No cumulative testing for Roundup. At all.

platterWhat is cumulative testing for pesticides?

Toxicity testing that tests more than one pesticide at the same time.  To make sure that when different pesticides accumulate together in our bodies,they’re safe.

Many different types of pesticides can be found on just one piece of fruit or a vegetable. Many different sprays can be used over the growing season for a variety of purposes.

Great, farmers need these tools.

But I would like to draw your attention to the fact that most of these pesticides are never tested together – cumulatively.

Especially the pesticide considered the most common pesticide in the world.

The US EPA mentions a testing program – it’s framework was established back in 2003. Roundup is not included.

Europe is currently working on their ‘cumulative assessment group methodology for pesticides’.  Cross to Europe’s ‘Scientific Opinion on the identification of pesticides to be included in cumulative assessment groups on the basis of their toxicological profile’. Roundup does not appear to be included.

Please advise SafeSaysWho if you know of any cumulative testing program of pesticides required by the World Health Organisation.

Internationally, glyphosate, the active ingredient in Roundup – simply isn’t tested together with any other pesticide.

And of course, as I repeat ad nauseum, there are no tests whatsoever held with the world authorities of the full stronger formula, Roundup.

How is Roundup excluded from cumulative testing?

The US EPA and Europe require pesticides to have a common mechanism of toxicity, for specific classes of pesticides to exhibit similar toxicological properties to a specific organ or system.

Glyphosate, the most commonly used pesticide in the world, is cleverly shelved into a minor class and conveniently ignored.

It’s regarded as a phosphanoglycine.

Other phosphanoglycine herbicides include: bensulide, bialaphos, ethephon, glufosinate and piperophos.

Glyphosate is a member of the organophosphate family because its chemical makeup includes carbon and phosphorous.  However, according to conventional scientific literature it acts a little differently from most organophosphates because glyphosate is not an organophosphate ester but a phosphanoglycine.

Through being a phosphanoglycine glyphosate, and hence Roundup, is excused from inclusion as an organophosphate pesticide (which contain organophosphate esters).  Various references on the internet states that glyphosate does not affect the nervous system in the same way as organophosphate insecticides, and that glyphosate not a cholinesterase inhibitor.

To quote Extoxnet: ‘While it can be described as an organophosphorus compound, glyphosate is not an organophosphate ester but a phosphanoglycine, and it does not inhibit cholinesterase activity’. [1]

This is the major loophole for pesticide companies to avoid testing glyphosate with other pesticides- for cumulative toxicity testing.  Here is the organophosphates testing program selected for cumulative studies with the EPA. And of course glyphosate is not included.

The most used pesticide, the most controversial pesticide, slipped through the net.

For years glyphosate was differentiated because scientists used to think it was not a cholinesterase/acetylcholinesterase (ChE) inhibitor but recent research studies [2] [3] [4] [5] refute this.  For example, in the Helman study, the fish didn’t die, but all levels showed an inhibitory effect on AChE.  Where are the up to date studies researching mammals? No funding.

This could move Roundup/glyphosate into a much more dangerous class – an endocrine disruptor, a xenohormone (like, for example, another organophosphate, atrazine).

Disorders and disease related to xenohormone exposure

1.            Increase in reproductive-site cancers (breast, uterine, & ovarian)

2.            Decreased fertility in both male and females

3.            Estrogen dominance

4.            Increased incidence of prostate cancers

5.            Heart disease

6.            Diabetes type 2, adult onset

7.            Premature Ovarian Failure

8.            Uterine leiomyomas

9.            Prostrate Cancer

10.          Obesity

11.          Thyroid Disruption

12.          Testicular Dysgensis Syndrome

13.          Endometriosis

14.          Uterine Fibroids

 Glyphosate needs reassessment and reclassification – by an independent scientific body.


It’s not considered neurotoxic by the EPA – as a result of the tests supplied by Cheminova, Syngenta and Monsanto, the corporations that supply the only studies that end up giving the safety levels. Therefore the USA doesn’t require neurotoxicity studies as part of its risk evaluation process.

(Please note the US EPA, WHO and Europe only ever ask the registrant, the pesticide corporation, to supply the studies required for toxicity assessment).

AChE (see above) ‘is an enzyme that metabolises the excitatory neurotransmitter acetylcholine. AChE inhibitors such as organophosphate pesticides are potent nerve agents’. Could there be a heightened effect on the brain from cumulative pesticide exposure?  We don’t know.


Herbicide resistant GMO’s (Eg. Roundup Ready varieties) are the GMO varieties that dominate.

While GMO’s were originally released as single trait varieties (Eg. Roundup Ready), they have evolved and now it is rare for farmers to purchase GMO’s with single traits.

What we have now are ‘stacked events’. Hybrids. For example Roundup Ready Corn with the Bt toxin insecticide. You could have three traits, 2 different toxins and a herbicide tolerance.

This Cornell University article explains stacked events further.

Stacked trait event products are a result of the inevitable growth of resistance to the single trait varieties. Naturally, the pesticide corporations are building more muscle into this war.

The latest product 2,4-D Tolerant Enlist Corn is a triple stacked event. It combines Roundup Ready, 2,4-D Ready, and tolerates glufosinate. (Glufosinate is the active ingredient in the ‘Liberty’ line of Bayer CropScience Herbicides). As researcher Charles Benbrook says, ‘If new genetically engineered forms of corn and soybeans tolerant of 2,4-D are approved, the volume of 2,4-D sprayed could drive herbicide usage upward by another approximate 50%’.

There is not one single study in the world testing the cumulative effects of 2,4-D and Roundup together, (let alone glufosinate as well).

Every research study held with the EPA, WHO and Europe that declares 2,4-D safe is paid for by Dow or an industry group which includes Dow.

Every research study held with the EPA, WHO and Europe that declares Roundup safe is paid for by Monsanto, Cheminova and Syngenta.

And there is no toxicity study in the world testing 2,4-D together with Roundup.

There is simply not enough public domain science supporting GMO food.

How to fix it.



[1] Extoxnet  or  Cornell listing  References:    Kidd, H. and James, D. R., Eds. The Agrochemicals Handbook, Third Edition. Royal Society of Chemistry Information Services, Cambridge, UK, 1991 (As Updated).10-2.   Kidd, H. and James, D. R., Eds. The Agrochemicals Handbook, Third Edition. Royal Society of Chemistry Information Services, Cambridge, UK, 1991 (As Updated).10-2

[2]  Sandrini JZ, Rola RC, Lopes FM, Buffon HF, Freitas MM, Martins Cde M, da Rosa CE.   Effects of glyphosate on cholinesterase activity of the mussel Perna perna and the fish Danio rerio and Jenynsia multidentata: In vitro studies.  Aquat Toxicol. 2013 Apr 15;130-131:171-3. doi: 10.1016/j.aquatox.2013.01.006. Epub 2013 Jan 18.

[3]  Menéndez-Helman RJ, Ferreyroa GV, dos Santos Afonso M, Salibián A. Glyphosate as an acetylcholinesterase inhibitor in Cnesterodon decemmaculatus. Bull Environ Contam Toxicol. 2012 Jan;88(1):6-9. doi: 10.1007/s00128-011-0423-8.

[4] Acute effects of glyphosate herbicide on metabolic and enzymatic parameters of silver catfish (Rhamdia quelen).  Lissandra Glusczak, Denise dos Santos Miron, Bibiana Silveira Moraes, Róli Rodrigues Simões, Maria Rosa Chitolina Schetinger, Vera Maria Morsch, Vânia Lucia Loro . Laboratório de Bioquímica Adaptativa, Departamento de Química, Universidade Federal de Santa Maria, Santa Maria, RS, Brazil.

[5] Effect of glyphosate-based herbicide on acetylcholinesterase activity in tadpoles, Hoplobatrachus rugulosus.  Commun Agric Appl Biol Sci. 2011;76(4):923-30. Ruamthum W, Visetson S, Milne JR, Bullangpoti V.    Department of Zoology, Faculty of Science, Kasetsart University, 50 Phahon Yothin Road, Chatuchak, Bangkok 10900, Thailand.  

[6] Disorders and disease related to xenohormone exposure.

[7]  Impacts of genetically engineered crops on pesticide use in the U.S. — the first sixteen years. Charles M Benbrook

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