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Risk Assessement Standard is Flawed
Risk Assessment is a flawed science
Date: 8/23/2009 10:35:00 AM ( 15 y ) ... viewed 1607 times
More to write on this...
got to go...
8:52 AM
8:19 AM
August 23, 09
RISK ASSESSMENT, is the standard that
the CODEX ALIMENTARIUS COMMISSION,
our accepted international RULES AND REGULATIONS
COMMISSION, as well as THE FDA both in Canada
and the USA, have used many times to say that
something is fit for Human Consumption.
They look at the Risk Involved.
Often the Risk is based on political decision.
Two of the Top Authorities using the standard of
RISK ASSEESSMENT, rather than true biochemical
analysis, are our very own US FOOD CZAR
MICHAEL R. TAYLOR, as well as DR ROLF GROSSKLAUS,
head of the Codex Aimentarius Commission.
The countless harm done to people through using
Risk Assessment needs to be reevaluated.
Michael R. taylor is currently one of the guiding
lights in sheparding the acceptance of the
Codex Alimentarius principles. His quote
before the REP DENNIS KUCINICH COMMISSION
looking at LEAFY GREEN GUIDELINES,
a proposed new national standard is telling.
Michael R Taylor submitted
this written testimony:
"In addition, FDA is leading an effort
through the Codex Alimentarius Commission,
the international food safety standards body,
with support of the Food and Agriculture
Organization/World Health Organization,
to develop commodity-
specific annexes to the Codex hygienic code
for fresh fruit and vegetable production,
starting with an annex for fresh leafy
vegetables and herbs."
--Mr MICHAEL TAYLOR
Our Food Czar for the FDA
Senior Adviser to the Commissioner on food issues
The above quote is from the written testimony
of MICHAEL TAYLOR July 29 at the
REP DENNIS KUCINICH
SUBCOMMITTEE ON DOMESTIC POLICY
COMMITTEE ON OVERSIGHT
AND GOVERNMENT REFORM
U.S. HOUSE OF REPRESENTATIVES.
The Subcommittee Hearing was Titled:
"Ready to Eat or Not? It Examined
the Impact of Leafy Green Marketing Agreements.
You can read Michael Taylor's complete
testimony at the above link.
THIS IS FROM THE CANADIAN HEALTH COALITION
REPORT, P 24
http://www.healthcoalition.ca/safetylast.pdf
The language of risk (risk assessment/management/communication),
is not the language of public health.
Risk assessment has been described
as “the most powerful tool that the poisoners
and destroyers of the planet ever invented”
(Rachel’s Environment & Health Biweekly, August 17, 2000).
In the U.S. and Canada, it is used:
“as a weapon against that prime bête noire of the political right,
government regulation of health and safety”.
(The Lancet, February 11, 1995). Here’s how it works.
Decision-makers generally decide what they want to do,
and instead of examining all the alternatives,
they hire a risk assessor to convince everyone
that the damage they are about to do to us is “acceptable”.
What is acceptable, is naturally a political judgment.
• Risk assessment can provide industry
with “scientific” cover for just about any damaging activity.
Risk assessment is used, for example,
to justify “acceptable levels” of pesticide residues, hormones,
antibiotics, genetically modified organisms,
pesticides and other toxic chemicals in food. Risk assess-
ment is not pure science. It is usually based
on imperfect information, requiring assumptions to be
made with a strong effect on results.
is a political mixture that can contain various ingredients:
prejudices, biases, vested interests, fraud, guesses, estimates,
limited scientific facts, and many value
judgments – all hiding under the cover of “objective”
science. Risk assessment and cost-benefit analy-
sis became a central feature of environmental
and health regulation under the Reagan administration.
The Mulroney regime prepared the way for it
in Canada but it was first applied to health regulation in
Canada by the Chrétien government in the early 1990’s.
• Risk assessment is a useful way to put together
different information on what the level of potential risk
of a specific chemical or other technology might be,
from its toxicology, what is known about effects
on people, then look at possible exposure levels
both for the population as a whole and to vulnerable
populations, and come up with some estimate
of the potential degree of harm. Because it is always
based on incomplete information, this is an inherently
uncertain modeling exercise. If done well and
honestly it should take explicit account of ignorance,
uncertainty, and the potential for error. It is use-
ful as a way to lay out what we do and don’t know
about the potential risks of environmental exposure, for example,
and come up with educated guesses about what might happen,
and in a way that is consistent with the Precautionary Principle.
There are two possible pitfalls. One is when you already
know what you want out of a risk assessment exercise
and therefore feed in assumptions that will feed
out a specific result. This is easy to do,
given all the uncertainties. The second pitfall
is what comes after –
decisions about risk management.
These are easily influenced
by economic aims and conflict of
interest.
RELATED BLOGS AND LINKS
Here is another great story that
discusses the contribution of this
highly successful man who
achieves many of his goals.
MICHAEL TAYLOR TO TACKLE
FOOD SAFETY at FDA
Small Farmer Warns “HR2749 Will Put Me Out of Business”
By Kimberly Hartke | Published: July 24, 2009
7:50 PM
July 30, 09
I first heard these words HAACP
a few days ago for the first time
in this article:
HR2749 (The Food Safety Enhancement Act of 2009) which is currently making its way rapidly through the House of Representative will put us out of business.
HR2749 calls for:
a yearly registration with the FDA with a $500 fee
[Some of this may have been eased a bit due
to last minute amendments accepted July 29 to
get the bill passed by the House. ]
full HACCP plan for every type of produce sold or processed, for us that mean one plan for the dairy, one one for cheese making, one for transporting and retailing at the market, one for the fruits and vegetables, and another one for the nuts
FDA approved methods by which crops are raised and harvested. The most likely outcome will be along the lines of the leafy green ordinance, scorched earth and exclusion of any wildlife.
http://hartkeisonline.com/2009/07/24/small-farmer-warns-hr2749-will-put-me-ou...
ARTICLE PRAISING CHOICE
OF MICHAEL TAYLOR IN HIS NEW POST
AS FOOD CZAR
Here is a the second time
I am running across "HAACP"
But before you decide that I must have drunk the Kool Aid on this one, hear me out. He really is a good choice for this job. Why? Because he managed to get USDA to institute HACCP (science-based food safety regulations) for meat and poultry against the full opposition of the meat industry — a truly heroic accomplishment. His position on food safety has been strong and consistent for years. He favors a single food agency, HACCP for all foods, and accountability and enforcement.
http://thepumphandle.wordpress.com/2009/07/08/michael-taylor-to-tackle-food-s...
BIO NOTE ON
MICHAEL R. TAYLOR
http://www.card.iastate.edu/food_safety/workshop3/presenter_bios.aspx
Michael R. Taylor is a Senior Fellow at Resources for the Future (RFF) and chairs the steering committee of the Food Safety Research Consortium, a multi-disciplinary, collaborative effort by RFF and six universities to improve the food safety system by developing risk ranking and priority-setting tools that policymakers and risk managers can use to better allocate research, regulatory, and educational resources and more effectively reduce food safety risks. Prior to joining RFF in 2000, Taylor's career included service as Administrator of the USDA's Food Safety and Inspection Service (1994-1996), Deputy Commissioner for Policy at the Food and Drug Administration (1991-1994), 12 years practicing food and drug law in Washington with King & Spalding, and 16 months as Vice President for Public Policy at Monsanto Company. Taylor served as co-chair of the National Academy of Sciences (NAS) Committee that issued the report Intentional Human Dosing Studies for EPA Regulatory Purposes: Scientific and Ethical Issues (2004) and was a member of the NAS committees that issued reports on Dioxin and Dioxin-like Compounds in the Food Supply – Strategies to Decrease Exposure (2003) and Animal Biotechnology – Science-Based Concerns (2002). He received his law degree from the University of Virginia and his B.A. in political science at Davidson College.
GOOD ARTICLE on FOOD SAFETY
MICHAEL R TAYLOR IN REFERENCES
http://ngm.nationalgeographic.com/ngm/0205/feature1/index.html
ABOUT THE CODEX
THE HEAD OF THE CODEX ALIMENTARIUS
COMMITTEE, THE UN sponsored
INTERNATIONAL REG AND RULE
MAKING BODY, has said THIS
CODEX works with the WORLD HEALTH ORGANIZATION (WHO)
and FAO:
Published on: 11/30/2001
Codex chairman, DR. ROLF GROSSKLAUS'
pronouncements include the assertion
that "only pharmaceutical drugs
prevent and mitigate disease",
even though product inserts
state categorically that drugs don't cure disease,
but only control symptoms.
--DR. ROLF GROSSKLAUS,
head of CODEX ALIMENTARIUS COMMISSION
"...Dr. Grossklaus actually declared nutrients to be toxins in 1994 and instituted the use of toxicology (Risk Assessment) to prevent nutrients from having any impact on humans who take supplements! It is worth mentioning that Dr. Grossklaus happens to own the Risk Assessment company advising CCNFSDU and Codex on this issue.
In fact, Dr. Grossklaus, who has said that nutrition has no place in medicine, called the EFSD the "future face of Codex" during CCNFSDU meetings.
Dr. Rolf Grossklaus, CCNFSDU chairman, is also the Chairman of the Board of BfR, a private corporation which specializes in Risk Assessment. Dr. Grossklaus's company submits Risk Assessment values to Codex. In his position at Codex Alimentarius, Dr. Grossklaus contributed to the bizarre definition of nutrients as toxins, and promoted the use of Risk Assessment to determine their "maximum" dosages.
THE SOURCE OF THE ABOVE QUOTE
IS NO LONGER ON ZOOMED IN...
I found it referred to in this article...
http://www.vitalitymagazine.com/industry_pushes_gmos_while_consumers_just_say_no
THE ROLE OF CODEX IN ENDANGERING PUBLIC SAFETY
Meanwhile, Codex appears determined to regulate trade to make the world safe for Big Pharma and biotech, even as many of its member states pass defensive laws at home and the European Union is up for grabs. So far, Codex has approved pesticide residues on foods in higher quantities than World Health Organization standards. Irradiation is fine by Codex, as is microwaving and biotechnology – anything is okay, it seems, that reduces nutrient value to zero.
On July 11, 2005, Codex announced their intention to enforce “labeling [designed] to stop overdosing on vitamin and mineral food supplements” (for which there is no shred of evidence). It proposes using “scientific risk assessment protocols” (designed for toxins, not nutrients) in order to establish “upper safe limits” (a meaningless concept for essential nutrients because the body metabolizes them as needed) predicated on a mythical “average” human. Fortunately, the scientific community has woken up and research from the UK, Germany and Israel is challenging Codex on, for example, Codex-approved baby formula that makes cow’s milk equivalent to human milk to serve the financial interests of the dairy industry (British Medical Journal, March 20).
Codex chairman Dr. Rolf Grossklaus’ pronouncements include the assertion that “only pharmaceutical drugs prevent and mitigate disease”, even though product inserts state categorically that drugs don’t cure disease, but only control symptoms (www.Dr-Rath-Foundation.org). Should this scientific gobbledygook actually become international regulatory policy, it would be enforced by the WTO; how it is obeyed, was described above. An excellent source of information on Codex is a new book by Mike Fillon.
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October 21, 09
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