Friday, 20 February 2015

Pesticide regulaton update

A couple of days ago I reported on what I heard Professor Seralini say at the Food Matters Aoteoroa conference last weekend, seeking rebuttal of three claims I thought he made. Nothing came back, which seemed odd given the pretty active opposition to my more general post about the conference just a day earlier(please do read the comments). So I directly asked all the people who'd volunteered criticisms a day earlier, several people who'd been at the conference, and the Science Media Centre.

In the course of those discussions, my competence to discuss this issue has been queried. I see that as a big red warning flag. There is a very simple issue here that does not much depend on understanding the science. No one has disputed that all pesticides (including herbicides and insecticides) have several ingredients but only the declared "active" ingredient(s) are tested for toxicity. If the other ingredients can magnify toxicity, then we need to test whole formulations not just the declared active ingredient. A smart 8 year old could understand that.

There is still a policy question that needs science information though. If the other ingredients can never magnify toxicity, then lets not bother incurring the cost of testing the whole formulation sold to the punters. But how on earth could you prove that?

With that background, here is an update based on what I've discovered from inquiries since my last post on this topic.

  1. My recall of what Seralini said appears accurate. He apparently referred to this paper which includes the following statement. "Since pesticides are always used with adjuvants that could change their toxicity, the necessity to assess their whole formulations as mixtures becomes obvious". Makes sense to me.
  2. While the claim was probably stunning for many of us, this is actually very old news for Seralini. Check out this paper from 2005.
  3. The ability of adjuvants to increase the toxicity of "active ingredients" is not restricted to glyphosate. These people (none of whom are Seralini) say much the same thing about the insecticides Talstar and Termidor, concluding that "increased toxicity due to inert ingredients should be considered in risk assessments and regulation of insecticides".
  4. The German government (none of whom are Seralini) is also concerned. Its regulator "believes that there is convincing evidence that the measured toxicity of some glyphosate containing herbicides is the result of the co-formulants in the plant protection products."    

I understand that SciBlogs will be commenting on this issue tomorrow, which is great. Debates need two sides.


  1. Ummm...this sure looks like it hits both glycosphate and Roundup.

  2. You really should read the rest of that paper Eric.

    The headlines sound good, but the methodology looks very dodgy indeed to me: some kind of one-time only index number / multicriteria analysis bullshit with utterly subjective weights unless I am mistaken.

    So it's just someone's opinion. From 1999.

    Doesn't sound like much of a substitute for accurate regulatory testing in 2105.

    1. Roundup has been around forever; it's not surprising that a pile of the tests are from pre-2000.

      The Cornell LD50 sheet has glycosphate and Roundup being pretty much identical.

      The burden of proof, as Grant notes, for products long held as safe, is on those claiming otherwise. Why do you think that Seralini hasn't convinced the chemists and toxicologists as yet?

    2. You've been off the farm too long Eric. Roundup is old news. Roundup Transorb the thing now, though there are several others. These are different products, are they not? So this historic "long held safe" thing doesn't apply. Where are the safety tests for these?

    3. Or try this question: How does Monsanto sell customers on the new thing (eg Transorb)?

      Answer: it's more effective = more toxic.

      How much more?

  3. I don't think this answers John's question. I understand him to be asking whether or not regulators (and this would be here as well as in the US and Europe) routinely require the testing of commercial formulations of the very many pesticides and all variants based on particular active ingredients that might be sold.
    It doesn't surprise me that some researchers have done tests that include some commercial formulations. After all, Seralini has and that is what prompted John's quest for answers. But this ad hoc finding does not tell us whether prior to release regulators test for safety of the product itself.
    Moreover, the answer to John's question would be to know whether or not the risk assessment included environmental as well as human health safety. Again, this paper does not address whether or not unintended adverse effects in the environment were excluded using actual commercial formulations.
    Considering that this paper is 15 years old and since its publication glyphosate has come off patent, it also does not even answer the question for all the different manufacturers of glyphosate-based herbicides.
    Finally, in 2015 the German regulator at least appears to be convinced that at least one other ingredient in Roundup is toxic.

  4. Hi John,

    You seem to have taken what others have written to you personally. Certainly I haven’t written that way and I can’t imagine anyone else at sciblogs has either.

    I’d rather you didn’t present this as some sort of adversarial "debate". Your post above has the effect of jumping before you think I will write something and set it up as “debate”.

    This isn’t how I have put things to you and is not the way I will take it forward. Adversarial/"debate" approaches are generally not useful, a point I have made quite a few times over the years on my blog, including briefly in my earlier writing on this topic. (I have to say that it leaves me wondering if you’ve actually read the things I’ve suggested to you to look at.)

    There are not two sides, only understanding a thing.

    With the greatest of respect, you have some confused thinking on this. That’s not entirely your fault: Séralini’s abstracts are easily (mis)read that way.

    Your post also has the effect of reversing the burden of proof. This interest in adjuvants is yours, not mine! You’re welcome to ask for assistance, but you want to be careful not to imply that others "must" "prove" you (or Séralini) wrong.

    I note your summary leaves out cautions about Seralini’s work; your summary is only presenting from one perspective.

    I’ve had a look and there are some things others have written that cover this issue but could be make a little simpler for non-scientists. While it’s probably easier for me to find these things than you, if you were researching the topic openly, I’d like to think you would have found these too. I’ll get these to you later one way or other.

    I’ve never said “SciBlogs will be commenting on this issue tomorrow” or similar. I did write that I “will post some links later” - note carefully this does not say where. Maybe you have mentally filled this in to be at sciblogs, but that is your doing not mine! In fact, at the time of writing it was intended for a comment in your blog. I did try suggest to you that I likely wouldn’t have time, pointing out how long a post on this would take.

    You might also want to note it’s not really “Sciblogs will be” - we’re not an organisation, but a collective of individual blogs who write whatever they do.

    I am extremely busy and am almost entirely spoken for until late next week. *IF* after I have everything today and I still have some time, I *might* a piece on it. If I do it will be a general thing, i.e. not addressed to you, or in response to you. Please don’t think I’m snubbing you in writing that - it’s just I much prefer discussion to “debate” approaches and there are a few other people that might benefit so I’d be inclined to write generally.

    A few loose comments while I’m here:

    I think if you re-read your post, you’ll find that “There is a very simple issue here that does not much depend on understanding the science” is better worded “There is a very simple non-science issue here that depends on understanding the science first.” (I’d express skepticism that it really is that simple.)

    As your conditional ‘if’ notes, you need to get the science right first before coming any idea that it might need regulatory attention at all.

    Finally, and sorry about this, but if you wish to contact me about this topic in future, please just write a comment to my blog on one of the posts on the topic, thanks. After all, that’s what comments sections are for right? I said in reply to your first email that I prefer people to write about blog topics in public, rather than effectively ‘go around’ the blog unless it is absolutely necessary. One of several reasons is that people lift things out of private correspondence and, not necessarily intending ill of it, misrepresent it.

    - Cheers

  5. Hi Grant

    Thanks very much for this. I really appreciate you taking the time to engage and appreciate that you’re very busy.

    That may be why you forgot that you did actually query my competence to be involved in this discussion. On my first post about Food Matters one of your comments said: “You’re an economist. On what basis do you think you have the expertise to critically judge the science presented?”

    Obviously my direct and indirect attempts to answer this question have been too cryptic, so let me try now to state things more plainly.

    The main purpose of a food safety system is to assure consumers that their food is safe. The system is broken if consumers can see glaring logical holes in it. This post describes a potential logical hole that a smart 8 year old can understand.

    There are really only three possible responses I think.
    1. There is no gap in the testing program: full formulations are always tested before being approved.
    2. There is a gap (full formulations aren’t tested) but we shouldn’t be worried for some reason.
    3. Yes this is a problem and we should fix it.

    I was really hoping that #1 would be the answer, but it seems this was a forlorn hope.

    That leaves #2 as the only way to save the status quo. But seriously, how could anyone run this argument in the face of so much product innovation? Obviously Eric’s 1999 literature review doesn’t cut it. Neither does dismantling a few Seralini papers. The issue is way broader than Roundup and not limited to the past. If you want to argue that food safety regime shouldn’t require full formulation testing you need to show that adjuvants can’t materially increase toxicity, ever. That is simply impossible and our 8 year old is going to see right through it.

    Cheers, John.

  6. “That may be why you forgot that you …”

    I didn’t forget. (Best not to put words in other‘s mouths!) I just choose to leave it as a courtesy to you. In my first sentence I wrote, “You seem to have taken what others have written to you personally” - that includes that. In any event, just because I didn’t mention something doesn’t mean I "had" to say something about it. It’s not as if you have addressed all the things I have suggested eh?

    “Obviously my direct and indirect attempts to answer this question have been too cryptic, so let me try now to state things more plainly.”

    Please, why the combativeness and the tone? It’s not helpful (nor accurate).

    You replied in that thread that you had no or little expertise in the science (I recall you saying something to the effect that you struggle, I forget the exact words now). That’s fine. I’m not sure why you seem to think this is worth hassling me about.

    And just to be clear, I wrote briefly not out of rudeness or accusation, but to be concise.

    While I’m writing, in my previous comment I also overlooked in your favour that that you lifted private correspondence to the public without asking me. It may be a small matter to you, but the principle does bother me.

    You originally wanted an understanding of Séralini’s paper re adjuvants, to understand the science first you said or something to that effect—that seemed to be what you wanted and were struggling with.

    “If you want to argue that food safety regime shouldn’t require full formulation testing you need to show that adjuvants can’t materially increase toxicity, ever. That is simply impossible and our 8 year old is going to see right through it.”

    I’ve never argued _anything_ about food safety regimes and herbicides - you’re placing your argument on me here!

    Not my patch, but you might want to add that more than one agency might be involved, with different agencies looking at different aspects. (In NZ, the EPA would be one; a quick search shows they look at herbicides.) You might also want to add they might draw from overseas agencies’ reports, etc. Your things to follow up if you’re inclined - I haven’t time and it’s not my interest.

    “Obviously Eric’s 1999 literature review doesn’t cut it.”

    I’m not sure dismissing it like that is helpful. (I haven’t time to read it beyond the abstract.)

    “Neither does dismantling a few Seralini papers.”

    Perhaps worth considering: your argument follows a line Séralini is pitching and you may be better informed if you understood what his logic plays with.

    “If you want to argue that food safety regime shouldn’t require full formulation testing you need to show that adjuvants can’t materially increase toxicity, ever.”

    Not my topic, but not quite correctly phrased. It wants to factor in ‘increases to toxicity to a level that might cause harm’. Consider: if the toxicity increased from zip to zip + next to nothing, the binary logic in “materially increase toxicity, ever” might be formally correct, but it would be nonsensical in real terms.

    Put another way, dosage invariably matters and toxicities (or any biological effects, enzyme activities, whatever) work in continuous scales not is/is not.

    By the way, I don’t write posts on poor claims on GMOs, vaccines, etc., because I have a fondness for them so much as out of a sense of public duty. I would much rather be writing on the really interesting things happening in genetics, genomics or computational biology and other things. It’s a pain in the neck dealing with responses that take me away from what I’d prefer to do, especially people with anti-GM, anti-vaccine, etc., views tend to try be combative or adversarial rather than discuss and work to understanding.

  7. Dear Grant

    I'm very sorry this is all such a pain in the neck for you. Seriously, for all and any grief you have suffered due to me, whether described above or left unsaid, I really am truly sorry. It was never my intention to hurt you or offend you in any way.

    Thanks for clarifying that this isn't actually your patch too and let me assure you that I'll think none the worse of you if you don't comment further for that reason.

    In case you do wish to continue though, I happily concede the theoretical possibility of your "zip + next to nothing" scenario. In return I'd ask you to recognise that it'd be a daunting task (as yet unattempted) to turn that theory into a general defence of what seems to be the status quo.

  8. Readers might like to investigate these links & notes:

    re “such a pain in the neck” - I was making a general observation, not one specifically about you. I thought that was clear. Not everything is about you! :-) (Your main nuisance to me is lifting from my private correspondence and misrepresenting me in public - things it’s worth being careful about in my humble opinion.)

    I said *regulatory* stuff isn’t my thing (just as biology doesn’t appear to be yours); I’m fine with the biology - that aspect is just a time thing - I haven’t much of it!

    What I pointed to isn’t a “theoretical possibility” - it’s how biology works: “dosage invariably matters and toxicities (or any biological effects, enzyme activities, whatever) work in continuous scales not is/is not”. You can’t treat biological activities as is/is not. (My example was to one end of the scale just to highlight the point; you point to the example, not the point it illustrates.)

    You might want to check what the EPA does, as I suggested, and that the EU (for one) in fact does check adjuvants, etc. (Contrary to what Séralini claims/implies.)

    (Excuse me if this is a duplicate; blogger’s login/posting regime isn’t one I use regularly and it’s not terribly user-friendly IMHO!)

  9. That's quite a slur on my integrity there Grant. I deny deliberately misrepresenting you and consider you have a duty to support your claim or retract it.

  10. One week later...

    I'm not going to speculate on why Grant hasn't withdrawn or substantiated his claim. But he hasn't.

    This is not how my ethical code works. I'm not in the habit of calling people liars but if I did, I'd feel obliged to supply details of that claim on request.

    Oh and by the way, the paper Grant discusses in the link above is not the one that Seralini discussed at the conference. Not that he says it is, just in case anyone thought it was.