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HomeMy WebLinkAboutCOM 0489.814 2018-2020 Murashige, Laura From: Peter Matlock <peter@biomatlock.com> q y ft Sent: Tuesday,January 07, 2020 2:25 PM To: Council Testimony Subject: Please do NOT overturn Mayor Kim's veto of Bill 101 (please read for the reasons) Dear Hawaii County Council, 1 urge you to NOT overturn Mayor Kim's veto of Bill 101. To overturn the veto and implement Bill 101 would be irresponsible and an abdication of public duty. We need sound, science-based policy that objectively evaluates alternatives, costs/benefits, actual versus perceived harms, uses data- driven analysis, and considers competing needs for limited public resources. The Bill 101 movement promotes incomplete and faulty analyses, and has failed to consider alternatives before banning a current solution that is already heavily regulated and practiced under controlled conditions to ensure safety. As pointed out by Mayor Kim, the list of pesticides to be banned is arbitrary, and seems driven primarily by desire to ban glyphosate. The primary focus on glyphosate in public discussions raises questions whether this effort is more a back- door attempt to discredit biotechnology crops than a sincere effort to enhance public safety. As an example of the many mis-statements surrounding this issue, a January 6, 2020 op-ed in the West Hawaii Today asserts that the"US Department of Health and Human Services US National Toxicology Program [labels] glyphosate as a 'probable human carcinogen.""' In fact, the US NTP says no such thing. The US NTP website (https:Hntp.niehs.nih..qov/whatwestud /ty opics/glyphosate/index.html?utm source=direct&utm medium=prod&utm campai gn=ntpgolinks&utm term=glyphosate) references the UN IARC's decision to list glyphosate as a probable human carcinogen, but also notes the European Food Safety Authority(EFSA) and UN FAONVHO concluded glyphosate is "unlikely" to be a human carcinogenic risk, and that due to the political controversy both the US EPA and US NTP are doing further studies but have not said there is a carcinogenic risk. Aside from the UN IARC's evaluation, leading worldwide government regulators have so far found glyphosate-based herbicides safe and not carcinogenic, including the US EPA, EFSA, ECHA, Australia, New Zealand, and the German BfR authority(source: Amici Curiae brief of the California Medical Association, et. al. in trial of Dewayne Johnson versus Monsanto Company). These regulators include those from countries (especially Europe and Germany)that have had the harshest political opposition to glyphosate. Of all the agricultural chemicals in use, glyphosate is among the most benign. It is non-toxic to mammals (we don't even have the same metabolic pathway), it is less toxic on an LD50 basis than caffeine, its half-life in the environment is short (months, instead of years compared to agents such as atrazine), and the link to NHL (the only cancer that is under discussion) is murky, controversial, and subject to often dubious methodology and small sample size biases. A prior IARC website listed the top global cancer concerns as tobacco, obesity, and alcohol, with no mention of glyphosate. Given their greater toxicity and carcinogenic potential, does Council further propose banning coffee, tobacco, obesity, and alcohol on Hawai'i Island? Epidemiological studies examining the potential carcinogenicity of glyphosate and its commercial formulations provide conflicting opinions regarding whether there is an actionable link to NHL, and generally state more thorough studies are required before establishing a purported link between glyphosate and NHL. The DeRoos 2005 study, which is one of the papers with a stronger statement of a potential link, says"Glyphosate exposure was not associated with cancer incidence overall or with most of the cancer subtypes we studied. There was a suggested association with multiple myeloma incidence that should be followed up as more cases occur in the AHS."Andreotti (2017, JNCI) concluded "In this large, prospective cohort study, no association was apparent between glyphosate and any solid tumors or lymphoid malignancies overall, including NHL and its subtypes," although there was some evidence (but not of statistical significance) of greater risk in those with the very highest exposures and a call for further study. Comm. 111Q. 1 Ref. o: WNW Ref. Dote JAN - 8 2020 The cart was put before the horse with Bill 101: the Bill seeks to ban pesticides first before Council/Countyunderstand the alternatives. County Parks& Rec says they need to hire 400 workers at$39,000 each, for direct salaries of$15.6 million. Benefits and additional County support staff need to be added on top of this, making a total personnel impact of $31.2million (doub|ing) not unreasonable. |fsalaries increase 296per year then in1Oyears this means$3Omillion in additional personnel expense, but if they increase 5% per year then personnel costs jump to$50.8 million. This doesn't include costs for new equipment and repaira, orfor other agencies. Before overtuning the Mayor's veto, it would be malpractice for the Council to ban these tools before having identified alternatives and the cost of these alternatives, and to incur such expenses without considering trade-offs with other urgent County needs. Finally, a court decision in the US judicial system means nothing to very little on a scientific basis. |naletter tothe West Hawaii Today(November 18. 2O1S). one ofthe jurors inthe Johnson vs. Monsanto trial said "My jury did not have hJ conclude that glyphosate definitively causes cancer in humans", making it irresponsible to base policy bans on the outcome of this trial. US jury trials are notorious for ignoring science and being swayed by emotion. In one famous case, a person held up their rotary lawn mower to use it as a hedge trimmer, tragically cut off their hand, and then won in court by saying the lawn mower manufacturer was liable. The U8Patent and Trademark Office moved patent infringement cases to a specialized court that was capable of understanding complex technical issues (and backward-looking epidemiology is a good example of complicated issue). The doctrine of joint and several |iabi|ity, in our legal system, under which Bayer/Monsanto was ordered topay large fines, is a means to reach into the deepest pocket--often regardless of scientific merit. Please act responsibly and doNOT overturn Mayor Kim's veto ofBill 1O1. Sincero|y, Peter Matlock ~-