{"id":6148,"date":"2016-05-19T10:50:21","date_gmt":"2016-05-19T08:50:21","guid":{"rendered":"http:\/\/www.randform.org\/blog\/?p=6148"},"modified":"2016-05-19T11:13:49","modified_gmt":"2016-05-19T09:13:49","slug":"p-values-and-glyphosate-animal-tests","status":"publish","type":"post","link":"https:\/\/www.randform.org\/blog\/?p=6148","title":{"rendered":"p-values and Glyphosate animal tests"},"content":{"rendered":"<p><a href=\"http:\/\/www.randform.org\/blog\/wp-content\/2016\/05\/MarderIMG_1468-450.jpeg\"><img src=\"http:\/\/www.randform.org\/blog\/wp-content\/2016\/05\/MarderIMG_1468-450.jpeg\" alt=\"\" title=\"MarderIMG_1468-450\" width=\"450\" height=\"300\" class=\"aligncenter size-full wp-image-6152\" srcset=\"https:\/\/www.randform.org\/blog\/wp-content\/2016\/05\/MarderIMG_1468-450.jpeg 450w, https:\/\/www.randform.org\/blog\/wp-content\/2016\/05\/MarderIMG_1468-450-300x200.jpg 300w\" sizes=\"(max-width: 450px) 100vw, 450px\" \/><\/a><br \/>\n<span style=\"font-size:80%\">Dead marten in our garden. Cause of death unknown. The head was unexplainably jammed by twigs (see image). The animal was already stiff when I found it. Could have been there at most for a day.<\/span><\/p>\n<p>Here a comment about a specific problem in statistics which is often ignored by (mostly) non-mathematicians. <\/p>\n<p>I originally intended to leave the comment in a <a href=\"https:\/\/golem.ph.utexas.edu\/category\/2010\/09\/fetishizing_pvalues.html#c050620\">mathematicians forum<\/a> where this problem is discussed. As an example I looked at the <a href=\"http:\/\/corporateeurope.org\/sites\/default\/files\/attachments\/glyphosate_rar_08_volume_3ca-cp_b-6_2013-12-18_san.pdf\">glyphosate Renewal Assessment Report from 2013<\/a> where I think this ignorance leads to very problematic conclusions. Warning: some details about the animal test results are rather explicit.<\/p>\n<p><!--more--><br \/>\n<\/p>\n<p>Here the comment:<\/p>\n<p>I haven&#8217;t found a remark to the problem of <a href=\"https:\/\/en.wikipedia.org\/wiki\/P-value#Sample_size_dependence\">sample size and p-value<\/a>. I hope I haven&#8217;t overlooked something.<\/p>\n<p>For obvious reasons drug testing with animals is usually done with not so many animals, so testing for significance only (and not also for the concrete values) seems highly problematic.<\/p>\n<p>However this seems to be a common method if I look for example at <a href=\"http:\/\/corporateeurope.org\/sites\/default\/files\/attachments\/glyphosate_rar_08_volume_3ca-cp_b-6_2013-12-18_san.pdf\">animal experiments in 2013<\/a> with glyphosate. The updated 2015 version (which seems not public) of this report is (<a href=\"http:\/\/www.bfr.bund.de\/cm\/343\/who-fao-gremium-jmpr-bewertet-glyphosat-neu-und-bestaetigt-das-ergebnis-des-bfr-und-der-efsa-dass-kein-krebserzeugendes-risiko-zu-erwarten-ist.pdf\">as explained here in german<\/a>) one of the main &#8220;scientific&#8221; ingrediences for the WHO recomendations about Glyphosate and also for the European EFSA. The main &#8220;rapporteur of member state&#8221; (RMS) was here Germany, so I think most of this was done at the <a href=\"http:\/\/www.bfr.bund.de\">Bundesinstitut f\u00fcr Risikobewertung.<\/a><\/p>\n<p><span style=\"font-size:120;color:#ff7700\"><strong>The report is about 1000 pages long, but sofar any random reading within the study gave me my hair stand on end.<\/strong><\/span><\/p>\n<p>The report gathered studies and tried to excerpt major findings. As a matter of fact it seems the big majority of the studies was done by chemical companies, but I didnt count.<\/p>\n<p>In the report excerpts from respective animal studies with glyphosate were briefly documented and then &#8220;evaluated&#8221; in a comment by the RMS (in italics). <\/p>\n<p>But back to the p-values. Again I didnt count but <span style=\"font-size:120;color:#ff7700\"><strong>it seems that in all evaluations of the RMS &#8220;significance testing&#8221; was a key element for evaluation. However the number of tested animals is often not even listed.<br \/>\n<\/strong><\/span><\/p>\n<p>A randomly picked example (in which some animal numbers are listed) for illustrating how the evaluation took place:<\/p>\n<p>page 285<br \/>\n2007 Glyphosate technical: 52-week Toxicity Study by<br \/>\nOral Route (Capsule) in Beagle Dogs<br \/>\nData owner: <a href=\"https:\/\/en.wikipedia.org\/wiki\/Nufarm\">Nufarm<\/a><\/p>\n<p>In Table B.6.3-32 one sees that at doses (which are 500  mg\/kg  bw\/day or below) a weight loss can be seen (and if I didnt oversee something also in all other of the few dog studies, where explicit numbers were displayed). The number of dogs here is not mentioned but in the table below a number of 4 dogs is mentioned. The mean weight decrease is not significant (p<0.05) and so the RMS comments:\n\n\n\n<blockquote>This study is considered acceptable. It is agreed<br \/>\n to set the <a href=\"https:\/\/en.wikipedia.org\/wiki\/No-observed-adverse-effect_level\">NOAEL<\/a> at the highest dose level of 500  mg\/kg  bw\/day.  It  can  be  confirmed  that  the  alterations  in  clinical  chemistry  parameters  were  mostly  not  statitically  significant  and,  if  so,  did  not  show  a  dose  response.  The  only  possible  exception  is  a  lower  blood  calcium  level in  high  dose  males  that  was  observed  in  other studies with glyphosate, too. However, without any concomitant findings, e.g, on bones, this perhaps treatment-related effects is not considered adverse.  <\/p><\/blockquote>\n<p>It should be mentioned that for example the <a href=\"http:\/\/www.efsa.europa.eu\/sites\/default\/files\/scientific_output\/files\/main_documents\/4302.pdf\">EFSA<\/a> luckily did not use this NOAEL in order to set the accepted daily intake, but then I dont know though what this &#8220;uncertainty factor&#8221; means and in particular what it implies for allowed dosages: <\/p>\n<blockquote><p>The acceptable daily intake (ADI) of glyphosate is 0.5 mg\/kg bw per day, based on the maternal and developmental NOAEL of 50 mg\/kg bw per day from the developmental toxicity study in rabbits and<br \/>\napplying a standard uncertainty factor (UF) of 100<\/p><\/blockquote>\n<p>They can&#8217;t mean the NOAEL, because a factor 100 would mean a NOAEL at 5000 mg\/kg bw !  <\/p>\n<p>The comment of the RMS goes on and in particular comments on another dog study of the same company where they used the double dose of 1000 mg per kg bodyweight (1000 mg\/kg bw) &#8211; I will therefore before citing the rest of the comment cite some information about that study.<\/p>\n<p>2007 Glyphosate Technical: 13-Week Toxicity Study By<br \/>\nOral Route (Capsule) In Beagle Dogs<br \/>\nLaboratory Study No.: 29646 TCC<br \/>\nData owner: Nufarm <\/p>\n<p>In the study (p.265) it is said:<\/p>\n<blockquote><p>Mortality: Two unscheduled sacrifices (one male and one female) were necessary in animals given 1000 mg\/kg bw\/day:<br \/>\nOne male was sacrificed on Day 61 on humane grounds. Vomiting was seen once in Week 7 (before  dosing)  and  liquid  faeces  were  noted  on  many  occasions  in  Weeks  8  and  9.  Prior  to  sacrifice,  signs  of  poor  clinical condition  including  thin  appearance,  dehydration,  and  pallor  of  lip  mucosa,  coldness  to  the  touch,  hypothermia  (34  to  35  \u00b0C)  and  hypoactivity  were  observed. These signs were associated with a body weight loss between Weeks 7 and 9 (-34 %) and reduced food consumption from Week 7 (generally only 25 to 50 % of this animal\u2019s<br \/>\ndaily ration was consumed), followed by an absence of food intake on the day before death. Medical  care  (Smecta\u00ae  and  Lactate  Ringer\u00ae)  was  given  in  order  to  stop  the  diarrhoea  and  rehydrate the animal.<br \/>\nOne female was sacrificed on Day 72 for humane reasons. This animal showed liquid or soft faeces  on  many  occasions  from  Week  4  and  dehydration  from  Week  9.  Vomiting was  observed  once  in  Week  10.  These  signs  were accompanied  by  a  body  weight  loss  between  Weeks 8 and 11 (-22 %) and decreased food consumption from Week 8 (generally only 25 to 50 % of this animal\u2019s daily ration was consumed), followed by an absence of food intake on the  two  days  prior  to  sacrifice.  Medical  care  (Smecta\u00ae  and  lactate  Ringer\u00ae)  was  given  in  many occasions. <\/p><\/blockquote>\n<p>and<\/p>\n<blockquote><p>The following treatment-related clinical signs were reported in animals given 1000 mg\/kg\/day (excluding  those  killed  in  extremis,  which  are  discussed separately):  liquid  or  soft  faeces  on  several occasions in all animals, vomiting in 2\/3 females on one occasion within 30 minutes or  3  to  5  hours  after  treatment,  thin  appearance  in  1\/3  males  and  all  females, dehydration  in  1\/3 males and 2\/3 females, pallor of ears and mouth in 1\/3 females. <\/p><\/blockquote>\n<p>The comment of the RMS to this study:<\/p>\n<blockquote><p>\nThe study is considered acceptable and the NOAEL is agreed. At the top dose level, the MTD was  clearly  exceeded.  It was  noticed  that  high  dose  effects  of  glyphosate  administration  in  this  study  were  particularly  severe,  much  more  pronounced  and  rather  different  from  what<br \/>\nwas  seen  in  other  dog  studies  or  other  species.  Thus,  because  of  the  clinical  signs  and  pathological  changes,  its  results  do  not  fit  into  the  toxicity  profile  of  glyphosate  as  it  was  established in the majority of studies. In the study by (1990, TOX9552384) that is decribed  in  detail  in  the  original  DAR  (1998,  ASB2010-10302),  the  same  high  dose  of  1000 mg\/kg bw\/day  was  administered  also  in  capsules  causing  only  minor  effects.<\/p><\/blockquote>\n<p>So if I see this correctly the &#8220;majority of studies&#8221; concerning dogs is (1990, TOX9552384).<\/p>\n<p>Now the rest of the RMS comment to the lower dose experiments: <\/p>\n<blockquote><p>This study was run in the same laboratory and under similar conditions as the 90-day study by (2007, ASB2012-11454) in which severe adverse effects were seen upon treatment of Beagle dogs with glyphosate at a high dose level of 1000 mg\/kg bw\/day. It is clear now that these adverse reaction to treatment was in fact confined to an exaggerated dose level and that the NOAEL is higher than 300 mg\/kg bw\/day as established in that previous study. <\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"<p>Dead marten in our garden. Cause of death unknown. The head was unexplainably jammed by twigs (see image). The animal was already stiff when I found it. Could have been there at most for a day. Here a comment about a specific problem in statistics which is often ignored by (mostly) non-mathematicians. I originally intended [&hellip;]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":[],"categories":[24,25,15,33,26,8],"tags":[],"_links":{"self":[{"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=\/wp\/v2\/posts\/6148"}],"collection":[{"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=6148"}],"version-history":[{"count":23,"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=\/wp\/v2\/posts\/6148\/revisions"}],"predecessor-version":[{"id":6173,"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=\/wp\/v2\/posts\/6148\/revisions\/6173"}],"wp:attachment":[{"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=6148"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=6148"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.randform.org\/blog\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=6148"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}