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

The Canadian Association of Physicians for the Environment and partner organizations argue that the PMRA's re-evaluation of glyphosate is flawed due to the dismissal of critical evidence regarding biodiversity loss, human health risks, and the inefficiency of current risk mitigation strategies.

• The PMRA failed to account for the causal link between intensive glyphosate use and the decline of monarch butterflies, specifically through the destruction of common milkweed (Asclepias syriaca) in agricultural regions and the removal of nectar-producing vegetation along roadsides.
• The authors contend that the PMRA ignored statistically significant cancer findings and relied on flawed evaluations from the EFSA and EChA, noting that 18 of 21 studies identifying positive tumor findings were not included in the PMRA assessment.
• The PMRA is accused of failing to assess the chronic toxicity of commercial glyphosate formulations, focusing instead on the active ingredient (glyphosate acid) and ignoring evidence that co-formulants like polyoxyethylene tallow amine (POEA) can be significantly more cytotoxic.
• Evidence is presented that glyphosate may cause hepatorenal, reprotoxic, and teratogenic effects at concentrations lower than the lowest No Observed Adverse Effect Level (NOAEL) of 32/34 mg/kg bw/day used by the PMRA.
• The document argues that riparian buffer strips (RBS) are inefficient at preventing glyphosate and AMPA leaching into surface and groundwater, and that the PMRA provided no scientific evidence to support the efficacy of these buffer zones.
• The authors claim the PMRA's reliance on product labelling as a risk management strategy is unsupported by science and fails to account for knowledge gaps, such as the misinterpretation of precautionary statements by users and barriers faced by migrant agricultural labourers.
• The document highlights the PMRA's failure to evaluate the chelation effects of glyphosate, which can deplete essential soil minerals and mobilize the neurotoxic carcinogen cadmium in grains.

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} }