Government chemical regulators responsible for ensuring public safety traditionally undertake:
(1) Hazard assessment - a chemical's potential to cause adverse effects to different body systems eg. neurotoxicity, carcinogenicity, reproductive and developmental toxicity; and
(2) Risk Assessment - the likelihood the hazard will occur based on specific exposures (what level of substance can be absorbed or consumed each day before adverse effects occur).
When we visit the beach with a toddler, hazard is constantly present. The likelihood of surviving being swiped by a wave and dragged out to sea, presents a varying level of risk. Parents at the beach become surprisingly alert risk managers. Sugar is another example. In recent years scientific literature has identified sugar as much more hazardous (toxic) than previously recognised, affecting multiple pathways (brain, liver, hormonal system). Science is also recognising smaller doses than previously recognised present risk, particularly to children.
Trust in government - a fiduciary duty to protect citizens from hazardous chemicals
Senior government decision-makers appear to comment off-handedly that if the herbicide glyphosate is probably carcinogenic as rated by the International Agency for Research on Cancer, it is as risky to the public as hairdressing or nightshift.
They avoid or ignore the fact that undeclared chemicals in staple foods, like lighting up a cigarette in a car with a toddler looking balefully at you in the rear-view mirror, constitutes an unavoidable exposure.
Risk is always dependent on the circumstances of the exposure. In a child, an adverse effect may happen at lower doses, may cause greater harm in later life than for an adult. Frequently scientists are finding that the lower our technologies enable us to investigate, the lower we find harm occurring.
Most of these government decision-makers operate under legislation that legally requires that they consider vulnerable groups such as pregnant women or children. Babies and children do not work nightshift. By ignoring their duty to take this fact into account, decision-makers are potentially misleading the public, or acting illegally, or both.
Trust in responsible governance requires that these vulnerable groups are not exposed to a probable carcinogen. For government agencies to turn around and say, but a little bit is fine, inspires the question - how much?
A little bit of each of the probable carcinogens on the Wikipedia page is fine? Because cumulative toxicity is, well, a 'thing'. Low level adverse endocrine disrupting exposures is also a 'thing'. And of course, the 'thing' regulators never talk about - the complete pesticide formulation that includes other (commercial in confidence) chemicals in the formulation to create patentable toxic synergies, is also a, 'thing.'
In relation to glyphosate, a herbicide formulation sprayed on food crops, the IARC conducted a hazard assessment in 2015 to understand whether glyphosate, but also the retail formulation, and breakdown products, could cause cancer. The IARC limited scrutiny to published and publicly available studies (whether laboratory or real world, epidemiological studies) concerning cancer and glyphosate. IARC concluded that glyphosate, the formulation sold in shops, and the breakdown product that persists in the environment (AMPA) are all probable carcinogens. It also concluded, that, because there were more animal studies, glyphosate caused cancer in animals.
Public health - act with precaution & protect the most vulnerable in society
If we consider the public interest, Europe is a linchpin here, as European legislation directive 1107/2009 requires that if a chemical is probably carcinogenic to humans it cannot be sold.
This is hazard based legislation – it is precautionary, and considers that exposure at any level constitutes an unreasonable risk to the European population.
Europe is the wealthiest continent, with the greatest public funding for health and wellbeing. It considers prevention an integral part of public health management. European legislation considers that precautionary health based decisions best serve the publics’ interest. Thus Europe appears to have a higher bar in order to protect the public. This is also why Europe is at the forefront of decision-making (and controversy) surrounding glyphosate.
If we come back to the massive list of probable carcinogens, a logical mind will commence calculating small permitted exposures and quickly arrive at the undeniable fact that the precautionary principle and restriction at any level is the only sane solution, when faced with a mountain of chemical exposure of varying complexity.
Only the greatest amount of cognitive dissonance could push those thoughts away, dismiss any notion of complex system dynamics and the vulnerability of a 6 month old starting on solids. (Which is why Roundup should not be sprayed on food crops before harvest).
Regulators including the US EPA, NZ EPA, EFSA and WHO-FAO claim that they take into account the likelihood of exposure. Thus they consider toxicity studies (hazard) and then look at potential exposures (evaluate risk).
But they don't for babies and they don't for kids. They don't even dose the pregnant mum in the first trimester to see if a baby might be harmed developmentally over this period. They don't think about the toxicity of the full formulation, and their decisions are dependant on industry science. And most of these regulators appear to think the precautionary principle should be adopted when they are 95-100% certain - instead of when they should - when spraying Roundup on wheat and oats could lead to 'morally unacceptable harm that is scientifically plausible but uncertain.'
Yet because Europe’s legislation specifically says that a probably carcinogenic chemical or substance must not be exposed to the public, it is hazard based. There is no ‘acceptable level’ that a probable carcinogen can be poured on food crops and sprayed in public parks. Latter risk assessment becomes obsolete.
Government decision-makers must have courage to act with integrity and place the public interest first, or face increasing distrust in the public sector.
Regulatory risk assessment currently has severe deficits that are impacting public health trust:
- Full formulation toxicity is not considered by NZ EPA, US EPA, WHO-FAO, EFSA (despite being in legislation - this is because industry supplies the studies for assessment and they are usually active ingredient only).
- Combination of adverse synergistic hazard from different pathways (neurotoxic, endocrine, carcinogenic etc) is never considered
- Gives weighting to serious endpoints (eg.mutation) rather than placing priority on sensitive endpoints that are hallmarks of disease (eg. Oxidative stress)
- IARC considered many tumour incidences highly significant, whereas they were dismissed by regulatory agencies
- Ignores greater vulnerability pregnancy, with infants, children and teenagers.
- IARC used published and publicly available data whereas regulatory agencies used data and evaluations directly supplied by the industries dependent on a positive outcome.
- Industry selects and supplies data for assessments