By Ing. Claudio Lowy, Lic. Silvana Buján, Tec, Eduardo Rossi
The WHO announced that an ad hoc working group will be formed to analyze whether glyphosate is carcinogenic or not. But the WHO's response leaves us with more concerns.
When we ask who will be the experts that will make up this special working group? By what criteria will they be selected and who will be responsible for such selection? And will the experts have territorial representation and the different schools of thought? the answer says that “they were selected from the WHO list of experts in toxicology and epidemiology. The requests were reviewed by an independent referee from the Organization and by the JMPR Secretariat ”(Joint FAO / WHO Meeting on Pesticide Residues)
That list lists 13 experts from North America, 15 from Europe, 4 from Asia, 2 from Oceania, 1 from Sub-Saharan Africa. There are no representatives from North Africa, Latin America, or the Caribbean. It is unknown how the call for the list was made, but it does not comply with the requirement of territorial representation. But the worst thing is that the JMPR that reviews this process is the one that classified glyphosate as non-carcinogenic! In fact, in the 2011 JMPR published report on pesticide residues in food the chapter on glyphosate was prepared by the Center for Substances and Integrated Risk Assessment, National Institute of Public Health and Environment of the Netherlands  . Precarious reference, since it is a first draft, it is not a peer-reviewed work, therefore, it is not a scientific work. This scientific precariousness increases by referencing a total of only 28 bibliographic citations of unpublished reports, of which 21 are reports made and / or provided by the DuPont corporation, and 7 are made and / or provided by the Monsanto corporation. In addition, the ad hoc group is made up of the members of the JMPR group, which said that glyphosate was not carcinogenic, and a single expert from the IARC group, who classified it as group 2A probably carcinogenic, of five classes, the second most dangerous.
The group does not include experts who represent the concerns of agroecological and family producers, rural workers, consumers, populations that suffer from the drift of the evaluated pesticides, nor of the doctors who treat them, nor of environmental organizations. that have caused the damage that these products are causing for many years. The WHO response states that “The call to join the expert group… is online:
www.who.int/foodsafety/areas_work/chemical-risks/etc_final_new_1.pdf?ua=1 ... which is not true ...
When we ask whether the experts will be independent or represent companies and corporations, the answer says that "Each expert must make a statement of interest in writing." Should we understand that you have to believe his affidavit without further ado? No one will check?
We are not answered on the place and date of the meeting of the special working group, the site with the references indicates that the consultations will be by correspondence; and it is not reported what precautions will be taken so that companies do not pressure the group of experts and the organizers.
In addition, the WHO claims to convene experts who have passed through the International Life Sciences Institute (ILSI), well known throughout the world for being financed by transnational companies, mainly agro-biotechnology, such as Monsanto, Cargill, Syngenta, Daw Chemicals. And it calls on experts who direct the pesticides area of the Federal Institute for Risk Assessment (BfR) in Germany, in which members of the agrochemical companies Basf and Bayer participate.
In summary, we are more concerned than before, because either information is hidden, or the information that is granted generates more distrust, since it confirms the enormous influence that chemical corporations exert on the institutions that should protect us.-
- the full reply to WHO with its references.
- The original note requesting information, which can be taken as a model for other citizens to ask in turn.
Ing. Claudio Lowy (BIOS - RENACE) [email protected]
Lic. Silvana Buján (BIOS-RENACE) [email protected]
Tec, Eduardo Rossi (Equística) [email protected]
Buenos Aires, September 4, 2015.
Madam Representative of PAHO / WHO
Dr Maureen Birmingham
Marcelo T. de Alvear 684 - 4th Floor C1058AAH
Buenos Aires, Argentina
S / D
Ref: Note received in relation to the request for information on the ad hoc ad hoc working group of WHO experts for scientific divergence on the carcinogenicity of glyphosate.
Of my highest consideration:
On August 24, I received an email in relation to our request for information that I addressed to you on August 7, referring to the formation and operation of the special working group of ad hoc experts of the WHO to express an opinion on the scientific divergence regarding the carcinogenicity of glyphosate, as well as the criteria with which the studies to be evaluated, the studies finally considered and the evaluation will be selected.
Unfortunately, the email signed by Maricel Seeger contains only formal paragraphs, some with information that we were aware of, knowledge that is evident from the content of the report request itself, and paragraphs that confirm and increase our concerns about the lack of impartiality with the that the ad hoc group for the evaluation of the scientific controversy in question will work, works or worked.
I cannot help but comment that it is discriminatory that the documentation to which Ms. Seeger refers and derives is only available in English language since the result of the carcinogenic re-evaluation of glyphosate will affect the preventions and regulations in its use of millions of people who don't speak english. At the same time, it should be noted that this is a task entrusted by a UN body whose official languages include Castilian (Spanish), Russian, Chinese-Mandarin, Arabic and French.
In our request we ask:
1.- Who will be the experts that will make up this special working group, with what criteria will they be selected and who will be responsible for such selection.
2.- If the experts will have territorial representation and the different schools of thought.
The answer in Seeger's note says:
The members of the Expert Working Group were selected from the WHO roster of experts in toxicology and epidemiology. This roster is comprised of scientific experts who have applied in response to the call for experts or are members of the Food Safety Expert Group. The applications were reviewed by an independent referee from the Organization and by the JMPR Secretariat. Each expert must make a written declaration of interest.
When making the selection, the aim is to balance the scientific knowledge and the geographical representation of the members of the Working Group.
The list of members and their abbreviated resumes of the Expert Working Group can be found at the following link (in English):
The list indicated on that site lists the following experts:
WHO CORE ASSESSMENT GROUP ON PESTICIDES EXPERT TASKFORCE ON CARCINOGENICITY OF DIAZINON, GLYPHOSATE AND MALATHION
ADCOCK Catherine (Canada), BOOBIS Alan (UK), DELLARCO Vicki (USA), EASTMOND David (USA), MORETTO Angelo (Italy), O’MULLANE Matthew (Australia), RUSYN Ivan (USA), SOLECKI Roland (Germany)
In this regard it is appropriate to comment:
- The composition of the group does not respect the fundamental principle of territorial representation established in the UN organizations since the list (roster) from which the experts of the ad hoc group were selected is made up of 13 experts from North America, 15 from Europe , 4 from Asia, 2 from Oceania, 1 from Sub-Saharan Africa. There are no representatives from North Africa, nor from Latin America or the Caribbean. It is unknown how the call for the registration of said list was made, given its very notorious territorial discrimination, and the lack of representation of the different schools of thought and scientific points of view.
- The conformation of the ad hoc group does not meet the requirement of territorial representation, since there is a majority representation from Europe and North America and only one expert from Oceania (which cannot be considered economically or culturally as a country of the South). Latin America and the Caribbean, Asia, North Africa and Sub-Saharan Africa are not represented. All this despite the fact that there are representatives from some of those territories on the list from which the experts who belong to the JMPR were selected.
- The composition of the ad hoc group is clearly unfair for the discussion of the scientific conflict raised between the JMPR that classified glyphosate as non-carcinogenic and the IARC group that classified it as possibly carcinogenic.
This ad hoc group of experts works in the context of the JMPR, made up of the list of experts of the JMPR, a group to which only one expert from the group that prepared the IARC Monograph 112 report is invited .
- Nor does the group represent the different scientific knowledge linked to the interests of the affected social sectors, nor the different schools of thought on the subject matter. The group does not include experts who represent the positions, concerns and interests of agroecological and family producers, rural workers, consumers, populations that suffer from the drift of the evaluated pesticides, nor the doctors who treat them, nor of environmental organizations that have been raising the damage that these products are causing for many years.
Ms Seeger's response also states:
The call to be part of the expert group, as well as the explanation about the selection process is also online: http://www.who.int/foodsafety/areas_work/chemical-risks/etc_final_new_1.pdf?ua=1
This answer lacks veracity, since the indicated site does not find the call to be part of the group of experts, nor the explanation of the selection process.
3.- If the experts will be independent of the companies and corporations, or they will represent them.
The response in Ms. Seeger's note reads: Each expert must make a statement of interest in writing.
Also in the indicated document  it says:
The Published Information is provided by the experts themselves and is the sole responsibility of the individuals concerned. WHO is not responsible for the accuracy, veracity and completeness of the Published Information provided. Furthermore, in no event will WHO be responsible or liable for damages in relation to the use of, and reliance upon, the Published Information.
This paragraph is very worrying because it makes explicit inefficiency in elementary controls of transparency and objectivity in evaluations since the WHO, the international body responsible for the scientific documents used as a reference for the elaboration of standards in most countries of the world, is not responsible for the veracity of the declaration of non-existence of conflict of interest of each expert.
Other working groups have included observers and representatives of the WHO Secretariat and the business sector in their formation. It is not mentioned whether that has been the case in this ad hoc group.
4.- The place and date of the meeting of the special working group and when it is estimated that they will issue their report.
There was no explicit answer to this point. The terms of reference  indicate that:
- The Taskforce will work by correspondence and in English.
- The Taskforce will compare the publications considered by IARC (2015) and those considered by the JMPR (2003, 2006, 2011) for each of the 3 pesticides, and identify those that have not been considered by either IARC or JMPR.
- The Taskforce will report to the WHO JMPR Secretariat by June 2015.
Ms Seeger's response does not mention when the report will be available to the public.
5.- What precautions will be taken so that companies do not pressure the group of experts and or the organizers to re-classify glyphosate as they did with the 2004 report and even the 1994 WHO Environmental Health Criteria 159. Glyphosate, which is still used as the most up-to-date information in the most up-to-date version of the WHO Classification of pesticides recommended by the WHO according to their danger and guidelines for classification: 2009.
There was no answer to this question.
Finally, and linked to all of the above, I point out the following relevant aspects of the studies and groups of experts involved:
- The 2011 JMPR published report on pesticide residues in food has two parts: the first, referring to residues , and the second referring to the toxicity of the agrochemical biocides evaluated.
In the first, the chapter referring to glyphosate residues, was prepared by the Center for Substances and Integrated Risk Assessment, National Institute of Public Health and Environment of the Netherlands . The precariousness of the reference is striking, since being a first draft, it is not a work that has been peer-reviewed for publication, which means that it is not a work that can be considered scientific. In addition, I reference a total of only 28 bibliographic citations, all from unpublished reports, of which 21 are reports made and / or provided by the Du Pont corporation, and 7 made and / or provided by the Monsanto corporation.
In the second part, referring to the toxicity of the biocidal agrochemicals evaluated , the toxicological evaluation of glyphosate is also contained in a first draft prepared only by an expert belonging to the US EPA, and one from the BfR of Germany, which only considered 14 reports, all of them were provided and / or made also by the Du Pont corporation, none of which was published, so they are not scientific works either.
- In the 2004 JMPR published report on pesticide residues in food, you can read on page xi:
Use of JMPR reports and evaluations by registration authorities
Most of the summaries and evaluations contained in this report are based on unpublished proprietary data submitted for use by JMPR in making its assessments.
This makes it clear that the majority of reports were used for this report that are not only unpublished, so they are not scientific, but were also provided by the corporations that produce agrochemicals, even though a detail of them is not provided. .
- The 2015 IARC report, for its part, considered more than 260 works published in the scientific literature, that is, with peer references, for the carcinogenic classification of glyphosate as class 2A, probably carcinogenic, carried out by independent researchers from the companies. Of these works, more than 160 were already available in the scientific literature at the time the JMPR conducted its evaluation in 2011; to which we must add the more than 20 that were published in the same year 2011.
- The IARC report took into account for its conclusions not only recent scientific literature but also publications over 30 years that have shown that glyphosate alters enzymes that regulate oxidative stress, alters enzymes that regulate DNA checkpoints, which are mechanisms that in the long term contribute to the promotion of tumor cells. It is very striking that the bibliography referenced by the IARC on, among others, the link of glyphosate with the alteration of genotoxicity mechanisms, DNA ChekPoint, oxidative stress, which were already publicly accessible even long before 2011, have been dismissed by the JMPR in its report that year.
- It is also noteworthy that the group formed to evaluate the aforementioned controversy, the WHO summons experts who, for example, have passed through the International Institute of Life Sciences (ILSI), well known throughout the world for being financed by transnational companies, mainly agrobiotechnology, such as Monsanto, Cargill, Syngenta, Dow Chemicals, which have worked to generate functional regulations for their commercial interests in different countries of the world. Or, call on experts who lead the pesticide area of the Federal Institute for Risk Assessment (BfR) in Germany, in which members of the agrochemical companies Basf and Bayer participate.
All the above will allow you to understand the magnitude of the concern that this issue generates in us. For this reason, I ask you to be kind enough to respond to the pending queries and observations made in my note of August 7 and to those that I am adding here.
I thank you in advance for your attention and I take this opportunity to greet you attentively
Forest Engineer (UNLP)
Master in Sustainable Human Development, Globalization and Local Development. (UNESCO Chair- University of Girona).
PhD candidate in Social Sciences. UBA
Mobile: 54 11-6467-5187
THE ORIGINAL NOTE ASKING FOR INFORMATION:
Madam Representative of PAHO / WHO
Birmingham, Dr. Maureen
Buenos Aires, Argentina
S / D
Ref: request for information from the WHO ad hoc ad hoc expert working group for scientific divergence on the carcinogenicity of glyphosate.
Of my highest consideration
I am part of the organization ……… .. (or I am a concerned citizen).
We have received with great expectation the IARC report that, based on more than 260 works published in scientific literature and official public access reports, classified glyphosate within group 2A, probably carcinogenic  , .
Information was recently distributed from the offices of officials of the Ministry of Health of the Argentine Nation that:
On July 30, the German Federal Institute for Risk Assessment mentioned that the WHO has established an "ad hoc ad hoc expert working group" given that there is a scientific divergence, since another body of the WHO, the Joint FAO / WHO on Pesticide Residues (JMPR)   had classified glyphosate as non-carcinogenic based on current data and assumption of intended uses. This group should compare IARC and JMPR publications in order to clarify the reasons for the different evaluations.
We are very concerned about the lack of response from the WHO to the questions that are being made to the IARC report from the business sectors, and the echo that international organizations make of these questions. As well as the lack of information from that special group of experts that will compare the two works.
We are writing to ask you to tell us about:
1. Who will be the experts? with what criteria will they be selected? Who will select them? have territorial representation and different schools of thought?
2. Will the experts be independent of the companies and corporations, or will they represent them?
3. Where will you meet? When? When is it estimated that they will issue their report?
4. How will it be done so that companies do not pressure the expert group and its organizers to re-classify glyphosate as they did with the 2004 report and even the 1994 WHO report (Environmental Health Criteria 159. Glyphosate [13 ] ), which is still incredibly used as the most up-to-date information in the WHO version "WHO-recommended classification of pesticides according to their hazard and classification guidelines: 2009"  
It depends on how that group is satisfied and what are the criteria with which the works to be considered will be chosen, will be the conclusions they arrive at.
If, as in the case of the 2009 recommendations, the group that classified glyphosate is made up of experts without territorial representation or from the different schools of thought, they consider works that were mostly not published in scientific literature and carried out or provided by them interested companies, and they are also not publicly accessible, will conclude that glyphosate is little less than innocuous and its formulations may continue to be classified as Class IV and identified with a green band by national authorities, as is currently the case with SENASA in Argentina.
A comparative table between WHO 2010 and WHO / IARC 2015 summarizes the divergences of the two methodologies.
Table 1. Comparison of the WHO (2010) and IARC (2015) glyphosate classification context and methodology. Conclusions
Evaluation of glyphosate in the Recommendations of the
Glyphosate Carcinogenic Risk Assessment by IARC.
Monographs Volume 112
|Formation of the working group|
The group that evaluated glyphosate was made up of an English expert, an Egyptian, two from the Netherlands, an American and a Chinese. As secretary of the group, a Swiss from the WHO International Chemical Safety Program.
The task force also has an observer: a representative from Monsanto, Missouri, St. Louis, USA.
|The evaluations are carried out by groups of international experts, selected on the basis of their experience and the absence of real or apparent conflicts of interest. For Volume 112, a working group of 17 experts from 11 countries met at the IARC on March 03-10, 2015 to evaluate the carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate.|
|Authors of the works considered||The reports referenced by WHO (1994) to classify glyphosate toxicologically are mainly based 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.||The Working Group did not consider summary tables in the online supplements to published articles, which do not provide sufficient detail for independent evaluation.|
|Scientific nature of the works considered||More than 150 of the cited reports were not published, that is, they were not submitted to peer review or criticism, therefore they do not meet the criteria to be considered scientific||The Working Group considered reports that have been published or accepted for publication in the openly available scientific literature, as well as data from government reports that are available to the public.|
|Update of the works considered||The most up-to-date works considered for the toxicological evaluation of glyphosate from the 2009 recommendations (WHO, 2010) are from 1992||The most up-to-date works considered for the 2015 carcinogenic evaluation of glyphosate (IARC, WHO, 2015) are from 2015.|
|Methodology||The classification is based on the acute 50% Lethal Dose||The classification is supported by studies evaluating chronic lethal and sublethal carcinogenic toxicity|
|Conclusions of the methodology and context||Of the five toxicological classes, glyphosate is classified as class III, blue band, and its formulations as class III or class IV, the least dangerous, depending on the concentration of the active principle and other components.||Of the five carcinogenic classes, glyphosate is classified as 2 A, probably carcinogenic, the second most dangerous|
Source: Elaboration by Ing. Claudio Lowy, BIOS Argentina, based on WHO (2010), WHO (1994) and IARC / WHO (2015)
Remaining at your disposal and awaiting your response, I greet you very atte.