11 September 2012Via website post: httpGo to http://www.regulations.gov/#!documentDetail;D=APHIS-2012-0046-0001.Via email: biotechquery@aphis.usda.gov

Biotech QueryUnited States Department of Agriculture/ Animal and Plant Health Inspection Service (“APHIS”)Docket No. APHIS-2012-0046Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238

Cc: Dr. John Turner, Director, Environmental Risk Analysis Programs, Biotechnology Regulatory Services, APHIS, 4700 River Road Unit 147, Riverdale, MD 20737-1236; (301) 851-3954, email: john.t.turner@aphis.usda.govcc: Ms. Cindy Eck, APHIS (301) 734-0667/cynthia.a.eck@aphis.usda.gov

DOCUMENT ORGANIZATION PageOpening Remarks 1Petition Item List 5Preface 5Physiological damage in people and animals, pollinating insects 7Environmental damage caused by Monsanto GM agri products, herbicides, etc 8Body of the Discussion of Contentious Issues 9Deceitful FDA – USDA trials practices yielding flawed test results 10Anticompetitive and abusive corporate practices by Monsanto, Dow and biotech cartel of players which are the actual beneficiaries vs. alleged beneficiaries such as the organic farmers, the non gmo farmers, and society which trust and expect a non contaminated food supply that is neutral and benign. Et al

Dear Sir(s)/Ma'am(s):

I learned only yesterday about the USDA request for comment closing today on the petitions by herbicide and GMO –GE or-ganizations. Please accept my comment which exists in much of the same form and substance that I had submitted in 27 February 12, to apply as my comment as a concerned citizen who opposes deregulation of, and any sort of taint and DAN-GER AT ALL in our food supply and in our environment-biosphere, by way of crops such as the following and associated herbicides(Roundup and 2,4D) to which they’re tolerant: Dow such as “ENLIST”, 1) DAS-40278-9 (aka GMO), which has been genetically engineered for increased resistance to broadleaf herbicides in the 1a) phenoxy auxin group (such as the herbicide 2,4-D) and resistance to grass herbicides in the 1b) aryloxyphenoxypropionate acetyl coenzyme A carboxy-lase inhibitor group (such as quizalofop herbicides thus, all inclusive in my opposition I label as 2,4D (dioxin and related contaminants) by DOW Agriscience LLC as well as: [Docket No. APHIS–2012–0046] GENECTIVE SA- Petition for Determination of Nonregulated Status of Maize Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0032] Dow AgroSciences LLC - Petition for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0020] Monsanto Co.- Petition for Determination of Nonregulated Status of Soybean Genetically Engineered for Increased Yield; [Docket No. APHIS–2012–0035] Monsanto Co.- Petition for Determination of Nonregulated Status of Canola Genetically En-gineered for Herbicide Tolerance; [Docket No. APHIS–2012–0031] Pioneer Hi-Bred International, Inc,- Peti-tion for Determination of Nonregulated Status of Canola Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0027] Monsanto Co.- Petition for Determination of Nonregulated Status of Maize Ge-netically Engineered With Tissue-Selective Glyphosate Tolerance Facilitating the Production of Hybrid Maize Seed; [Docket No. APHIS–2012–0047] Monsanto Co.- Petition for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0025] Okanagan Spe-cialty Fruits, Inc.- Petition for Determination of Nonregulated Status of Apples Genetically Engineered To Re-sist Browning; [Docket No. APHIS–2012–0028] BASF Plant Science, LP - Petition for Determination of Nonreg-ulated Status of Soybean Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0024] Syn-genta Biotechnology, Inc. - Petition, Plant Pest Risk Assessment, and Environmental Assessment for Deter-mination of Nonregulated Status of Corn Genetically Engineered for Insect Resistance; [Docket No. APHIS–2012–0019] Dow AgroSciences LLC - Petition, Plant Pest Risk Assessment, and Environmental Assessment for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0029] Bayer CropScience LP - Petition, Plant Pest Risk Assessment, and Environmental As-sessment for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Toler-

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ance. Please where throughout the document where I condemn and urge rejection of the Petition by Dow or Monsanto for their use of additional herbicides and their GMO tolerant and terminator grains, substitute the list I provided beginning with [Docket No. APHIS–2012–0046] and ending with [Docket No. APHIS–2012–0029]

I also urge re-regulation and actually ban-prohibit-cease and desist ALL GMO. THE USDA leaves itself open for mockery, ridicule and Department of Justice legal review or Court system rules against itself related to how it recently de-regulated GMO – Per Mother Jones’ Tom Philpott, “It's a hoary bureaucratic trick, making a controversial announcement on the Friday afternoon before a long weekend, when most people are daydreaming about what beer to buy on the way home from work, or are checking movie times online. But that's precisely what the US Department of Agriculture pulled last Friday.

In an innocuous-sounding press release titled "USDA Responds to Regulation Requests Regarding Kentucky Bluegrass," agency officials announced their decision not to regulate a "Roundup Ready" strain of Kentucky bluegrass—that is, a strain genetically engineered to withstand glyphosate, Monsanto's widely used herbicide, which we know as Roundup. The maker of the novel grass seed, Scotts Miracle Gro, is now free to sell it far and wide. So you'll no doubt be seeing Roundup Ready bluegrass blanketing lawns and golf courses near you—and watching anal neighbors and groundskeepers literally dousing the grass in weed killer without fear of harming a single precious blade.

Which is worrisome enough. But even more worrisome is the way this particular product was approved. According to Doug Gurian-Sherman, senior scientist at the Union of Concerned Scientists' Food and Environment Program, the documents released by the USDA's Animal and Plant Health Inspection Service (APHIS) along with the announcement portend a major change in how the feds will deal with genetically modified crops.

Notably, given the already-lax regulatory regime governing GMOs (genetically modified organisms, click here for a primer), APHIS seems to be ramping down oversight to the point where it is essentially meaningless. The new regime corresponding with the bluegrass announcement would "drastically weaken USDA’s regulation," Gurian-Sherman told me. "This is perhaps the most serious change in US regs for [genetically modified] crops for many years." (Wait, Did the USDA Just Deregulate All New Genetically Modified Crops?, In a surprise move, the agency green-lights Roundup Ready lawn grass—and perhaps much, much more. http://motherjones.com/environment/2011/07/usda-deregulate-roundup-gmo-tom-philpott)

“Not at all surprisingly, weeds are becoming increasingly resistant to Roundup, creating “superweeds” which are “galloping through the Midwest.” So Dow AgroScience created a strain of corn that has been genetically engineered to withstand a different class of herbicides—those containing 2,4-D, a known carcinogen. Dow is now seeking to freely use this 2,4-D-resistant corn. GE modification to create resistance means they will be free to use ever-increasing amounts of the herbicide, with no limits whatsoever. These new herbicide-resistant crops will be planted alongside conventional and organic crops. This increases the potential for cross-contamination, and for the spillover of toxic herbicides into the groundwater and neighboring farms. The manufacturer of this seed will of course reject our use of the term “Agent Orange Ready” seed. But don’t be deceived. 2,4-D was a principal ingredient of Agent Orange—and it is the toxic pesticide that these new seeds are designed to survive. Three million people had health effects and 150,000 were born with birth defects as result of Agent Orange’s use during the Vietnam War. The US Department of Veterans Affairs has a shocking list of the diseases related to Agent Orange exposure, including leukemia, diabetes, Hodgkin’s lymphoma, heart disease, Parkinson’s, and numerous different cancers. ( Do We Want to Spray More Agent Orange on Our Crops? Are We at War with Ourselves (and Our Children)? February 7, 2012 http://www.anh-usa.org/agent-orange-on-our-crops/ )

Even scarier, Monsanto and Dow now seem to be in collusion with one another . In its petition, Dow states that the 2,4-D trait in the GE seeds will be stacked with Monsanto’s Roundup Ready trait so that the seeds are resistant to multiple herbicide tolerances . Soon we’ll be eating food with a whole cocktail of different herbicide traits cooked into the seed—all so they can be sprayed with chemicals that are more toxic than ever before! The real solution here is to stop using GE seeds altogether. Why (Do We Want to Spray More Agent Orange on Our Crops? Are We at War with Ourselves (and Our Children)? February 7, 2012 http://www.anh-usa.org/agent-orange-on-our-crops/ )

And, apparently farmers, scientists and academics are finding that “GM Crops Facing Meltdown in the USA” because of herbicide resistance and the flaws generally of GMO. Major crops genetically modified for just two traits - herbicide tolerance and insect resistance – are ravaged by super weeds and secondary pests in the heartland of GMOs as farmers fight a losing battle with more of the same; a fundamental shift to organic farming practices may be the only salvation. HT crops encouraged the use of herbicides, resulting in herbicide-resistant weeds that demand yet more herbicides. But the increasing use of deadly herbicide and herbicide mixtures has failed to stall the advance of the palmer super weed in HT crops. At the same time, secondary pests such as the tarnished plant bug, against which Bt toxin is powerless, became the single most damaging insect for US cotton. (Dr. Mae-Wan Ho ISIS Report 01/02/10 http://www.i-sis.org.uk/GMCropsFacingMeltdown.php)

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Monster plants that can’t be killed. It is the Day of the Triffids - not the genetically modified plants themselves as alluded to in John Wyndham’s novel - but “super weeds that can’t be killed” [2], created by the planting of genetically modified HT crops, as seen on ABC TV news. The scene is set at harvest time in Arkansas October 2009. Grim-faced farmers and scientists speak from fields infested with giant pigweed plants that can withstand as much glyphosate herbicide as you can afford to douse on them. One farmer spent US$0.5 million in three months trying to clear the monster weeds in vain; they stop combine harvesters and break hand tools. Already, an estimated one million acres of soybean and cotton crops in Arkansas have become infested. (Dr. Mae-Wan Ho ISIS Report 01/02/10 http://www.i-sis.org.uk/GMCropsFacingMeltdown.php)

“In effect, given this cocktail below, we’re dealing with “Agent Orange” Ingredient to be Used in GMO CropsDow's new GM product, dubbed "Enlist," is a three-gene, herbicide-tolerant soybean that has been engineered to be resistant to glyphosate, the active ingredient in Monsanto's popular Roundup herbicide, along with glufosinate and 2,4-D. The company expects to earn $1.5 billion in additional profit in 2013 by selling these triple herbicide-resistant seeds. As noted by the U.S. Department of Veteran Affairs: "The two active ingredients in the Agent Orange herbicide combination were equal amounts of 2,4-dichlorophenoxyacetic acid (2,4-D) and 2,4,5-trichlorophenoxyacetic acid (2,4,5-T), which contained traces of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)."

Ironically, while Dow's new crops would seriously escalate the use of 2,4-D, Monsanto is currently facing a class-action lawsuit involving the other Agent Orange ingredient, 2,4,5-T. The suit alleges that homes and schools near one of its 2,4,5-T chemical plants are now contaminated with cancer-causing dioxin, a byproduct of the manufacturing process. This should be a wake-up call to those considering widespread application of any toxic Agent Orange ingredient. (Hidden "Agent Orange" Chemical They Want to Sneak into Your Food Posted By Dr. Mercola | February 12 2012 | 199,114 views http://articles.mercola.com/sites/articles/archive/2012/02/12/dow-

agrosciences-developed-new-genetically-modified-crops.aspx )

I also oppose this “Arm’s Race in herbicides and GMO alleged, but impossible to defeat the problems, unless those problems were planned across US land under agriculture. That speaks of other problems and as I have observed, none of this sort of herbicide and GMO abuse is happening or permitted in Germany and generally in Europe.

Dow's "Agent Orange" corn will trigger a large increase in 2,4-D use--and our exposure to this toxic herbicide--yet USDA has not assessed how much, nor analyzed the serious harm to human health, the environment, or neighboring farms. This GE corn will foster rapid evolution of resistant weeds that require more toxic pesticides to kill, followed by more resistance and more pesticides--a chemical arms race in which the only winners are pesticide (aka biotechnology) firms.

2,4-D corn is only the first of many new herbicide-resistance crops being developed by the biotechnology industry to usher in a new era of increased chemical use that represents a very significant opportunity for Dow, Monsanto, DuPont, Bayer, and Syngenta. These "biotechnology" companies are actually pesticide firms that have acquired a large portion of the world's seed supply, and they use biotechnology to create synergies between their seed and pesticide divisions. In short, biotechnology = pesticide + seeds. One indication of this is that nearly two-thirds of GE crops pending approval by our USDA (13 of 20) are herbicide-resistant " Agent Orange" Corn: Biotech Only Winner in Chemical Arms Race as Herbicide Resistant Crops Fail Andrew Kimbrell Executive Director of the Center for Food Safety, 22 Feb 12, http://www.huffingtonpost.com/andrew-kimbrell/agent-orange-corn-biotech_b_1291295.html

Included also in this my opposition to glyphosate and associated class of herbicides (ie, Roundup) in our food supply and associated GMO by both Dow and Monsanto respectively that are tolerant to those harmful herbicides and harmful to the earth, the biosphere/environment, our food animals and mankind. Sane people want clean food, clean environment and clean water. GMO and associated terrible herbicides and pesticides are contrary in every way to the aforementioned.

Thank your for including my comment as a factor in your decision with regard to opposing 2,4D and associated dioxin contaminants for any sort of use in the US, and any sort of GMO in the US ah, demanding it and associated GMO be utterly banned completely from the US food supply at any level or at any point. I urge you to follow this link on at least 1 compelling study for landmark ruling, the NZ Commerce Commission tests done by Dr. Jack Heinemann where people were complaining about the lack of labeling on food which had GMO ingredients of any sort. “Animals Raised on Genetically Engineered Feed Are Different” GM Watch, Jan 10, 2010 1. A LANDMARK RULING NZ Commerce Commission: animals fed on GM components ARE different Comment by GM-Free Cymru http://www.gmfreecymru.org/documents/landmark.html). h ttp://www.comcom.govt.nz/media-releases/detail/2009/inghamswarnedovergmfreechickenclai/

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I am supportive to see the better prospects for the Plaintiff OSGATA rather than corporate abuse against that association by the defendant Monsanto in that lawsuit to which I think Dow should be attached. I have encouraged that lawsuit to proceed against Monsanto, among other things and oppose the use of the terrible Herbicides and insecticides and the GMO.

In Europe these are not used, nor GMO permitted generally in its food supply and their efforts by their agriculture to resist and oppose using our toxic cocktail of herbicides, pesticides and GMO has their farms, farmers, and people more healthy, better land and quality of life, and VASTLY BETTER QUALITY FOOD.

It’s sad and despicable that our food is now a hazard to one’s health, those of the animals in our food supply, and the herbicides and GMO are a hazard to nature and our environment here in the US, as if it’s corporate war against nature, man and our food in the US, but not in Europe especially Germany. BASF may not sell or do GMO over there and as a result GMO and associated contaminants like glyphosate and dioxin herbicides that had been used or proposed to be used here in the US be utterly banned, ceased & desisted, and prohibited.

My concerns are found following and the document’s organization you will find below. Thank you again for your attention to my concerns on behalf of opposing Dow’s herbicides, its GMO and especially GMO that resists DOW’s and Monsanto’s herbicides and also note my support for Plaintiff OSGATA against Monsanto. This plaintiff class also has been harmed by DOW, and also should have attached DOW to the Monsanto lawsuit as I said above.

Please consider my comment as a Friend of the OSGATA plaintiffs suing Monsanto in 2nd District Federal Court in Southern Manhattan. Please Rule against and oppose 2,4D (dioxin and related contaminants) use in the US and Dow being able to vend this anywhere.

Please Rule against any sort of GMO that is resistant to 2,4D and GMO resistant to ANY OTHER HERBCIDE including glyphosate, ie, Roundup by Monsanto. Also note I have requested 2nd District Federal Court to over-rule Monsanto’s demand to have the OSGATA case dismissed against it, when in reality Monsanto’s corporate charter (and perhaps Dow’s) should be revoked and its business cease and desisted and required to pay reparation payments to farmers, society harmed by Round-up, Agent Orange and 2,4D (1a) phenoxy auxin group (such as the herbicide 2,4-D) and resistance to grass herbicides in the 1b) aryloxyphenoxypropionate acetyl coenzyme A carboxylase inhibitor group (such as quizalofop herbicides), and GMO including DAS 40278-9 and that commercial and cultural warfare against mankind and the environment.

Notice it’s generally not permitted in Europe and will continue to be rejected going forward based in part on the superior quality, independent research of its agri/bio scientists. Notice it’s not permitted to engage in Fraud in regulatory trains in Europe nor for its abuse and shedding regulator investigation for employee death by dioxin, as in Monsanto’s case.

Please excuse this is a little aggressive and not really the current matter before you in your court however when practicable, I urge ‘CONVICTING’ Dow and Monsanto #GUILTY#! in its FULL COURT PRESS AGAINST MANKIND AND NATURE as it is ENGAGING SLOW GENOCIDE against mankind and the environment

Respectfully,Andrea PsorasNY, NY 10026(212) 666 2569http://www.linkedin.com/in/andreapsoras ; http://www.bankinnovation.net/profile/AndreaPsoras http://www.bankinnovation.net/profile/AndreaPsoras

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Petition Item ListI URGE YOU TO – AND A NUMBER OF YOU TO WHOM I ADDRESS THIS 'PETITION':1. Punish all producers of GMO and the herbicides producers which produce GMO for their environmental hazardous behavior as well as Monsanto for the same; ruling against the use of 2,4-D (and other herbicide) tolerant GMO grains and ruling against ALL GMO GRAINS, as well as those associated herbicides. 2. Sanction Monsanto for engaging in Fraud against the USDA when it presented its trial materials for the GMO, Bt products, most recently Alfalfa mixing the trial materials while also manipulating the trial comparisons of rats which at GMO rather than a Control group of Rats which ate no GMO while also presenting more robust tests on more rodents over longer periods of time to expose the transfer of genetic harm across proteins which transfers down the generations for increasing still birth and sterility in the test rats, while also failing to respect and acknowledge the transfer of genetic engineering across protein and other physiological/anatomical materials from the sterile seeds in to the livestock fed it and now harmful and damage in the people. Rather than the EPA and USDA continuing to disgrace and defile themselves with these repugnant scandalous companies, sanction Monsanto and also DOW of its dioxin abuses and for Monsanto’s environmental disaster and conspiracy to obstruct justice over the period from 1990 -1994 and discussed in the Abuse section ( see EPA INVESTIGATES MONSANTO, Reported by RACHEL'S HAZARDOUS WASTE NEWS #400 July 28, 1994, http://www.ejnet.org/rachel/rhwn400.htm )

3. Rule in favor of Organic Seed Growers Trade Association, aka “OSGATA”, organic farmers, and other plaintiffs against Dow’s and Monsanto’s interests to override the interests for ‘plaintiff's OSGATA et al like the NRDC for ban on 2.4D and dioxins of every sort in every form that by way of man finds its way into the food supply and the environment. 4. By Ruling against Dow and Monsanto, you're thwarting anti-social, corporate abusers Monsanto in court to litigate it against any further abuse and monopolistic practices against any and all organic and non-GMO farmers and agricultural commerce by small and family owned farms and agricultural cooperatives growing any and all crops, seeds. I urge attaching Dow to the defendant as a defendant. 5. Require labeling of all food in any form to people, animals and commercial or organizational enterprises that have any and all Dow and Monsanto GMO of any and every sort in any way at any point in the food chain again from barn or lab to manger or dinner table.6. Cease and desist all corporate or private production and sale or buying of GMO of every, any and all sorts by Monsanto, Dow or otherwise by any and all other perpetrators including also BASF and associated herbicides and pesticides. 7. BAN COMPLETELY IN ANY WAY FROM THE FOOD SUPPLY AT ANY TIME AND AT ANY LEVEL OR FORM – GMO IN ANY FORM AT ALL IN ANY WAY - AND REQUIRE UNWIND-CLEANUP OF ALL SUCH CONTAMINTION IN ANIMALS, THE ENVIROMENT INCLUDING POLLINATORS AND WATER SUPPLY8. Cease and desist use of all herbicides especially Monsanto’s Roundup and Dow’s 2,4D and its related herbicides, and pesticides, 9. Cease and Desist all further GMO of any and every sort as well as cease and desist all cloning of any and all creation already on the face of the earth and/or in the water or air.10. http://www.regulations.gov/#!submitComment;D=APHIS-2010-0103-0001 opposition against Dow 2,4D class and Monsanto glyphosate resistant plants and seeds, Roundup resistant plants and seeds and any and all other seeds genetically modified in any way that produce their own insecticides and/or resist herbicide destruction other than for academic or research analysis.

PrefaceOver the past few years, little has aroused my deep concern because in a way, I have seen it 'all', as a bank analyst who endured a great deal of retaliation and isolation as a whistle blower at the beginning and during the Financial sector's Enronesque heist that continues to funnel trillions of dollars out of the financial system into the hands of the largest institutional investors, the very wealthy, and the largest global corporate as well as our largest financial institutions which are not ‘profitable’ without their parasitic agency self dealing business of Over the Counter derivatives contracting.

Until a friend had emailed me about the corporate abuse of Dow and Monsanto looking to get their GMO food into the people food supply and use of Dow 2,4D class and associated herbicides (dioxin) and pesticides, I was only beginning to experience the problems of occasionally eating GMO and herbicide: glyphosate and dioxin polluted food, pork, meat, and dairy, thinking my health problems were related to dairy/livestock pharma I virtually always avoid by avoiding contaminated livestock and dairy however over the holidays strayed with milk chocolate.

Although I am busy with FASB comments and muck-raking of sorts publicly condemning the ISDA financial cartel members, or the German dominated G20 (Transatlantic Union) Agreements, after reading Bob's commercial-investor newsletter in which he mentions the Agent Orange component 2,4D and Roundup resistant crops ie, GMO, I began to research this issue Bob mentioned. What I found based on what he mentioned about Dow and Monsanto takes on genocidal proportions like using Agent Orange components and crops that are resistant to these toxic substances rather than using responsible land husbandry such as crop rotation. I remembered Agent Orange; I’d grown up during the Vietnam War era. Even if a component of Agent Orange, dioxins are serious contaminants. These are among the most toxic contaminants in our society. The EPA

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considers Dioxin an environmental contaminant like PCB when a Category III harbor sludge, a serious bio-accumulant (concentration increases up the ‘food chain’) and known health hazard.

As recently as last week 24 Feb 2012, the Natural Resources Defense Council filed in federal court against the US EPA to ban use of dioxin: NRDC Seeks Ban of 2,4-D Herbicide (http://legalnewsgroup.com /2012/02/24/nrdc-seeks -ban-of-24-d-herbicide/6126) The EPA itself, admits that “ according to a Sept 1994 EPA report, not only does there appear to be NO "safe" level of exposure to dioxin, but levels of dioxin and dioxin-like chemicals have been found in the general US population that are "at or near levels associated with adverse health effects. “ That draft report released for public comment by the US Environmental Protection Agency clearly describes dioxin as a serious public health threat. Dioxins and furans are some of the most toxic chemicals known to science; the public health impact of dioxin may rival the impact that DDT had on public health in the 1960's.” (http://www.ejnet.org/dioxin/

The EPA document also acknowledges that the newly appreciated hazards of dioxin go far beyond the risk of cancer... the ex-pected non-cancer effects include: ** disruption of endocrine hormone systems, especially those related to sexual development; ** disruption of critical stages of embryonic development, for example of the nervous system; ** damage to the developing immune system, leading to increased susceptibility to infectious diseases. These are intergenerational defects, they are imprinted for life on the developing fetus by the effect of dioxin on the mother and sometimes the father. ( RACHEL'S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL's HAZARDOUS WASTE NEWS) September 1, 1994 Turning point for the Chemical Industry, http://www.ejnet.org/rachel/rehw405.htm )

We’ve known about this since the Vietnam War when not only the soldiers experienced serious health problems from the Agent Orange and Dioxins, but also their dogs were sick and died of for example testicular cancers , as are dogs today sick and dying which role around on the lawns where their masters used Roundup and 2,4-D in some form produced by Dow or Monsanto. (“Turning point for the Chemical Industry” ,RACHEL'S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL's HAZARDOUS WASTE NEWS) September 1, 1994 http://www.ejnet.org/rachel/rehw405.htm; and “The Dogs of War”, on dioxins - RACHEL'S ENVIRONMENT & HEALTH WEEKLY #436 ---April 6, 1995- http://www.ejnet.org/rachel/rehw436.htm )

For example, the 24 Feb 2012 NRDC lawsuit filed in the U.S. Court of Appeals for the District of Columbia asks the court to intervene in NRDC’s 2008 petition that the EPA ban use of the chemical that has been used in the United States since the 1940s The complaint asks the appeals court to compel the EPA to cancel all 2,4-D registrations and revoke all regulatory tolerances for the chemical within 45 days of the court’s decision. The compound is one of two ingredients in the neurotoxic herbicide and defoliant Agent Orange, which the U.S. military used in the Vietnam War. About 46 million pounds of 2,4-D are used in the United States every year, NRDC said. Classified by the EPA as a hazardous air pollutant, exposure to 2,4-D can cause damage to the nervous system, liver and kidneys. ”( http://www.jdsupra.com/post/documentViewer.aspx?fid=3eaaa845-ba7a-448a-8cd8-23bc2acdff0e )

I suspect this is why ( Quality Pork Processors Inc. in Austin, Minnesota) employees who worked on the line that blasted hog brains out of the hog skulls for Hormel’s sausage production became ill with neural and motor problems from the aerosole of brain matter of hogs fed GMO and dioxin 2,4D herbicide sprayed grain (AMP). Nerve damage mentioned from Dioxins would have likewise effects found in the Hormel employees as if they themselves had eaten that dioxin sprayed GMO grain rather than breathing in the aerosole’d hog brain matter. “His legs felt dead, paralyzed…Every test revealed neurological abnormalities, most importantly a severe spinal-cord inflammation, apparently caused by an autoimmune response.”( http://motherjones.com/politics/2011/06/hormel-spam-pig-brains-disease )

As a result since the existence of the EPA, there’s been a body of knowledge about 2,4-D and related dioxin contaminants by corporate and other parties used while corporate and trade association interests which use these as herbicides have taken aggressive steps to attempt to thwart EPA official public disclosure about cancer from dioxin. (http://www.pesticideinfo.org/Detail_Chemical.jsp?Rec_Id=PC33613#Toxicity http://www.wsws.org/articles/1999/jun1999/diox-j01.shtml US study establishes link between dioxin and cancer By Perla Astudillo 1 June 1999 )

Dr Mercola (note follows) recently posted to his readers that biotech giant Monsanto and Dow Agrisciences have created some of the most dangerous products on the planet, including Agent Orange, dioxin, recombinant bovine growth hormone (rBGH)… and genetically modified seeds. The latter is one of the most pressing concerns because GM crops are now a mainstay of American agriculture which Dow wants similarly to abuse society with its GMO(1).

Mercola: “Ninety percent or more of all US-grown corn, soybeans, canola, and sugar beets are genetically modified versions, which means that virtually all processed food contains at least one or more genetically modified ingredi-ents. GM foods are, from what I perceive, one of the most significant threats that we have against the very sustain -ability of the human race. Why? In a nutshell, these toxins are being linked to a growing repertoire of assaults against human health and the environment -- and they are already migrating into fetal blood, which means future

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generations are now at risk.” (1)“Banned in Germany, But You're Probably Still Eating It Posted By Dr. Mercola | January 31 2012 “Monsanto Named the Worst Company of 2011”)

Deeper digging about the GMO and herbicide/pesticide problems has me concluding that Monsanto and Dow are mad, genocidal, socio-pathic scientists run amok on society.

My next judgment was and is that we NEVER SHOULD HAVE SANCTUARIED NAZI SCIENTISTS AFTER THE MILITARY WAR OF WW2, AND HAVING GIVEN THEM EMPLOYMENT AT DUPONT INCLUDING MONSANTO, DOW and other industrial companies, and institutions such as academic, medical/hospital and think tanks in our society. Now two generations after thinking we're in the plowshares time, apparently we're not by way of this war of some bizarro kind that is worse than any nightmare from which one can wake-up AND IS more than likely NOT HAPPENING IN GERMANY, NOR VIRTUALLY ANYWHERE ELSE IN the EU which had had tight regulations.

BASF is not permitted to sell its GMO science and associated products in Germany, however sells those outside Germany. Ask yourself WHY? The German chemical firm confirmed Monday it plans to move the headquarters of BASF Plant Science from Limburgerhof, Germany, to Raleigh, North Carolina, and to halt all development and commercialization work on products aimed solely at the European market. "We are convinced that plant biotechnology is a key technology for the 21st century," BASF board member Stefan Marcinowski said in a release. "However, there is still a lack of acceptance for this technology in many parts of Europe -- from the majority of consumers, farmers and politicians. “BASF to focus plant biotech work on Americas. German firm to halt all Europe-focused projects. (Jan 19, 2012 12:01 AM http://www.grainews.ca/news/basf-to-focus-plant-biotech-work-on-americas/1000833917/ )

Given the damage about which I'm reading in the environment, the pollinating insects, the water and the plants/crops, livestock/poultry/fish i.e. Thanks to the Dairy trade association for the percent of dioxin the EPA estimates is from our food which the IDFA says the EPA estimates is the source for estimated 95% of dioxins in the livestock and from the herbicide origins (AMP) bio-accumulated up the food chain, we by our ignorance have facilitated those warring scientists' destruction against us, our trust and typically what our people need while on this earth, and needing to have to eat clean food and drink clean water.

This need apparently has been expropriated or let's say served as form by which these scientists and their employers (and perhaps other off-the-radar-screen parties) that have decided to extract a feudal toll - aside from the ISDA financial cartel - about as bad as any 'free' rider that I have every seen: for their profits, control and power, you’ve risked your life if you eat their food and what they've polluted in the environment and those participants in nature like the pollinating insects, the aquatic animals, the water supply, like the sun there to do good for mankind, but now hijacked and in its way, like radio-active or toxicity more robust and harmful, cancer producing than had been acknowledged in the developed world.

For example I site the Dioxin exposure and cancer risk in the Seveso (http://en.wikipedia.org/wiki/Seveso_disaster ) Women's Health Study found at Environ Health Perspect. 2011 Dec;119(12):1700-5. Epub 2011 Aug 2 http://www.ncbi.nlm.nih.gov/pubmed/21810551 . A study and health tracking of people was monitored over decades after a dioxin spill in Seveso, Italy. After 3 decades a robust number of women were found to have Breast Cancer.

We trusted scientists and the regulatory framework to keep the line drawn between corporate interests for profit and a clean environment, clean food and responsible regulators who themselves know where these lines are, rather than allowing themselves to be hijacked by lawless self interests, expedience and other powers that perhaps are beyond their control. I suggest not, however, because that's why they're in the jobs, roles and appointments that they are, while those deemed as 'consumers' and presumed to be not qualified to be in the roles of regulators, are not. (EPA reassessment of Dioxin -http://www.ejnet.org/dioxin/#reassessment )

Because controlling dioxin is expensive, since 1985 industry has maintained relentless pressure on government to relax dioxin standards. Some animal studies showed dioxin to be an extremely potent toxin in some species; other studies showed it to be weaker in other species. EPA established a Workgroup to review the data and conclusions of its 1985 assessment.( RACHEL'S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL's HAZARDOUS WASTE NEWS) September 1, 1994 Turning point for the Chemical Industry, http://www.ejnet.org/rachel/rehw405.htm ]

Meanwhile, trade association interests have been attempting to thwart EPA public reports on dioxin contamination such as the dairy association and chemical companies like Dow and Monsanto; November 2, 2011 IDFA Requests Agency Coordination to Fix Flawed Dioxin Assessment (http://www.idfa.org/key-issues/details/6584/ ) and IDFA, Others Urge White House to Intervene on Dioxin Reassessment ( http://www.idfa.org/key-issues/category/food-safety–defense/details/6721 / ); December 20, 2011: American Chemistry Council (ACC) requests EPA delay the release of the dioxin reassessment ( http://www.americanchemistry.com/Policy/Regulatory-Reform/Cal-Dooley-Letter-to-Administrator-Jackson-Fix-Dioxin-Reassessment.pdf )

7 Psoras, 2/20/2012 11:35 AM

Dow and Monsanto seem to be hankering for that sort of 'crisis' situation and associated damage, unless thwarted by hands more powerful than its own social genocide drives and suicidal behaviors.

As a bank analyst and an expert of sorts on the financial sector, however a long time ago the blush was off that rose and knowing what trade associations' and sectors' lobbying, and those campaign contributions can buy and has bought in Washington and elsewhere. As a result I was not ignorant about the facile – lack of guard - and thus with associated co-optability – in those responsible for making law, regulating and administrating that regulatory framework, whether it is the intelligence apparatus, the financial regulators, the White House or elected public servants at the federal and state levels, and even the courts.

Although I am not isolating and blaming any single party or regulator, I am shocked however at the swift decay of the environment, the quality of food in the US while other countries in Europe, Australia have held the line generally against this class of glyphosate and 2,4-D herbicides, pesticides and GMO and Genetic engineering at all of any sort, at any level of the food supply and its production from barn or in the case of the defendants – the lab – to the livestock feeding trough or dinner table. The decay I mention doesn’t seem to be unconnected with how the regulatory and legislative environment in the US seems to think it is fraudster Monsanto's and Dow's best friend, while those corporate malefactors are attempting and arguably perpetrating mass -slow- annihilation of mankind and the environment in the US, while Europe and its people have been able to remain largely unharmed.

My father reminded me of Rachel Carson and “Silent Spring”. Apparently the US EPA and the shock of environmental/ biosphere contamination didn’t stop the USDA and/or FDA and/or EPA from again giving a pass to corporate criminals of the most despicable sort; Enronesque malefactors in the Food and Agricultural and Environmental sectors.

Current dioxin regulations are based on old and outdated science,” says Mike Schade, a campaign coordinator at the Center for Health and Environmental Justice. “Once EPA’s health report is finalized, agencies can develop new regulations that are responsive to dioxin’s toxicity.” Dioxins get spewed into the air, where they eventually settle into soil, water, and plants. Animals ingest dioxins as they graze, and the chemicals build up in the creatures’ fatty tissues. t Dow Chemical and the American Chemistry Council (ACC), a chemical and plastics industry group, are leading the charge against the EPA’s dioxin study. In December, the ACC requested [PDF] that the EPA delay the release of its long-awaited study. Major food producers are also pressuring the EPA to turn a blind eye to dioxins, citing concerns that consumers will unnecessarily fear their food. The Food Industry Dioxin Working Group [PDF]—which is made up of industry groups like the International Dairy Foods Association, American Frozen Food Institute, and the National Chicken Council—recently wrote to the White House, urging officials to block the EPA’s study. “Since the agency contends the primary route of human exposure to dioxin is through food, this could not only mislead and frighten consumers about the safety of their diets, but could have a significant negative economic impact on all U.S. food producers,” the group wrote. “Dow and the chemical industry are following the tobacco industry's strategies to keep information from the public and delay release of the report,” says Schade. “In recent months, the chemical industry and Big Ag have been working behind closed doors to hide and distort the truth about the dangers of dioxin. EPA nor the USDA shouldn’t cave in to chemical industry dollars and interests over public health.” Why the U.S. Government Won't Protect Us From Toxic Chemicals In Our Food Supply Sarah Parsons February 7, 2012 • 11:00 am PST http://www.good.is/post/why-the-u-s-government-won-t-protect-us-from-toxic-chemicals-in-our-food-supply/

Given the fact that dioxins are about as common as salt on the American dinner table, you’d think the EPA—whose sole purpose is to protect public health and the environment—would prioritize studying dioxins’ safe limits. Why the years of delay? As Sass explains, “the delay has been political, not scientific.” The EPA faces major pressure from the chemical and food industries not to release its dioxin study—not now, and, if lobbyists get their way, not ever. Why the U.S. Government Won't Protect Us From Toxic Chemicals In Our Food Supply, SARAH PARSONS food columnis LIFESTYLE February 7, 2012 • 11:00 am PST http://www.good.is/post/why-the-u-s-government-won-t-protect-us-from-toxic-chemicals-in-our-food-supply/

How are we exposed to dioxin? The major sources of dioxin are in our diet. Since dioxin is fat-soluble, it bioaccumulates, climbing up the food chain. Dioxins & Furans: The Most Toxic Chemicals Known to Science http://www.ejnet.org/dioxin/

According to May 2001 “INTAKE OF DIOXINS AND RELATED COMPOUNDS FROM FOOD IN THE U.S. POPULATION”, The efforts of environmental agencies to set and enforce regulations to decrease dioxin formation and spread into the environ-ment should further reduce food contamination. Generally, however, government regulations and enforcement of standards for dioxin levels in food appear not to be in effect in the United States. Given both the uncertainty about the long-term health ef-fects of various levels of exposure to dioxin-like chemicals and the progress apparently made so far in some European coun-tries in reducing levels of exposure, it seems reasonable to continue periodic surveillance of populations’ exposures to dioxins through the food supply (INTAKE OF DIOXINS AND RELATED COMPOUNDS FROM FOOD IN THE U.S. POPULATION Schecter, Arnold, et al. Journal of Toxi-cology and Environmental Health, Part A, 63:1–18, 2001 Copyright© 2001 Taylor & Francis) “. The new attempt to downgrade the dioxin hazard, like all the earlier ones, has failed. But in failing, it has not simply confirmed the important but narrow result of the 1985 risk assessment that dioxin is an enormously potent carcinogen. It has

8 Psoras, 2/20/2012 11:35 AM

also greatly expanded the range and biological impact of dioxin's effects, at levels of exposure already experienced by the entire U.S. population.

... Apparently Americans are sufficiently exposed to some very general source of dioxin to put us all well above the "accept-able" cancer risk of one in a million, and within range of its numerous other harmful effects. That source, according to the forthcoming EPA report, is chiefly food [meat and dairy products]....

Stated more simply, the situation is this: The general spread of dioxin and dioxin-like chemicals in the U.S. environment has already exposed the entire population to levels of these extremely toxic substances that are expected to cause a number of serious health effects. These include an average risk of cancer of 100 or more per million in the entire U.S. population --100 times greater than the risk standard that has triggered EPA remedial action, for example at Times Beach near St Louis, MO. (RACHEL'S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL's HAZARDOUS WASTE NEWS) September 1, 1994 Turning point for the Chemical Industry, http://www.ejnet.org/rachel/rehw405.htm ])

BODY OF DISCUSSION OF CONTENTIOUS ISSUES AGAINST DOW AND MONSANTOPhysiological damage to people, pollinating insects, lab animals and food supply animals

Released last week as a deflection against heavy criticism for having delayed its report on Dioxin damage to health and cancer links, the EPA stated, “Most Americans have low-level exposure to dioxins. Non-cancer effects of exposure to large amounts of dioxin include chloracne, developmental and reproductive effects, damage to the immune system, interference with hormones, skin rashes, skin discoloration, excessive body hair, and possibly mild liver damage (1)” and nerve damage although Vietnam War vets have a robust manifestation of cancers. (1) EPA Updates Science Assessment for Dioxins / Air emissions of dioxins have decreased by 90 percent since the 1980s, 02/17/2012. (http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/33bcba60ed25a9b1852579a700604ed7!OpenDocument )

“Scientists have known since the mid-1960s that dioxin is an extremely powerful promoter of cancer in laboratory animals, but industry researchers have recently been claiming that humans somehow are exempt from the dioxin danger. The question of dioxin's hazard to humans took on real urgency in the early '80s when 15,000 veterans sued Dow chemical and other producers of Agent Orange (a dioxin-contaminated herbicide widely used to defoliate the jungle in Vietnam from 1962 to 1971); the vets sought money damages for health effects (cancer, defective offspring, and so forth) they said they were experiencing. Lawyers for the Vietnam vets offered documentary evidence that Dow chemists convened a private meeting of their competitors in 1965 to share new information that impurities [dioxins] in the herbicide 2,4,5-T (principal component of Agent Orange) caused severe liver damage in rabbits. According to court records, a chemist at Hercules Powder Company who attended the private Dow meeting in 1965, received a phone call from a Dow executive who "warned him to keep the findings away from the federal government," according to a reporter for Nature, the British science journal. [2] If this is true, it would not be the first time, nor the last, that money has influenced the outcomes, and the uses, of scientific studies. (see RHWN #171, #173, #175). (RACHEL'S HAZARDOUS WASTE NEWS #219---February 6, 1991. “New Study Links Dioxin to Cancer” http://www.ejnet.org/rachel/rhwn219.htm)

Dow AgriScience’s variety of corn up for USDA approval, DAS-40278-9, is tolerant to ACCase inhibitor herbicides (including quizalofop, which is not registered for use on corn) as well as 2,4-D. The chemical 2,4-Dichlorophenol (2,4-D) once made up half of the herbicide mix known as Agent Orange. Corn with 2,4-D tolerance could be dangerous to eat because a metabolite of 2,4-D is known to cause skin sores, liver damage and sometimes death in animals. 2,4-D is a potential endocrine disruptor and can affect development. Rats exposed to 2,4-D exhibited depressed thyroid hormone levels, which can affect normal metabolism and brain functioning. Studies found that men who applied 2,4-D had lower sperm counts and more sperm abnormalities than those unexposed to the herbicide. Moreover, The chemical treadmill model cannot be continued indefinitely. Weed resistance to these chemicals will continue to abound and the application of more noxious herbicides will increase exponentially. This new corn variety is not only unsafe and inefficient, but it is a completely unsustainable solution to the broader problem of high-input production agriculture and associated environmental pressures. (No Date or Author. “Agent Orange Ready Corn. Food & Water Watch. http://www.foodandwaterwatch.org/food/genetically-engineered-foods/24-d-corn/ )

“A 1986 National Cancer Institute (NCI) study found that famers in Kansas exposed to 2,4-D for 20 or more days per year had a six-fold higher risk of developing non-Hodgkins Lymphoma than non-farmers (note). The risk of cancer was higher for farm-ers who mixed or applied the pesticide themselves. Another study done in 1990 found a 50% increase in non-Hodgkin’s Lym-phoma in farmers who handle 2,4-D (note) (2,4-D, chemicalWatch Factsheet/BEYOND PESTICIDES-2004, Washington DC, http://www.beyondpesticides.org/gateway/pesticide/24d.htm )

Carcinogenic effects: 2,4-D fed to rats for 2 years caused an increase in malignant tumors [7]. Female mice given a single injection of 2,4-D developed cancer (reticulum-cell sarcomas) [7]. Another study in rodents shows a low incidence of brain tu-mors at moderate exposure levels (45 mg/kg/day) over a lifetime [1,7]. However, a number of questions have been raised about the validity of this evidence and thus about the carcinogenic potential of 2,4-D. In humans, a variety of studies give con-

9 Psoras, 2/20/2012 11:35 AM

flicting results. Several studies suggest an association of 2,4-D exposure with cancer. An increased occurrence of non-Hodgkin's lymphoma was found among a Kansas and Nebraska farm population associated with the spraying of 2,4-D [25,27]. Other studies done in New Zealand, Washington, New York, Australia, and on Vietnam veterans from the U.S. were all nega-tive. There remains considerable controversy about the methods used in the various studies and their results [“Note 28”]. Thus, the carcinogenic status of 2,4-D is not clear. [“Note 28”] U.S. Environmental Protection Agency. Proposed Rules. Fed. Regist. 55: 24116-17, 1990.7-29 http://extoxnet.orst.edu/pips/reflist7.htm Clearly this is grossly out of date and there is more recent research that refutes this seeming conundrum. Agricultural pesticide use and risk of t(14;18)-defined subtypes of non-Hodgkin lymphoma.

A population based, case control study in Nebraska looking at different molecular subtypes of NHL discovered that the risk of t(14;18)-positive NHL subtype is significantly elevated among farmers who used animal insecticides (OR 2.6), crop insecti-cides (OR 3.0), herbicides (OR 2.9) and fumigants (5.0 OR) and that there was no increased risk of t(14;18)-negative NHL subtype for these pesticides, which may explain some of the inconsistencies in epidemiological study of NHL and pesticide ex-posure. They also find that the risk increases with longer duration of use. This abstract shows however, that in that era, and perhaps there wasn’t as wide use of the dioxins however other herbicides were more likely over the long term to spur NHL and it also appears that what one may breath also more likely would spur NHL and shown in Table 4 (herbicides) http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1566872/?tool=pubmed. and [Chiu, B., et al. 2006. Blood 108(4):1363-1369] http://www.ncbi.nlm.nih.gov/pubmed/16621961 Blood. 2006 Aug 15;108(4):1363-9. Epub 2006 Apr 18 Chiu BC, Dave BJ, Blair A, Gapstur SM, Zahm SH, Weisenburger DD. Source Department of Preventive Medicine, Feinberg School of Medicine, Northwestern University, Chicago, IL 60611-4402, USA. bchiu@northwestern.edu

“The latest study is not by industry researchers but by Dr. Marilyn Fingerhut of the federal National Institute for Occupational Safety and Health (NIOSH); Fingerhut looked at the health of 5172 workers at 12 chemical plants that manufacture (or for-merly manufactured) products contaminated with dioxin such as the herbicides 2,4,5-T, Silvex, Ronnel, Erbon, and pen-tachlorophenol (which has also been used as a fungicide, algicide, and wood preservative for telephone poles and pilings), and the bacterial cleansing agent, hexachlorophene--until the 1970s, a leading bactericide in hospitals.

Among the entire cohort of 5172 men, the occurrence of all cancers was significantly increased, by 15%; in the high-exposure group of 1520 men, the "all cancers combined" increase was even more pronounced--46%; furthermore "all cancers com-bined" were increased among workers at nine of the 12 plants studied. Even when cancers of the respiratory tract were omit-ted in an attempt to eliminate smoking as a possible the cause, "all cancers combined" was increased among the 5172 and even more so among the high-exposure 1520.

Dr. Fingerhut says correctly that her results do not prove that dioxin causes cancer in exposed workers. The workers she stud-ied were exposed to many other chemicals, in addition to dioxin, on the job, and these other chemicals could explain the can-cer increases she observed.

Nevertheless, the Fingerhut study makes it ever more difficult for the purveyors of dioxin-creating machines (such as incinerators for solid waste, hazardous waste, or sewage sludge) to claim that their dioxin emissions are negligi-ble or harmless. Because dioxin accumulates in the food chain, even small amounts can build up to significant lev-els as time passes (AMP). (see RHWN #171, #173, #175). RACHEL'S HAZARDOUS WASTE NEWS #219---February 6, 1991. “New Study Links Dioxin to Cancer” http://www.ejnet.org/rachel/rhwn219.htm;

Meanwhile, Monsanto has engaged in Fraud and the EPA was investigating it over several years. Monsanto Corpora-tion Criminal Investigation Cover-up of Dioxin Contamination in Products Falsification of Dioxin Health Studies Cit -ing a UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C. 20460 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSEMEMORANDUM DATE: November 15, 1990. (Below)

SUBJECT: Criminal Investigation of Monsanto Corporation - Cover-up of Dioxin Contamination in Products - Falsification of Dioxin Health Studies.FROM: Cate Jenkins, Ph.D., Chemist Regulatory Development Branch (OS 332) Characterization and Assessment Division.TO: John West, Special Agent in Charge Office of Criminal Investigations Center U.S. Environmental Protection Agency Building 53, Box 25227 (303) 236-5100 Kevin Guarino, Special Agent Office of Criminal Investigations National Enforcement Investigations Center, EPA

As per our meeting yesterday, I am summarizing information available to me supporting allegations of a long pattern of fraud by Monsanto Corporation. The fraud concerns 2,3,7,7-tetrachlorodibenzodi (dioxin) contamination of Monsanto's dioxin-exposed workers. You indicated that you would contact me regarding the specific documents which would be useful to your investigation. ( http://www.vetshome.com/monsanto_cover_up_agent_orange.htm)

10 Psoras, 2/20/2012 11:35 AM

“A new study of Vietnam veterans, conducted by Air Force physicians, links dioxin exposure to increases in cancer, birth defects, psychological damage, liver damage, cardiovascular deterioration, and degeneration of the endocrine system. The new work stops short of saying dioxin exposures CAUSED the observable health damage among dioxin-exposed vets, but it explicitly reverses the conclusions of a 1984 Air Force study which said dioxin exposures had been shown to be harmless.

Cancer : The study found that 4.59% of the Ranch Hands have some kind of cancer, compared to 2.33% of the unexposed group. Thus the overall risk of cancer among the dioxin-exposed group is doubled (risk increased by a factor of 1.97). The greatest risk increase is for skin cancers (where the risk is increased by a factor of 2.6), whereas the risk of "systemic cancers" (non-skin cancers) is increased by a factor of 1.2; in other words, the dioxin-exposed group has a 20% greater chance of getting a non-skin cancer.

Birth Defects : Analyzing for birth defects, the study looked at children born before the Vietnam experience and children born after Vietnam. Prior to Vietnam, the dioxin-exposed group had born 85% as many children with birth defects as the non-ex-posed group; after Vietnam, the exposed group bore 139% as many children with birth defects. The earlier Air Force study had said birth defects among dioxin-exposed families were limited to "minor skin lesions" but the new study reverses that con-clusion; 32 children with severe defects were born to families in the exposed group, vs. 18 in the nonexposed group. The total number of birth defects in the two groups was: 80 with defects out of 917 total births in the exposed group vs. 48 with defects out of 744 total births in the non-exposed group.

Psychological Damage : Psychological testing revealed significant increases in fatigue, anger, anxiety, and isolation among the dioxin-exposed group compared to the non-exposed group.

Liver Functions : The new study looked at nine chemical measures of liver function and in three categories the dioxin-exposed group showed reduced liver functions, compared to the non-exposed group. In addition, among the exposed group, 16 showed enlarged livers, vs. six among the non-exposed group. Furthermore, 13 among the exposed group had a verifiable medical history of liver disorder other than hepatitis, jaundice, or cirrhosis, vs. only two with such histories among the non-ex-posed group.

Cardiovascular system : Heart disease rates and heart attack rates did not differ among the two groups. However, during physical examination, 10 different heart pulse measurements were taken in the extremities (e.g., the ankle), and statistically significant abnormalities were found in one or more pulses in 12.8% of the exposed group vs. 9.4% of the nonexposed group. Abnormal pulses in the extremities are evidence of blood circulation problems. Endocrine system : The endocrine system is a body control system composed of a group of glands that maintain a stable in-ternal environment by producing chemical regulatory substances called hormones. Glands that participate in the endocrine system include the pituitary, thyroid, parathyroid and adrenal glands, as well as the pancreas, ovaries and testicles. The new study looked at five chemical measures of endocrine system functions. In three of the five measures, the dioxin-exposed group showed abnormal functioning of the endocrine system, compared to the non-exposed group. Functioning of the en-docrine system reduces with age, but the new study showed that, among the dioxin exposed group, functioning of the en-docrine system is being reduced much faster than among the non-exposed group.

Thus the new study shows that, in six out of 11 areas of suspected dioxin effects, exposed Vietnam veterans have health problems in greater proportion than the comparison group. (STUDY OF DIOXIN-EXPOSED HUMANS REVEALS CANCER, BIRTH DEFECTS, LIVER AND CARDIOVASCULAR DAMAGE RACHEL'S HAZARDOUS WASTE NEWS #73 ---April 18, 1988---)

“2,3,7,8-tetrachlordibenzo-p-doxin (TCDD) would not have been designated as a Group 1 carcinogen by IARC had there not been a change in the criteria used for inclusion in this category. The exposure-response meta-analysis of TCDD and cancer developed by the United States Environmental Protection Agency (USEPA) is seriously compromised by its failure to adequately fit the data. The studies used by the USEPA also likely underestimate TCDD body burdens and may be confounded by smoking and other occupational exposures. Furthermore, the use of a linear dose-response model by the USEPA is scientifically unjustified since the underlying model of TCDD as a human carcinogen is based primarily on its supposed receptor-mediated, non-genotoxic (or promotional) mode of action. Authors suggest that “The long-term accumulation of negative, weak, and inconsistent findings suggests that TCDD eventually will be recognized as not carcinogenic for humans, however bio-accumulation of those who come into frequent contact and/or larger concentrations I suggest to the contrary of the authors’ suggestion. “(Dioxin and cancer: a critical review” . Cole P, Trichopoulos D, Pastides H, Starr T, Mandel JS. Regul Toxicol Pharmacol. 2003 Dec;38(3):378-88., Source Department of Epidemiology, School of Public Health, University of Alabama at Birmingham, USA. jsmande@sph.emory.edu http://www.ncbi.nlm.nih.gov/pubmed/14623487 )

Moreover, biotech firms like Dow and Monsanto claim they offer a genetically modified, pest-resistant crop. Pest-resistant in this context actually means the crops are genetically modified to contain their own built-in pesticide.

11 Psoras, 2/20/2012 11:35 AM

These seeds are ‘tolerant’ to herbicides and are sterile, largely so that the farmer has to again purchase seed or not have seed usable from the previous year's crop which is monopolistic and an abusive corporate practice of control the seed producer sector. Moreover, the GMO seeds genetically modified to not replicate, thus for seed to be sterile seems to be passing on corrupted properties that are producing damage in the ingesting subject(s), regardless of that 'target' as well as moving up whatever food chain into which the GMO is introduced.

Moreover, eating a GM plant i.e., from GM seeds, whether you’re a bug or a human, means you’re ingesting toxic pesticides (that are created by the seeds that are engineered to be herbicide resistant). These herbicides include Monsanto’s Roundup and an herbicide pari-pasu, if not a form of Agent Orange which is produced by Dow Chemical. (2)More information is found at “Everything You HAVE TO KNOW about Dangerous Genetically Modified Foods” http://www.naturalhealthstrategies.com/dangerous-genetically-modified-foods.html

Dow’s and Monsanto's GMO products are causing protein corruption that also has been found to cause protein damage in cells that would happen in people who eat GMO products and/or livestock fed GMO products including the vegetarian ‘grains’ and alfalfa. Damage is proven to happen in test animals such as rats although Monsanto only tested rats over a 90 day period rather than a longer time, and also failed to test other mammals whereas other organizations and scientific groups also tested over longer periods of time other mammals and academic studies on pollinating insects are showing patterns of severe damage in those fauna Findings on Monsanto's Roundup herbicide also show this product is lethal to frogs and toxic to human placental and embryonic cells. It is used on more than 80 percent of all GM crops planted in the world. (2 Everything You HAVE TO KNOW about Dangerous Genetically Modified Foods”) http://www.naturalhealthstrategies.com/dangerous-genetically-modified-foods.html “ and . http://foodfreedom.wordpress.com/2010/01/01/three-approved-gmos-linked-to-organ-damage/

“When testing for drug or pesticide safety, the standard protocol uses three mammalian species. The subject studies (by Monsanto) only used rats, yet won GMO approval in more than a dozen nations. Tests other than those by Monsanto showed, “Chronic problems are rarely discovered in 90 days; most often such tests run for up to two years. Tests “lasting longer than three months give more chances to reveal metabolic, nervous, immune, hormonal or cancer diseases,” wrote Seralini, et al. in their Doull rebuttal. [See “How Subchronic and Chronic Health Effects can be Neglected for GMOs, Pesticides or Chemicals.” IJBS; 2009; 5(5):438-443. http://www.biolsci.org/v05p0706.htm]

In Bees, “it is certain that the digestive shutdown (found in bees dead in hives) is due to hard material in the digestive tract that compromises the immune system. Circulatory problems would (occur) without doubt. Could it be that humans are going through the same process with the rise of Colon Cancer? As seen below in the comparison of the healthy Bee and the unhealthy bee, it is obvious that the bees that are ingesting GMO pollen are having severe digestive problems, so severe that the disease is terminal.” (Death of the Bees. Genetically Modified Crops and the Decline of Bee Colonies in North America by Brit Amos – Global Research, 9Aug11, March 2008 article http://globalresearch.ca/index.php?context=va&aid=25950)

Poultry fed GMO soy is causing damage in those fowl. The genetic engineering in the soy, scientists found residual effects in the poultry that resulting in ‘consumers’ demanding labeling of GM foods and concerns over safety has consumers demanding truth in labeling and transparency. Jack Heinemann, Professor of Genetics and Molecular biology at Canterbury University (was commissioned) to research and report on the question of whether animals exposed to feed containing genetically modified material (GM Feed) do in fact contain 'no GM ingredients'. In his report, a copy of which is available on the Commission's website, Professor Heinemann concluded, "The cumulative strength of the positive detections reviewed  (referring to GMO in feed)…leave me in no reasonable uncertainty that GM plant material can transfer to animals exposed to GM feed in their diets or environment, and that there can be a residual difference in animals or animal-products as a result of exposure to GM feed  (Inghams warned over GM free chicken claims. Nov 18, 2009 Press release Commerce Commission from New Zealand). h ttp://www.comcom.govt.nz/media-releases/detail/2009/inghamswarnedovergmfreechickenclai/ )

Dr Don Huber, a retired military Colonel, contacted USDA Secretary Vilsack by imploring the government to commit the resources necessary to find definitive answers (regarding GMO and related issues). Dr Huber, at the time of this article, was a professor emeritus at Purdue University, believes the appearance and prevalence of the unnamed organism may be related to the nation’s over reliance on the weed killer known as Roundup (here and paragraphs following until cite).

In a letter to Secretary of Agriculture Tom Vilsack, obtained by SafeLawns, the Dr Huber is calling on the federal government to immediately rescind the Jan. 27, 2010 decision to allow genetically modified alfalfa to be released to farmers this spring. “A team of senior plant and animal scientists have recently brought to my attention the discovery of an electron microscopic pathogen that appears to significantly impact the health of plants, animals and probably human beings,” wrote Huber in the letter (from “Safe Lawns”). “Based on a review of the data, it is widespread, very serious, and is in much higher concentrations in Roundup Ready (RR) soybeans and corn — suggesting a link with the RR gene, or more likely the presence of Roundup. This organism appears NEW to science!” In a Safe Lawns phone interview, Huber said he was assured that the United States Department of Agriculture was taking his letter seriously — yet he remained deeply pessimistic that his warnings would ultimately lead to affirmative action.

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“I believe we’ve reached the tipping point toward a potential disaster with the safety of our food supply,” he said. “The abuse, or call it over use if you will, of Roundup, is having profoundly bad consequences in the soil. We’ve seen that for years. The appearance of this new pathogen may be a signal that we’ve gone too far.” This man’s research and associated experience with this body of data reputes that. ( through to note)

Laboratory tests have confirmed the presence of this organism in a wide variety of livestock that have experienced spontaneous abortions and infertility. Preliminary results from ongoing research have also been able to reproduce abortions in a clinical setting.” “It is urgent to examine whether the side effects of Round-up’s active ingredient, glyphosate use may have facilitated the growth of this pathogen, or allowed it to cause greater harm to weakened plant and animal hosts. It is well documented that glyphosate promotes soil pathogens and is already implicated with the increase of more than 40 plant diseases; it dismantles plant defenses by chelating vital nutrients; and it reduces the bioavailability of nutrients in feed, which in turn can cause animal disorders. (The pathogen) deserves immediate attention with significant resources to avoid a general collapse of our critical agricultural infrastructure.” http://www.safelawns.org/blog/index.php/2011/02/researcher-roundup-may-be-causing-miscarriages-in-cattle-humans/ http://www.safelawns.org/blog/ Wed, Feb 16, 2011

Researchers in France at CRIIGEN, Universities of Rouen and Caen, for the first time find cell level damage in mammals' organs by way of chemical interaction with GMO (through this material to note). “The most fundamental point to bear in mind from the outset is that a sample size of 10 for biochemical parameters (referring to Monsanto’s trial it provided for approval by the FDA or USDA) measured two times in 90 days is largely insufficient to ensure an acceptable degree of power to the statistical analysis performed and presented by Monsanto. For example, concerning the statistical power in a t test at 5%, with the comparison of 2 samples of 10 rats, there is 44% chance to miss a significant effect of 1 standard deviation (SD; power 56%). In this case to have a power of 80% would necessitate a sample size of 17 rats” ( begun at opening of this section through to cite de Vendemois et al).

MONSANTO ALSO ENGAGED IN FRAUD AND ITS TRIAL IT PRESENTED TO THE REGULATORS AND THE RETRIAL/MORE THOROUGH TRIAL BY EUROPEAN SCIENTISTS EXPLAINS WHAT MONSANTO DID AND USED IT WITH THE US REGULATORS. With regard to the Statistical power related to the experimental designs used by Monsanto versus these researchers “in reality, in their (Monsanto's) report containing the raw data and statistical analysis, Monsanto did not apply in any case their chosen and described statistical methods. Only parametric tests (one-way ANOVA under homoscedasticity hypothesis and Student t tests on contrasts) were employed. Moreover, to select significant results, they only contrasted the data sets from the 33% GM maize feeding groups (for NK 603 and MON 810) with all reference groups

–( which seems to be that Monsanto attempted to manipulate the perception of the Regulators by using a data set from those fed a partial diet of GMO maize and what damage there is there, serves as that to which all groups are compared. Whatever may be marginal damage in the partially fed GMO group looks only slightly worse than the normal and not as bad as those fed only GMO, but the fed only GMO wasn’t the group used and over a longer time, but also in which more damage became evident over time, as if diluting the findings and attempting to obscure this from the Regulators. AMP)

Per deVednemois moreover, their biological interpretation of statistically significant results differs from case to case. In particular, sex differences were frequently used to reject pathological significance, despite the fact that this was without measuring effects on sex hormone levels. They also used the lack of linear dose-related effects, which is almost inevitable given that only two feeding doses were measured, to declare the diet as safe, as proposed for MON 863 GM maize [4 site’s footnote]. In the MON 863 experiments, the authors still failed to apply their declared methodology, which was slightly different. The ANOVA and contrast analysis (33% GM feeding dose versus controls) were in this case the determining criteria for evaluation of statistical significance, but only if the mean of the 33% GM feeding group was outside the range of the mean of the reference cohorts. All this increases noticeably the risks of false negative results.

Consequently, based on the clear inadequacy of the statistical power (in how Monsanto crafted its trial and reported what it’s used to refute toxic effects for instance the unquestionable large size effects in this study), knowing also that billions of people and animals can consume these products prior to the performance of appropriate in vivo safety evaluation, we applied an appropriate, experimentally validated statistical analytical methodology [5 cite’s footnote], elements of which are described below. (deVednemois)

Monsanto's tests were found to be flawed and its results bogus and erroneous that it had provided to oversight bodies.

In “a comparative analysis of blood and organ system data from trials ... rats (were) fed three main commercialized genetically modified (GM) maize (NK 603, MON 810, MON 863), which are present in food and feed in the world,” “Maize type NK 603 has been modified to be tolerant to the broad spectrum herbicide Roundup and thus contains residues of this formulation. MON 810 and MON 863 are engineered to synthesize two different Bt toxins used as insecticides. Approximately 60 different biochemical parameters were classified per organ and measured in serum

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and urine after 5 and 14 weeks of feeding. GM maize-fed rats were compared first to their respective isogenic or parental non-GM equivalent control groups. This was followed by comparison to six reference groups, which had consumed various other non-GM maize varieties. We applied nonparametric methods, including multiple pair-wise comparisons with a False Discovery Rate approach. Principal Component Analysis allowed the investigation of scattering of different factors (sex, weeks of feeding, diet, dose and group).

The analysis by De Vendomais, et al clearly reveals for the 3 GMOs new side effects linked with GM maize consumption, which were sex- (affects worse on males than females) and often dose-dependent. Effects were mostly associated with the kidney and liver, the dietary detoxifying organs, although different between the 3 GMOs. Other effects were also noticed in the heart, adrenal glands, spleen and haematopoietic system. We conclude that these data highlight signs of hepatorenal toxicity, possibly due to the new pesticides specific to each GM corn. In addition, unintended indirect metabolic consequences of the genetic modification cannot be excluded.” de Vendômois JS, Roullier F, Cellier D, Séralini GE. A Comparison of the Effects of Three GM Corn Varieties on Mammalian Health. Int J Biol Sci 2009; 5(7):706-726. Available from http://www.biolsci.org/v05p0706.htm )

(Moreover, if the regulators were ignorant they were being defrauded, as it were, they’re still accessories before and after the fact to the criminal acts/actions of Monsanto and its damage perpetrated in the food supply and the environment. If the regulators were aware they were being defrauded by Monsanto, then they’re co-conspirators, and aided and abetted Monsanto in its criminal actions against the food supply, mankind and the environment for which it then needs to be punished and the regulators sued by the victims of which there are very many. The dead bees and pollinators, and bats and other insect eating creatures and some of the quality of life of the environment has been murdered and silenced and unable to represent itself in court, and against the regulators which in one way or another atrociously failed in their duty to cease and desist and ban Monsanto’s products and corporate abuse and crimes. Whatever mechanism that needs to punish Monsanto and the beneficiaries of its criminal acts must be put into action AMP ).

Suppressed report shows cancer link to GM potatoes ( through until cite until note). The Independent in the UK reported “that campaigners against genetically modified crops in Britain are calling for trials of GM potatoes this spring to be halted after releasing more evidence of links with cancers in laboratory rats. UK Greenpeace activists said the findings, obtained from Russian trials after an eight-year court battle with the biotech industry, vindicated research by Dr Arpad Pusztai, whose work was criticized by the Royal Society and the Netherlands State Institute for Quality Control.

The disclosure last night of the Russian study on the GM Watch website led to calls for David Miliband, the Secretary of State for Environment, Food and Rural Affairs, to withdraw permission for new trials on GM potatoes to go ahead at secret sites in the UK this spring. Alan Simpson, a Labour MP and green campaigner, said: "These trials should be stopped. The research backs up the work of Arpad Pusztai and it shows that he was the victim of a smear campaign by the biotech industry. There has been a cover-up over these findings and the Government should not be a party to that."

Mr. Simpson said the findings, which showed that lab rats developed tumors, were released by anti-GM campaigners in Wales. Dr Pusztai and a colleague used potatoes that had been genetically modified to produce a protein, lectin. They found cell damage in the rats' stomachs, and in parts of their intestines. The research is likely to spark a fresh row about GM crops in Britain. Graham Thompson, a Greenpeace campaigner, said: "It is important because it backs up the research by Pusztai, which was smeared at the time by the industry."

Brian John of GM Free Cymru, who released the findings, said the research was conducted in 1998 by the Institute of Nutrition of the Russian Academy of Medical Sciences and has been suppressed for eight years…Irina Ermakova, a consultant for Greenpeace, said she had conducted her own animal feeding experiments with GM materials. "The GM potatoes were the most dangerous of the feeds used in the trials ... and on the basis of this evidence they cannot be used in the nourishment of people." Greenpeace said the Russian trials were also badly flawed. Half of the rats in the trial died, and results were taken from those that survived, in breach of normal scientific practice. ( Suppressed report shows cancer link to GM potatoes The Independent: By Colin Brown , Deputy Political Editor /Saturday 17 February 2007 http://www.independent.co.uk/life-style/health-and-families/health-news/suppressed-report-shows-cancer-link-to-gm-potatoes-436673.html http://www.independent.co.uk/life-style/health-and-families/health-news/suppressed-report-shows-cancer-link-to-gm-potatoes-436673.html and http://www.responsibletechnology.org/article-gmo-soy-linked-to-sterility )

“Before the FDA decided to allow GMOs into food without labeling, FDA scientists had repeatedly warned that GM foods can create unpredictable, hard-to-detect side effects, including allergies, toxins, new diseases, and nutritional problems. They urged long-term safety studies, but were ignored. Since then, findings include (through cite to note): Thousands of sheep, buffalo, and goats in India died after grazing on Bt cotton plants Mice eating GM corn for the long term had fewer, and smaller, babies More than half the babies of mother rats fed GM soy died within three weeks, and were smaller Testicle cells of mice and rats on a GM soy change- shrink - significantly

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By the third generation, most GM soy-fed hamsters lost the ability to have babies Rodents fed GM corn and soy showed immune system responses and signs of toxicity Cooked GM soy contains as much as 7-times the amount of a known soy allergen Soy allergies skyrocketed by 50% in the UK, soon after GM soy was introduced The stomach lining of rats fed GM potatoes showed excessive cell growth, a condition that may lead to cancer. Studies showed organ lesions, altered liver and pancreas cells, changed enzyme levels, etc.

Unlike safety evaluations for drugs, there are no human clinical trials of GM foods. The only published human feeding experiment revealed that the genetic material inserted into GM soy transfers into bacteria living inside our intestines and continues to function. This means that long after we stop eating GM foods, we may still have their GM proteins produced continuously inside us. This could mean: If the antibiotic gene inserted into most GM crops were to transfer, it could create super diseases, resistant to antibiotics If the gene that creates Bt-toxin in GM corn were to transfer, it might turn our intestinal bacteria into living pesticide factories. Although no studies have evaluated if antibiotic or Bt-toxin genes transfer, that is one of the key problems. The safety assessments are too superficial to even identify most of the potential dangers from GMOs. (Genetically Modified Soy is Linked to Sterility, Infant Mortality See our Health Risks brochure and State of the Science report for more details and citations. http://www.responsibletechnology.org/

Please see the sub paragraph in the article on the Institute for Responsible Technology: “Denial, Attack and Canceled Follow-up” Scientists who discover adverse findings from GMOs are regularly attacked, ridiculed, denied funding, and even fired.

When Ermakova reported the high infant mortality among GM soy fed offspring, for example, she appealed to the scientific community to repeat and verify her preliminary results. She also sought additional funds to analyze preserved organs. Instead, she was attacked and vilified. Samples were stolen from her lab, papers were burnt on her desk, and she said that her boss, under pressure from his boss, told her to stop doing any more GMO research. No one has yet repeated Ermakova's simple, inexpensive studies. In an attempt to offer her sympathy, one of her colleagues suggested that maybe the GM soy will solve the over population problem! ( “Denial, Attack and Canceled Follow-up” http://www.responsibletechnology.org/article-gmo-soy-linked-to-sterility)

Pesticides associated to genetically modified foods (PAGMF), are engineered to tolerate herbicides such as glyphosate (GLYP) and gluphosinate (GLUF) or insecticides such as the bacterial toxin bacillus thuringiensis (Bt). The aim of this study was to evaluate the correlation between maternal and fetal exposure, and to determine exposure levels of GLYP and its metabolite aminomethylphosphoric acid (AMPA), GLUF and its metabolite 3-methylphosphinicopropionic acid (3-MPPA) and Cry1Ab protein (a Bt toxin) in Eastern Townships of Quebec, Canada. Blood of thirty pregnant women (PW) and thirty-nine non-pregnant women (NPW) were studied. Serum GLYP and GLUF were detected in NPW and not detected in PW. Serum 3-MPPA and CryAb1 toxin were detected in PW, their fetuses and NPW. This is the first study to reveal the presence of circulating PAGMF in women with and without pregnancy, paving the way for a new field in reproductive toxicology including nutrition and utero-placental toxicities. (Aris, A. and S. Leblanc (2011). "Maternal and fetal exposure to pesticides associated to genetically modified foods in EasternTownships of Quebec, Canada."Reproductive Toxicology 31(4).)

“Direct causal links between pesticide exposure and subsequent long-term illness are extremely difficult to establish. However, the evidence is mounting (through cite to note). Out of 426 chemicals named in 1988 by the Ministry of Agriculture, Fisheries, and Food as ingredients in pesticides cleared for use in England, 164 had been implicated in causing cancer, genetic mutations, irritant reactions, or reproductive problems ranging from impotency to birth de-fects. A 1986 National Cancer Institute study reported that farmers exposed to herbicides - especially 2,4-D - for more than twenty days per year were six times as likely to develop non-Hodgkins lymphoma, a cancer of the lym-phatic system. In the prime agricultural region of the San Joaquin Valley of California, where 35% of the wells are contaminated with DPCP (DBCP?), the State Department of Health Services found an increased mortality rate for stomach cancer, the primary site for tumor induction in animals used in testing DPCP (DBCP?). In the small farm community of McFarland, California, thirteen children have developed cancer since 1981, and six have died; miscar-riages, fetal deaths and low birth weights are common. A definitive causal link has not been established, but pesti -cide contamination in the region is a likely factor. Other recent studies link agricultural chemicals to an increase in birth defects.

Scientists are finding higher and higher levels of pesticides in people throughout the world. The effects are poorly understood, but the increased use of pesticides and other industrial chemicals has been followed by increased cancer rates. Since chronic health problems are usually slow in developing, it may well be that the most serious effects of pesticide contamination are yet to come. Pesticides and other chemicals are stored mainly in body fat and tend to concentrate in breast milk fat. They can thus be passed on to children during breast feeding, or to unborn

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babies through the placenta. (From the Ground Up, Rethinking Industrial Agriculture, p. 23. Pesticides, and You http://www.celsias.com/article/pesticides-and-you/)

Human health, of course, is of primary import to us, but ecological effects are also in play. Ninety-nine percent of GMO crops either tolerate or produce insecticide. (http://globalresearch.ca/index.php?context=va&aid=25950 http://www.ucsusa.org/food_and_agriculture/science_and_impacts/impacts_genetic_engineering/environmental-effects-of.html#monarch) This may be the reason we see bee colony collapse disorder and massive butterfly deaths. If GMOs are wiping out Earth’s pollinators, they are far more disastrous than the threat they pose to humans and other mammals. (http://foodfreedom.wordpress.com/2010/01/01/three-approved-gmos-linked-to-organ-damage/ )

Children of agriculture families are likely to be exposed to agricultural chemicals, even if they are not involved in farm activities. Although four organophosphorous (OP) insecticides commonly used on tree fruit were targeted for analysis: azinphosmethyl, chlorpyrifos, parathion, and phosmet. “Pesticides in household dust and soil: exposure pathways for children of agricultural families National Institute of Environmental Health Sciences: Enviornmental Health Perspectives. 1 Dec 95 N J. Simcox, R A. Fenske, S A. Wolz, I C. Lee, D A. Kalman Department of Environmental Health, University of Washington, / http://ehp03.niehs.nih.gov/article/fetchArticle.action?articleURI=info%3Adoi%2F10.1289%2Fehp.951031126 and http://dx.doi.org/10.1289/ehp.951031126

The corn, dubbed "Agent Orange Corn," is being developed by Dow AgroSciences, a subsidiary of Dow Chemical, one of two companies that manufactured Agent Orange (the other was Monsanto). "This novel corn will foster resistant weeds that require more toxic pesticides to kill, followed by more resistance and more pesticides—a chemical arms race in which the only winners are pesticide/biotechnology firms," Andrew

Kimbrell, director of the anti-GMO nonprofit Center for Food Safety, said in a statement. If approved, the crop could be planted as early as next year, bringing with it all the health problems of 2,4-D exposure, including Parkinson's disease, nerve damage, and hormone disruption—to say nothing of the birth defects and cancers caused by dioxin, a potential contaminant. Studies by the Environmental Protection Agency have also found that, in countries with high rates of 2,4-D use on farms, birth defect rates are as much as 60 to 90 percent higher than in other countries.

What's threatening to farmers of non-genetically modified crops is that 2,4-D damages neighboring crops more so than any other weed killer, according to the Center for Food Safety. It can kill wheat before the grain has had a chance to sprout, and can kill as much as 82 percent of sunflowers in a field, just by drifting in from a nearby farm. In 2008, the Natural Resources Defense Council (NRDC) petitioned the Environmental Protection Agency to ban 2,4-D entirely. On February 23rd, the environmental nonprofit sued the agency for failing to respond to that petition. Citing the chemical's toxic effects on people and water, NRDC scientists warn that, if 2,4-D-resistant corn gains USDA approval, use of the herbicide could increase by 50-fold or more.

Genetically modified crops, the Center for Food Safety has said, are a failed technology. Repeated field trials by the United Nations Food and Agriculture Organization and at the Pennsylvania-based Rodale Institute have shown that they produce no better yields than non-genetically modified and organic varieties, and often, according to the UN, under certain circumstances, perform worse than their organic counterparts, rendering new genetically modified varieties as providing "no public benefit," Kimbrell said in his statement. Emily Main 2012-02-22 15:34 Speak Up Now to Stop 'Agent Orange Corn'! http://www.rodale.com/research-feed/gmo-corn

Environmental damage caused by Dow and Monsanto GM agri products, and associated herbicides such a 2,4D and related dioxin and glyphosate, etc

Last week (17Feb12) the US EPA released EPA’s Science Plan for Activities Related to Dioxins in the Environment in which the US EPA website states: “This document provides hazard identification and dose-response information on 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD) and the most up-to-date analysis of non-cancer health effects from TCDD exposure. The report also include a reference dose (RfD) and a detailed and transparent description of the underlying data and analyses. EPA will complete Reanalysis, Volume 2, containing the full dioxin cancer assessment, as expeditiously as possible. In Volume 2, EPA will complete the evaluation of the available cancer mode-of-action data, and will augment the cancer dose-response modeling, including justification of the approaches used for dose response modeling of the cancer endpoints, and an associated quantitative uncertainty analysis. The U.S. Environmental Protection Agency is currently addressing several issues related to dioxins and dioxin-like chemicals in the environment. These include the comprehensive human health and exposure assessment for dioxin, commonly called the dioxin reassessment and a review of dioxin soil clean-up levels currently in use across the United States. To move forward with both of these efforts, as well as other dioxin related activities, a plan with interim milestones has been developed and it is outlined below.

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It made the following DISCLAIMERS however, that again serve to thwart accountability by corporate polluters and BigAg abusers like Dow and Monsanto, which continue to produce herbicides and GMO tolerant to those that harm the environment including the soil and water as well as insect, acquatic live, animal and food supply quality and people physiology.

Volume 1 (noncancer) of the Reanalysis contains some descriptive cancer information. The cancer information in Volume 1 should not be used for regulatory or risk management decision-making. Volumes 1 and 2 of the Reanalysis will supersede the 2003 draft dioxin Reassessment.

The 2003 draft dioxin Reassessment includes a disclaimer that the document should not be cited or quoted. As such, information in this draft document should not be used for regulatory or risk management decision-making. “ EPA Updates Science Assessment for Dioxins / Air emissions of dioxins have decreased by 90 percent since the 1980s, 02/17/2012, Latisha Petteway, petteway.latisha@epa.gov, 202-564-3191 Notice http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=209690

Mother Jones reported in Feb 2007, “In a ruling that could make it more difficult for the USDA to speed through permits for the testing of genetically engineered crops, a federal judge halted field trials of several controversial GMOs yesterday pending a more detailed review of their potential environmental hazards. It was the first time a field trial of a GE crop has been stopped by a U.S. court. Judge Harold Kennedy found the USDA should have required environmental impact statements before approving field trials of pesticide-resistant creeping bentgrass and Kentucky bluegrass in Oregon. Last year, pollen from the grasses escaped from the test area and fertilized plants several miles away in a national grassland.

The ruling was a rebuke to a common practice at the USDA of approving GMO field trials under a "categorical exclusion"--basically, an argument that field trials are too environmentally insignificant to merit detailed oversight. Although the judicial pounding has by no means driven a nail in the coffin of GMOs, it's certainly a sign that the USDA is starting to face rebukes for years of lax policies on a very poorly understood area of science. (For the First Time Ever, a U.S. Court Halts a GMO Field Trial, Josh Harkinson, | Tue Feb. 6, 2007 4:26 PM PST http://motherjones.com/blue-marble/2007/02/first-time-ever-us-court-halts-gmo-field-trial )

“EPA Updates Science Assessment for Dioxins / Air emissions of dioxins have decreased by 90 percent since the 1980s” although most of the dioxins contaminating food is from herbicides.http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/33bcba60ed25a9b1852579a700604ed7!OpenDocument

“In any case, as a result of these lawsuits, during the 1980s the question of dioxin's effects on humans became subject of bitter controversy--with enormous sums of money riding on the outcome of the debate. As the 1980s drew to a close and it became known that all incinerators create and release dioxin into the local environment, industry felt enormous pressure to "prove" that dioxin was harmless to humans. From 1980 onward, industry researchers published several studies of dioxin-exposed workers, claiming to show that they suffered no more cancer than the general public. Last year, however, evidence began to accumulate indicating that the industry-funded studies of dioxin dangers to humans were badly flawed or were simply fraudulent (see RHWN #171, #173, #175)”.( RACHEL'S HAZARDOUS WASTE NEWS #219---February 6, 1991. “New Study Links Dioxin to Cancer” http://www.ejnet.org/rachel/rhwn219.htm )

Despite claims that genetically modified organisms (GMOs) will lower the levels of chemicals (pesticides and herbi-cides) used, quite the opposite has occurred, with 1.6 billion pounds of glyphosate (the active in ingredient in Roundup) being applied to American soil in 2007 alone ( through cite to note). This is of great concern both because of the negative impacts of these chemicals on ecosystems and humans, and because there is the danger that in-creased chemical use will cause pests and weeds to develop resistance, requiring even more chemicals in order to manage them.

Monsanto has been claiming that through genetic engineering it can breed crops for drought tolerance and other cli-mate-resilient traits. This is a false promise. (“Banned in Germany, But You're Probably Still Eating It Posted By Dr. Mercola | January 31 2012, Dr. Mercola – “Monsanto Named the Worst Company of 2011”)

Pesticides associated to genetically modified foods (PAGMF), are engineered to tolerate herbicides such as Round-up, chemically known as glyphosate (GLYP) and gluphosinate (GLUF) or insecticides such as the bacterial toxin bacillus thuringiensis (Bt). Glyphosate [N-(phosphonomethyl) glycine] is an herbicide used widely throughout the world in the production of many crops and is heavily used on soybeans, corn and cotton. Glyphosate is used in almost all agricultural areas of the United States, and the agricultural use of glyphosate has increased from less than 10 000 Mg in 1992 to more than 80 000 Mg in 2007.

Thanks to glyphosate that is sprayed on massive acreages of GM Roundup Ready soybeans, cotton, and corn grown in the United States each and every year, super weeds are growing at an alarming rate. It's estimated that more than 130 types of weeds spanning 40 U.S. states are now herbicide-resistant, and the super weeds are showing no signs of stopping. In fact, the situation is getting progressively worse.

Extremely hardy Roundup-resistant weeds are already boosting costs and cutting crop yields for U.S. farmers. And with world food stores already strained, diminished crop production is a serious problem. In addition, the creation of

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these super weeds is leading farmers to douse their fields with ever increasing amounts of herbicides in a desperate attempt to stop their spread.

Along with the environmental devastation, research published in 2010 showed that glyphosate causes birth de-fects occurred in frogs and chicken embryos at far lower levels than used in agricultural and garden applications. And numerous animal studies suggest reproductive problems are a common side effect of glyphosate exposure and the consumption of genetically engineered Roundup Ready crops. (“Banned in Germany, But You're Probably Still Eating It. Dr. Mercola | January 31 2012, Dr. Mercola – “Monsato Named the Worst Company of 2011”)

The greatest intensity of glyphosate (Round-up) use is in the Midwestern United States, where applications are predominantly to genetically modified corn and soybeans (through cite to note). As well as being used increasingly widely in food production, glyphosate/Round-up-based weed-killers often also get sprayed onto railway lines, urban pavements and roadsides. According to an article in German in the Ithaca journal, a German university study has found significant concentrations of glyphosate/Round-up in the urine samples of city dwellers. Last year also saw the publication of two US Geological Survey studies which consistently found glyphosate in streams, rain and even air in agricultural areas of the US. In spite of the increase in usage across the United States, the characterization of the transport of glyphosate and its depredate aminomethylphosphonic acid (AMPA) on a watershed scale is lacking. Because of significant pressure by agrochemical representatives and the fear that the work of the lab could be influenced, the complete analytical data will only be published in the course of this year." (Now glyphosate is found in people's urine http://www.ithaka-journal.net/herbizide-im-urin; http://www.gmwatch.org/latest-listing/1-news-items/13549)

CONCLUSIONS: Glyphosate use in a watershed results in some occurrence in surface water; however, the watersheds most at risk for the offsite transport of glyphosate are those with high application rates, rainfall that results in overland runoff and a flow route that does not include transport through the soil (18). Because very little research has been done, in spite of concentrations in the environment and increased use on crops, this cite is for the first report on the ambient levels of glyphosate, the most widely used herbicide in the United States, and its major degradation product, aminomethylphosphonic acid (AMPA), in air and rain. Chang, F. C., M. F. Simcik, et al. (2011). "Occurrence and fate of the herbicide glyphosate and its depredate aminomethylphosphonic acid in the atmosphere these contaminants are now being found in people’s urine presumed from the water supply (19)." (18 Copyright (c) 2011 Society of Chemical Industry. Coupe, R. H., S. J. Kalkhoff, et al. (2011). "Fate and transport of glyphosate and aminomethylphosphonic acid in surface waters of agricultural basins.", Pest Manag Sci. 19 Environ Toxicol Chem 30(3): 548–555. GMWatch (website) Now glyphosate found in people's urine, Friday, 20 January 2012 16:39 )

Bio-magnification: the higher up the food chain the poison travelled, the more Herbicides accumulated (although here referring to glyphosate, however dioxins also do the same), or 'magnified' it becomes, and this magnification can be exponential. We're at the top of most food chains (through cite to note). Moreover, the United States pro -duces between 100 and 150 million pounds of pesticides which are considered too dangerous for use within the country's borders. These chemicals are exported for use in other nations with less stringent environmental safe-guards. ( From the Ground Up, Rethinking Industrial Agriculture, p. 23. Pesticides, and You http://www.celsias.com/article/pesticides-and-you/ )

Summary of Remarks by Pesticide Research Team - Queen’s Park News Conference, April 23, 2004 (21)BACKGROUND ONLY — NOT TO BE USED AS ATTRIBUTED QUOTESOur review has found evidence of serious harmful effects in several areas including cancer, reproductive effects and impacts on the nervous system. These effects are found in both occupational and home and garden exposures. (21 http://www.ocfp.on.ca/communications/public-policy-documents Pesticides Literature Review Dr. Margaret Sanbord, Dr. Donald Cole, Dr. Kathleen Kerr, Dr. Cathy Vakil, Dr. Luz Helena Sanin, Dr. Kate Bassil / Published: 4/23/2004 12:00:00 AM

Although I was not able to quickly find if dioxin based herbicides chelated trace elements out of the soil as well as render the plants with little or inferior nutritional value like “wimpy” milk and butter from cows administered rBHT and similar bovine stimulant hormones and pharma, and the USDA probably already knows this and PROBABLY already understands this, however,

“The same nutrients that glyphosate chelates and deprives plants of – essential minerals such as iron, zinc, copper, manganese, magnesium, calcium, and boron – are also critical for animal and human health. One example is manganese, a mineral whose losses can be severe. The nutrient not only is chelated by glyphosate but also is reduced in Roundup Ready plants. Recently veterinarians have found low levels of manganese and sometimes no detectible levels in livestock that they’ve tested. Veterinarians also report much sicker animals since GM foods started to dominate animal feed, and when livestock is switched from GMO to non-GMO feed, the animals experience dramatic improvement in health. Minerals are simpler in chemical form and are tiny in comparison to vitamins, but they are one of six groups of nutrients we need for healthy function each and every day. With depleted levels of minerals, failure to thrive develops, then deficiency diseases with severe health consequences, and eventually death. This occurs not only in humans, but also in animals and plants.

This loss is something we simply can’t afford. We’re already suffering from progressive nutrient deprivation even without Roundup. In a UK study, for example, they found between 16-76% less nutrients in 1991, com-

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pared to levels in the same foods in 1940. ” (Herbicide Used on GM Corn & Other Crops a Mineral Chelator by Melissa Diane Smith http://www.againstthegrainnutrition.com/newsandnotes/2011/01/23/herbicide-used-on-gm-corn-other-crops-a-mineral-chelator/)

This is their (Dow’s and Monsanto’s) job to understand * and be responsible about * plant and soil nutrition and quality. Yet they and the FDA and USDA permitted and had permitted BigAg-BioTech and BigDairy to produce and plant GMO seeds/crops into the environment that have been eroding the environment and food quality; meanwhile it’s disgraceful corruption to see the erosion in the quality of the environment and the plant and livestock/diary/poultry-eggs food supply and feeds to those that has continued to go forward in our agriculture/land ‘husbandry’ and livestock dairy and poultry production without ANY efforts on the part of the USDA, the FDA, and the EPA to professionally assess food and environmental quality. ( AMP)

Although not directly related to Monsanto's GMO environmental and physiological harm, the similar abuses and contaminations exist in other related contexts: Meanwhile, the meat industry built a multi-billion dollar business based on stuffing animals by the thousands into tight spaces amid their own waste. To keep them alive and growing to slaughter amid such conditions, feedlot operators give their animals daily doses of antibiotics and other of Monsanto’s pharma. The FDA recently revealed that factory animal farms now burn through fully 80 percent of all antibiotics consumed in the United States. (http://motherjones.com/tom-philpott/2012/01/monsanto-gmo-drought-tolerant-corn Mother Jones: Tom Philpott, Mon Jan. 23, 2012 12:15 PM PST USDA Greenlights Monsanto's Utterly Useless New GMO Corn)

And deceitful trial practices to obtain regulator approval yielding flawed test results not to mention support by wealthy and influential players like Bill Gates**

See also Page 13,14 deVednemois Study for the fraud in its trials it presented to the US regulators. Monsanto knew in presenting the materials in the way that it did for the trial, it would minimize what would be observed by the Regulators, who are complicit with the fraud if they knew that Monsanto not only mixed its trial materials but also in the manner of what it also presented in the trial, limiting the number of lab rats as well as limiting its trials to only rats rather than also using other mammals it used and over too short a time frame failed to reveal the damage caused by those rats eating Monsanto GMO feed.

MONSANTO ENGAGED IN FRAUD, MEANWHILE IT also mixed/OBSCURED its trial subject matter and presented results of this corrupted trial to the USDA and/or FDA for approval ” Further, Monsanto’s analysis compared unrelated feeding groups, muddying the results. The June 2009 rebuttal explains, “In order to isolate the effect of the GM transformation process from other variables, it is only valid to compare the GMO … with its isogenic non-GM equivalent.” (through cite to note)

(Moreover, if the regulators were ignorant they were being defrauded, as it were, they’re still accessories before and after the fact to the criminal acts/actions of Monsanto and its damage perpetrated in the food supply and the environment. If the regulators were aware they were being defrauded by Monsanto, then they’re co-conspirators, and aided and abetted Monsanto in its criminal actions against the food supply, mankind and the environment for which it then needs to be punished and the regulators sued by the victims of which there are very many. The dead bees and pollinators, and bats and other insect eating creatures and some of the quality of life of the environment has been murdered and silenced and unable to represent itself in court, and against the regulators which in one way or another atrociously failed in their duty to cease and desist and ban Monsanto’s products and corporate abuse and crimes. Whatever mechanism that needs to punish Monsanto and the beneficiaries of its criminal acts must be put into action AMP).

The researchers which conducted this excellent review of Monsanto’s trial it used with the ‘appropriate’ regulators, as well as responsible research for the efforts in their own countries on whether or not to permit GMO in their food supply and environment as well as the use of the herbicides and pesticides used in the US but banned in Europe because of their toxicity to the environment have provided us robust information. These researchers have concluded that the raw (Monsanto as well as their own research) data from all three GMO studies reveal novel pesticide residues will be present in food and feed and may pose grave health risks to those consuming them.” They have called for “an immediate ban on the import and cultivation of these GMOs and strongly recommend additional long-term (up to two years) and multi-generational animal feeding studies on at least three species to provide true scientifically valid data on the acute and chronic toxic effects of GM crops, feed and foods.” (http://foodfreedom.wordpress.com/2010/01/01/three-approved-gmos-linked-to-organ-damage/; **http://www.takepart.com/article/2012/02/02/the-flip-side-what-bill-gates-doesnt-know-about-gmos

The Examiner.com reports that Rep Kucinich introduced, H.R. 3554 The Genetically Engineered Safety Act, which aims to protect the food supply from Monsanto and GMOs, the use of which largely has been unrestricted in part because it has presented findings from flawed tests in order to deceive the regulators. His HR is looking to attempt to prevent biological contamination of the food supply. (http://www.examiner.com/democrat-in-national/kucinich-bill-aims-to-protect-food-supply-from-monsanto-gmos

In order to prevent further harm in the environment, the food supply, the insect and animal wildlife, the domestic livestock food supply, the people who eat the livestock, poultry/egg and dairy industries' production from its deceitful

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representations to the FDA and USDA, Kucinich's HR would prohibit open air cultivation of GE pharmaceutical and industrial crops (through cite to note). The 'bill' also would prohibit the use of common human food or animal feed as the host plant for a GE pharma or industrial chemical. If passed the legislation would establish a tracking system to regulate the growing handling, transport, and disposal of pharma and industrial crops, and protect native ecosystems and traditional farms from the poorly studied or misrepresented dangers of growing GE organisms. Kucinich rightfully so is concerned about irreversible damage to our food supply.... Many Americans are unaware that crops that are GE to produce experimental pharma are being grown in this country in the open, allowing them to contaminate conventional crops without detection. We cannot rely on industry to prevent the undetected spread of GE organisms. We have taken few steps to ensure that our own genetic experiments are kept in check: (sounds similar to what the nazis did in the concentration camps). He is attempting to have what would be legislation that ensures that cloning and GE do not disrupt our traditional food supply. The USDA has allowed outdoor field trials of more than 300 outdoor field plants to produce experimental pharma, industrial enzymes, and novel proteins. Those GE substances are not intended to be incorporated into food or to be spread into the environment or our food supply. The potential for already significant contamination introduces risks of grand scale destructive consequences. (Examiner.com/ Michael Stone, 12Dec11 http://www.examiner.com/democrat-in-national/kucinich-bill-aims-to-protect-food-supply-from-monsanto-gmos )

Anti-competitive/Monopolistic and Corporate abusive practices so that Monsanto, Dow and this cartel of biotech players are those who are the Actual Beneficiaries versus those alleged to Benefit from the use of GMO. The Non GM Agriculture- the every day non gmo and organic farmers and society which expect and trust the system for clean, uncontaminated, undamaging food have been harmed by Monsanto, Dow and the biotech cartel.

Monsanto and Dow are probably colluding and engaging in abusive anti-monopolistic practices, as well as harmful, abusive practices to society and the environment; Even scarier, Monsanto and Dow now seem to be in collusion with one another. In its petition, Dow states that the 2,4-D trait in the GE seeds will be stacked with Monsanto’s Roundup Ready trait so that the seeds are resistant to multiple herbicide tolerances. Soon we’ll be eating food with a whole cocktail of different herbicide traits cooked into the seed—all so they can be sprayed with chemicals that are more toxic than ever before! The real solution here is to stop using GE seeds altogether.( http://www.anh-usa.org/agent-orange-on-our-crops/

Per Mother Jones SEC Investigates Monsanto's Roundup Biz —By Tom Philpott “ The SEC is investigating Monsanto's tactics for defending the market for its herbicide, Roundup. The news emerged just before the July 4 holiday weekend, during Monsanto's press conference about its quarterly financial earnings. Company execs boasted of a 77 percent increase in profit before dropping a mini-bombshell, The Wall Street Journal reported: Monsanto said it was cooperating with a previously undisclosed US Securities and Exchange Commission probe into its customer incentive programs for herbicides in fiscal years 2009 and 2010, and had received a subpoena to provide related documents.

Neither the SEC nor Monsanto will comment on the ongoing investigation. But Monsanto did issue a terse press release after the earnings call explaining that the probe "relates to financial incentives Monsanto offered to distributors who carry its glyphosate products and the financial reporting of those incentives."

Glyphosate is the active ingredient in Monsanto's flagship Roundup herbicide, and "distributors" refers to the seed industry's middlemen, the companies that buy seeds and agrichemcals from suppliers like Monsanto and sell them to farmers. So what the company is saying its that it gave "financial incentives"—presumably, discounts—to somehow promote Roundup sales in 2009 and '10.

Here's the context. For years, the company minted profits by selling farmers seeds engineered to withstand that potent weed killer, and also selling them copious amounts of the weed killer itself. But its patent on glyphosate expired in 2000. By the late 2000s, Chinese competitors selling cheap generic glyphosate had stormed into the market, eating away at Monsanto's Roundup sales. In response, according to Bloomberg, Monsanto announced in early 2010 that it would spend up to $150 million on "incremental price concessions or trade incentives" to boost its Roundup brand.Did Monsanto essentially bribe agrichemical dealers to promote Roundup and squeeze out competitors? That, I suspect, is the question SEC investigators are asking. Monsanto certainly has a history of using its heft to manipulate the markets it dominates. Here's what AP's Christopher Leonard concluded after digging into Monsanto's business practices for an an excellent 2009 investigative report: "The world's biggest seed developer is squeezing competitors, controlling smaller seed companies, and protecting its dominance over the multibillion-dollar market for genetically altered crops." And as the SEC investigation suggests, it may be resorting to illegal tactics to maintain its Roundup cash cow. (SEC Investigates Monsanto's Roundup Biz —By Tom Philpott | Tue Jul. 19, 2011 2:00 AM PDT, http://motherjones.com/tom-philpott/2011/07/roundup-sec-investigates-monsanto )

Meanwhile, Reported by RACHEL'S HAZARDOUS WASTE NEWS #400 July 28, 1994 EPA INVESTIGATED MONSANTO, an internal memorandum by an official of the U.S. Environmental Protection Agency [EPA], has accused EPA of conducting a "fraudulent" criminal investigation of Monsanto, the St. Louis chemical corporation. [1 William Sanjour, EPA Office of

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Solid Waste and Emergency Response, "Memorandum: The Monsanto Investigation" to David Bussard, Director, EPA Characterization and Assessment Branch, dated July 20, 1994. Available for $5.00 from Citizens Clearinghouse for Hazardous Waste, P.O. Box 6806, Falls Church, VA 22040; phone (703) 237-2249. ]

The 30-page memo, from William Sanjour to his supervisor, David Bussard, dated July 20, 1994, describes a two-year-long criminal investigation of Monsanto by EPA's Office of Criminal Investigation (OCI). The Sanjour memo says EPA opened its investigation on August 20, 1990 and formally closed it on August 7, 1992. "However, the investigation itself and the basis for closing the investigation were fraudulent," the Sanjour memo says. According to the Sanjour memo: ** EPA's investigation of Monsanto was precipitated by a memo dated February 23, 1990, from EPA's Dr. Cate Jenkins to Raymond Loehr, head of EPA's Science Advisory Board. ** The Jenkins memo said that EPA had set dioxin standards relying on flawed Monsanto-sponsored studies of Monsanto workers exposed to dioxin, studies that had showed no cancer increases among heavily exposed workers. ** Attached to the Jenkins memo was a portion of a legal brief filed by the plaintiffs as part of a trial known as Kemner v. Monsanto, in which a group of citizens in Sturgeon, Missouri had sued Monsanto for alleged injuries they had suffered during a chemical spill caused by a train derailment in 1979. ** The Jenkins memo had not requested a criminal investigation; instead Jenkins had suggested the need for a scientific investigation of Monsanto's dioxin studies. But in August 1990, EPA's Office of Criminal Investigation (OCI) wrote a 7-page memo recommending that a "full field criminal investigation be initiated by OCI." ** Plaintiffs in the Kemner suit made the following kinds of allegations (which we quote verbatim from the Sanjour memo): "* Monsanto failed to notify and lied to its workers about the presence and danger of dioxin in its chlorophenol plant, so that it would not have to bear the expense of changing its manufacturing process or lose customers;... "* Monsanto knowingly dumped 30 to 40 pounds of dioxin a day into the Mississippi River between 1970 and 1977 which could enter the St. Louis food chain; "* Monsanto lied to EPA that it had no knowledge that its plant effluent contained dioxin; "* Monsanto secretly tested the corpses of people killed by accident in St. Louis for the presence of dioxin and found it in every case;... "* Lysol, a product made from Monsanto's Santophen, was contaminated with dioxin with Monsanto's knowledge." [The Sanjour memo says that, at the time of the contamination, "Lysol (was) recommended for cleaning babies' toys and for other cleaning activities involving human contact."] "* The manufacturer of Lysol was not told about the dioxin by Monsanto for fear of losing his business; "* Other companies using Santophen, who specifically asked about the presence of dioxin, were lied to by Monsanto;... "* Shortly after a spill in the Monsanto chlorophenol plant, OSHA measured dioxin on the plant walls. Monsanto conducted its own measurements, which were higher than OSHA's, but they issued a press release to the public and they lied to OSHA and their workers saying they had failed to confirm OSHA's findings; "* Exposed Monsanto workers were not told of the presence of dioxin and were not given protective clothing even though the company was aware of the dangers of dioxin; "* Even though the Toxic Substances Control Act requires chemical companies to report the presence of hazardous substances in their products to EPA, Monsanto never gave notice and lied to EPA in reports; "* At one time Monsanto lied to EPA saying that it could not test its products for dioxin because dioxin was too toxic to handle in its labs."...

OCI's August memo alleged that "Monsanto did, in fact, produce 'research' to defend its position. 'The Record however, shows a deliberate course of conduct designed to convince its employees and the world that Dioxin is harmless,'" the OCI memo said. [2 ] Memorandum from [name redacted] in EPA Office of Criminal Investigation to [name redacted] in EPA Office of Criminal Investigation dated August 16, 1990. A copy of this memo was sent to us by EPA's Freedom of Information Officer in Washington, D.C. ]

OCI's memo concluded, "Based upon review of the available information submitted to the EPA-OCI by the Office of Enforcement, it is recommended that a full field criminal investigation be initiated by OCI.

"Information in the plaintiff's brief indicate a potential conspiracy, between Monsanto and its officers and employees, exists or has existed to defraud the US EPA, in violation of 18 USC 371. The means of the conspiracy appears to be by (1) providing misleading information to the EPA; (2) intentional failure by Monsanto to fully disclose all pertinent TSCA [Toxic Substances Control Act] related information to the EPA; (3) false statements in notices and reports to EPA; (4) the use of allegedly fraudulent research to erroneously convince the EPA, and the scientific community, that Dioxin is less harmful to health and the environment." (“EPA Investigates Monsanto” RACHEL'S HAZARDOUS WASTE NEWS #400---July 28, 1994--- http://www.ejnet.org/rachel/rhwn400.htm )

The public ‘record’ provides robust information about relationships between Dioxin causing cancer however the corporate record is reported to alter or control or defraud ‘official’ reports and tests by the US regulators on which upgrading environmental and agricultural standards rely. For example studies in which Monsanto and BASF of Dioxins engaged in fraud and similar miscreant activity such as conspiracy have diminished the regulatory ‘official’ record that would force the regulators to require indsutray and agriculture to comport themselves in more responsible and less reckless ways in the environment, agriculture and in their science, rather than presume teir science is absolute and without accountability. (Dioxins and Cancer: Fraudulent Studies. RACHEL'S HAZARDOUS WASTE NEWS #171 ---March 7, 1990---http://www.ejnet.org/rachel/rhwn171.htm)

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The following leaked memo to the US Environmental Protection Agency, summarised by The Ecologist, shows how Monsanto lied to the US authorities about its dioxin production, and deliberately falsified data to prevent compensation claims or the tightening of regulations. (Monsanto's Dioxin Fraud, http://www.lightparty.com/Economic/MonsantoDioxinFraud.html)

“Marie-Monque Robin reports that following Monsanto’s long history of manufacturing hazardous chemicals and lethal herbicides, it is now marketing itself as a "life sciences" company, seemingly convinced about the virtues of sustainable development ( through cite to note) (although ‘sustainable development means to shrink the world’s population by 8/9s using any means to achieve that in different geographies AMP). However, Monsanto now controls the majority of the yield of the world's genetically modified corn and soy--ingredients found in more than 95 percent of American households--and its alarming legal and political tactics to maintain this monopoly are the subject of worldwide concern. The author’s documentary is the result of a three-year-long investigation that took across four continents (North and South America, Europe, and Asia), The World According to Monsanto tells the little-known yet shocking story of this agribusiness giant--the world's leading producer of GMOs (genetically modified organisms)--and how its new "green" face is no less malign than its PCB- and Agent Orange-soaked past…” (The World According to Monsanto: Pollution, Corruption, and the Control of the World's Food Supply [Hardcover] Marie-Monique Robin, http://www.amazon.com/gp/product/1595584269/ref=cm_cr_dpvoterdr?ie=UTF8&isSRAdmin=#RVI73YD1JL5P5.2115.Helpful.Reviews )

Monsanto wants you to simply trust them because they're "experts" and because their industry-funded studies "prove" their GM foods are safe (through cite to note). But these same experts also told you PCB's, Agent Orange, and DDT was safe, and we now know those claims were far from accurate. Of course, in terms of reliability, there's a big difference between corporate science, which tends to primarily favor and support corporate interests, and inde-pendent science, performed without preconceived bias. (Monsanto Named the Worst Company of 2011.htm by Dr. Mercola Jan 31, 2012 “Banned in Germany but you’re probably still eating it”)

What appears to be is the aggressive and prolific use of herbicides and insecticides which already caused environmental and nature blowback, has served as a reason for Monsanto and Dow to produce GM seeds and crops that actually ENCOURAGE MORE use of yet more and more powerful herbicides and pesticides. In Feb 2008, Friends of the Earth published its Media Advisory entitled: “NEW REPORT: GM CROPS INCREASE PESTICIDE USE”. It reported “In 2007 GM crops still failed to tackle hunger and poverty in developing countries” (through cite to note).

A new report released on February 13th (2008) shows that planting genetically modified (GM) crops are causing an increased use of harmful pesticides in major biotech crop producing countries. A new report released (by Friends of the Earth) on February 13th shows that planting genetically modified (GM) crops is causing an increased use of harmful pesticides in major biotech crop producing countries. GM crops are not ‘green’. The adoption of Roundup Ready (RR) crops, the most extensively grown GM crop today, has led to an increase in pesticide use:

- In the United States, data from the U.S. Department of Agriculture (USDA) shows that RR crops drove a more than 15-fold increase in the use of glyphosate –the herbicide associated with RR crops- on major field crops from 1994 to 2005. In 2006, the last year for which data is available, glyphosate use on soybeans jumped a substantial 28%. The intensity of glyphosate use has also risen dramatically. From 1994 to 2006, the amount of glyphosate applied per acre of soya rose by more than 150%. The increase in glyphosate herbicide is no longer displacing other herbicides in the US. From 2002 to 2006 the use of 2,4-D –one of the most widely used herbicide in the world- on soybeans more than doubled, and the use of atrazine (an herbicide banned in Europe due to links to health problems) on corn increased by 12 per cent from 2002 to 2005.

- In major RR soybean producer countries, like Brazil and Argentina, glyphosate use and weed resistance have risen. A 2007 study by a Brazilian governmental agency shows that the use of glyphosate increased 79.6% between 2000 to 2005, much faster than the expansion in area planted with RR soya. In 2007 a glyphosate-resistant weed called Johnson Grass infested over 120,000 ha in Argentina. An estimated 25 million litres of herbicides other than glyphosate will be needed, resulting in increasing production costs of between $160 to 950 million per year. In India, a 2007 study from Andhra University concluded that Bt cotton uses the same amount of pesticides as conventional cotton.

The 2008 edition of the Friends of the Earth International “Who Benefits from GM crops?” report series is titled “The Rise in Pesticide Use” and concludes that GM crops on the market today have on the whole caused an increase rather than a decrease in toxic pesticides use, and have failed to tackle hunger and poverty. GM crops do not tackle hunger or poverty. Most GM crops commercialized so far are destined for animal feed, not for food, and none have been introduced to address hunger and poverty issues. GM crops are not providing help to small farmers in develop-ing countries. In South Africa, for example since the adoption of Bt cotton, the number of small cotton farmers have plummeted from 3229 in 2001/02 to just 853 in 2006/07.

“The biotech industry is telling Africans that we need GM crops to tackle the food needs of our population. But how can we believe such statements when the majority of GM crops are used to feed the animals of rich countries, pro-

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duce industrial products like agrofuels, and overall don’t yield more than conventional crops?”, said Nnimmo Bassey of Friends of the Earth Nigeria/ERA. As it were, “GM crops still fail to deliver the long-promised benefits. They are not good for the environment, as they are increasing pesticide use. In addition, they do not benefit small farmers or consumers in terms of quality or price,” added Bassey. (28 MEDIA ADVISORY- Friends of the Earth International, February 13, 2008, BRUSSELS (BELGIUM), LAGOS (NIGERIA), KUALA LUMPUR (MALAYSIA) – February 13, 2008 –: NEW REPORT: GM CROPS INCREASE PESTICIDE USE http://www.foei.org/en/media/archive/2008/gm-crops-increase-pesticides/ )

Moreover, regarding criticism of its trials and its products and ‘science’ Monsanto’s rebuttal to its opponents was disingenuous and vague. Damage also was experienced by live stock producers and bt alfalfa which Monsanto sloughed off and ridiculed. “Genetically modified seeds are produced and distributed by powerful biotech conglomerates (29 through cite to note). The latter manipulate government agricultural policy with a view to supporting their agenda of dominance in the agricultural industry. American conglomerates such as Monsanto, Pioneer Hybrid and others, have created seeds that reproduce only under certain conditions, often linked to the use of their own brands of fertilizer and/or insecticide and obtain this capability to engage in this abuse by regulatory approval.“ (29 http://globalresearch.ca/index.php?context=va&aid=25950 Death of the Bees. Genetically Modified Crops and the Decline of Bee Colonies in North America by Brit Amos – Global Research, 9Aug11, based on March 2008 article)

OSGATA v Monsanto. Since March, 82 other plaintiffs representing over 300,000 organic farmers, seed companies and food associations have joined the case (30 through cite to note). “The trajectory from the past fifteen years, which been increasing in recent years, is that organic farmers will be forced out of business because the extended contamination will become so extensive because of its increasing acreage,” Gerritsen said when Lekas Miller asked what inspired him to file a lawsuit. “So either we stand up and fight now, or we’re going to lose our options.” (30 Tuesday 1/30/12, Gerritsen and over 50 plaintiff representatives, New York City, Public Patent Foundation lawyer Dan Ravicher *http://www.alternet.org/health/153982/occupy_vs._monsanto:_activists,_farmers_fight_the_corporation_they_fear_will_take_over_all_america's_crops?page=entire)

Monsanto begin to purchase as many seeds as possible—spending $8 billion and acquiring over 20 seed companies over the past decade alone. Today, Monsanto controls 93 percent of soybean crops, 86 percent of corn crops, 93 percent of cotton crops, and 93 percent of canola seed crops in the United States alone (31 through cite to note).

Monsanto is far from finished. To continue its corporate monopoly and push more seeds off the market, Monsanto specifically targets organic farmers, often testing their crops without permission. If the crops are resistant to RoundUp, Monsanto’s signature pesticide, Monsanto sues the farmer for patent infringement.

In many instances, pollen from a neighboring farm growing Monsanto’s genetically modified crops can migrate to an organic farm, contaminating its crops. In addition to losing these crops and losing important organic buyers due to this genetic trespass, many organic farmers face undeserved, crippling lawsuits from Monsanto that force them into debt, bankruptcy, and often out of business entirely.

“Family scale farmers are the most in danger; all of us are hanging on by our fingertips,” Jim Gerritsen, an organic potato farmer from Northern Maine and president of the Organic Seed Growers and Trade Association (OSGATA), told Lekas Miller. “The thought of having to fight off a monster like Monsanto under false charges—and in this country, as wonderful as it is, anybody can sue anybody for anything—having to defend ourselves from a frivolous lawsuit could bankrupt any of us.” ( http://www.alternet.org/health/153982/occupy_vs._monsanto:_activists,_farmers_fight_the_corporation_they_fear_will_take_over_all_america's_crops?page=entire Alternet/Personal Health - Anna Lekas Miller: Occupy vs. Monsanto: Activists, Farmers Fight the Corporation They Fear Will Take Over All America's Crops, 6Feb12)

“The U.S. Is Behind the Curve in Rejecting GM Foods” (through cite to note)People around the world have joined forces to refuse GM foods and crops because of the dangers they present to biosphere and physiology and the future of the food supply. Europe, for example, eliminated GMOs from their food supply 10 years ago.In the United States, however, because there is no labeling for GMO in the food, many are still not even aware they're eating GM foods every day.That’s because an estimated 75 percent of foods in U.S. grocery stores contain GM ingredients. About seven out of every 10 items in the average grocery cart have been genetically modified. And don’t bother reading labels to see if you’re buying a GM product, because no labeling is required.

Why Genetically Modified Food in the First Place? The stated purpose for the development of GMOs is to increase crop yields, reduce costs for farmers, and to use less herbicide.

Actual results? No increase in yields: GM soy decreased yields by up to 20 percent compared with non-GM soy, and up to 100 percent failures of GM cotton have been recorded in India.

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Increase in costs to farmers: "Terminator technology" is being used to create seeds that self-destruct. The seeds (and subsequent crops) are sterile, which means farmers must buy them again each year instead of using the seeds from their harvest to replant the following year, which is the traditional way. This means bigger profits for the food companies that are patenting GM seeds, and more money shelled out from farmers. Worse still, this practice could actually threaten the entire food supply because the sterile seeds may spread to nearby fields. No reduction in pesticide use: USDA data showed that GM crops increased pesticide use by 50 million pounds from 1996 to 2003 in the United States Biotech firms claim they offer a genetically modified pest-resistant crop. Pest-resistant in this context actually means the crops contain their own built-in pesticide. So eating a GM plant, whether you’re a bug or a human, means you’re ingesting toxic pesticides.

The fact is genetic engineering is crude, imprecise and insidious. The process itself alters DNA and mutates genes. It’s a game of genetic roulette that can’t be won, and is ultimately dangerous. (http://www.celsias.com/article/who-benefits-from-gm-crops/

It has been proven GM crops do not fulfill their stated purpose. They have not influenced the escalating rates of hunger, poverty, food prices and environmental disasters” (http://www.naturalhealthstrategies.com/dangerous-genetically-modified-foods.html “ Everything You HAVE TO KNOW about Dangerous Genetically Modified Foods”)

“Jeffrey M. Smith, author of Seeds of Deception, and Genetic Roulette, asserts that genetically modified (GM) soy has decreased yields by nearly 20 percent compared with non-GM soy, and failures of GM cotton have been as high as 100 percent in some cases. The irony is that supporters of GMOs originally claimed that they would increase crop yields, and would reduce both the costs for farmers and the necessity for herbicides. But the use of GMOs has proven to have exactly the opposite effects. Likewise, the use of GMOs has resulted in cost increases to farmers. Smith explains that “terminator technology” — which creates seeds that self-destruct — forces farmers to purchase more of the same seeds each year, instead of using the seeds from their harvest in the following year. As noted by Smith, this situation also results in larger profits for the food companies which patent GM seeds. Those seeds could pose threats to the food supply because the sterile seeds may spread to nearby fields.

Meanwhile, there has been no reduction in the use of pesticide. In fact, data from the USDA reveal that the rise of GM crops in the United States increased pesticide use by 50 million pounds from 1996 to 2003 (34 through to note). Smith pointed out that Roundup herbicide, which is said to be poisonous to frogs as well as placental and embryonic cells, has been used on 80 percent of GM crops around the world. In other words, what was once offered as a solution to a problem has created yet more problems.” (34 http://www.thenewamerican.com/usnews/politics/10731-kucinich-bills-would-control-gmos-good-intent-bad-policy http://globalresearch.ca/books/SoD.html)

William Engdahl has research “Seeds of Destruction: The Hidden Agenda of Genetic Manipulation”. The book focuses on how a small socio-political American elite seeks to establish control over the very basis of human survival: the provision of our daily bread (35 through to note). "Control the food and you control the people." Engdahl takes the reader inside the corridors of power, into the backrooms of the science labs, behind closed doors in the corporate boardrooms. The author cogently reveals a diabolical World of profit-driven political intrigue, government corruption and coercion, where genetic manipulation and the patenting of life forms are used to gain worldwide control over food production. If the book often reads as a crime story, that should come as no surprise. For that is what it is.

Engdahl's carefully argued critique goes far beyond the familiar controversies surrounding the practice of genetic modification as a scientific technique. (35 http://globalresearch.ca/books/SoD.html, http://www.alternet.org/health/153982/occupy_vs._monsanto:_activists,_farmers_fight_the_corporation_they_fear_will_take_over_all_america's_crops?page=entire

Herbicides and insecticides are potent environmental toxins. Where GE crops cannot deliver meaningful reductions in reliance on pesticides, policy makers need to look elsewhere. In addition to toxic pollution, agriculture faces the twin challenges of climate change and burgeoning world populations (36 through to note). The biotechnology indus-try’s current advertising campaigns promise to solve those problems, just as the industry once promised to reduce the chemical footprint of agriculture. Before we embrace GE crops as solution to these new challenges, we need a sober, data-driven appraisal of its track record on earlier pledges. THIS HONEST PROCESS HAS BEEN DE-FRAUDED BY BOTH MONSANTO AND THE REGULATORY FRAMEWORK.

The government has the capability, and we would argue a responsibility, to conduct periodic surveys of sufficient depth to track and accurately quantify the impacts of GE crops on major performance parameters, including pesti-cide use. While the USDA continued to collect farm-level data on pesticide applications during most of the 13 years covered in this report, the Department has been essentially silent on the impacts of GE crops on pesticide use for al -most a decade. This is why the groups listed in the Acknowledgements commissioned this study by Dr. Benbrook, the third he has done on this topic since 2002.

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Authors of this report hope that it will help trigger new government and academic assessments of the performance, costs, and risks associated with today’s GE crops. Without such assessments, American agriculture is likely to con-tinue down the road preferred by the biotechnology industry, a path that promises to maximize their profits by captur-ing a larger share of farm income, and limit the ability of plant breeders and other agricultural scientists to address other pressing goals of wider importance to society as a whole. (36 Dr. Margaret Mellon, Director, Food and Environment Program Union of Concerned Scientists; Mr. Mark Retzloff, Board Chair, The Organic Center, President, Aurora Organic Dairy. “Impacts of Genetically Engi-neered Crops on Pesticide Use in the United States: The First Thirteen Years”. November 2009 by Charles Benbrook, Ph.D. Chief Scientist, The Organic Cen-ter: Critical Issue Report: The First Thirteen Years The Organic Center. Access the Supplemental Tables on The Organic Center’s website at: http://www.organic-center.org/reportfi les/ Supplmental%20Tables.pdf Access the October, 2004 report, Ag BioTech InfoNet Technical Paper Number 7, at http://www.organic-center.org/science.latest.php?action=view&report_id=158 )

Thank you again for taking my concerns into account on behalf of OSGATA against corporate criminal Monsanto.

“The earth is the Lord’s and the fullness thereof; the world and they that dwell therein. Ps 24:1“ For as many as are led by the Spirit of God, they are the sons of God. For ye have not received the spirit of bondage again to fear; but ye have received the Spirit of adoption, whereby we cry, Abba, Father. The Spirit itself beareth witness with our spirit, that we are the children of God: And if children, then heirs; heirs of God, and joint-heirs with Christ; if so be that we suf -fer with [him], that we may be also glorified together. For I reckon that the sufferings of this present time [are] not worthy [to be compared] with the glory which shall be revealed in us. For the earnest expectation of the creature waiteth for the manifes-tation of the sons of God. For the creature was made subject to vanity, not willingly, but by reason of him who hath subjected [the same] in hope, Because the creature itself also shall be delivered from the bondage of corruption into the glorious liberty of the children of God. For we know that the whole creation groaneth and travaileth in pain together until now.” Rom 8:14-22

I do not want to see the earth and creation on it have to travail more because of miscreant activities by Monsanto and its cor -porate chums that had been permitted by our society’s crippled framework.

Respectfully, Andrea Psoras, New York, NY 10026, apsoras@gmail.com (212) 666 2569

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