-Hodgkin lymphoma, are often ignored, especially by low income or non-English speaking users dependent on their pesticide application occupation for survival.
10. The EPA has admitted to not having any long-term animal studies with blood analysis on the final formulation of any glyphosate herbicides.  The EPA cannot state that the final formulation is safe.
11. For approval of pesticides and herbicides, the EPA only requires safety studies, by the manufacturer who benefits from the sales, on the one declared active chemical ingredient- in this case glyphosate. Glyphosate is never used alone.
12. The main manufacturer, Monsanto, has been found to be guilty on all counts by a San Francisco Supreme Court Jury (and two other trials) in the Johnson v Monsanto awarding plaintiffs over $2.1 billions dollars collectively. This includes guilty of “malice and oppression” which means that the company executives knew that their glyphosate products could cause cancer and suppressed this information from the public.

Clearly, it is time for food and beverage manufacturers to have a zero tolerance for glyphosate residue levels and for the US EPA and regulatory agencies everywhere to stop ignoring the science and to revoke the license of glyphosate immediately.

Tracking number

1k3-9adc-gbsr

You can comment here:

https://www.regulations.gov/comment?D=EPA-HQ-OPP-2009-0361-2340&fbclid=IwAR1xPnZN9p5LJQi92_ShDJ3ESxZinxPwA0blVJYi1zysBT5YXdYtO7BKUhg

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Moms Across America is a 501c3 non profit organization whose motto is “Empowered Moms, Healthy Kids.”