4. Ensure all existing research is open and publicly available for peer review by other scientists.

The US EPA, WHO and European Commission directly request studies from the pesticide corporations.

The studies that directly contribute to the section of the evaluations that always end up providing the global populations ADI or RfD - permitted consumption levels of pesticides - are these same studies. 

These studies are usually private, and hidden by commercial confidentiality agreements between Agency and corporation. They are produced either in-house (like many Dow studies for the 2,4-D evaluations) or via a contracted laboratory.

They are not released to a public journal for consultation by other scientists. Other scientists then, are not free to understand the decisions that may have lead to the conclusion that for example, 'these symptoms are not treatment related' or that leads to tumours being dismissed due to 'histopathological' reasons or due to 'historical control data'.

Peer review by other independent scientists is essential to arrive at a common understanding as to whether a pesticide is safe or not. It is a form of 'insurance' to ensure the study fulfils all requirements, alerts us to potential problems, and pushes us on to pursue more science if this is required.

One prominent study in the last WHO glyphosate/Roundup assessment (2004) declared the safe level to be the highest level (1000 mg/kg bw/day), dismissing tumours and sarcomas at the highest, mid range and lowest levels:  'owing to the lack of a dose–response relationship, the lack of statistical significance and the fact that the incidences recorded in this study fell within the historical ranges for controls, these changes are not considered to be caused by administration of glyphosate'. [1]

However as this study is private, public health endocrinologists are unable to understand the science behind these decisions that are taken in the public interest. It is well known in endocrinology science that dose response may not be consistent with endocrine system response. 

Caution - Journal integrity

However it is important to understand that as with organisational integrity, not all journals are equal.  The prominent scientific journal Food and Chemical Toxicology (FCT), recently engaged 'Richard E. Goodman, a former Monsanto scientist and an affiliate of the GMO industry-funded group, the International Life Sciences Institute, to the specially created post of associate editor.' [2]

This journal then went on to retract the only lifetime study of the complete formula of Roundup.  This retraction was based on 'inconclusivity'. Normally journals retract for reasons of fraud or misrepresentation. Seralini went on to republish the study and document the conflicts of interest in another paper.

How is there 'no public interest reason'?

Independent scientists are actively campaigning for these private studies to be made public.  In December 2012 a German court in Braunschweig, Germany decided there is no public interest public interest reason to publish the original industry toxicity studies on glyphosate, the active ingredient in Roundup herbicide, on which the EU approval of glyphosate is based. Many independent scientist believe that the studies are hiding birth defects, tumours and immunopathological disease responses.

The court document noted that: 'protection of the interests of the manufacturers of that substance had to prevail.' ....  'The Secretary General of the Commission concluded that the information requested did not relate to emissions into the environment, within the meaning of Article 6(1) of Regulation No 1367/2006, and that there was no evidence of an overriding public interest in disclosure, within the meaning of Regulation No 1049/2001; in her view, such an interest lay in protecting the commercial interests and intellectual property rights of the glyphosate manufacturers.' ( Case T‑545/11). 


Open peer review in credible journals is the best possible assurance that the studies stand the test of public domain criticism.

In the best interests of the public sector. 

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References:

[1] Page 122 WHO/FAO Glyphosate 2004 Pesticide Residues in Food Toxicological Evaluations

Atkinson, C., Martin, T., Hudson, P. & Robb, D. (1993a) Glyphosate: 104 week dietary carcinogenicity study in mice. Unpublished report No. 7793, IRI project No. 438618, dated 12 April 1991, from Inveresk Research International, Tranent, Scotland. Submitted to WHO by Cheminova A/S, Lemvig, Denmark

[2] Journal retraction of Séralini study is illicit, unscientific, and unethical, C. Robinson. GM Watch.

[3] German court decides public can't see industry toxicity studies on glyphosate. GMWatch report 17 December 2012