An Open Letter re: the Outstanding NB Medical Officer of Health’s Report on Glyphosate Herbicides

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Council of Canadians – Kent County NB Chapter
FB Page: https://www.facebook.com/KentCountyChapterCoC/?fref=ts
email: coc.kent.county.nb@gmail.com
June 28, 2016

Acting Chief Medical Officer of Health
Office of the Chief Medical Officer of Health
Government of New Brunswick
HSBC Place, Floor: 5
P. O. Box 5100, Fredericton, NB, E3B 5G8
transmitted by email: Jennifer.Russell@gnb.ca

Dear Dr. Russell:

We need to see that report on glyphosate that you promised we would have before the spray season begins. We need to see that report now. It is not clear to us if your report has been scrapped, suppressed, or something else has happened.

Dr. Russell, the spray season is upon us. Both CN Rail and NB Power have already publicly released their approved spray plans. Timber industries have already compiled their lists of acreage they want to spray for their monoculture conifer plantations. Their applications for taxpayer-financed provincial silviculture spraying are being reviewed, and they anticipate approvals within the next few weeks.

We remember all too well how the government of that day tried to bury Dr. Cleary’s report on fracking in 2012. They knew they could not “control” her when it came to matters of public health, and they knew the report did not agree with their stated view that fracking is perfectly safe and would be great for NB. A similar situation potentially exists with this matter because in recent weeks, Minister Denis Landry and Premier Brian Gallant have both said glyphosate is safe.

On May 18th, I and eleven other New Brunswickers hand-delivered a formal complaint to the New Brunswick Ombudsman. It addresses matters pertaining to the “no cause” termination of the former Chief Medical Officer of Health (CMOH), Dr. Eilish Cleary. Our major concern is the status of Dr. Cleary’s promise to investigate and report re: the risks of glyphosate herbicide compounds on population and environmental health. Our conversation with NB Ombudsman Charles Murray is ongoing.

During her exemplary tenure as CMOH, Dr. Cleary established a very high standard for independent and comprehensive research, both with her peer-acclaimed 2012 report on population impacts of shale gas development, and in the Health Impact Assessments model developed in 2015 for the NB Commission on Hydraulic Fracturing. Since we learned that Dr. Cleary was put on leave and then dismissed, I am only one of thousands of New Brunswickers who are concerned that we will not see a comprehensive and independent report from the Office of the CMOH on glyphosate herbicide spray use in our province.

In her communication to me promising this report (sent August 14, 2015), Dr. Cleary said that her office would develop “a plan” for reporting “in the coming year.” In response to the issues I raised on behalf of our group, the Kent County Chapter of the Council of Canadians, Dr. Cleary also made the following comments:

  • concurrence with the IARC/WHO conclusion that glyphosate is “probably carcinogenic to humans”;
  • there is need investigate “the nature, duration and intensity of the exposure to the toxins in this province” and to look into the high incidence of non-Hodgkins lymphoma among men in NB;
  • any further protections needed to protect the population in New Brunswick would be independently developed and not curtailed by Health Canada’s Pest Management Regulatory Agency conclusions.

On September 24, 2015, I wrote the former-CMOH concerning some additional issues raised by members of our group. You responded to this letter, Dr. Russell, on November 9th, as follows:

  • re: “cases of poor compliance with setback distances, inadequate signage and ineffective advance notice of spraying,” your “office will bring these issues forward to the Department of Environment and Local Government which regulates these aspects of pesticide use”;
  • regarding when we could expect the report: “it is our understanding that its use is seasonal so we do not expect any significant spraying between now and the summer of 2016. We anticipate completing our action plan in advance of the next spraying season.” Subsequently, in a communication to Dr. Caroline Lubbedarcy, you promised the report this Spring.

Dr. Cleary’s impending and then actual dismissal broke in the media in early December 2015. At that time, the Deputy Minister of Health, the Minister of Health, and the Premier all affirmed that this report was forthcoming as originally promised. Spring is over, and the spray season has begun. Where is the report?

I am sure you are aware that new research is coming out all the time on these herbicide compounds.

A literature review by 14 diverse scientists called Concerns over use of glyphosate-based herbicides and risks associated with exposures: a consensus statement, was published in the peer-reviewed journal Environment Health on February 17, 2016. You will find the content in the appendices especially alarming. Other research suggests that glyphosate on its own is not nearly as bad as the complex herbicide formulation, glyphosate PLUS additives and adjutants, that make it work and are protected as “trade secrets.” As I understand it, these additional substances are what carry the glyphosate across cell walls and increase the hazards by untold magnitudes in a multitude of ways. Of huge concern to scientists studying glyphosate is that its use is so widespread: people’s exposures to the residue are pandemic, and tests show high concentrations in humans.

I am sure you are also aware that a 2001 Supreme Court of Canada decision affirmed government has a rightful mandate to apply the “precautionary principle” on the directly related matter of pesticides. The Consensus Statement referenced above clearly advocates for caution and care, and is part of the reason we are convinced that the precautionary principle must be applied to use of glyphosate here in New Brunswick. The precautionary principle can be understood as: first, do no harm; and, second, avoid doing things when there is a reasonable likelihood this could cause harm. The principle applies until the safety of the matter in question can be established.

Thousands and thousands of New Brunswickers share the concerns I have penned on behalf of our Kent County NB Chapter of the Council of Canadians. Valid population and environmental health research of the risks associated with these compounds is urgently needed. We sincerely hope that the report you have been working on will meet the tests for being valid, in depth and independent.

Please send me the report that we are promised.

Respectfully yours,

Ann Pohl
Chairperson, Kent County NB Chapter – Council of Canadians

Copies:

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Men in New Brunswick have an exceptionally high rate of non-Hodgkins lymphoma. The World Health Organization says that Glyphosate defoliant sprays, used “safely” on NB forests/fields/roadsides for decades, cause this rare cancer… Please read on to learn what valid science has uncovered about these herbicides…

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August 3, 2015
Kent County NB Chapter, Council of Canadians
transmitted by email from: 
coc.kent.county.nb@gmail.com

Office of the Chief Medical Officer of Health
HSBC Place, P. O. Box 5100
Fredericton, NB E3B 5G8
also transmitted by email to:
Eilish.Cleary@gnb.ca

Re: Glyphosate-based Herbicides and Health/Environmental Concerns

Dear Dr. Eilish Cleary,

I am writing to ask for your opinion on the risks of the continued use of glyphosate herbicidal products. Under trade names such as Forza, Vantage Forestry, Vision, Vision Max, and Roundup, it is used widely in New Brunswick for:

  • forestry management, to promote cultivation of soft-wood trees;

  • clearing roadsides and hydro-lines;

  • agricultural purposes – at seeding time to prevent weed plants from competing with desired seedlings, and to dry off cereal crops at harvest time (by slightly killing them).

According to research recently released by the International Agency for Research on Cancer (IARC), an arm of the World Health Organization (WHO), this broad-spectrum weedkiller is a probable carcinogen for human beings and animals. In an interview on CBC Radio, Dr. John McLaughlin, a Canadian environmental health epidemiologist who was a member of IARC’s glyphosate panel, explained that a wide range of qualified scientists took part in this “rock-solid”, “rigorous” and “transparent” research study. He also said that these scientists were pre-screened to ensure they had “no conflict of interest.” Dr. McLaughlin said a major reason for this reclassification is a clear association between workplace exposure and the incidence of “one rare cancer”: non-Hodgkins lymphoma. These findings caught my attention.

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I live in a hunting, fishing, lumbering and farming community. Most of my neighbours are – like me – troubled by spraying of glyphosate in our forest, and on fields near people’s homes. After the reclassification was announced, I became very concerned about the health of the (predominantly) men who are exposed to these chemicals through their work, as well as neighbours who live near areas being sprayed. Sometimes it seems as if every second person in Kent County has cancer.

I went past “concerned” and “troubled” to alarmed, when I learned that the Public Health Agency of Canada has found an exceptionally high incidence of non-Hodgkin’s lymphoma among men in New Brunswick, the same exact “rare” cancer that is correlated by the IARC/WHO panel with glyphosate pesticides.

The US non-profit group Beyond Pesticides reports that in 1985 the US Environmental Protection Agency (EPA) decided to classify glyphosate as ‘possibly carcinogenic to humans’ based on tumors in laboratory animals. This group, Beyond Pesticides, has suggested that “industry influence” may account for the EPA rescinding this classification. After the EPA removed this warning with apparently no reason, the chemical became the most widely used herbicide in the US, and perhaps the world. The change was certainly lucrative for its manufacturer, Monsanto.

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The decision to use these herbicides is not about jobs. There are more jobs in looking after our renewable forest resources using the old ways – like silviculture – that do not involve toxic chemicals on the environment that sustains us all. Use of these chemicals is about fattening the bottom line of corporations.

From what I have read, numerous scientifically rigourous and valid studies have concluded that glyphosate formulations are – for example – toxic to fish, a common contaminant in agricultural soil, genotoxic, an oxidative stressor, etc. 385 scientists from around the world have launched an online, Independent Scientists Manifesto on Glyphosate, which makes a “call” to “governments at all levels to ban the spraying of glyphosate herbicides.” Their advocacy “manifesto” says in part:

…“probable human carcinogen” is only a small part of the known toxicity of glyphosate herbicides. Chronic exposure to glyphosate herbicides is associated not only with cancers, but also with infertility, impotence, abortions, birth defects, neurotoxicity, hormonal disruption, immune reactions, an unnamed fatal kidney disease, chronic diarrhoea, autism and other ailments.

In addition to human diseases, glyphosate herbicides are linked to more than 40 new and re-emerging major crop diseases. They are causing irreparable harm to the entire food web; including the plant kingdom, beneficial microbes that supply nutrients to our crops and soils, fish and other aquatic life, amphibians, butterflies, bees, birds, mammals, and the human microbiome.”

Scientists are usually a reclusive and very cautious lot. Why are so many willing to stick their necks out on a controversial matter like this? This on its own is a huge warning signal. It seems clear they are driven by their professional ethics and this is the only way they can find to say these important things.

Also of great concern to me are the possible gastrointestinal impacts of widespread glyphosate herbicide use. In recent decades, we are seeing an epidemic of gastrointestinal disorders (e.g. food allergies, irritable bowel syndrome, celiac symptoms/disease, “wheat belly,” Chrons, Colitis). Glyphosate is used in agriculture in two ways: to eliminate weed competition at planting time; and, to dry up cereal crops just before harvest (actually killing the crop to ripen it). A recent study in the United Kingdom found glyphosate in up to 30% of commercial bread samples. Because bread is a staple for almost everyone, and not everyone has access to organic grain products, the UK Soil Association is calling for an immediate ban on use of glyphosate sprays for wheat, both as a pre-harvest weed killer and to help the crop ripen faster.

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It is not only humans who are at risk. Rod E. Cumberland is a wildlife biologist who retired from the provincial civil service in 2013. He has said, “’Herbicides kill hardwood trees and deer eat hardwood trees.” Over “roughly the same period of time” that glyphosate use has been widespread in our forests, “deer populations in New Brunswick have plummeted to fewer than 80,000 today, from well over 200,000.” Rod Cumberland speaks with authority, having been responsible for “managing” New Brunswick’s deer herds for over two decades.

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The Conservation Council of New Brunswick (CCNB) has researched glyphosate sprays as part of their forest health protection mandate. CCNB is deeply concerned about the impact of this defoliant in regards to the integrity of the fauna of the endangered Acadian Forest as a whole, as well as forest wildlife, and humans who are exposed second-hand. Further, CCNB observes that New Brunswick is the only province that pays to have its forests sprayed with these chemicals” and “mechanical site preparation, planting and spraying of our public lands” can “exceed $1,000/ha.”

I work closely with Mi’kmaq environmental protectors in this Sikniktuk District of Mi’kma’ki. The Peace & Friendship Treaties do not discuss surrender of resources or land, so New Brunswick is unceded territory of the Wabanaki confederacy of First Peoples (which includes all of Mi’kma’ki), who signed these treaties. To the point: what is commonly called “Crown Land” should more legitimately be called “Shared Treaty Land.” The damage done to forest ecology with these chemicals is a major concern to Indigenous Peoples of this region, who “Aboriginal” rights to sustainable use of the forests for all future time.

Prior to sending you this communication, Dr. Cleary, I shared the contents with the members of the Iapjiw Maliaptasiktɨtiew Wskwitqamu (Protecting the Earth for Future Generations) Consultation Delegation headquartered at Kopit Lodge in Elsipogtog First Nation. They asked me to let you know that they understand the way everything connects in the Forest: in fact the whole world is connected as one living being. They see all the damage done to the forest because they have knowledge of the forest handed down to them through the generations. It is not possible to justify poisoning the forest and all the beings that live there. No matter how “minimal” the danger might appear to scientists, it is unimaginable: there are no “acceptable risks” in this case. Further, they have never been consulted on whether this treatment of the forest is acceptable and can be accommodated by them.

The Government of New Brunswick just released “notice of intent” to spray these defoliants on 16,000 hectares of our forest beginning August 10, 2015. It seems simply wrong that our cash-strapped government is paying corporations to make us sick, all for the sake of corporations’ profits.

As of July 29/15, the Government of New Brunswick’s website still says that the World Health Organization (parent to the IARC panel) is not concerned about glyphosate herbicide formulations. The extremely influential J.D. Irving (JDI) corporation seems to be brushing-off this scientific finding. An April 1, 2015 CBC news story quotes Ms. Keith, spokesperson for JDI, saying IARC “provides no new scientific data to support their conclusion,” and “all national regulatory review bodies have classified glyphosate as unlikely to pose a carcinogenic risk.”

Heath Canada recently concluded a review of glyphosate and concluded it was not unsafe. Rod Cumberland reviewed Health Canada’s study, commenting on its deficiencies, saying it: is limited to glyphosate only and excludes toxic adjuvants and emulsifiers also used in these herbicides; denies any residual impact of water, soil or food but recent research has concluded differently; and, most significantly, relies about 90% on older research, ignoring many papers published in the past 10 years which address issues such as those discussed above – especially cancer, and cell malformations in the gastrointestinal and reproductive systems.

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Dr. Cleary, you wrote in 2012 that a huge question for public health officials is “what is the cost of being wrong about estimating risk?” You also wrote, “Public health decision making depends on… ethical principles” such as “beneficence and non-maleficence” and doing “what is good for the whole community, not just individuals” (under the law, “individuals” can be corporations or human beings). Please see the attached reference list: in view of the research I have been able to assemble, it seems to be time for invocation of the Precautionary Principle. I know I am asking you to step into a difficult situation but you must realize the population of this province has deep admiration for your professionalism. I look forward to your response. 

Very respectfully yours,

Ann Pohl
Spokesperson, Kent County NB Chapter, Council of Canadians

Hotlinks to Sources for Information (in order of topics raised)

  1. Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate (Lancet journal article about the IARC/WHO panel and their conclusions)

  2. Gylphosate: IARC MONOGRAPHS (some of their research findings)

  3. Threat to Human Health? (CBC) (Terry Seguin interviews Dr. John McLaughlin from IARC panel)

  4. Herbicide chemical glyphosate ‘probably carcinogenic,’ WHO agency finds (CBC)

  5. Cancer in Canada – An Epidemiologic Overview: A report based on the Cancer Incidence Atlas — Volume 2, 2000-2006 (February 2014; HP35-43/2014E-PDF; ISBN: 978-1-100-22759-7; page 19: “Significantly elevated rates were observed among… males in New Brunswick.”

  6. Glyphosate Classified Carcinogenic by International Cancer Agency, Group Calls on U.S. to End Herbicide’s Use and Advance Alternatives (Beyond Pesticides)

  7. Chemical Watch Factsheet: Glyphosate (Beyond Pesticides) (extensive literature review; addresses multiple issues including resistant weeds and general environmental toxicity)

  8. Independent Scientists’ Manifesto on Glyphosate

  9. Cytotoxic and DNA-damaging properties of glyphosate and Roundup in human-derived buccal epithelial cells (abstract for article regarding impact on cells/DNA).

  10. Phase-out Herbicides (CCNB)

  11. Tracy Glynn on herbicide use in our Crown forest (CCNB)

  12. Cancer classification warrants phase-out of widely-used herbicide (CCNB)

  13. What you need to know about what’s sprayed on our forests (CCNB)

  14. Glyphosate in our food: Carcinogenic Glyphosate Linked to DNA Damage, as Residues Are Found in Bread (Beyond Pesticides)

  15. Over 60% of breads sold in the UK contain pesticide residues, tests show. (The Guardian)

  16. UK Soil Association calls for ban on Glyphosate: the world’s most widely sold weedkiller

  17. Rod Cumberland, deer biologist, responds to J.D. Irving on herbicides and deer (several relevant links about forest ecology issues on this page)

  18. GLYPHOSATE OVERVIEW (comprehensive literature review focussed on agricultural uses; including toxicity throughout the environment and gastrointestical issues in humans)

  19. A Former GMO Scientist Sends An Open Letter to Canada’s Minister of Health (addresses toxicity factors in agricultural uses, including issues arising such as food allergies)

  20. Be informed about herbicides (GNB – “not harmful”, “do not cause cancer” etc.)

  21. ISSUES: Shooting down Health Canada’s re-assessment of glyphosate.
    (Dr. Rod Cumberland; an email to all NB MLA’s critiqueing Health Canada’s re-assessment of glyphosate; 2015)

  22. Proposed Re-evaluation Decision PRVD2015-01, Glyphosate (possible relabelling)

  23. Crown Land Herbicide Program (2015 spray season notice)

  24. Chief Medical Officer of Health’s Recommendations Concerning Shale Gas Development in New Brunswick (2012) (pgs 14-15: “Public Health Ethical Considerations”)

     

Sources/credits for Images used in this post:

protest in moncton: http://nbmediacoop.org/wp-content/uploads/2015/05/Moncton-demo-pic-1-IMG_0601.jpg
decimated forest: http://www.cbc.ca/news/canada/new-brunswick/nb-power-s-herbicide-essentially-non-toxic-to-humans-wildlife-1.3161385
ain’t salad dressing: http://www.sott.net/article/260280-How-GMO-farming-and-food-is-making-our-gut-flora-unfriendly
original art work (habitat x 2, moncton protest) by the AAAA+ (amazing Acadian airbrush artist) Gerry LeBlanc: gerry.leblanc.98@facebook.com
no safe sprays: http://jamesrobertdeal.com/roundup-is-toxic/