Opinion: Pesticide Safety Unproven (André Leu) By André Leu It might surprise you to learn that there is no scientific proof of safety for the majority of the pesticides, additives or chemicals that companies put in our food and our body care and household products. Most are not tested, and when there is testing, it misses the vast majority of diseases at the normal rates at which they occur due to faulty protocols. According to the World Health Organization (WHO), there is a global epidemic of non-communicable chronic diseases: “Non-communicable diseases (NCDs), such as heart disease, stroke, cancer, chronic respiratory diseases and diabetes, are the leading cause of mortality in the world. This invisible epidemic is an under-appreciated cause of poverty and hinders the economic development of many countries. The burden is growing — the number of people, families and communities afflicted is increasing.” You cannot catch these diseases from other people. Their multiple causes are a result of environment and lifestyle. This means that we can prevent them by changing our habits and our food consumption so as to avoid the environmental exposures and lifestyle factors that cause them. Pesticides and chemicals are strongly implicated in this global epidemic, but the full extent of their role is being ignored by researchers and health professionals. This is because the current best practice testing guidelines for pesticides, food additives and chemicals are designed to miss the majority of diseases. Let’s look at these guidelines to understand why. Best Practice Testing Guidelines The Organization for Economic Co-operation and Development (OECD) Guidelines for the Testing of Chemicals are regarded as best practice for testing animals for diseases caused by chemicals such as pesticides and are similar to most good practice testing guidelines. Guideline 451 is used for testing chemicals, such as pesticides, for cancers. It requires that “Each dose group and concurrent control group should therefore contain at least 50 animals of each sex.” This is a group of 100 animals, with an equal number of males and females. The guidelines also state that “At least three dose levels and a concurrent control should be used.” This means that there must be one group of 100 animals, usually rats, as the control and are not dosed with the chemical. There will be three other groups of 100 rats in each group, each given a dosage of the chemical — one a high dose, one a medium dose and one a low. The numbers of cancers in each of the dosed groups are compared with the number of cancers in the control group. If the number of cancers is the same between the treated group and the control, then the researchers will conclude that the cancers were not caused by the chemical but by some other means, since the control group has not been exposed to the chemical. This result is then used to say that a chemical or pesticide does not cause cancer. However, there are serious flaws in this method. If just one animal from one of the dosed groups gets cancer, while none from the control group do, then the test results will say that the chemical caused one animal in 100 to contract cancer. This is the lowest theoretical rate of detection, and it means that cancer would only be detected if the pesticide caused more than 1,000 people per 100,000 to get cancer. The test could thus fail to detect lower rates of cancer. The problem is that actual rates of cancer from environmental exposure are often below 1 percent. Rates of diseases are reported as the number of people with the disease per 100,000 people. According to the U.S. Centers for Disease Control and Prevention (CDC), the rates of common cancers such as lung cancer are 57.5 people per 100,000; colon and rectum cancer 38 per 100,000; non- Hodgkin lymphoma 18.4 per 100,000; leukemias 13.2 per 100,000; pancreatic cancer 12.8 per 100,000; and liver and intrahepatic bile duct cancers 8.3 per 100,000. For sex-specific cancers such as breast, ovarian, cervical, endometrial, prostate and testicular cancers, the lowest theoretical level of detection is one animal in 50 because there are just 50 animals of each sex in a group. This means that these cancers would only be detected by Guideline 451 tests if there are more than 2,000 cases of cancer per 100,000 people. Consequently, despite no evidence of cancer being found in the dosed groups, the study would miss a chemical that could be causing common cancers. According to the CDC, in 2015 the rate of breast cancer was 124.8 women per 100,000; prostate cancer was 99.1 men per 100,000; ovarian cancer was 11 per 100,000; cancer of the cervix 7.6 per 100,000; and testicular cancer 5.6 per 100,000. There is no statistically valid way to determine that a dosed group of 100 animals that shows no sign of cancer can determine that the chemical in question cannot cause cancer at rates below 1,000 people per 100,000. All of the current cancers found in our communities will be missed. As an example, breast cancer affects 124.8 women per 100,000 in the United States. To positively determine if a pesticide does not cause this cancer, an experiment would need a control of 10,000 rats along with three dose groups of 10,000 rats each — 40,000 rats total. However, as far as I know, no such experiment has ever been done, so there is no evidence that pesticides are not contributing to breast cancer and that the levels in our food are safe. On the other hand, there is evidence showing that some pesticides are contributing to this cancer epidemic. Other Diseases OECD Guideline 408 is used for testing whether toxic chemicals cause diseases. It requires that “At least 20 animals (10 female and 10 male) should be used at each dose level.” Like cancer Guideline 451, Guideline 408 states that “At least three dose levels and a concurrent control should be used.” Guideline 408 states that a descending sequence of dose levels should be selected with a view to demonstrating any dosage related response and a NOAEL (No Observable Adverse Effect Level) at the lowest dose level. This is based on the dosage of the pesticide that does not cause any adverse effects to organs, tissues and other body functions of the test animals, compared to the control animals that have not been dosed with the pesticide. Under Guideline 408, one animal in 20 with a disease means that the disease could only be detected to a minimum of 5,000 cases per 100,000. For sex-specific diseases such as endometriosis and declines in fertility, the level of disease detection is just 10,000 cases per 100,000 people. This means that if there is no evidence of disease in the highest dose group then the test will miss a chemical that could be causing a chronic disease epidemic at the normal rates at which they occur. Not everybody who is exposed to a toxic substance that causes cancer or other diseases will get these diseases. Some people seem to be immune to them, such as people who have smoked tobacco and/or consumed alcohol all their lives and live to be 80 or 100. This is despite alcohol and tobacco being classed as Type 1 carcinogens — the highest level. However, there are other people who are sensitive to the smallest amounts of substances and can get seriously ill from this exposure. The NOAELs established by the current testing protocols cannot test for subgroups of people who are particularly sensitive to the smallest exposures to these chemicals. Most importantly, the OECD guidelines cannot test for most of the diseases that afflict our communities. As an example, the CDC gives the following numbers for some of the major diseases in the United States: 1,600 people per 100,000 have liver disease; kidney disease is 2,000 per 100,000; and stroke affects 3,000 people per 100,000. These diseases will be missed by the current best practice guidelines, which can only detect diseases to a minimum of 5,000 cases per 100,000 people. The only way this could be done statistically would be to have greater numbers of test subjects. Autism Spectrum of Diseases There is an autism epidemic in the developed world. According to the CDC, in 2014 the rates of autism were 1,680 children per 100,000, or one child in 59. In 2000 it was 670 children per 100,000, or one child in 150. This is a startling 250 percent increase in 14 years. A dramatic increase in a disease like this should be attributed to environmental and lifestyle factors rather than genetics. The current best practice testing guidelines will fail to detect if chemical/chemicals are causing this massive epidemic in our children. The OECD guidelines cannot detect a disease below 5,000 cases per 100,000. There is no way they could statistically detect a disease epidemic that affects 1,680 children per 100,000. The other major factor for not finding the chemical/chemicals responsible for an epidemic like autism is the fact that there has never been any testing of diseases in children. The OECD guidelines state, “young healthy adult animals of commonly used laboratory strains should be employed.” Fetuses, babies and pubertal animals (i.e., children) are not tested. This means that there will be no data on the safety of pesticides and other chemicals for children. The developing fetus, young childhood and going through puberty are three very critical periods in the development of humans and are completely ignored under the guidelines for diseases and cancer. There is no published scientific evidence-based testing to show that any of the current chemicals and pesticides are safe for our children, because there is no requirement to specifically test for them. There are many published studies that show that chemicals, including pesticides such as glyphosate and organophosphates, are significant contributors to the ADHD, autism, schizophrenia and bipolar spectrums of diseases because of the way they damage developing nerve cells. The brain is the largest collection of nerve cells. However, the full extent of their roles in causing multiple diseases will not be known until the guidelines for testing chemicals are changed to reflect the real rate of diseases in our communities, especially for children. The schizophrenia and bipolar spectrum of diseases typically start around puberty and early adulthood, but without testing for pesticides and other chemicals during the development of the fetus, childhood and puberty, there is no way to determine if they are contributing to this disease. Many diseases such as autism and ADHD are evident at birth. There needs to be testing on the mother and fetus to see if small amounts of pesticides are contributing to these disease epidemics. Ideally, these tests should be intergenerational, testing the parents first, then the pregnant mothers and their offspring throughout their development and life. OECD Guideline 416, “Two-Generation Reproduction Toxicity,” is the only methodology to cover this. It is focused primarily on reproductive effects, and if it were modified to test more than 10,000 pregnant females per group, it could be a very useful methodology to find diseases and/or to ensure a high probability that a chemical is safe. Until this is done, though, there is no valid science to assure us that any of the chemicals in our food, body care or household products are safe. Neither the pesticide and medical industries nor the government regulators have any evidence to state that known nerve toxins such as glyphosate, mercury, aluminum, organophosphates, pyrethroids and neonicotinoids are not contributing to this epidemic. The peer-reviewed scientific papers by Samsel and Seneff have extensively reviewed the published medical and scientific literature on glyphosate. Their research papers show how glyphosate is responsible for disrupting multiple metabolic and other biochemical pathways in animals. They show how these disruptions are linked to numerous diseases such as autism, cancers and celiac disease. Samsel and Seneff’s research has been rebutted by the pesticide industry, government regulators and some research scientists, who state that glyphosate is not toxic enough, or that the amounts are too low, to cause these multiple diseases. However, it is statistically impossible for the current best practice testing guidelines to find diseases that occur in less than 5,000 people per 100,000. Samsel and Seneff have presented a huge amount of peer-reviewed scientific evidence about the harm that glyphosate causes, whereas the detractors of their studies do not have any evidence of safety. The fact is that studies using OECD or similar guidelines that do not find cancer, autism or any other diseases cannot say that a chemical does not cause these diseases. The absence of a disease in these tests does not mean that it does not cause the disease and is safe. The opposite is true. It means there is no evidence that the chemical is safe. The Glyphosate Debate The decision by the International Agency for Research on Cancer (IARC) and the verdict in the Dewayne Johnson court case agreed that glyphosate is linked to non-Hodgkin lymphoma. The IARC paper showed how glyphosate caused cancer in test animals. The manufacturer states that it does not cause non-Hodgkin lymphoma or any other cancer. The published studies on glyphosate (and other pesticides), even if they used OECD or similar guidelines, use numbers of animals that are too small to detect any of the current cancers, and therefore there is no basis to say that it does not cause cancer. It is statistically impossible to use a testing methodology that can only detect cancers to a minimum level of 1,000 cancers per 100,000 people for common cancers like lung cancer that occur at rates of 57.5 people per 100,000, not to mention liver cancer, which affects 8.3 per 100,000. As an example, non-Hodgkin lymphoma affects 18.4 people per 100,000 in America. To positively determine that glyphosate does not cause this cancer, an experiment would need a control of 100,000 rats, along with three dose groups of 100,000 rats each — 400,000 rats total. If this experiment showed no sign of non-Hodgkin lymphoma, then it would be statistically probable that it did not contribute to the 18.4 people per 100,000 with the disease. There is no published evidence that a study of this size has ever been done on a pesticide. The fact is that the current testing protocols can only tell us if a pesticide causes a disease. It cannot tell us if a pesticide is safe. Finding no evidence that a pesticide does not cause cancer, autism or other diseases in a study is not the same as saying that the chemical in question does not cause these diseases. In my opinion, it is a gross misrepresentation to say that any of the current published toxicology studies can be used to say that any of the thousands of pesticide products used in the world do not cause cancer or other diseases. The fact is that there is no evidence that pesticides are safe. It is very concerning that when these tests show diseases, that the number of people who could be affected by the chemicals is extraordinarily high. It is important to remember that the majority of people get their exposure to pesticides from food. Most people, including children, carry a body burden of a cocktail of these toxic chemicals with no scientific evidence that they are safe. However, there is ample evidence that these chemicals are harming our children. Parents should ensure that they and their children only eat organic and regenerative foods from reliable sources, such as certified organic systems that can demonstrate that toxic pesticides such as glyphosate have not been used. For much more on this important topic, pick up a copy of Poisoning Our Children: The Parent’s Guide to the Myths of Safe Pesticides, available from the Acres U.S.A. bookstore or call 800-355-5313. André Leu is the author of The Myths of Safe Pesticides and Poisoning Our Children. He previously served as president of IFOAM — Organics International and is currently the international director of Regeneration International. This article appeared in the March 2019 issue of Acres U.S.A. magazine.