6. Seek to create an independent, publicly managed organisation, with international authority to oversee independent public interest research for toxicology and risk evaluation.
(With no liability to pesticides organisations for its decisions).
How to do this?
- Work with the smartest people in diplomacy, science and organisational politics.
- Work with people free from ties to pesticide corporations and agribusiness.
- Create an ethical framework that will work to prevent organisational loopholes and respond to new challenges.
- Locate it in a country recognised for integrity, transparency and good science.
- Allow it to grow and flourish in the interests of global welfare with constant monitoring from external independent organisations such as Transparency International.
The complexity and detail required to safely assess and evaluate chemicals including pesticides, far exceeds the capacity of individual countries.
The World Health Organisation and the (industry allied) Food and Agriculture Organisation carry out internationally focused JMPR toxicological evaluations, yet restrict themselves to decision-making from data primarily supplied by industry, resist considering full formulation toxicity and have been criticised for maintaining close industry relationships that could impact independence of the assessments.
Yet it appears that even the wealthy European Commission is daunted by the resources involved in assessing chemicals.
'much of the German government’s recent evaluation of glyphosate - favourably compared to the IARC’s evaluation by the agrochemical industry - was not actually written by scientists working for the German Federal Institute for Risk Assessment (BfR), but rather by the European Glyphosate Task Force, a consortium of agrochemical firms.
BfR officials explained that due to the quantity of evidence they did not have the time to report the original studies in detail, but instead based their evaluation on descriptions provided by the agrochemical industry. But those descriptions also contained the industry’s assessment of the reliability and interpretation of each study, which involves exactly the kinds of choice-laden decisions described earlier. BfR regulators commented, in italics, on the industry text, but this falls well short of what most people would understand as an independent review.
We do not know if the BfR evaluation is unusual in having been drafted by the firms whose products were being evaluated, or unusual because German regulators were honest enough to make that practice explicit. But if one of the world’s wealthiest nations does not have sufficient resources to conduct its own independent evaluations of toxicological evidence we might well ask what are the practices in regulatory institutions elsewhere?'