3.  Accept research by organisations financially independent from the final risk assessment decision and rapidly move towards a system in which all the testing is done by such independent organisations.

The new independent Agency would contract independent laboratories, or manage its own toxicologists in an Agency laboratory for the purpose of conducting independent research.

[a] Current research proving pesticide safety held by the Agencies is corporate owned & private.

The current evaluations of the pesticides Roundup and 2,4-D by the WHO, US EPA and European Commission demonstrate standard Agency practices. All critical scientific studies that advise permitted residue levels are supplied by the same corporations that produce and sell the products.

It is from these studies today's ADI/RfD is taken which provides the daily residues the human population is permitted to be exposed to, on a daily basis, for the rest of their lives.

There is a direct connection between the ADI/RfD and quantity sprayed per acre, and therefore sales.

Eg. Roundup Pesticide: The critical studies forming the core of current assessment - the long term, acute toxicity and carcinogenicity and reproductive and development - are supplied by Monsanto, Cheminova and Syngenta.

Eg. 2,4-D:  All studies proving safety that provide the daily level of exposure, the ADI/RfD are provided either by Dow or 2,4-D Task Force, an industry coalition comprising corporations with interest in the production of 2,4,-D including Dow corporation.

In addition, corporate studies form the core of research in cancer assessments.

European legislation (Regulation 1107/2009) states that all literature, including independent studies (i.e. science financially independent of private interests), now need to be taken into account when the EU Commission and EU member states (MS) discuss whether to approve a pesticide for sale. Unfortunately when industry submits the studies, they remove independent studies because they are not 'relevant and reliable enough to be used for decision-making,' generally because they were not performed according to OECD-test protocols (including Good Laboratories Practice, GLP). A guideline of Food Authority EFSA showed industry the way for dismissing these independent studies. Yet independent scientists regularly find risks likely because of the more sensitive methods of detection used.' [1]

Lists of corporations providing research for the neonicotinoids here.


[b] The changing face of university research.

Traditionally, research coming out of universities as public domain, peer reviewed science was considered conflict free and trustworthy.

Unfortunately today a substantially higher proportion of research is tied to corporate funding grants - in the USA these corporate grants for funding exceed the USDA grants to universities.  Scholars hands are tied. [2] [3]

Future risk assessment for pesticides must take this altered funding model into account.

[c] How Good Laboratory Practice works against true safety.

GLP in its present form put was together by the USDA and since then the OECD has promoted it and developed it alongside ‘Test Guidelines’ and helped get it in lots of country’s regulations. Please note the OECD is all about development and trade, and NOT science.

Good Laboratory Practice has nothing to do with rigorous scientific testing for toxicity of chemicals.

In fact it is only ever the registrant (the chemical company) that is asked for studies in the first place.  Never public domain science – independent science.  And when independent scientists try to provide studies, they are rejected often because they do not use this protocol: ‘Good Laboratory Practice’, a narrow, tick the box industry approved data quality system.  A laboratory management system.  To prevent fraud.  A system that hitches its wagon to an OECD test guideline system that has nothing to do with identifying sensitive results for safe risk assessment, that public domain science often finds.

“This criterion effectively excludes most independent (non-industry sponsored) studies from consideration, since only industry studies are done according to GLP. GLP is not a hallmark of good or reliable science: it is a laboratory management system invented for the purpose of preventing fraud in industry studies conducted for regulatory purposes. Researchers operating independently of industry consider GLP to be irrelevant to their research – and thus too expensive in terms of labour hours to implement without good reason. Crucially, at no point have regulators informed independent scientists that their study is considered unreliable for not using GLP.” [4]

And for many scientists working in the public sector results happen all over the place, but GLP doesn’t really allow for that to happen.  So public sector scientists don’t use it. They want true results.  And the results from scientific studies can be messy, difficult to comprehend, and inconsistent.

Illness can derive from delicate responses to subtle chemical effects.

Independent research searches for causation (and therefore prevention) more thoroughly than corporate owned studies ever can.


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[1] Missed & Dismisssed: Pesticide Regulators Ignore the legal obligation to use independent science for deriving safe exposure levels. Pesticide Action Network Europe and Generation Futures. September 2014.

[2] Food & Water Watch: Public research, private gain. Corporate influence over university agricultural research. 2012.

[3] Salon.com.  Monsanto's College Stranglehold. 

[4] Bekelman JE, Li Y, Gross CP. Scope and impact of financial conflicts of interest in biomedical research. JAMA  2003; 289:454e65.