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

The document argues that the PMRA's re-evaluation of glyphosate is flawed due to the dismissal of critical evidence concerning ecological risks, human health impacts, and the inefficiency of proposed risk management strategies.

• The PMRA failed to adequately consider the link between glyphosate use and the decline of monarch butterflies, specifically by ignoring the herbicide's impact on milkweed (Asclepias syriaca), which is essential for monarch breeding.
• The document asserts that the PMRA ignored evidence regarding glyphosate's impact on both human and soil microbiomes, despite glyphosate being registered as a patented antibiotic.
• The authors claim the PMRA's cancer risk assessment was biased and incomplete, noting that it excluded several statistically significant animal studies and failed to reference a large federally-funded Canadian case-control study on non-Hodgkin Lymphoma.
• The PMRA is accused of failing to assess the chronic toxicity of commercial glyphosate formulations, relying instead on the active ingredient (glyphosate acid), which may underestimate risks since co-formulants like POEA can be significantly more toxic.
• The document argues that the PMRA's reliance on riparian buffer strips (RBS) as a risk management strategy is unsupported by evidence, citing research from Québec showing these strips have low efficiency in minimizing glyphosate and AMPA leaching.
• The authors challenge the PMRA's use of labelling as a primary risk management strategy, stating there is a significant knowledge gap regarding its efficacy, particularly for migrant agricultural labourers.
• The PMRA is criticized for its lack of methodological rigour, specifically for not using systematic review protocols and for including duplicate studies in its reference lists, which may artificially inflate the weight of certain evidence.
• The document highlights that the PMRA failed to evaluate the chelation effects of glyphosate, which can lead to the mobilization of the neurotoxic carcinogen cadmium in grains.

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} }