It's simple. The corporation selling the product should not Select the safety studies.
The science is skewed. Pesticide corporations are intimately involved with the assessment process and as the registrant or sponsor, are given the responsibility by the regulatory agencies to supply the critical studies these assessment agencies use to establish the safe levels for human exposure. On numerous occasions they have been found to have withheld the truth about the harmful effects of their products.
These agencies only ever use private corporate studies for the critical research that establishes the acceptable daily intake levels (ADI). They hold onto ancient, unpublished studies to maintain high ADI/RfD (permitted levels in daily diets for a lifetime - 60 years). In the last decade pesticide residues on staple food groups have been permitted to increase, massively. Multiple applications of different products on the one plant has increased massively. When new assessments are conducted, these agencies still manage to only consider science solely selected and supplied by the agrichemical industry - a profound conflict of interest.
A corporations' primary obligation is to their stakeholders, their shareholders. They carry a legal obligation to shareholders to maximise profits. This is naturally, their priority. Pesticide corporations work intimately with the agencies to provide the specific studies that establish the ADI. The ADI level directly impacts product sales.
Regulatory agencies are created from legislation that places the highest priority on protecting the public. Agencies using suboardinate legislation to create rules (regulation and policy e.g. Klimisch) which are inconsistent with the obligations the risk assessment agency is established under, in legislation, referred to as the 'purpose'. When authorities ignore their (fiduciary) obligations, public trust can decline, and they risk becoming irrelevant, or worse, acting illegally.
A higher purpose (founding legislation) should never be subverted by a lower purpose (regulations and policies acting under that legislation). Consider, for example, twenty first century best scientific knowledge (ie. that formulations can cause chronic harm at a biologically - endocrine - relevant level, and responses may be worse at extremely parts per billion, low levels) yet this knowledge has not been adopted in risk assessment (only the active ingredient is tested at milligrams per kilogram and studies are frequently dismissed if there is not a direct dose response pattern) - which relies on 18th and 19th century understanding, and these outdated requirements are embedded in regulatory rules.
Respected public domain scientists have been producing published research for years, that demonstrates how unsafe current pesticide exposure levels are. Yet this independently produced science doesn't appear to be included in the major assessments that are held every 12-15 years. This research usually isn't added to government pesticide information systems in the interim period, either.
Farmers and pesticide applicators trust that government regulators, such as the EPA or EFSA, will consider all science to ensure the product they use on a regular basis is safe. But regulators only consider science supplied by the pesticides organisations (frequently known as the applicant). Regulators ignore recently published science that establish that exposures are unsafe, and frequently use 10-20 year old seller sponsored (corporate paid) studies to establish the AOEL - accepted operator exposure level. Regulators ignore endocrine studies, long term sub-lethal effects, the impact on the gut that can be tied to depression or gastrointestinal disease. Regulators ignore full formulation studies.
Every farmer and applicator knows the full formulation is stronger and more effective. Risk assessment is completely inadequate for those who use pesticides frequently. It's not just the public, farmers trust risk assessment agencies to use the most up to date science to assess the chemicals used weekly.
The current evaluations systems are broken.
- Independent, public domain science demonstrating harm is rarely consulted and often dismissed.
- Residue levels on food and in drinking water accumulate in the body, the environment and water. The amount we eat directly relates to amount of pesticides farmers can spray per hectare.
- Pesticide corporations are in control of the quality of studies that directly affects their sale levels.
- Conflicts of interest are rife within this assessment process - within all the agencies.
- The US EPA, WHO and European Union, are failing in their guardianship and public trust is declining.
Note: The agrichemical industry has consolidated. 6 firms control
RITE: Requirement for Independent Toxicity Evaluations - a framework for establishing a new global system to safely assess pesticides.
Explanation & illustration: glyphosate and 2,4-D assessments reveal a flawed assessment system:
RITE uses the examples of glyphosate (Roundup) and 2,4-D to illustrate the endemic conflicts of interest and flaws within the current assessment sytems. Roundup and glyphosate based herbicides are the most commonly used pesticides in the international food system. While we think of them as a tool for farmers, in the last 20 years their mode of use has changed. Initially, these pesticides were developed to spray out paddocks/fields for future crop use. To 'clean them up'.
Today glyphosate is sprayed ON our staple cereals and on GMO's. This different use pattern has contributed towards accelerated exposure levels. Glyphosate is now detectable in city workers urine on all continents. 2,4-D herbicide is the next pesticide to be added to the GMO herbicide tolerant plants. For the same reason it was used in the Vietnam War - as a defoliant. Sales are projected to explode with consents to grow the product.
All studies that say 2,4-D are not carcinogenic are directly supplied by Dow corporation and the 2,4-D Industry Task Force - pesticide corporations united to provide the studies required by the US EPA, WHO and EU. As are all studies declaring 2,4-D are not neurotoxic.
Originally, Roundup sprayed on genetically modified herbicide resistant Roundup Ready plants was effective at eliminating the weeds. But as weeds grow resistant to Roundup, stronger, in the current system, more effective pesticides are required.
Click here for an excellent explanation of why the European court of justice was correct in August 2018 - in the public interest - to act precautionarily and regulate the new generation of genetic engineering techniques as genetically engineered crops.
This next generation of 'stacked' GMOs - the 2,4-D Ready GMO can tolerate (ie. is resistant to) glyphosate, 2,4-D and glufosinate - together. These stacked plants have the potential to have the highest residues of any food ever served to humans before. Dicamba, a close relative to 2,4-D, is also in the pipeline.
But agency tests have never looked at the cumulative effects, at the effects to the gut, the immune system & the low dose effects of the endocrine system (and this is not all). They never assess how these pesticides affect the soil and nutritional makeup of the food we eat - there are massive data gaps - this is why there is so much debate regarding glyphosate and Roundup. Why scientists and individuals are concerned about the pending use of 2,4-D on our food and the excessive use of Roundup.
The current assessments are not safe because they're not independent.
Roundup and 2,4-D are an integral part of the story of pesticides.
Regulatory, risk assessment agencies must replace opacity and 20th century guidelines with transparency and 21st scientific advances, and put the rights of the developing foetus, the infant, the child first to protect the future, or else facing the challenge of being irrelevant to 21st century environmental and health challenges.
We need scientific independence & transparency. RITE demonstrates that this is a world wide problem.