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

A formal Notice of Objection filed by a coalition of environmental and health organizations, including the Canadian Association of Physicians for the Environment, challenging the Pest Management Regulatory Agency's (PMRA) re-evaluation decision (RVD2017-01) on glyphosate. The objectors argue that the PMRA dismissed critical evidence regarding glyphosate's impact on monarch butterflies, human and soil microbiomes, carcinogenic potential, and the inefficiency of current risk mitigation strategies like buffer zones and labeling.

• The PMRA failed to consider evidence linking glyphosate use to the decline of monarch butterflies by ignoring the herbicide's impact on milkweed (essential for breeding) and nectar-producing flowers (essential for migration). In the US Midwest corn and soy belt, milkweed declines have been measured between 93.7% and 96.5%.
• The objectors claim the PMRA ignored evidence of glyphosate's carcinogenic potential, specifically citing Dr. Christopher Portier's analysis which identified eight significant increases in tumor incidence not present in government evaluations. The PMRA allegedly only included 3 of 21 studies identifying positive tumor findings.
• The PMRA is criticized for assessing only the active ingredient (glyphosate acid) rather than commercial formulations. Evidence suggests co-formulants like polyoxyethylene tallow amine (POEA) can be significantly more toxic; one study found POEA was ten thousand times more cytotoxic than glyphosate in human tissue culture cells.
• The document argues that riparian buffer strips (RBS) are inefficient for mitigating glyphosate leaching. Research in Québec indicates that 3-m-wide RBS do not significantly decrease aqueous glyphosate and AMPA leaching in runoff waters and may even increase infiltration into groundwater.
• The objectors assert that the PMRA's reliance on product labeling as a risk management strategy is not based on scientific grounds and fails to account for knowledge gaps, such as the fact that precautionary statements are often misinterpreted by users.
• The PMRA is accused of ignoring glyphosate's role as a chelator, which can deplete essential soil minerals and mobilize the neurotoxic carcinogen cadmium in grains.
• The document highlights that the PMRA's lowest No Observed Adverse Effect Level (NOAEL) of 32/34 mg/kg bw/day is significantly higher than concentrations where hepatotoxicity, reprotoxicity, and teratogenicity have been reported in studies.

APA

Canadian Association of Physicians for the Environment (2017). Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017. https://cape.ca/wp-content/uploads/2018/03/2.Letter-to-Minister-Philpott-re-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-June-2017.pdf

Chicago

Canadian Association of Physicians for the Environment. Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017. 2017. https://cape.ca/wp-content/uploads/2018/03/2.Letter-to-Minister-Philpott-re-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-June-2017.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017 |date=26 June 2017 |url=https://cape.ca/wp-content/uploads/2018/03/2.Letter-to-Minister-Philpott-re-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-June-2017.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2017notice, author = {{Canadian Association of Physicians for the Environment}}, title = {{Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2017}, month = jun, url = {https://cape.ca/wp-content/uploads/2018/03/2.Letter-to-Minister-Philpott-re-Notice-of-Objection-to-Glyphosate-Re-evaluation-Decision-June-2017.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }