Tell California’s Prop 65 Regulators: There’s No Safe Level of Monsanto’s Cancer-Causing Roundup Herbicide

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The proposed No Significant Risk Level of 1100 micrograms for glyphosate is too high.
There is no safe level of Monsanto’s Roundup herbicide. Warnings must be required for any exposure to the carcinogen glyphosate. Discharges of glyphosate to sources of drinking water must be prohibited.
California Code of Regulations Section 25703 requires appraisal of epidemiologic data in a quantitative assessment of a No Significant Risk Level. The Initial Statement of Reasons fails to consider any epidemiological studies. Imposing a safe harbor for a chemical known to the State of California to cause cancer and deemed by the International Agency for Research on Cancer to be a “probable human carcinogen”, without considering any epidemiological literature, as required by Section 25703 is a violation of the law. 
Additionally, the proposed NSRL is based on an insufficient number of animal bioassays. OEHHA reviewed a two-year rodent carcinogenicity study where 50 male CD-1 mice were fed a diet containing glyphosate at concentrations intended to achieve dose rates of 0, 100, 300, or 1000 milligrams of glyphosate per kilogram of body weight per day. Tumor incidence was observed in the 1000 milligrams per day dose group. 
However, other studies have found the development of tumors at much lower doses, including:
1. In a 1981 study by Lankas, lymphocytic hyperplasia was observed at 11 mg/kg-bw/day in Sprague-Dawley rats. Source
2. A 2009 study by Wood found lung tumors at low and mid doses in males at 71.4 and 234.2 mg/kg-bw/day in a study where malignant lymphomas were significantly induced at 810 mg/kg-bw/day. Source
3. In 1981, Lankas observed testicular interstitial tumors in male Sprague-Dawley rats which demonstrated a significant trend and a significant pairwise comparison between control and the high dose of 31.49 mg/kgbw/ day. Source
4. In 1990, Stout and Ruecker noted Pancreatic islet cell adenoma in male Sprague-Dawley rats demonstrating a significant pairwise comparison relative to controls at the low dose, 89 mg/kg-bw/day. Source
The intent of Prop 65 is to warn consumers about the potential of a product to cause cancer. The law is only effective if it establishes realistic thresholds. Based on the available science, the proposed 1100 mg NSRL is way too high.
Thank you.

California is moving forward with its legal responsibility under Proposition 65 to warn the public that glyphosate, the main ingredient in Roundup weed-killer, is a probable human carcinogen.

Monsanto tried, but failed to keep the warning off its labels. So now the Biotech Bully is trying to convince Proposition 65 regulators at the Office of Environmental Health Hazard Assessment to adopt a ridiculously high level (it’s called a No Significant Risk Level) for how much glyphosate is allowed in something before the public has to be warned that it’s carcinogenic. 

TAKE ACTION BEFORE 5 P.M. TODAY: Tell California’s Office of Environmental Health Hazard Assessment (OEHHA), “There is no safe level of Monsanto’s Roundup herbicide! Warnings must be required for any exposure to the carcinogen glyphosate! Discharges of glyphosate to sources of drinking water must be prohibited!”

The OEHHA has proposed a No Significant Risk Level (NSRL) of 1.1 milligrams of glyphosate per person per day. According to a 2016 federal EPA analysis, the typical adult is exposed to 0.09 mg/kg/day of glyphosate per day through diet. So, it is unlikely that the 1.1 mg limit would result in warnings on food.  

The OEHHA’s proposed No Significant Risk Level for glyphosate does not comply with the statutory requirements of Title 27 of the California Code of Regulations § 25703(a). According to Moms Across America, OEHHA:

Is proposing a No Significant Risk Level (NSRL) thousands of times higher than the level proven to cause liver disease, which is a precursor to cancer, and millions of times higher than the level shown to stimulate the growth of breast cancer cells.

•  Does not take into consideration the unique vulnerability of a fetus, baby or child, including their sensitivity during development or their vulnerable immune systems.

•  Exempts non-target exposure from farm applications, including aerial sprays and pesticide drift, as well as use on playgrounds, roadsides and forests.

•  Did not review epidemiology studies as is required by California law.

The correlation between glyphosate exposure and cancer rates, as well as laboratory evidence of a causal link, was the basis for the World Health Organization’s finding that glyphosate is a probable human carcinogen. 

More than 10 million pounds of glyphosate is used on 250 different crops in California. In the decade from 2003 to 2012, application rates skyrocketed, growing by nearly two-thirds, and they continue to rise. 

In 2015, glyphosate was California’s number one pesticide by acreage. Among crops, almonds consume the lion’s share (about 20 percent) of the state’s glyphosate use. It is also used on alfalfa, carrots, cotton, oranges, peaches and nectarines, pistachios, processing tomatoes, rice, strawberries, table, wine and raisin grapes, and walnuts. 

Living near agriculture increases rates of serious heath problems, including cancer. Overall cancer incidence for California children under 20 years of age is the same as the national rate (17.4 per 100,000), but California Department of Health data shows the child cancer rates in some agricultural counties are up to 24 percent higher than the national average.

The increased and intensified use of glyphosate may also explain the high incidence of cancer among children in places like Napa County. The California Department of Pesticides Registry shows Napa County farmers in 2013 used 50,416 pounds of glyphosate on 34,776 acres of grapes in 3,412 applications. This is up from 2003 figures which show the use of 42,771 pounds on 37,055 acres in 3,245 applications. Glyphosate use on vineyards is so intense that tests of wines revealed contamination of every sample.

In addition to agricultural uses, glyphosate is used on public lands, playgrounds and golf courses across the state. School districts in BurbankGlendaleIrvine, Santa Rosa, Sonoma Valley, Petaluma, Cloverdale and Sebastopol have agreed to halt their use of glyphosate after demands from parents.

Since most of our exposure to glyphosate comes through agricultural pollution that can’t be labeled with a warning, we have to demand the lowest possible No Significant Risk Level. That’s the only way to get agricultural users to reduce their glyphosate use. Plus, for breast and liver cancer, where infinitesimal doses can trigger illness, we won’t be protected unless the NSRL is lowered.



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