GM-Free Cymru has filed a formal complaint over the EFSA’s farcical “public consultation” over whether the EU should renew its approval of glyphosate and raise the allowable level of the poison in water and food, as Germany, the EU’s “rapporteur state” for glyphosate, recently recommended.
Although the EFSA is legally required to receive public comments, it flouted this requirement by setting up a tortuous, arcane online submission system which was designed to make it near-impossible to submit substantive comments. Respondents were required to tailor their comments to EFSA specifications including tight space restrictions. The EFSA required commenters to sign a waiver basically disavowing their right to have their comments published at EFSA discretion. This too is designed to evade the law. There are several other parts of GM-Free Cymru’s complaint detailing how the process is openly discouraging to potentially adverse commenters, and how the initial German assessment is corrupt and has had information illegally and unscientifically redacted from public releases.
Most substantively fraudulent, the EFSA declared that it would delete any comments which referred to Roundup. Respondents are allowed to comment only on glyphosate. This is in spite of the fact that in agricultural practice it’ll be Roundup and similar formulations which are actually sprayed, while pure glyphosate is never used anywhere but in the laboratory test.
This is a standard scam on the part of poison manufacturers and regulators. The regulatory process, meager and inadequate as it is, deals only with an isolated so-called “active ingredient” such as glyphosate. It never deals with the kind of commercial formulation which will be used in the real world. Therefore it’s a fraud from any scientific or government ethics point of view. “Active ingredient” isn’t a practically meaningful term, since the commercial formulation will contain several bioactive ingredients. Instead this is an ideological term meant to isolate one ingredient in an unworldly ivory tower manner. Under such isolation of a single ingredient which never appears in isolation in reality, it’s easier for corporations and regulators to manufacture the sham semblance of testing and assurances of safety.
Meanwhile independent testing and epidemiological evidence has abundantly documented that many such commercial poisons are far more toxic in their real-world form than the “active ingredient” is in laboratory isolation.
In the case of glyphosate, the evidence proves that the combination of glyphosate with the surfactant POEA is far more toxic to human health than glyphosate in isolation. This combination, along with several other truly active poisons, is typical of glyphosate’s commercial formulations including Roundup.
Regulators are practically robotic in mechanically raising allowable levels of industrial poisons in air, water, soil, crops, food, and human bodies in response to corporate demands. It’s literally the case that the regulator sets the “safe” level of the poison based on how much of the poison the corporations expect to sell. When the corporations project a market expansion and concomitant increase in the environmental presence of the poison, they lobby the regulator to raise the “safe” level commensurately. The regulator invariably complies, since the regulator sees its job as to assist the corporate prerogative, never to hinder it.
I’ve described this process before, calling it “regulator triangulation”. By triangulation I mean the regulator pretends to be a public servant but is really trying to represent a corporatist agenda as “public service”.
1. The government regulator regards the corporate prerogative as normative. Indeed, as an EFSA memo discussing the EU law which would gradually ban endocrine-disrupting chemicals like Roundup openly says, the regulator ideology is based on an assumed corporate right to maximum profit. Any competing value is generally considered an irritant to be quashed. Under no circumstance will even the most conscientious regulator do anything which would seriously hinder corporate profit and control.
2. Given (1), a regulator may or may not try to ameliorate the worst harms and “abuses”. As we see in this case and many others, the EFSA is the kind of bureaucracy which doesn’t even want meager amelioration, but is gung ho on behalf of the full corporate onslaught.
3. The regulator then places its imprimatur on the resulting policy. It calls this the result of meticulous deliberation which takes the public interest into account. It declares the product “safe” and promises its own professional vigilance in ensuring the policy is carried out. But in fact only the corporate agenda and how to camouflage it went into the deliberation, “safe” is an Orwellian term which means, “what’s the minimum paper restraint we can politically get away with?”, and there’s seldom even a modest attempt on the regulator’s part to enforce this sham minimum. The US EPA’s “refugia” policy for Bt crops is a good example of a policy which is weak and insufficient in principle and is indifferently enforced in practice, whose only real purpose is as propaganda.
By means of this parallax effect the regulator helps direct public attention to a sham depiction of “good government” and “public health” while the real position is a direct, coordinated assault of the corporate state on public health and on every other human value.
The EFSA’s campaign to help force more of this viciously toxic poison upon us while making it look “safe” is a typical example. As is the contempt for democracy and accountability it’s demonstrating in the process. But then, the whole “public comment” process is intrinsic to the basic regulation scam.