Renewable Farming

Examples of comments submitted to EPA on glyphosate safety

Several groups and individuals concerned about glyphosate health issues are urging friends and neighbors to send their facts to an FDA advisory panel which is meeting Oct. 18 through 21 to evaluate the “carcinogenic potential” of glyphosate.

We’ve collected some of their comments and include them below the green lines in this report.

Here’s the official announcement and the link you can use to send comments to the panel.

There will be a 4-day meeting of the Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (FIFRA SAP) to consider and review a set of scientific issues being evaluated by the Environmental Protection Agency (EPA) regarding EPA’s evaluation of the carcinogenic potential of glyphosate, a non-selective, phosphonomethyl amino acid herbicide registered to control weeds in various agricultural and non-agricultural settings.

The meeting will be held on October 18-21, 2016, from approximately 9 a.m. to 5 p.m.

Comments. The Agency encourages written comments be submitted on or before October 4, 2016, to provide adequate time for the FIFRA SAP to review and consider the comments. The Agency encourages requests for oral comments be submitted on or before October 11, 2016.

For submittal instructions, visit this link:



Howard Vlieger,   4947 US 75 Avenue, MAURICE, IOWA 51036

To Mr. Knott and EPA panel on glyphosate:

I have been a crop and livestock nutrition adviser since 1992. I have witnessed firsthand the damage caused by glyphosate to everything from the soil to livestock and people. Glyphosate is a strong mineral chelator and is reducing mineral nutrition and availability wherever it is present. In addition to this, glyphosate is a potent antibiotic, and only a minuscule amount is required to cause damage to beneficial organisms.

The erosion and flooding during rain events has dramatically increased as a result of glyphosate herbicide use. Beneficial soil organisms that are necessary to have healthy soil are severely diminished by glyphosate.

USDA research scientists as well as other independent researchers have published numerous scientific papers documenting the harm caused by glyphosate from both a mineral nutrition and soil biology stand point.

Glyphosate residues are showing up everywhere in the environment and the food chain.

It is time for EPA to STOP this madness and refuse the reapproval of glyphosate herbicide.

We already have countless years of cleanup of glyphosate residue and its subsequent damaging effects to deal with.

There is no need to make this problem worse.


Henry Rowlands

Director, The Detox Project,
Director, Sustainable Pulse,
International Coordinator, Global GMO Free Coalition, 
GMO Evidence,

My comment to EPA:

After studying glyphosate closely for the last six years as a journalist, farmer and expert consultant on pesticides, I would like to ask: What has changed since the 1980s?

In the 1980s data supplied by Monsanto to support its position that the tumours were not related to glyphosate exposure was considered by the EPA to be “not… convincing”:
This same data is now somehow not being questioned in the same way and is being used in this current EPA review.

As we all know the findings of all glyphosate carcinogenicity studies on rats should be re-evaluated in light of up-to-date scientific knowledge, which shows the dose does not make the poison.

Studies to take note of: 
A laboratory study on Roundup by independent researchers in mice also revealed cancer-promoting effects. Roundup was found to promote cancerous tumour growth in the skin of the mice: George J, Prasad S, Mahmood Z, Shukla Y. Studies on glyphosate-induced carcinogenicity in mouse skin: A proteomic approach. J Proteomics. 2010;73:951-964. doi:10.1016/j.jprot.2009.12.008.

A laboratory study in human cells with glyphosate alone showed that the chemical is an endocrine disruptor in vitro. Glyphosate was found to increase the proliferation of estrogen-dependent breast cancer cells by estrogenic mechanisms at a level far below that permitted in drinking water in the EU: 

Unexpected tumor findings must be followed up:

An in vivo study of Roundup administered to rats in drinking water diluted to 50ng/L glyphosate equivalence – half of the level permitted in drinking water in the EU12 and 14,000 times lower than that permitted in drinking water in the USA – resulted in severe organ damage and a trend of increased incidence of mammary tumours in female animals over a 2-year period of exposure: Séralini G-E, Clair E, Mesnage R, et al. Republished study: long-term toxicity of a Roundup herbicide and a Roundup-tolerant genetically modified maize. Environ Sci Eur. 2014;26(14). doi:10.1186/s12302-014-0014-5. This study was republished and thus is not ‘retracted’ as stated in the latest EPA review.

This study was not a dedicated carcinogenicity study but a chronic toxicity study that unexpectedly found tumours. Because chronic toxicity studies use lower numbers of animals than carcinogenicity studies, the tumour findings need to be followed up with a full-scale carcinogenicity study using a larger number of animals (50 per sex per group). Roundup has never been tested for long-term toxicity in animals for regulatory purposes; only glyphosate alone has been tested, with the concerning results detailed above.

Rats are a good human cancer model. Data collected over 30 years at the Ramazzini Institute in Italy shows that the Sprague-Dawley strain of rat used at the Institute and in many toxicological studies worldwide is a good model for human cancer, provided the studies are well-designed. In other words, if a chemical causes cancer in this type of rat, there is a high likelihood that it will cause cancer in humans, too.

Human epidemiological studies confirm cancer risk:

Studies in human populations have found an association between Roundup exposure and two types of blood cancer:

An epidemiological study of pesticide applicators in the USA found that exposure to glyphosate herbicide was associated with higher incidence of multiple myeloma. De Roos AJ, Blair A, Rusiecki JA, et al. Cancer incidence among glyphosate-exposed pesticide applicators in the Agricultural Health Study. Env Health Perspect. 2005;113:49-54.

Epidemiological studies conducted in Sweden found that exposure to glyphosate herbicide was linked with a higher incidence of non-Hodgkin’s lymphoma.

a) Hardell L, Eriksson M. A case-control study of non-Hodgkin lymphoma and exposure to pesticides. Cancer. 1999;85:1353-1360. doi:10.1002/(SICI)1097-0142(19990315)85:6<1353::AID-CNCR19>3.0.CO;2-1.
b) Eriksson M, Hardell L, Carlberg M, Akerman M. Pesticide exposure as risk factor for non-Hodgkin lymphoma including histopathological subgroup analysis. Int J Cancer. 2008;123:1657-1663. doi:10.1002/ijc.23589.
c) Hardell L, Eriksson M, Nordstrom M. Exposure to pesticides as risk factor for non-Hodgkin’s lymphoma and hairy cell leukemia: Pooled analysis of two Swedish case-control studies. Leuk Lymphoma. 2002;43:1043-1049.
A systematic review of the literature published in 2014 concluded that there was an association between exposure to glyphosate herbicides and non-Hodgkin’s lymphoma.
Schinasi L, Leon ME. Non-Hodgkin lymphoma and occupational exposure to agricultural pesticide chemical groups and active ingredients: a systematic review and meta-analysis. Int J Environ Res Public Health. 2014;11(4):4449-4527. doi:10.3390/ijerph110404449.
Zen Honeycutt
Executive Director
Moms Across America

Mission Viejo CA 92691

Here is my comment to the EPA:

Dear Distinguished Public Officials,
As you consider whether glyphosate should be re approved, you must consider the widespread contamination of glyphosate based herbicides in water, urine, breast milk, Pediasure enteral nutrition, baby formula, cows’ milk, Gatorade, and oil. Glyphosate contamination has also been reported in cereal, bread, honey-(by the FDA), soy sauce, pet food, wine, beer and more. Concerned that ingredients derived from soy, corn, sugar and other genetically crops or animals are exposed to GMO feed and glyphosate, testing of vaccines for glyphosate was also recently conducted.
Independent lab results have shown that multiple batches of vaccines tested positive for the chemical glyphosate. See attached report for test results.  Alarmingly, the MMR II vaccine (Merck), which the CDC whistleblower Dr. William Thompson has linked to autism, had levels 25-34 X times higher than the other vaccines. Glyphosate has been shown to destroy gut bacteria ( micro biome) and studies have shown that children with autism have damaged gut micro biomes. The fact is that if you re approve glyphosate, you will be allowing the destruction of the gut biome which can lead to autism and more. The carcinogenic effect of glyphosate must not be your only concern. Glyphosate has also shown to be an anti biotic, neurotoxin, heart damage, and by your own words to “be a reproductive effector” and ” can cause liver and kidney damage.”
No weed killer should be in our food, water, breast milk or especially vaccinations in any amount. Safety for the injection of glyphosate based herbicides in human infants has never been proven. Many babies in America receive 5-13 vaccinations at 6 months old in one sitting, the CDC recommended amount is up to 49 doses by 12 years old and 69 vaccine doses by 18 years old. Glyphosate has been shown to accumulate in bone marrow and fat molecules. In addition, these amounts are injected directly into the muscle tissue and bloodstream, not filtered by the intestine, liver, and pancreas as toxins ingested through food. Studies have shown that due to hormone changes, glyphosate stimulated the growth of breast cancer cells in amounts as low as 0.1 PPT as well as numerous other forms of serious harm.
The detection of glyphosate is also an indicator of the presence of co-formulants in glyphosate-based herbicides which have recently been shown by French scientist Seralini’s team to be endocrine disruptors and to be 1000 times more toxic than glyphosate alone. Glyphosate alone has shown to stimulate the growth of breast cancer cells. (attached)
The initial approval of glyphosate-based herbicides was innately flawed. The EPA policy only requires testing for the one declared “active” chemical ingredient in a product, not the final formulation. By not requiring or having the full formulation long term safety testing of all chemical combinations in products eaten, used or administered into our citizens the claim that any of these products or chemicals are safe is unfounded, labels are misleading and use is risky. The fact is that none of the pesticides, food, supplements, and now medical treatments, are properly tested or labeled.
At a minimum, our data confirms that an analysis of childhood vaccines for glyphosate should be undertaken immediately by the EPA and FDA. Consumers and physicians should be made fully aware of the likely contamination by this herbicide. Vaccines that contain detectable levels of glyphosate should be discarded. Manufacturers that use genetically modified ingredients and regulators who approve their products should conduct or require independent testing for glyphosate and co-formulants immediately, comprehensively, and responsibly in order to ensure the safety and purity of the products that respectively, they produce and license.
 We urge that the EPA, FDA, and vaccine makers immediately test all batches of all vaccines for glyphosate based herbicides and toxic pesticides and recall contaminated products. In the meantime and until there is a clear scientific resolution of this issue, there must be a moratorium on all and any vaccine mandates, with revocation of such laws where they have already been passed.  No parent should have to knowingly vaccinate their infants and children with a known neurotoxin, probable carcinogen,cardiovascular damaging chemical, or reproductive effector which causes liver and kidney damage. 
We request that the  EPA to do a formal investigation into the widespread contamination and likely harm caused by glyphosate, test for the contamination of pesticides in all consumer products including vaccines, halt the mandate of vaccines. Additionally, we request that the EPA immediately change their policy to require long term full formulation safety testing with full disclosure labeling and revoke the license of glyphosate to prevent further contamination. 
Thank you.
Empowered Moms, Healthy Kids
Editor’s note:  Moms Across America has accumulated a brief library of links to scientific studies on GMOs, glyphosate and other family health issues.
You can see the list of references to Glyphosate on the Moms Across America site, on their page at this link:
Stephanie Seneff
Senior Research Scientist
MIT Computer Science and Artificial Intelligence Laboratory
I am writing in response to the solicitation for feedback regarding the 4-day meeting of a Scientific Advisory Panel to consider and review scientific evidence for the possibility that glyphosate is a carcinogen.  Together with Anthony Samsel, I recently published a paper discussing the carcinogenic potential of glyphosate (Glyphosate, pathways to modern diseases IV: cancer and related pathologies. Anthony Samsel and Stephanie Seneff, Journal of Biological Physics and Chemistry 2015;15: 121–159).  I am convinced from the evidence from the research literature that glyphosate is causal in certain cancers, particularly breast cancer among premenopausal women, prostate cancer, non-Hodgkin’s lymphoma, pancreatic cancer, thyroid cancer, renal cancer and bladder cancer. There is strong epidemiological evidence supporting a link between glyphosate and many of these cancers.

However, my main point in contacting you is to alert you to the potential for glyphosate to be causal in the alarming increase we are seeing today in multiple food allergies and autoimmune diseases.  I now believe that the evidence is overwhelming that glyphosate is the main factor in the epidemic we’re seeing in autism, Alzheimer’s disease, lupus, rheumatoid arthritis, inflammatory bowel disease, chronic fatigue syndrome, and type I diabetes (a partial list), and in the enormous rise in food intolerances in the population, particularly gluten intolerance, peanut allergy, and allergies to casein, soy, and corn.  I believe that all of these autoimmune diseases are on the rise because glyphosate is substituting by mistake for glycine during protein synthesis. Anthony Samsel and I published a “Glyphosate V” paper following the paper on glyphosate and cancer where we detail the devastating consequences of this insidiously toxic and cumulative effect of glyphosate: (Glyphosate pathways to modern diseases V: Amino acid analogue of glycine in diverse proteins. Anthony Samsel and Stephanie Seneff,  Journal of Biological Physics and Chemistry 2016;16:9-46.)

Zen Honeycutt of Moms Across America took the initiative to test several vaccines for possible glyphosate contamination, following my suggestion that the MMR would likely contain glyphosate due to the fact that the live virus is grown on gelatin derived from collagen harvested from pigs and cows fed a heavy dose of glyphosate in their GMO Roundup-Ready feed.  Zen found by far the highest levels of glyphosate in MMR compared to several other vaccines, and Anthony Samsel followed up with more tests which simply confirmed her preliminary results.  Prof. Singh of Utah State University has published a series of papers beginning in 1993 showing a very strong link between autism and autoimmune attack on myelin basic protein, induced by exposure to a peptide sequence in hemagglutinin produced by the measles virus.  It is extremely plausible to me that the vaccine version of the virus grown on collagen is picking up glyphosate and incorporating it into its hemagglutinin protein, which is causing it to resist proteolysis and induce an over-active response by the human immune system.

I believe that glyphosate is by far the worst chemical in our environment today. It needs to be banned immediately if we have any hope for the future of our children.

I attached 7 studies which are found on our website backingup the claims of harm.

Dr. Michelle Perro

Integrative Pediatritian, Marin County, California

I am a pediatrician of 35 years. Of the past 15 years, I have seen a precipitous drop in the health of children. I have studied their gut immune responses as well and their intestinal microbiome and what I learned was shocking.

I have found extremely high levels of antibodies to foods, intestinal permeability and abnormal T and B cell function. Their microbial diversity of their guts is low and overabundance of potential pathogens In addition, there is early evidence of autoimmune markers which a decade ago was rarely found. When I removed glyphosate from their diets, many of their symptoms and findings resolved. Therefore, I was able to surmise that the abnormal findings are linked to glyphosate and its’ associated adjuvants.

I have found glyphosate to act as an antibiotic and a chelator. In particular, I have found extremely low levels of magnesium and zinc as well as other minerals. This significantly impairs neurocognitive development/function.

Both of those minerals are involved in over 200 chemical reactions in the brain alone. Simple corrections of these nutrient issues had significant improvement on school performance (focus), mood lability and sleep.

Glyphosate approval needs to be put on hold. I have studied and clinically treated children for the past decade and without a doubt, ill health is directly correlated to the ever-increasing application of its usage.