Living Rivers Council submits expert comments on glyphosate and its ‘inert’ substances in formulation to the EPA
- Peril to human health
- Contamination of our food chain
- Aquatic lethality/mortality of the ‘inert’ binders in formulation with glyphosate
- Pernicious persistence in the environment
See these attached expert comments:
April 30, 2018
Ms. Dana Friedman
Pesticide Re-Evaluation Division (7508P)
Environmental Protection Agency, Office of Pesticide Programs
1200 Pennsylvania Ave. NW
Washington, DC 20460–0001
Re: Comments on the Human and Ecological Risk of Glyphosate and Other Chemical in
Response to Federal Register Vol. 83, No. 39, 1846-1848
Dear Ms. Friedman,
Please accept these comments to the U.S. Environmental Protection Agency (U.S. EPA) in
response to the Federal Register (FR 2018) entitled: Registration Review; Draft Human Health
and/or Ecological Risk Assessments for Several Pesticides; Notice of Availability. The comments
have been created for the Living Rivers Council, a Napa, California based non-profit group that
has as its mission “to protect, restore, defend and preserve watersheds in natural harmony with
people and wildlife.” I am a consulting fisheries biologist and watershed scientist with extensive
experience in assessing ecological impacts of pesticides and herbicides (see below).
Although the FR (2018) notice includes several chemicals besides glyphosate, LRC is most
concerned with the latter chemical and these comments, therefore, I focus on that substance
exclusively in the discussion below.
There are several critical flaws in the U.S. EPA approach to studying and regulating glyphosate.
While the U.S. EPA studies the health and ecological effects of pure glyphosate, numerous
studies show that binders can increase harmful effects and lethality. These substances can act
with glyphosate but may also be toxic when acting alone. The U.S. EPA does not deal with the
fact that the glyphosate degradant AMPA has a long life in soil and poses equal or greater
biological risk. Risk to individual organisms, ecosystems and humans is under-estimated due to
this study design flaw. Impacts to amphibians are ignored by the U.S. EPA and the glyphosate
product Roundup is known to be deadly to them. Ecological impacts include the near
disappearance of the Monarch butterfly because glyphosate killed off its host plant. Glyphosate
is also very soluble in water and may persist and directly impact downstream organisms if
sediment is not available in the water column to bind it. Glyphosate is now widespread in surface
waters and is found even in rainfall, and yet the U.S. EPA says that most is bound in soils.
U.S. EPA human health risk assessment of glyphosate finds studies related to carcinogenicity are
inconclusive, but there is an increasing body of evidence that glyphosate and binders are
carcinogenic and hormone disruptors. Herbicide binders and the glyphosate degradant AMPA
can break down cell walls and increase human health effects.
I have acquired considerable expertise pertaining to pesticides and herbicides working for clients
over the last 20 years. I am acquainted with the literature due to environmental protection work
for Indian Tribes (Resighini Rancheria 2010, QVIR 2016) that served the purpose of protecting
their water supplies and Tribal Trust resources. I also assessed potential problems from
application of herbicides related to the proposed Bohemian Grove timber harvest plan (1-06
NTMP-011SON) and potential cumulative effects of pesticides and herbicides in the lower
Russian River (Higgins 2007). Other timber harvest related reviews having to do with
applications of pesticides and herbicides include the Kidd Creek Non-Industrial Timber
Management Plan (1-15 NTMP-007 SON) (Higgins 2017a) and the Fox Meadows THP (THP 1-
17-017 SON), which are both also in the Russian River watershed.
I became extremely well versed in the use of pesticides and herbicides and their ecological
impact while working on the Salinas River for the Monterey Coastkeeper and the Stanford
Environmental Law Center (Higgins 2009). My knowledge expanded greatly in service to the
two latter clients, but also Earth Rise, when I created the Conditions Report on the San Joaquin,
Merced, Tuolumne and Stanislaus Rivers and Effects of East San Joaquin Pollution on
Downstream Receiving Waters Including the San Francisco Bay Delta Ecosystem (Higgins
2017b). I found that the synergistic effects of pesticides and herbicides were driving Pacific
salmon species extinct in the San Joaquin River and causing the ecological collapse of the San
Francisco Bay-Delta ecosystem.
This is an organophosphorus broad-spectrum herbicide used to kill weeds, especially annual
broadleaf weeds and grasses that compete with crops. Marketed as Roundup since 1974, more
than hundreds of millions of pounds are used on crops including corn, soybeans, wheat, cotton,
rice, alfalfa, and pastures (Saunders and Pezeshki 2015). Use of the product increased as
glyphosate resistant crops were developed. Essentially glyphosate kills all broadleaf plants it
comes in contact with that aren’t bred to be resistant to it. Toxicity may be increased depending
on other contents added as binders (Saunders and Pezeshki 2015). It adheres strongly to clay
soils, but can run off and contaminate surface waters, if is not filtered to through soil or riparian
vegetation (Saunders et al. 2007). If streams are fairly free of suspended sediment, glyphosate
can stay suspended for up to two weeks, but it rarely leaches to groundwater.
Glyphosate Degradant Aminomethylphosphonic Acid (AMPA)
The primary metabolite of glyphosate is aminomethylphosphonic acid (AMPA). Studies show
that is degrades more slowly than glyphosate because it has an even stronger adherence to soil
particles and has less of a tendency to be broken down by micro-organisms. Horner (1990) found
that the average half-life for the dissipation of glyphosate was 100 days and 118 days for
AMPA. In a Midwestern study (Battaglin et al. 2005):
“Glyphosate was detected at or above 0.1 μg/l in 35 percent of pre-emergence, 40 percent
of post-emergence, and 31 percent of harvest season samples, with a maximum
concentration of 8.7 μg/l. AMPA was detected at or above 0.1 μg/l in 53 percent of preemergence,
83 percent of post-emergence, and 73 percent of harvest season samples, with
a maximum concentration of 3.6 μg/l.”
Saunders and Pezeshki (2015) point out that AMPA “is phytotoxic in its own right, negatively
affecting plant physiology.” Scribner et al. (2003) monitored widely in Midwestern states and
stated that “Results show that AMPA was detected more frequently and occurred at similar or
higher concentrations than the parent compound glyphosate.” Benachour et al. (2007) noted that
the substance may also have some potential impact on human health: “AMPA and
Polyethoxylated tallow amine (POEA) act separately and synergistically to damage cell
herbicides under-estimate its impacts because they do not fully consider the effects of its main
break-down product that is even more persistent in the environment and sometimes more toxic.
U.S. EPA (2017a) carried results of a study showing potential human health effects of AMPA
and binder POEA stating that “AMPA was more toxic to human cells than glyphosate” (p 100 of
204). Yet AMPA goes unmonitored in the environment or within humans that are widely
exposed to Roundup. That exposure is growing through our food supply chain due to the
Roundup ready crops that now dominate the American market.
Binders and Adjuvants Not Inert – In Fact More Toxic Than Glyphosate
Substances are added to glyphosate to help the chemical penetrate cell walls and for more
uniform application and these are called binders, surfactants or adjuvants. Numerous studies
have concluded that binders may significantly change the toxicity of the product applied to well
beyond effects caused by glyphosate alone (Schuett 1998, Relyea 2005, Gasnier et al. 2009, Vera
et al. 2012, Saunders and Pezeshki 2015, Mesegne et al. 2015, Defarge et al. 2018). Defarge et
al. (2018) noted that the surfactant POEA is a major component of Roundup and that it is itself a
far greater toxicant than glyphosate. Their study exposed plants and human cells to component
formulations of glyphosate-based herbicides and found some surprising and alarming things:
“Glyphosate was only slightly toxic on plants at the recommended dilutions in
agriculture, in contrast with the general belief. In the short term, the strong herbicidal and
toxic properties of its formulations were exerted by the POEA formulant family alone.”
Relyea (2005) found much higher toxicity to frogs and tadpoles from Roundup with POEA than
from pure glyphosate in a controlled experiment. He concluded “high mortality associated with
commercial forms of Roundup is actually due to the POEA surfactant and not to glyphosate
Defarge at al. (2018) point out the duplicity involved in analyzing impacts of glyphosate, often
not in combination with binders or formulants:
“In the short term, the strong herbicidal and toxic properties of its formulations were
exerted by the POEA formulant family alone. The toxic effects and endocrine disrupting
properties of the formulations were mostly due to the formulants and not to glyphosate.”
Gasnier et al. (2009) noted problems with POEA in terms of human health:
“The adjuvants in Roundup formulations are not inert. Moreover, the proprietary
mixtures available on the market could cause cell damage and even death around residual
levels to be expected, especially in food and feed derived from Roundup formulationtreated
Mesegne et al. (2013) had corollary findings:
“Here we demonstrate that all formulations are more toxic than glyphosate, and we
separated experimentally three groups of formulations differentially toxic according to
their concentrations in ethoxylated adjuvants. Among them, POE-15 clearly appears to be
the most toxic principle against human cells…..Altogether, these results challenge the
establishment of guidance values such as the acceptable daily intake of glyphosate, when
these are mostly based on a long term in vivo test of glyphosate alone. Since pesticides
are always used with adjuvants that could change their toxicity, the necessity to assess
their whole formulations as mixtures becomes obvious.”
Cox and Surgan (2006) called for mandated monitoring of binders to comply with federal law:
“Evaluations of pesticides under the National Environmental Policy Act, the Endangered
Species Act, and similar statutes should include impact assessment of formulations.
Environmental monitoring for pesticides should include inert ingredients. To enable
independent research and risk assessment, inert ingredients should be identified on
U.S. EPA (2017a) found that oral and inter-tracheal administration of glyphosate to rats caused
only mild lung hemorrhages and epithelial damage, but rats died immediately or after several
days when given POEA (p 96 of 204). Therefore, U.S. EPA knows that POEA is not inert and
instead is highly toxic and yet it fails to monitor this substance.
Mesegne et al. (2015) summed up the problems of adjuvants and current regulation loop holes:
“Glyphosate-based herbicides (GlyBH), including Roundup, are the most widely used
pesticides worldwide. Their uses have increased exponentially since their introduction on
the market. Residue levels in food or water, as well as human exposures, are escalating.
We have reviewed the toxic effects of GlyBH measured below regulatory limits by
evaluating the published literature and regulatory reports. We reveal a coherent body of
evidence indicating that GlyBH could be toxic below the regulatory lowest observed
adverse effect level for chronic toxic effects. It includes teratogenic, tumorigenic and
hepatorenal effects. They could be explained by endocrine disruption and oxidative
stress, causing metabolic alterations, depending on dose and exposure time.
Some effects were detected in the range of the recommended acceptable daily intake.
Toxic effects of commercial formulations can also be explained by GlyBH adjuvants,
which have their own toxicity, but also enhance glyphosate toxicity. These challenge the
assumption of safety of GlyBH at the levels at which they contaminate food and the
environment, albeit these levels may fall below regulatory thresholds. Neurodevelopmental,
reproductive, and transgenerational effects of GlyBH must be revisited,
since a growing body of knowledge suggests the predominance of endocrine disrupting
mechanisms caused by environmentally relevant levels of exposure.”
Thus, the entire U.S. EPA analysis of impacts of glyphosate and its major derivative Roundup is
flawed because the supposed “inert” binder POEA is the actual toxicant. Since POEA is not
studied separately, we have no idea of its prevalence in the environment or in humans.
Therefore, the U.S. EPA should deny further continued use of Roundup and similar glyphosatebased
herbicides, following the precautionary principal, and require the removal of POEA from
Heavy Metals in Glyphosate-Based Herbicides
Defarge et al. (2018) found major problems with heavy metal pollution in glyphosate-based
“We measured in the formulations other contaminants such as, among others, the heavy
metals arsenic (As), cobalt (Co), chromium (Cr), nickel (Ni) and lead (Pb), which are
known to be toxic and endocrine disruptors. Eleven formulations were assessed, as well
as 11 other pesticide formulations as comparators. Formulations from both groups were
comparably and heavily contaminated (Fig. 5) with the heavy metal As, present in almost
all samples. In total, all except 3 formulations had 5–53 times the permitted level of As in
water in European Union or USA; all except 1 had Cr above (up to 40 times) the
permitted level; all except 1 contained Ni, with 19 samples being above the permitted
level (up to 62 times); 6 contained up to 11 times the permitted level of Pb.”
This is extremely alarming and shows major negligence of the U.S. EPA in regulating Roundup
and other glyphosate-based herbicides, if the findings of Defarge et al. (2018) are representative.
If they are, the consequences for human and environmental health are far-reaching. The
permitting of Roundup and other similar products should be withdrawn from the market, at least
until heavy metal pollution issues are resolved.
Dispersal – Problems in the Water, the Soil and the Air
The U.S. EPA ecological assessment of glyphosate in the environment follows a simplistic logic
that the chemical adheres to sediment and will not likely runoff, and that impacts and risk is
mostly at the site of application. In fact, that is not the case and dispersal of glyphosate-based
herbicides offsite is common in surface water, on the wind, and even in the rain (Scribner et al.
2003). Problems in the soil proximate to applications of glyphosate herbicides are
underestimated by U.S. EPA, as the longevity of in the soil may also come with residual toxicity
to non-target plant species and organisms essential to sustainable agriculture like earth worms.
Coupe et al. (2011) studied Midwestern streams and found glyphosate to be ubiquitous in surface
“Glyphosate use in a watershed results in some occurrence in surface water; however, the
watersheds most at risk for the offsite transport of glyphosate are those with high
application rates, rainfall that results in overland runoff, and a flow route that does not
include transport through the soil.”
Saunders and Pezeshki (2015) had the following findings: “(1) glyphosate often runs off of fields
where it is applied; (2) glyphosate can be translocated by plant roots; and (3) glyphosate can
affect plant functioning in non-target plants.” Roots of plants killed is another pathway into the
soil for glyphosate, AMPA and POEA. Glyphosate may and AMPA may remain for up to 196
days in clay soils with unknown biological impact as noted by Scribner et al. (2003).
Scribner et al. (2003) not only found surface water runoff with glyphosate-based herbicides, but
also found them in isolated ponds where aerosol drift carried them. Furthermore, Scribner et al.
(2003) actually measured glyphosate and AMPA in rainfall in Mid-western states. A U.S.
Geological Survey (USGS 2008) found substantial amounts of glyphosate in runoff in a
Clackamas River tributary after forest herbicide application.
The U.S. EPA needs to acknowledge the potential for some pesticides and herbicides to have
impacts many miles from their application location (Cordell and Baker 1998). Although the
incidence of contamination is not involving glyphosate, Davidson and Knapp (2007) found that
pesticides applied on the southern Central Valley floor are killing mountain yellow-legged frogs
inside Wilderness Areas along the crest of the Sierra 100 kilometer away:
“Using generalized additive models, we found that, after accounting for habitat effects,
the probability of Rana muscosa presence was significantly reduced by both fish and
pesticides, with the landscape-scale effect of pesticides much stronger than that of fish.
The degree to which a site was sheltered from the predominant wind (and associated
pesticides) was also a significant predictor of R. muscosa presence.”
Biological and Ecological Impacts
The U.S. EPA review of glyphosate completely misses the mark in terms of acting on the side of
caution to protect fish and wildlife and to protect public trust resources. Coupe et al. (2011)
noted the following:
“In spite of the increase in usage across the United States, the characterization of the
transport of glyphosate and its degradate aminomethylphosphonic acid (AMPA) on a
watershed scale is lacking.”
Scientists and academics have plugged some data gaps and characterized the risk to various
species. Relyea (2005) conducted controlled experiments with glyphosate-based herbicides in
ponds and noted:
“Collectively, the available data indicate that, contrary to conventional wisdom, current
application rates of Roundup can be highly lethal to many species of amphibians. This
result is of particular interest in light of the global decline of amphibians (Wake 1998,
Alford and Richards 1999, Houlihan et al. 2001, Blaustein and Kiesecker 2002) which, in
some cases, is correlated with a proximity to agricultural areas that use pesticides (Bishop
et al. 1999, Davidson et al. 2001, 2002, Sparling et al. 2001). Although Roundup is an
herbicide, two lines of evidence suggest that the widespread tadpole mortality was
directly due to toxicity and not to the destruction of the tadpoles’ algal food source. This
indicates that Roundup directly kills amphibians rather than indirectly causing
amphibians to starve to death.”
Battaglin et al. (2005) had the following findings
“Several studies have documented that some of the surfactants used in glyphosate
formulations are more toxic to wildlife than the glyphosate itself (Martinez and Brown,
1991; Mann and Bidwell, 1999; Tsui and Chu, 2003; Howe et al., 2004); however, the
surfactants used in glyphosate products were not included in this study. Glyphosate and
its surfactant polyoxyethylene amine (POEA) were more toxic to microalgae and
crustaceans than to bacteria and protozoa (Tsui and Chu, 2003). Another study reported
‘significant effects’ of the herbicide formulation on amphibians including a statistically
significant reduction in survival of adults.”
Another significant finding of Battaglin et al. (2005) was the interaction of glyphosate-based
herbicides with predators and the environment. Relyea (2012) found similar effects in the altered
shape of frog larvae in the presence of predators and Roundup. His secondary finding was that
tadpoles avoided Roundup by swimming to the bottom of ponds, and thereby had less interaction
with top-water predators.
Studies of the endangered Lange’s metalmark butterfly and its near relative Behr’s metalmark
butterfly indicate that applications of imazapyr and other herbicides lessened survival of these
species at the Antioch Dunes National Wildlife Refuge in Contra Costa County, CA, which is the
only known habitat for the species (Stark et al. 2012). Although the agent in the latter case may
not have been glyphosate, the decline of the Monarch butterfly is linked to glyphosate. Roundup
killed all the milkweed that the caterpillars of the species relied on (FOEE 2013): “It is estimated
that common milkweed has been largely eliminated from 100 million hectares of US cropland
following the introduction of glyphosate-resistant crops.”
In the soil, earth worms are negatively impacted by glyphosate-based herbicides (Correia and
Moreira 2010). Correia and Moreira (2010) found that glyphosate “demonstrated severe effects
on the development and reproduction of Eisenia foetida in laboratory tests”, which is the most
common European earthworm.
Potential Human Health Impacts
As in the realm of environmental effects, U.S. EPA (2017b, 2017c) evaluation of human health
risk and glyphosate-based herbicides is also flawed in that the binder POEA and the long-lasting
breakdown product AMPA, that both have equal or greater toxicity, are not considered. Recent
studies and literature indicate alarming toxicity to human cells from the latter two substances
Stalled by bureaucratic inertia brought on by crushing pressure from Monsanto, the U.S. EPA
(2017b, 2017c) is narrowly focused on whether glyphosate-based herbicides caused specific
types of cancer as a result of direct exposure (DeRooz et al. 2005). Andreotti et al. (2017) used a
larger sampling pool of exposed farmers and their families and was unable to find any significant
statistical correlation between glyphosate and any specific cancer. However, of the 44,932
farmers participating in the program and reporting exposure to glyphosate, a total of 5,779 later
Meanwhile, there is major public health risk because of the casual way herbicides are marketed.
Approximately half of the acute exposure reports filed annually are from homeowners mixing
pesticides without following instructions (U.S. EPA 2014). Also, 5-27% of exposure cases are
children who were exposed, with the route of exposure “accidental ingestion and tampering with
the product.” The U.S. EPA (2014) explains why the study of glyphosate was initiated:
“Given the magnitude and frequency observed in the initial screening evaluation of acute
poisoning incidents related to glyphosate use, Health Effects Division determined that a
more extensive Tier II report of the acute and chronic human health effects linked to
glyphosate use should be performed.”
The International Agency for Research on Cancer (IARC 2015), the cancer-research arm of the
World Health Organization, found that glyphosate-based herbicides were likely human
carcinogens based on animal tests and potential for cell destruction, DNA disruption, and
endocrine disruption. Much recent research has highlighted the substantial human health risk of
glyphosate-based herbicides and particularly the degradant AMPA and the binder POEA
(Benachour et al. 2007, Gasnier et al. 2009, Mesnage et al. 2013; 2015).
Findings of Gasnier et al. (2009) and Mesnage et al. (2013, 2015) reported above present
considerable evidence of negative human health effects because of the toxicity of glyphosate
herbicides, especially in combination with the deadly binder POEA.
Gasnier et al. (2009) expressed the following reservations about glyphosate and protection of
“In addition, these herbicides are spread on most eaten transgenic plants, modified to
tolerate high levels of these compounds in their cells. Up to 400 ppm of their residues are
accepted in some feed. A real cell impact of glyphosate-based herbicides residues in
food, feed or in the environment has thus to be considered, and their classifications as
carcinogens/mutagens/reprotoxics is discussed.”
Friends of Earth of Europe (FOEE 2013) documented that 44% of people in the EU have some
level of glyphosate in their blood stream. They also presented evidence that glyphosate affects
the activity of the enzyme acetyl-cholinesterase, which is vital for the operation of the nervous
system (FOEE 2013).
U.S. EPA is making its determination of cancer risk on the basis of glyphosate alone, and not
measuring co-occurring chemicals and their risk. Therefore, their whole process of evaluation is
fundamentally flawed and does not provide the basis for judgement as to whether continuing use
glyphosate-based herbicides as presently formulated is prudent.
Glyphosate and the World’s Food Production System
Coupe et al. (2011) point out how widespread use of Roundup ready crops are in the United
“More than 90% of the soybeans grown in the United States are glyphosate tolerant, with
some states having an even higher percentage, such as South Dakota with 97% and
Mississippi with 96% in 2007. In the United States, most of the cotton (72%) and about
half of the corn (52%) planted in 2007 were glyphosate tolerant.”
The advent of Roundup ready crops now insures an increasing contamination of the of food
supply. This is in effect a large, uncontrolled, world-wide experiment with human health. The
over-reliance on Roundup ready crops is leading to a major loss of genetic diversity as seeds are
proprietary and monocultural. Historic genetic resources for food crops are being lost, a formula
for the collapse of the world food supply. Super-weeds that are immune to herbicides are rapidly
evolving and will lead to the need for even more toxic substances, yet the U.S. EPA doesn’t even
address this problem.
The U.S. EPA review of glyphosate-based herbicides is not sufficient to meet the standards of
the National Environmental Policy Act (NEPA) or the California Environmental Quality Act
(CEQA) because both require examination of all possible related impacts associated with the
permitted activity. Since the chemical in question, glyphosate, in its most common formulation
Roundup, is always accompanied in the environment by the degradant AMPA and the binder
POEA, and both these substances have been found to be more toxic than glyphosate; therefore,
the U.S. EPA does not meet the standard for cumulative effects assessment at the ecosystem or
human health level for NEPA or CEQA.
It is time that the U.S. EPA gave greater emphasis to consideration of ecological impairment
(Vera et al. 2012). The chemicals you are setting up to reauthorize under this review are killing
the bees that pollinate plants, the frogs and aquatic biota, and worms and other soil organisms
that create living soils. In short, allowing continuing use of these chemicals is killing the
ecosystems and soils that support agriculture and human life. The impending agricultural
collapse brought on by this chemically dependent monoculture will have huge consequences in
terms of human suffering and possibly put our survival as a species at risk.
In terms of human health considerations, it is time that the U.S. EPA switched the burden of
proof to chemical companies and acted on the side of caution. Effects of pesticides may be
delayed for decades and the diseases that afflict those exposed are never linked to the casual
mechanism or the linkage cannot be proved. While the European Union and Canada respond
rationally to studies that show human and ecological health risk, banning substances like
glyphosate, the U.S. EPA is studying the problems further in order to delay decisions that stop
that sale of this extremely lucrative product. This is a pattern of undue influence of money on
regulatory over-sight that is preventing protection of public health and leading the collapse of
once great ecosystems all across the United States.
The whole construct of U.S. EPA regulation is also completely behind the times with regard to
recognizing the synergy of pesticides and herbicides acting in combination that is killing fishes
(Leitz et al. 2009) and frogs (Relyea 2005) and causing extensive damage to aquatic biota (Vera
et al. 2012). The cumulative effects of pesticides and herbicides are causing unacceptable
damage to the environment, sometimes many miles away, and the regulation of individual
pesticides has failed.
I urge you not to re-authorize the license for the use of Roundup and make the company pay for
monitoring of AMPA and POEA in the environment. If the amount of heavy metals in
glyphosate-based herbicides found by Defarge et al. (2018) is routine, then the U.S. EPA must
move immediately to have them prevent such toxic contaminants and issue appropriate fines for
current heavy metal pollution attendant with use of Roundup.
I respectfully, submit these comments on behalf of the Living Rivers Council. I am available to
the U.S. EPA staff for consultation at any time.
Consulting Fisheries Biologist
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