By Claudio Lowy
The reasons why the classifications proposed by the WHO are not reliable are many and varied. Here I limit myself to expounding some of them, in my opinion the most important: the WHO itself says that the classification has no guarantees of any kind and that it is not responsible for the damages derived from its use, it specifically states that the classification criteria they are only a complementary guide and reference their classification in outdated and biased research, concluding that pesticides are much less dangerous to health and the environment than they really are.
Argentina: The transgenic soy discourse
Part 1: Agrochemicals: Why World Health Organization Studies Are Not Enough To Take Care Of People's Health
They are not enough because the WHO itself says that they have no guarantee, clarifies that the classification criteria are only a complementary guide and because they are based on outdated and biased research.
The transgenic soy discourse
Today there are two agri-food systems in conflict:
- On the one hand, the extensive monoculture system with agrochemicals, of which the transgenic system is only the last link.
- On the other hand, the system that integrates family agriculture, the peasant way and the different agro-ecological systems, which has enterprises that are sustained despite the systematic attacks they suffer, and is in permanent formation, articulation and growth.
The objective of these writings is to show the lies, deceptions, concealments and distortions of the discourse of those who promote and / or benefit from the extensive monoculture system with agrochemicals, including transgenic, which just for short is called here " transgenic soy speech ”. In this first text I develop one of the main ones related to the approval and classification of agrochemicals. The analysis of the approval and classification of all the pesticides used far exceeds this work, so I focus only on some general and other specific ones referring to glyphosate, which is the pesticide that is used the most on the largest surface and affects the more people.
Why analyze the WHO classification of agrochemicals
Analyzing the way in which the WHO categorizes agrochemicals in general and glyphosate in particular is very important because the resulting classifications, and those derived from them, are used by public and private institutions for various purposes:
- By the National Government, through the Ministry of Agriculture, Livestock and Fisheries of the Nation, more specifically the National Service of Agrifood Health and Quality (SENASA), to justify the approvals and classifications of pesticides.
- By the provincial and local governments to elaborate the norms that regulate the application of pesticides, especially regarding the determination of the free distances of aerial and terrestrial spraying around the places where people develop their life, and the corresponding controls.
- By agricultural producers and producers and marketers of agricultural inputs, as well as the associations that group them, such as CASAFE , ACSOJA  and CIAFA , to promote and disseminate in society and put pressure on public bodies arguing that pesticides applied massively do not harm health and the environment.
Why are WHO reports and classifications not enough?
The reasons why the classifications proposed by the WHO are not reliable are many and varied. Here I limit myself to expounding some of them, in my opinion the most important.
1. Because the WHO itself says that the classification has no guarantees of any kind and that it is not responsible for any damages arising from its use.
At the beginning of the WHO publication "Classification of pesticides recommended by WHO according to their dangerousness and guidelines for classification: 2009", then WHO (2009) says:
… The published material is distributed without warranty of any kind, either explicit or implicit. The responsibility for the interpretation and use of the material rests with the reader. In no case will the World Health Organization be responsible for damages derived from its use.
The text is clear: WHO recommends but is not responsible for the consequences of what it recommends.
Further reaffirming the responsibility of the enforcement authority (in our case the Ministry of Agriculture, Livestock and Fisheries, and more specifically SENASA), the report says:
The specific precautions necessary for the use of a pesticide depend on the nature of the formulation and the pattern of use; and they are best decided by a pesticide registration authority when it accepts a trade label.
2. Because the WHO specifically states that the classification criteria are only a complementary guide.
In WHO (2009) a text extracted from the proposal that was approved by the World Health Assembly in 1975 is rescued, which includes the following paragraph:
The classification criteria are a guide to complement but never to substitute for special knowledge, sound and informed clinical judgment, or experience with a compound.
The Ministry of Agriculture, Livestock and Fisheries of the Nation and SENASA should especially take into account the knowledge of the doctors who care for the population affected by the use of pesticides. They have been spreading numerous and detailed reports for several years that show the advance of diseases such as cancer, spontaneous abortions and congenital malformations associated with the increase in spraying. Many of these reports are contained in the report of the 1st Meeting of Medicines of Fumigated Peoples held at the Faculty of Medical Sciences of the National University of Córdoba in August 2010 .
It is clearly a special and well-founded knowledge that should not be replaced by the classification criteria of the WHO, as indicated by that same institution for more than 35 years.
3. Because the WHO references its classification in outdated and biased research, concluding that pesticides are much less dangerous to health and the environment than they actually are.
This is delicate and requires more development, so I ask the reader for a little patience. In the introduction to WHO (2009) there is a paragraph that states:
The World Health Organization has taken all reasonable precautions to verify the information in this publication.
What it doesn't say is that the information it uses is absolutely skewed and out of date; and that this out-of-date is part of the bias, since it is precisely the studies subsequent to those considered, carried out by independent researchers, that mainly show the damage to health that glyphosate produces, in this case.
Any reader of OMS (2009) assumes in good faith that it is referenced in an updated form. However, the work cites for the classification of glyphosate "Environmental Health Criteria: 159 Glyphosate" , publication of the International Program on Chemical Safety, World Health Organization, 1994, then WHO (1994)  , . This report is not based on trials by the institution itself but on studies and research conducted by third parties.
Let's see when and who did those jobs.
a) Reference to outdated works.
The most up-to-date works cited in WHO (1994) are from 1992, which implies that WHO 2009 was conducted ignoring at least the research on glyphosate from the last 15 to 17 years. In other words, the most up-to-date WHO report that is used to regulate practices and legislation around the world in general and in Argentina in particular, ignores all the research on glyphosate between 1992 and 2007/9.
To this it is necessary to add that the context for investigators with independent criteria of the companies is particularly hostile, since they must face systematic criticism and discredit from official and private organizations, which mount smear campaigns against them. This was evident, among many others, in the perhaps best known cases of Gilles-Eric Seralini in France and Andrés Carrasco in Argentina.
These works show the link of glyphosate with multiple toxicological damages, ranging from cancer to congenital malformations, including allergies; enzyme malfunction; the affectation of the energy metabolism of the mitochondria, which puts cell survival at risk; spontaneous abortions; hormonal disruption, with concentrations much lower than those that can even be ingested with the consumption of foods of transgenic origin from vegetables treated with these products.
The list of those jobs is very long, and deserves detailed research and a report in itself. Those who want to have an idea of them can consult, for example, Lapolla (2010) , Carrasco (2009) , Kaczewer, J (2002) .
There are also several studies on glyphosate ecotoxicity, of which I am particularly interested in pointing out those carried out by national research centers in Argentina, such as the national universities of Litoral and Luján, and those developed through the articulation of knowledge, work and the resources of various centers (see Annex). These works are ignored in the classification made by the WHO and not considered by SENASA, despite being special and well-founded knowledge.
b) Who carried out the works cited by WHO.
The reports referenced by WHO (1994) are not only out of date, ignoring most of those that demonstrate the actual toxicity of glyphosate, but are also based mainly on work supplied by companies interested in the production and marketing of the product and its formulations. For example, 180 were made and / or supplied by Monsanto.
More than 150 of the cited reports were unpublished, meaning they were not peer-reviewed or reviewed, of which a hundred were provided by Monsanto.
Many of the other referenced works were also provided by other companies that produce and commercialize the product and / or its formulations, and were not published, such as the 17 by Agrichem B.V., a producer and marketer of pesticides based in the Netherlands; the 5 from Luxan B.V., also from the Netherlands, or the 5 from Rhône Poulenc.
These reports are not used in a complementary way, as might be expected, but as the main information in the considerations used for the classification. Suffice it to cite a couple of examples. The unpublished report identified as Monsanto 1990a  is cited twice to justify glyphosate dissipation considerations, and Monsanto (1988a)  twice in reference to methodological issues and metabolic transformations.
c) Other reasons.
There are other reasons for not considering the WHO classification sufficient to protect the health of the population and the environment from the damage caused by agrochemicals. For example, the classification is based mainly on acute oral and dermal toxicity to the rat, considering that these determinations are the standard procedures in toxicology, and leaves out in principle chronic toxicity and sublethal toxicity . On the other hand, the procedures for forming the teams responsible for choosing the studies to be used as a reference, their analysis, evaluation and preparation of the final considerations and classification are not disclosed.
FAO / WHO 2004
Another frequently cited by proponents of glyphosate use is the 2004 JMPR Report  of the FAO / WHO Expert Meeting .
It should be noted that this is not a scientific report, because it cannot be subjected to peer criticism. In its 383 pages, it does not refer to the conclusions it reaches, that is, it does not say on which works it is based to draw the conclusions, so it is not possible to know which ones it considers and which ones it does not. This implies that it is ignored if the conclusions reached are reasonably supported by research, who carried out the research, what methodology he used, and whether or not he had independent judgment.
On the other hand, in the introduction it recognizes that: "Most of the summaries and evaluations contained in this report are based on unpublished works of private property presented to the Committee to make the evaluations."
This paragraph shows that the Committee recognizes that the works on which the evaluations are based are privately owned; most likely from the companies that produce and market these products, or are linked to them.
Furthermore, the document does not propose classifications of agrochemicals.
These are the reasons why this report is not analyzed in this text. What happens is that their conclusions are often distorted by the transgenic soybean discourse. These and other misrepresentations will be analyzed in a future work.
Classification and fumigation-free distances
WHO classifications should not be used as the sole basis for setting pesticide spray-free distances.
The WHO is not responsible for its recommendations, it says that the classification should be considered as a complementary criterion of clinical and special knowledge, it uses biased and notoriously outdated studies, and it also specifically states that:
The hazard referred to in this Recommendation is the acute risk to health that may be accidentally encountered by anyone who handles the product in accordance with the instructions indicated by the manufacturer or in accordance with the standards established for storage and transport. indicated by the competent international organizations.
Nowhere does it say that these classifications are made to protect the general population.
In fact, one of the two final recommendations of WHO (1994) states:
A study of the basket of pesticides sold in the market would be useful to determine the possible exposure of the general population
At least two things can be said about this recommendation:
- In 1994, the WHO recognized that it is not known what harm pesticides cause to the general population.
- After 13/15 years of having made this recommendation, the WHO does not refer to any study on the dangers to which the general population is exposed, despite the massive increase in the use of pesticides in general or glyphosate in particular .
Due to the above, it is unacceptable that the WHO agrochemical classifications, nor those derived or related to them, or those that were carried out with related procedures, are used as the main criterion to set the distances free of pesticide sprays.
Legislators who develop standards for pesticide spray-free distances should primarily consider the special knowledge of independent judgmental local researchers and physicians in affected populations. Classifications such as that of the WHO that we are analyzing should be taken into account only in a complementary way, applying in all cases the precautionary principle to protect the health of the population and the environment.
Buenos Aires, February 7, 2011.
Claudio lowy - Forest Engineer - Master in Sustainable Human Development
Annex: Some ecotoxocological research on glyphosate in Argentine academic settings
- Cassano, Alberto, Consultant Professor at UNL. Senior Researcher Emeritus of Conicet, points out that serious studies carried out most of them at the National University of the Litoral and subjected to international criticism on tributaries or direct waters of the Paraná, indicate their proven toxicity in various natural aquatic environments.
- Lajmanovich, R., Lorenzatti, E. Maitre, M.I., Enrique, S., Peltzer, P., 2003. Comparative acute toxicity of the commercial herbicides glyphosate to neotropical tadpoles Scinax nasicus (ANURA: HYLIDAE). Fresenius Env. Bulletin, 12, 364-367.
- Pérez, GL, Torremorell, A., Mugni, H., Rodríguez, P., Solange Vera, M., do Nascimento, M., Allende, L., Bustingorry, J., Escaray, R., Ferrara, M. , Izaguirre, I., Pizarro, H., Bonetto, C., Morris, DP, Zagarese, H., 2007. Effects of herbicide Roundup on freshwater microbial communities: a mesocosm study. Ecol. Appl., 17, 2310-2322.
- Polleta, G.L., Larriera, A., Kleinsorge, E., Mudry, M.D., 2009. Genotoxicity of the herbicide formulation Roundup® (glyphosate) in broad-snouted caiman (Caiman latirostris) evidenced by the Comet assay and the Micronucleus test. Mutation Res., 672, 95-102
- Fernando Momo, Dr. in Biological Sciences and researcher at the National University of Lujan, in his writing "Harmful effects of glyphosate on the health of human beings and the environment", cites the works where the important toxic effects of glyphosate on earthworms, decreasing their number and the fertility of their eggs, and can affect soil fertility in the medium and long term. It points out that the product, and especially its commercial formulations, cause damage to ecosystems, causing a decrease in their diversity, an alteration of their material and energy flows, a dramatic decrease in some populations and an irreparable loss of various ecosystem services.
- Effects of the herbicide Roundup on freshwater microbial communities: a mesocosm study. Pérez, G.L. (1,5), Torremorell, A. (1), Mugni, H. (2), Rodriguez, P. (3), Solange Vera, M. (3), do Nascimento, M.3, Allende, L. (3), Bustingorry, J. (1), Escaray, R. (1), Ferraro, M. (1), Izaguirre, I. (3), Pizarro, H. (3), Bonetto, C. (2 ), Morris, DP (4), and Zagarese, H. (1) (2007) - Effects of the herbicide roundup on freshwater microbial communities: a mesocosm study. Ecological Applications, 17 (8), 2007, pp. 2310–2322 - 2007 by the Ecological Society of America
1) Institute of Biotechnological Research, Technological Institute of Chascomús (Intech), CONICET, Camino Circunvalación Laguna Km. 6, CC 164, 7130, Chascomús, Argentina.
2) Dr. Ringuelet Institute of Limnology, Avenida Calchaquí Km. 23.5, 1888, Florencio Varela, Buenos Aires, Argentina
3) Department of Ecology, Genetics and Evolution, Faculty of Exact and Natural Sciences, University of Buenos Aires, Buenos Aires, Argentina
4) Department of Earth and Environmental Sciences, Lehigh University, Bethlehem, Pennsylvania 18015 USA
- Ecotoxicological evaluation of Glyphosate and Chlorpyrifos in an Argentine soybean field. Casabé N, Piola L, Fuchs J, Oneto, ML, Pamparato L, Basack S, Giménez R, Massaro R, Papa JC, Kesten E (2007): Ecotoxicological Assessment of the Effects of Glyphosate and Chlorpyrifos in an Argentine Soya Field. J Soils Sediments, DOI: http://dx.doi.org/10.1065/jss2007.04.224
 Chamber of Agricultural Health and Fertilizers
 Association of the Argentine Soybean Chain
 Chamber of the Argentine Industry of Fertilizers and Agrochemicals
 Environmental Healt Criteria 159 Glyphosate; Geneva, International Program on Chemical Safety, 177pp. 1994.
 Published under the joint sponsorship of the United Nations Environment Program, the International Labor Organization and the World Health Organization.
 He also cites the "FAO / WHO Pesticide Data Sheet" No. 91, corresponding to Glyphosate, July 1996.  As the most up-to-date reference of the latter is the previous publication, I only analyze the one contained in “Environmental Health Criteria 159: glyphosate”.
 Lapolla, A. J. (2010) - The 52 million tons of transgenic soy and the ethics of scientists and Agricultural Engineers.
 Carrasco, A (2009) - Effect of glyphosate on the embryonic development of Xenopus laevis (Teratogenesis and glyphosate) - Preliminary Report.
 Kaczewer, J (2002) - Glyphosate Toxicology: Human Health Risks.
 Monsanto (1990a) Dissipation of glyphosate and aminomethylphosphonic acid in forestry sites. St. Louis, Missouri, Monsanto Ltd (Unpublished report No. MSL-9940).
 Monsanto (1988a) Metabolism of glyphosate in Sprague-Dawley rats. Part II. Identification, characterization, and quantitation of glyphosate and its metabolites after intravenous and oral administration. MSL-7206).
 See Agrochemicals: Infamous Standards
 Joint Meeting of the Expert Group on Pesticide Residues in Food and the Environment
 Report of the 2004 JMPR FAO / WHO Meeting of Experts
 A market-basket survey would be useful to determine the possible exposure of the general population.