Living Rivers Council submits expert comments on glyphosate and its ‘inert’ substances in formulation to the EPA

Living Rivers Council submits expert comments on glyphosate and its ‘inert’ substances in formulation to the EPA

Living Rivers Council submitted our substantive scientific expert comments by Patrick Higgins, fisheries biologist, on glyphosate and its ‘inert’ substance formulation due to:
  • 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
Note: Napa County has had the highest cancer rates in the state for several years. Last year children in Napa had the highest cancer rates in California and this year it is white women.

See these attached expert comments:

Chris Malan

April 30, 2018

Ms. Dana Friedman

Pesticide Re-Evaluation Division (7508P)

Environmental Protection Agency, Office of Pesticide Programs

1200 Pennsylvania Ave. NW

Washington, DC 204600001

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.

Executive Summery

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.

My Qualifications

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.

Glyphosate Overview

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


Therefore, the U.S. EPA (2017a, 2017b, 2017c) studies of the effects of glyphosate-based

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

product labels.

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

herbicide formulations:

“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 553 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 effectsof 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

(Defarge 2018).

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

contracted cancer.

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{5fc40a96f14c4a6aa4c2a32569b0a57dcc67c0b31eb04c341474283f11b6cdd2} 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

human health:

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{5fc40a96f14c4a6aa4c2a32569b0a57dcc67c0b31eb04c341474283f11b6cdd2} 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{5fc40a96f14c4a6aa4c2a32569b0a57dcc67c0b31eb04c341474283f11b6cdd2} 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{5fc40a96f14c4a6aa4c2a32569b0a57dcc67c0b31eb04c341474283f11b6cdd2} and

Mississippi with 96{5fc40a96f14c4a6aa4c2a32569b0a57dcc67c0b31eb04c341474283f11b6cdd2} in 2007. In the United States, most of the cotton (72{5fc40a96f14c4a6aa4c2a32569b0a57dcc67c0b31eb04c341474283f11b6cdd2}) and about

half of the corn (52{5fc40a96f14c4a6aa4c2a32569b0a57dcc67c0b31eb04c341474283f11b6cdd2}) 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.


Patrick Higgins

Consulting Fisheries Biologist


Alford, R. A., and S. J. Richards. 1999. Global amphibian declines: a problem in applied

ecology. Annual Review of Ecology and Systematics 30:133165.

Andreotti, G., Koutros, S., Hofmann, J.N., Sandler, D.P., Lubin, J.H., Lynch, C.F., Lerro, C.C.,

De Roos, A.J., Parks, C.G., Alavanja, M.C., Silverman, D.T. 2017. Glyphosate use and cancer

incidence in the Agricultural Health Study. JNCI: Journal of the National Cancer Institute.


Battaglin, W.A., D.W. Kolpin, E.A. Scribner, K.M. Kuivila, and M.W. Sandstrom. 2005.

Glyphosate, Other Herbicides, and Transformation Products in Midwestern Streams, 2002.

Journal of the American Water Resources Association (JAWRA) 41(2):323-332.

Benachour, N. and G.E. Séralini. 2009. Glyphosate formulations induce apoptosis and necrosis

in human umbilical, embryonic, and placental cells. Chemical Research in Toxicology, Volume

22, Issue 1, January 2009, Pages 97-105.

Bishop, C. A., N. A. Mahony, J. Struger, P. Ng, and K. E. Pettit. 1999. Anuran development,

density and diversity in relation to agricultural activity in the Holland River watershed, Ontario,

Canada (19901992). Environmental Monitoring and Assessment 57:2143.

Blaustein, A. R., and J. M. Kiesecker. 2002. Complexity in conservation: lessons from the global

decline of amphibian populations. Ecology Letters 5:597608.

Cox, C. and M. Surgan. 2006. Unidentified inert ingredients in pesticides: Implications for

human and environmental health. Environmental Health Perspectives, Volume 114, Issue 12,

December 2006, Pages 1803-1806

Cordell, S. and T.P. Baker. 1998. Pesticide Drift. University of Arizona, College of Agriculture.

4 p.

Correia, F.V. and J. C. Moreira. 2010. Effects of Glyphosate and 2,4-D on Earthworms (Eisenia

foetida) in Laboratory Tests. Bull Environ Contam Toxicol (2010) 85: 264.

Coupe, R.H., S.J. Kalkhoff, P.D. Capelc and C. Gregoired. 2011. Fate and transport of

glyphosate and aminomethylphosphonic acid in surface waters of agricultural basins.

Davidson, C., H. B. Shafer, and M. R. Jennings. 2002. Spatial tests of the pesticide drift, habitat

destruction, UV-B, and climate-change hypotheses for California amphibian declines.

Conservation Biology 16:15881601.

Davidson, C. and R.A. Knapp. 2007. Multiple stressors and amphibian declines: Dual impacts of

pesticides and fish on yellow-legged frogs. Ecological Applications 17(2):587-597.

Defarge, N.; Spiroux de Vendômois, J.; Séralinia, G. E. (2018). “Toxicity of formulants and

heavy metals in glyphosate-based herbicides and other pesticides”. Toxicology Reports. 5: 156

163. doi:10.1016/j.toxrep.2017.12.025

De Roos, A. J., Blair, A., Rusiecki, J. A., Hoppin, J. A., Svec, M., Dosemeci, M., Alavanja, M.

C. (2005). Cancer Incidence among Glyphosate-Exposed Pesticide Applicators in the

Agricultural Health Study. Environmental Health Perspectives, 113(1), 4954.

Friends of the Earth Europe (FOEE). 2013. The environmental impacts of glyphosate. Friends of

the Earth Europe, Brussels, Belgium. 20 p.

Gasnier, C., C. Dumont, N. Benachour, E. Clair, M.C. Chagnon, and G.E. Seralini, G.E., 2009.

Glyphosate-based herbicides are toxic and endocrine disruptors in human cell lines. Toxicology

262, 184191p.

Gilliom, R.J., J.E. Barbash, C.G. Crawford, P.A. Hamilton, J.D. Martin, N. Nakagaki, L.H.

Nowell, J.C. Scott, P.E. Stackelberg, G.P. Thelin, and D.W. Wolock. 2006. The Quality of Our

Nation’s Water, 1992-2001. U.S. Geologic Survey, Reston, VA. 184 p.

Higgins, P.T. 2007. Comments on the Bohemian Grove NTMP (1-06NTMP-011SON) with an

Emphasis on the Aquatic Environment and ESA-Listed Pacific Salmon Species. Performed

under contract to John Hooper by Patrick Higgins, Fisheries Consultant, Arcata, CA. 48 p.

Higgins, P.T. 2009. Comments on Salinas River Channel Maintenance Project (CMP) 404

Permit Application and Mitigated Negative Declaration. Performed under contract to the

Monterey Coastkeeper by Patrick Higgins, Fisheries Consultant, Arcata, CA. 22 p.

Higgins, P.T. 2017a. Herbicides and Kidd Creek Non-Industrial Timber Management Plan 1-15

NTMP-007 SON. Prepared for Thomas Lippe, Attorney at Law by Patrick Higgins, Consulting

Fisheries Biologist. McKinleyville, CA. 10 p.

Higgins, P.T. 2017b. 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. Prepared for Earth Rise, Stanford Environmental Law

Center and Monterey Coast Keeper by Patrick Higgins, Consulting Fisheries Biologist.

McKinleyville, CA. 75 p.

Higgins, P.T. 2017c. Comments on Proposed Fox Meadows Timber Harvest (THP 1-17-017

SON) and Threat Posed to ESA-Listed Pacific Salmon Species and Their Habitat. Prepared for

Thomas Lippe, Attorney at Law by Patrick Higgins, Consulting Fisheries Biologist.

McKinleyville, CA. 30 p.

Houlihan, J. E., C. S. Findlay, B. R. Schmidt, A. H. Meyers, and S. L. Kuzmin. 2001.

Quantitative evidence for global amphibian population declines. Nature 404:752755.

Howe, C.M., M. Berrill, B.D. Pauli, C.C. Helbing, K. Werry, and N. Veldhoen, 2004. Toxicity of

Glyphosate-Based Pesticides to Four North American Frog Species. Environmental Toxicology

and Chemistry 23(8):1928-1934.

International Agency for Research on Cancer. 2015. IARC Monographs Volume 112: evaluation

of five organophosphate insecticides and herbicides. IARC, Lyon, France.

Laetz, C., D. Baldwin, T. Collier, V. Hebert, J.D. Stark, and N. Scholz. 2009. The Synergistic

Toxicity of Pesticide Mixtures: Implications for Risk Assessment and the Conservation of

Endangered Pacific Salmon. Environmental Health Perspectives, No. 3, Vol. 117, 348-353.

Mann, R.M. and J.R. Bidwell, 1999. The Toxicity of Glyphosate and Several Glyphosate

Formulations to Four Species of Southwestern Australian Frogs. Archives of Environmental

Contaminant. Toxicology 36:193-199.

Martinez, T.T. and K. Brown, 1991. Oral and Pulmonary Toxicology of the Surfactant Used in

Roundup Herbicide. Proceeding of the Western Pharmacological Society 34:43-46.

Mesnage, R., B. Bernay, and G.E. Séralini. 2013. Ethoxylated adjuvants of glyphosate-based

herbicides are active principles of human cell toxicity. ToxicologyVolume 314, Issue 2-3, 16

November 2013, Pages 122-128

Mesnage, R., N. Defarge, J. Spiroux de Vendômois, and G.E. Séralini. 2015. Potential toxic

effects of glyphosate and its commercial formulations below regulatory limits. Food and

Chemical Toxicology Volume 84, August 14, 2015, Pages 133-153.

National Marine Fisheries Service. 2016. Pesticide Mixtures: Deadly Synergy in Salmon. NMFS

Northwest Fisheries Science Center, Seattle, WA. On-line:

Pérez, G.L., A. Torremorell, H. Mugni, P. Rodriguez, M. Solange Vera, M. do Nascimento, L.

Allende, J. Bustingorry, R. Escary, M. Ferro, I. Izaguirre, H. Pizzaro, C. Bonetto, D.P. Morris

and H. Zagarese. 2007. Effects of the herbicide Roundup on freshwater microbial communities:

a mesocosm study. Ecological Applications Vol 17 pp 2310-2322.

Quartz Valley Indian Reservation. 2016. Standard Operating Procedures for Ground Water

Sampling For Heavy Metals, Pesticides, and Herbicides. Provided by QVIR to U.S. EPA R 9

with technical assistance from Kier Associates. QVIR, Ft Jones, CA. 26 p.

Relyea RA. 2005. The lethal impact of roundup on aquatic and terrestrial amphibians. Ecological

Applications Vol 15: 1118-1124.

Relyea, R. A. 2012. Amphibians are not ready for Roundup. In C. Bishop, and C. Morrisey (eds.)

Wildlife Ecotoxicology – Forensic Approaches, Pages 267-300, Springer Press.

Resighini Rancheria. 2010. Surface Water Sampling and Analysis Plan for the Resighini

Rancheria. Pursuant to Section 106 Water Quality Assessment, Clean Water Act Project.

Prepared by Resighini Environmental Protection Authority (REPA), Klamath, CA. 18 p.

Scribner, E.A., W.A. Battaglin, J.E. Dietze, and E.M. Thurman. 2003. Reconnaissance data for

glyphosate, other selected herbicides, their degradation products, and antibiotics in 51 streams in

nine midwestern states, 2002: U.S. Geological Survey Open-File Report 2003-217, 101 p.

Saunders, L.E. and R. Pezeshki. 2015. Glyphosate in Runoff Waters and in the Root-Zone: A

Review. Toxics 2015, 3, 462-480; doi:10.3390/toxics3040462

Schuette, J. 1998. Environmental Fate of Glyphosate. Environmental Monitoring & Pest

Management Department of Pesticide Regulation, Sacramento, CA 95824-5624.

Sparling, D. W., G. M. Fellers, and L. S. McConnell. 2001. Pesticides and amphibian population

declines in California, USA. Environmental Toxicology and Chemistry 20:15911595.

Stark, J.D., X.D. Chen, and C.S. Johnston. 2012. Effects of herbicides on Behr’s metalmark

butterfly, a surrogate species for the endangered butterfly, Lange’s metalmark. Environmental

Pollution Volume 164, May 2012, Pages 2427.

Tsui, Martin T.K. and L.M. Chu, 2003. Aquatic Toxicity of Glyphosate-Based Formulation:

Comparison Between Different Organisms and the Effects of Environmental Factors.

Chemosphere 52:1189-1197.

U.S. Environmental Protection Agency. 2014. Glyphosate: Tier II Incident Report. US EPA

Health Effects Division, Washington D.C. 127 p.

U.S. Environmental Protection Agency. 2017a. Glyphosate Systematic Review of Open

Literature. US EPA Office of Chemical Safety and Pollution Prevention, Washington D.C. 204


U.S. Environmental Protection Agency. 2017b. Glyphosate: dietary exposure Ana;lysis in

Support of Registration Review. US EPA Office of Chemical Safety and Pollution Prevention,

Washington D.C. 20 p.

U.S. Environmental Protection Agency. 2017c. Summary Review of Recent Analysis of

Glyphosate and Cancer Incidence in the Agricultural Health Study. US EPA Office of Chemical

Safety and Pollution Prevention, Washington D.C. 3 p.

U.S. Geologic Survey. 2008. Pesticide Occurrence and Distribution in the Lower Clackamas

River Basin, Oregon, 2000-2005. USGS Scientific Investigations Report 2008-5027, Portland,


Vera M.S., E. Di Fiori, L. Lagomarsino, R. Sinistro, R. Escaray, M.M. Iummato, A. Juárez, M.C.

del Ríos de Molina, G. Tell, and H. Pizarro. 2012. Direct and indirect effects of the glyphosate

formulation Glifosato Atanor on freshwater microbial communities. doi: 10.1007/s10646-012-

0915-2. Ecotoxicology Vol 21 pp 1805-1816.

Wake, D. B. 1998. Action on amphibians. Trends in Ecology and Evolution 13:379380.