Final Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017

This document is a Notice of Objection filed on July 24, 2017, by a coalition of environmental and health organizations—including the Canadian Association of Physicians for the Environment and the David Suzuki Foundation—against the Pest Management Regulatory Agency's (PMRA) re-evaluation decision (RVD2017-01) on glyphosate. The objectors argue that the PMRA failed to consider critical evidence regarding glyphosate's impact on the monarch butterfly, human and soil microbiomes, and carcinogenic risks, while relying on flawed risk management strategies such as riparian buffer strips and product labelling.

• The objectors claim the PMRA failed to account for the causal link between glyphosate use and the decline of the monarch butterfly, specifically through the destruction of milkweed (Asclepias syriaca) in agricultural regions. They cite evidence that milkweed abundance in some soy fields declined by more than 70% following a single glyphosate application.
• The document asserts that the PMRA ignored evidence regarding glyphosate's impact on the human gut microbiome and soil microbiota. It notes that glyphosate is a patented antibiotic and that its use in soil can lead to a shift toward fungal species and an increase in aflatoxins in grains.
• The objectors argue that the PMRA's cancer risk assessment was flawed because it excluded significant epidemiological studies and ignored findings from animal studies. They reference an analysis by Dr. Christopher Portier, who identified eight significant increases in tumor incidence in animal studies that were not reported in government evaluations by EFSA or ECHA.
• The report claims that the PMRA failed to assess the chronic toxicity of commercial glyphosate formulations, focusing instead on the active ingredient (glyphosate acid). It cites research suggesting that co-formulants, such as the surfactant polyoxyethylene tallow amine (POEA), can be significantly more cytotoxic than glyphosate alone.
• The objectors challenge the efficacy of riparian buffer strips (RBS) as a risk management strategy, citing Canadian research from Québec indicating that 3-meter-wide RBS do not significantly decrease the leaching of glyphosate and its byproduct AMPA into runoff waters.
• The document argues that the PMRA's reliance on product labelling to manage risk is unsupported by scientific evidence and fails to account for knowledge gaps, such as the fact that precautionary statements are often misinterpreted by users.
• The objectors state that glyphosate acts as a chelator, which may lead to the mobilization of the neurotoxic carcinogen cadmium in grains, a risk they claim the PMRA dismissed as being beyond the scope of pesticide assessment.
• The document criticizes the PMRA's methodology for lacking systematic review rigour and transparency. It identifies several instances of duplicate reports in the PMRA's reference lists, which the objectors claim creates a false impression of the volume of available evidence.

APA

Canadian Association of Physicians for the Environment (2017). Final Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017. https://cape.ca/wp-content/uploads/2018/03/1.Letter-to-Minister-Philpott-re-Final-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-July-2017.pdf

Chicago

Canadian Association of Physicians for the Environment. Final Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017. 2017. https://cape.ca/wp-content/uploads/2018/03/1.Letter-to-Minister-Philpott-re-Final-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-July-2017.pdf.

Wikipedia

{{cite report |author=Canadian Association of Physicians for the Environment |title=Final Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017 |date=24 July 2017 |url=https://cape.ca/wp-content/uploads/2018/03/1.Letter-to-Minister-Philpott-re-Final-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-July-2017.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{canadianassociationofphysiciansfortheenvironment2017final, author = {{Canadian Association of Physicians for the Environment}}, title = {{Final Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017}}, institution = {Canadian Association of Physicians for the Environment}, year = {2017}, month = jul, url = {https://cape.ca/wp-content/uploads/2018/03/1.Letter-to-Minister-Philpott-re-Final-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-July-2017.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }