1500 words March 6, 2015 Dr. Richard Aucoin Executive Director Pest Management Regulatory Agency Health Canada Dr. Aucoin, Thank you for your response of January 23. The letter I sent to the Minister in October was meant as a briefing paper for her staff to include in their next scheduled review of glyphosate for Canada. To be made aware of the scientific studies that have been published in the last five years - overwhelmingly concluding that glyphosate is linked to a long list of chronic illnesses that can be explained by the chemical property of glyphosate as a powerful chelating agent that robs cells of plants and animals of micronutrients. Our food is now so frequently contaminated with this chemical that it has become like a common food additive. By the admission of the biotech industry, over 80% of food items in the grocery stores contain engineered ingredients, mostly soy and corn, but also canola and sugar. Add to this, all north American cereals and their products, since the crops are sprayed with RoundUp as a desiccant, just before harvest. We probably have 90% of food items in the store polluted with this chemical. Years later, it turns out that it is also a powerful antibiotic. Granted we did not know about the importance of the human micro-biome when glyphosate was patented as a powerful descaling agent in 1964, or commercialized a herbicide in 1974. But surely in 2015, some of your staff must be aware of the powerful antibiotic glyphosate can be – patent granted in 2010. Glyphosate kills all bacteria and damages the human micro-biome as much as shown in animals at the University of Leipzig in Germany last year. We are now learning that losing biodiversity in the micro-biome can and does results in serious metabolic imbalances translating as severe organ symptoms in more and more people. Good examples are: intestinal infections, particularly with Clostridium difficile, or autism, or diabetes, and a host of other chronic organ deficiencies or inflammation. This is absolutely not a problem of technology, this pesticide story has nothing to do with genetic engineering. The controversy about the safety of this technology has been overblown to keep people focused away from the real issue of chronic toxicity of food residues of glyphosate that bioaccumulate in human organs and cause toxification and inflammation. This is a simple pesticide story. A chemical very good at cleaning up industrial pipes and boilers of scale’s mineral buildups, ended up as a herbicide and then turned into the most successful agricultural chemical of all times. So successful in fact, that our food system is thoroughly polluted with detectable levels of this chemical in much of the food. Dr Nancy Swanson has published her correlation analyses of glyphosate use and chronic cases treated in the US every year for 20 years. Her results are staggering. The correlation coefficients are so high that any statistician will tell you that the link is certain between the two data sets. Dr Swanson’s conclusion is a warning to her government to not ignore these statistics published in the Journal of Organic Systems 9 (2) 2014 “Genetically engineered crops, glyphosate and the deterioration of health in the United States of America. Abstract: A huge increase in the incidence and prevalence of chronic diseases has been reported in the United States (US) over the last 20 years. Similar increases have been seen globally. The herbicide glyphosate was introduced in 1974 and its use is accelerating with the advent of herbicide-tolerant genetically engineered (GE) crops. Evidence is mounting that glyphosate interferes with many metabolic processes in plants and animals and glyphosate residues have been detected in both. Glyphosate disrupts the endocrine system and the balance of gut bacteria, it damages DNA and is a driver of mutations that lead to cancer. In the present study, US government databases were searched for GE crop data, glyphosate application data and disease epidemiological data. Correlation analyses were then performed on a total of 22 diseases in these time-series data sets. The Pearson correlation coefficients are highly significant (< 10-5) between glyphosate applications and hypertension (R = 0.923), stroke (R = 0.925), diabetes prevalence (R = 0.971), diabetes incidence (R = 0.935), obesity (R = 0.962), lipoprotein metabolism disorder (R = 0.973), Alzheimer’s (R = 0.917), senile dementia (R = 0.994), Parkinson's (R = 0.875), multiple sclerosis (R = 0.828), autism (R = 0.989), inflammatory bowel disease (R = 0.938), intestinal infections (R = 0.974), end stage renal disease (R = 0.975), acute kidney failure (R = 0.978), cancers of the thyroid (R = 0.988), liver (R = 0.960), bladder (R = 0.981), pancreas (R = 0.918), kidney (R = 0.973) and myeloid leukaemia (R = 0.878). The Pearson correlation coefficients are highly significant (< 10-4) between the percentage of GE corn and soy planted in the US and hypertension (R = 0.961), stroke (R = 0.983), diabetes prevalence (R = 0.983), diabetes incidence (R = 0.955), obesity (R = 0.962), lipoprotein metabolism disorder (R = 0.955), Alzheimer’s (R = 0.937), Parkinson's (R = 0.952), multiple sclerosis (R = 0.876), hepatitis C (R = 0.946), end stage renal disease (R = 0.958), acute kidney failure (R = 0.967), cancers of the thyroid (R = 0.938), liver (R = 0.911), bladder (R = 0.945), pancreas (R = 0.841), kidney (R = 0.940) and myeloid leukaemia (R = 0.889). The significance and strength of the correlations show that the effects of glyphosate and GE crops on human health should be further investigated.” You write – and I applaud you for reminding me, and I quote “before a product such as the RoundUp herbicide is approved for use in Canada, it must undergo a thorough science – based risk assessment and meet strict environmental standards. This includes the examination of long term (lifetime) animal toxicity tests that assess the potential for the active ingredient to cause chronic, cancer, reproductive and developmental toxicity, or various other effects, as well as a variety of environmental toxicity to birds, bees, and aquatic organisms.” Every items of your list is documented and published as a high risk, the birds, the aquatic organisms, the people, showing chronic symptoms, cancer, reproductive and developmental toxicity. The impact on the health of Canadians will overwhelm the public care system as chronic cases become epidemic. Canadians will be interested to see the evidence that your experts based their decision on. I hope that you will spare me the tired response that these documents are actually not available because they are corporate trade secrets. That would identify them instantly as being suspiciously missing or else corporate property, i.e. the chemical company tests its own product and does not need to show the results to a regulatory agency such as PMRA. You write also If the specified use of a product poses risk of concern to human health, future generations or the environment, it is not registered in Canada. Are we discussing the same chemical Dr Aucoin? Is this the same molecule that is a patented antibiotic at one part per million? Is this the same molecule causing birth defects in frogs and human babies as well as all kinds of cancers and liver and kidney failures in test animals in Universities in Austria, Germany, China, India, France, Holland, Italy, and Russia, just to name a few? The US Environmental Protection Agency has a web site where the page on glyphosate shows a Maximum Contaminant Level of 0.7 ppm in drinking water in Canada. In view of the published evidence of risk, does your agency test the drinking water of canadians regularly? The same page indicates that people drinking well water polluted with higher contamination levels than 0.7 ppm should expect kidney and infertility problems. We know that glyphosate bioaccumulates in all our organs so kidney disease and infertility are only two of many documented inflammation and toxification symptoms showing. There are many research studies showing the safety of GMOs. I suppose they mean to reassure the public and the scientific community. But why do so few of them, if any, ever include the herbicide in their studies? None if any of these so called safety studies bothers to mention residues of glyphosate in the grain. They use seeds from research plots given to them by the owner of the technology. They conclude about GMOs, not about glyphosate. On the other hand there is now a long list of studies showing toxicity, and the list of countries regulating and banning the RoundUp Ready technology is long too. I trust that you and the Minister will take my plea seriously. I think there is cause for a national pause when so many foreign governments have chosen the precautionary principle or else been convinced by the existing data already. What do they know that we refuse to see ? Cui bono? I assume your previous letter is a public document. Thank you for your service, Dr. Thierry Vrain