Imagine if the most important stakeholders were public health professionals & environmental experts.

8.  Underpin effective & safe risk assessment with sound stakeholder representation comprising consumer organisations and NGO’s focused on public health and the environment.  Eg. Embryologists, endocrinologists,  epidemiologists, neurodevelopmental experts, ecologists and soil biologists.

Today, the WHO, US EPA and the European Commission place more emphasis on corporate paid studies directly supplied from the pesticide corporations than they do on public domain research. These assessments rely on a narrow range of inside experts that have been demonstrated to maintain close relationships with industry. Industry may even ghost-write published research papers and assessments.

Decisions as to toxicity are made within these agencies and very few, if any, public health professionals are consulted. Guidelines and protocols adopted within regulatory assessments are slow to adapt to new knowledge. Frequently meetings to alter guidelines are more heavily stacked with industry than public health professionals. This may reflect the stress on academia and lack of comparative resourcing.  

This bias results in lag, delaying adoption of new scientific understanding and limiting the capacity to evaluate data in the public interest.

Apparent industry capture of regulatory agencies is evident in the extensive reliance on industry to supply and then evaluate data; the refusal to acknowledge greater toxicity from commercial product synergies, and the exclusion of experts who can offer experience and offer new insights into pathways to disease - particularly relating to low-dose, environmentally relevant exposure that may harm a developing endocrine system.

Health

Wide ranging enquiry to facilitate transparency and enable consideration of potential downstream impact:

  • Endocrine specialists to investigate commercial formulation, multi-system effects, particularly effects on feedback loops of chemical mixtures
  • Lags arise from latency to adopt new scientific knowledge e.g. non-linear low-dose effects are not accepted, yet widely used in modern medicine
  • Experts required to assess intergenerational harm 'transgenerational epigenetic effects' resulting from prenatal exposure that affects how DNA works (rather than actually harming or changing/mutating actual DNA) and act to minimise long term health problems decades into the future.
  • Prenatal, post-natal, childhood and adolescent vulnerabilities (including neurological, endocrine harm that may impact future disease) remain unexamined.
  • Academic enquiry into the environmental origins of disease is poorly funded in comparison to research concerning genetic origins of disease, yet the greatest explosion in disease today appears environmentally mediated and may directly relate to both toxicity exposure and nutrient deficiency.
  • Co-morbidity - the potential for multiple diseases to co-exist and the greater cost and stress placed on the population is not considered.
  • Economic cost - disease costs form a relatively unconsidered sector of economic analysis and may place a significant burden on taxpayers. Endocrine disruption causing disease and disability from chemicals in Europe and the USA is estimated to directly affect regional budgets.
  • De-siloise Health: Increase public funding to encourage experts and academics to research cross-system chemical-mediated health based effects

Water & Environment

Unpublished corporate paid science is extrapolated by the Agencies, the WHO, US EPA and the EU to establish recommended drinking water levels. Regulators narrowly consider toxicity, yet the potential for unintended downstream effects that may not be reversible in a human lifetime is considerable.

The effects of pesticides in drinking water and ecosystems are long term.  The most common pesticide in the world, Roundup, is largely impossible to extract from drinking water and its lifetime is known to be longer than previously considered by regulators. 

The pragmatic advice of independent advisers directed towards the large agencies gets lost, ignored or dismissed. Scientists call to follow the precautionary principle rule is quietly dropped.

Wide ranging enquiry to enable consideration of potential downstream impact:

1. Science is documenting buildup of pesticides and their breakdown products (metabolites) in surface and groundwater.

  • Is modelling is being carried out to understand the increasing rate of buildup in groundwater, acknowledging degradation sans sunlight may be slower?
  • Is modelling being carried out to understand buildup in drinking water of common pesticides groups that act the same way on human biology? (eg. common organophosphates, azole groups)
  • Is modelling being carried out to estimate the role of adjuvants and their breakdown capacity in water sources?
  • Is modelling being carried out to understand impact and degradation for aquatic cellular life from synergies of multiple chemicals at low doses

2. Soil quality - Effects to soil and plant systems are more complex and have long term adverse ramifications

  • Pesticide tolerant weeds continue to evolve at an alarming rate, replacement products may be more toxic and result in continued tolerance
  • Continued depletion & microbial death of soils has been related to pesticide use -  soils depend on healthy micro-organisms to maintain soil balance, retain nutrient levels, enable plant uptake of nutrients and grow shelf-stable healthy food. 
  • Breakdown of organic matter is reliant on healthy bacterial/microbial and insect populations in soil. Carbon content in soil is connected to drought resistance.

Public Health

Endocrinologists
Paediatricians
Neurologists
Oncologists
Toxicologists
Thyroid specialists

Environment

Soil health
Biologists
Pollinator groups
Waterways
Aquifer management
Fisheries

Animal

Veterinarian
Animal research
Ornithologists

Requirements of public health stakeholders, not the demands of private shareholders- must be at the core of international decision making for pesticide safety. 

Independent stakeholders make independent decisions.

We forget that the water cycle and the life cycle are one.
— Jaques Cousteau