• The assessment only considers a 70 kg adult, not a fetus, infant or child.

• The assessment does not follow OEHHA's Code of Regulations 25703 because it was based on one bioassay (animal) study, not epidemiology studies, as required.

• The assessment would not protect children, as described above, children are already 2 x higher than the NSRL, and could be nearly 6 times higher, according to EPA allowances.

• The assessment does not include co-formulants which have been shown to be 1000X higher.

• The proposed level does not include exposure to glyphosate herbicides at playgrounds, near farms, or backyard gardens.

• The assessment does not include impact to pollinators, wildlife, soil or marine life.

• The assessment does not include the fact that glyphosate is also an endocrine disruptor at minute levels.

My name is Zen Honeycutt, Mom of 3 boys, who had severe health issues before we began avoiding glyphosate in our diet. I am also the Founder and Director of Moms Across America and I speak on behalf of thousands of mothers and families who are struggling with health issues in the CA.

We do not want any glyphosate exposure to our children through food, water or any products. We want the current products which do contain glyphosate to be immediately labeled. The current scientific data and skyrocketing numbers of children and family members with chronic illness and cancer show us that the only ethical action for the CAL-EPA to declare a NO safe level of glyphosate. Zero.

Before you dismiss this request as unreasonable, consider that the amount of glyphosate in our food and the OEHHA current proposal is actually what is unreasonable.

Share the Facebook link to a video of Glyphosate in Food click Here.

The levels of glyphosate in our food currently, and the risk we face, due to the allowable levels of glyphosate residues, set by the EPA, are as follows:

Here are the calculations of a child’s intake glyphosate in one day

Numbers are the maximum risk exposure as set by the EPA in micrograms per kg.

Breakfast- Oatmeal 1,275, Orange juice 42.4, Eggs 4.2.

Snack - Berries 22.6 and chips 2,547 and water 700.

Lunch- Pita and Hummus 5,100

Snack Toast and Jam 1,100

Dinner - Pasta 560 and Milk at least 30.7   

Available testing data shows that our children are currently being exposed to glyphosate at levels 2.2 X higher than the proposed NSRL Of 1100 micrograms per day. And their risk of exposure, according to the EPA allowable levels, is at least 5.6 X higher.

 It is clear that the amount of glyphosate our children are and could be exposed to according to the EPA is millions of times higher than has been shown to cause liver disease, destroy gut bacteria, or cause cancer.

If  OEHHA followed 25703 CA code of regulations they would consider ALL available studies showing harm. For example:

In Mesnage and Antoniou’s study, 4 nanograms per kg caused liver disease which predisposes cancer. This level is 4000 times lower than the proposed NSRL.

Carrusco’s and Monika Kruger’s studies, glyphosate has shown to destroy beneficial gut bacteria at 0.1ppb and promote the proliferation of pathogenic gut bacteria.

The gut bacteria is where 70% of the immune system lies, making a child is much more likely to get cancer. Cancer is now the number 1 or 2 killer of children in America.

High levels of daily glyphosate exposure can create an environment in the gut for Candida and fungus cause inflammation which can contribute to autoimmune disease and cancer.

Destroyed gut bacteria cannot expel heavy metals properly. The toxins build up in the liver and the body, which can lead to cancer.

When glyphosate destroys the gut bacteria, the gut biome can no longer make essential hormones which can lead to multiple forms of cancer such as Thyroid, NHL, breast and reproductive cancers.  1 out of 2 males and 1 out of 3 females in America are expected to get cancer today.

The lowest level of glyphosate showing harm is Thongprangisang’s study of 1 ppT showing glyphosate stimulates the growth of breast cancer in vitro. This means, according to the EPA, that the lowest exposure level should be 100 fold less which  10 ppQ. This is millions of times lower than the proposed NSRL.

However, because Ridly and Mirely’s and Monika Krueger’s  studies show that glyphosate bioaccumulates in the bone marrow, that 10 ppQ should be a one time lifetime exposure, not daily. Bioaccumulation is why there is no safe level of glyphosate.

I get contacted by moms almost daily that their child has chronic disease or cancer. I was told that my son’s gut issues could lead to stomach cancer. When I removed glyphosate from his diet, his gut issues drastically improved. I believe I am preventing my son from stomach cancer by avoiding glyphosate and eating organic. Every Californian however, no matter whether they can afford organic food or not, should be able to protect their child. They will be protected from glyphosate if you take the action of setting NO safe level of glyphosate. With this setting, food manufacturers will have to label their food for glyphosate. Many will instead source ingredients which do not allow glyphosate, and then, even people who cannot afford organic will be protected.

 You have an opportunity to transform the health of our state.

Thank you.

PUBLIC COMMENT PERIOD EXTENDED to JUNE 21, 2017 by 5:00 pm PT Sacramento, California

LINKS to Choose: CA State Website or Email to Comment (Please do not comment on both):

1) CA OEHHA Online Comments: https://oehha.ca.gov/proposition-65/comments/proposed-specific-regulatory-level-chemical-causing-cancer-glyphosate

2) Email CA OEHHA: Esther Barajas-Ochoa [email protected]

Include In Subject Line: “GLYPHOSATE NSRL”

Sources

Multiomics reveal non-alcoholic fatty liver disease in rats following chronic exposure to an ultra-low dose of Roundup herbicide Mesnage, Reney, Seralini, Ward, Antoniou

The Effect of Glyphosate on Potential Pathogens and Beneficial Members of Poultry Microbiota In Vitro Awad A. Shehata • Wieland Schro¨dl • Alaa. A. Aldin • Hafez M. Hafez • Monika Kru¨ger

Allergy and the gastrointestinal system G Vighi,* F Marcucci,‡ L Sensi,‡ G Di Cara,‡ and F Frati‡

Genetic Heavy Metal Toxicity: Explaining SIDS, Autism, Tourette's, Alzheimer Tara Lang Chapman

The Effect of Glyphosate on Potential Pathogens and Beneficial Members of Poultry Microbiota In Vitro Awad A. Shehata • Wieland Schro¨dl • Alaa. A. Aldin • Hafez M. Hafez • Monika Kru¨ger

Gut microbial degradation of organophosphate insecticides-induces glucose intolerance via gluconeogenesis Ganesan Velmurugan1*, Tharmarajan Ramprasath2 , et al.

Glyphosate induces human breast cancer cells growth via estrogen receptors. Thongprakaisang S1, Thiantanawat A, Rangkadilok N, Suriyo T, Satayavivad J.

Increase of non Hodgkin’s Lymphoma, International Agency for Research on Cancer in International Journal of Environmental Research and Public Health

In addition:

Non-Hodgkin Lymphoma and Occupational Exposure to Agricultural Pesticide Chemical Groups and Active Ingredients: A Systematic Review and Meta-Analysis http://www.mdpi.com/1660-4601/11/4/4449/htm Leah Schinasi and Maria E. Leon http://www.gmoevidence.com/dr-schinasi-glyphosate-herbicides-linked-to-non-hodgkins-lymphoma/

Integrative assessment of multiple pesticides as risk factors for non-Hodgkin’s lymphoma among men A J De Roos, S H Zahm, K P Cantor, D D Weisenburger, F F Holmes, L F Burmeister, A Blair

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1740618/pdf/v060p00e11.pdf 

Our children’s future is being compromised from glyphosate herbicides and toxic chemicals. That means our future as a state, and as a nation is being compromised by allowing chemical companies to poison us. The people of California will be forced to continue to contaminate our children, strain our resources, and sabotage our state unless you take bold action. It is simply a matter of state and national security to declare a NO safe level of glyphosate.