The recent “public consultation” conducted by the European Food Safety Agency (EFSA) on the pesticide glyphosate has been slammed by the community group GM-Free Cymru as “entirely unfit for purpose.” (1) The exercise, which came to an end on 11th May, was in theory designed to elicit public responses to an application for the renewal of European consent for the chemical glyphosate, which is the “active ingredient” of Monsanto’s Roundup herbicide. Unlike most of the other chemicals assessed by EFSA, there is a massive peer-reviewed literature — and huge public concern — about the effects of glyphosate on health and the environment (2).
When the Group tried to submit its evidence to EFSA via a designated electronic template, it found that the process that had been put in place was so byzantine and difficult to negotiate that it was virtually impossible to use. When requests were made to EFSA to behave in a more “user friendly” manner and to accept submissions by Email or by post, those requests fell on deaf ears. As a result, some members of the public who wished to send in submissions were so discouraged that they simply gave up on the idea.
GM-Free Cymru is now convinced that the system put in place by EFSA (in relation to glyphosate and other chemicals) was actively designed to discourage submissions from the public, and on that basis the group has issued a formal complaint to the European Ombudsman about EFSA maladministration. In its complaint, the Group claims the following:
1. EFSA refused (on the grounds of administrative inconvenience) to accept submissions sent by Email or via PDFs or by post. It insisted that all submissions should be entered via EFSA’s own online electronic template which “forced” comments into predetermined categories, with severe limitations on space.
2. Before receiving the key consultation documents (15 large PDFs) potential consultees were forced to sign this disclaimer: “By sending the request I acknowledge that EFSA has the right to disregard any comments not related to the risk assessment or received after the deadline set for the selected active substance. I also accept that comments have to be submitted electronically to the email address given in the general instruction by using the template.” GM-Free Cymru says that EFSA had no right in law to impose these conditions.
3. Although it is at liberty to examine the safety of the herbicide Roundup, EFSA has decided to eliminate all comments received which might relate to it, although that is the herbicide widely used across Europe in conjunction with cereal pre-harvest dessication and in many other situations. It is also the herbicide found in supplies of GMO corn and soy which are imported into Europe from Argentina, Brazil and the United States for use in the food chain. GM-Free Cymru argues that by restricting the public consultation to the “active ingredient” glyphosate, EFSA is seeking to avoid the much more important issue of Roundup toxicity. (3)
4. The fifteen PDF documents made available by the German regulatory authority (Germany is the member state taking the lead in the peer-review / reassessment process) comprised for the most part a mass of detail which was again almost impossible to penetrate. Although the German authority has expressed the strong view that glyphosate is safe and should be given a renewed consent, it is almost impossible to see from the documents how that conclusion has been reached (4). The recommendation from the German authority is in any case blacked out, presumably on the basis that it is something from which the public should be protected.
5. There is strong evidence in the literature relating to this consultation of very close — and possibly corrupt — links between the German regulatory authority and the pesticide industry lobby group called the European Glyphosate Task Force. There is a clear impression that the decision relating to the renewal of glyphosate consent is already fixed, for the commercial convenience of the pesticide / GMO industry (4); and that “inconvenient” comments from members of the public are not particularly welcome.
6. The consultation takes place in the context of ongoing attempts by EFSA to “loosen up” and speed up the regulatory regime relating to pesticides and GMOs, including attempts to shift the focus from a strict hazard assessment of glyphosate to a much broader risk assessment in which the commercial “benefits” of using the chemical might be used to trump the health and environmental damage involved (5).
Speaking for GM-Free Cymru, Dr Brian John said: “Our suspicion is that the electronic response system was designed by EFSA for the convenience of the pesticides and biotechnology industries, both of whom have dedicated and motivated staff who want to see the re-authorisation of glyphosate for their own commercial advantage. The system was designed for peer review by pesticides specialists and civil servants, and not for public consultation. It is therefore biased, and heavily weighted towards those who want to see glyphosate continue in use — whatever the dangers to the public health and to the environment may be. It is entirely unfit for purpose.”
The Group claims that through the “consultation methodology” forced on members of the public, EFSA is guilty of maladministration, as a result of which democratic rights are denied and the health of the citizens of Europe is placed at risk.
This is yet another complaint of maladministration brought against EFSA, which has been pilloried in recent years for its pro-industrial bias, for its revolving doors with industry, and for its blind adherence to the position that there cannot possibly be anything wrong the GMOs and their related chemical products. (6)