The Agrochemical Cartel · Investigation · 1991–2017
Capturing the referee.
Owning the seed and bundling the chemical only pays if the umpire calls the game your way. So the cartel staffed the umpire.
FACT
§2 · Thesis
Regulatory capture here is not a metaphor — it has names and dates: Michael Taylor at the FDA, Jess Rowland at the EPA.
One lawyer moved from Monsanto's law firm into the FDA post that wrote the rBGH labeling rule, then out to a Monsanto VP job. One EPA reviewer told Monsanto he 'should get a medal' for killing a rival agency's glyphosate study.
§5 · Graded Claim
The revolving door: Monsanto's law firm → FDA Deputy Commissioner for Policy → Monsanto VP.
FACT
Michael R. Taylor led King & Spalding's food-and-drug practice (1981–91), a firm whose clients included Monsanto, then became the FDA's first Deputy Commissioner for Policy in July 1991 — the post from which the FDA issued its 1994 guidance discouraging clear 'rBGH-free' milk labels. He later returned to Monsanto as a vice-president for public policy. The job sequence is documented FACT.
§5 · Graded Claim
The 1994 FDA rBGH guidance made it hard to tell treated milk from untreated.
FACT
The February 1994 interim guidance on voluntary labeling of milk from cows treated with recombinant bovine growth hormone (Monsanto's Posilac) discouraged 'rBGH-free'/'hormone-free' claims unless paired with a statement that the FDA found no significant difference — blunting any clear marketplace distinction. Issued from the policy post Taylor held.
§5 · Graded Claim
An EPA glyphosate reviewer told Monsanto: 'If I can kill this I should get a medal.'
FACT
Jess Rowland chaired the EPA committee whose report backed glyphosate's safety. An April 2015 internal Monsanto email — unsealed in the Roundup MDL (In re Roundup Products Liability Litigation, N.D. Cal.) — records a Monsanto executive recounting Rowland's offer to try to stop a separate ATSDR glyphosate review, with the 'should get a medal' line. FACT that the email exists and says this; we do not assert a proven quid-pro-quo or that he actually blocked the review.
The record
How this page is graded.
- FACT: the Taylor job sequence, the 1994 rBGH labeling guidance, and the existence of the unsealed Rowland email.
- NOT asserted: that Taylor committed an unlawful conflict of interest — a 1994 conflict allegation is presented as an allegation.
- NOT asserted: that Rowland was paid, that a quid-pro-quo is proven, or that he in fact killed the ATSDR review — only that the email exists and says what it says.
§7 · Why it matters now
Why it matters.
Owning the seed and bundling the chemical only pays if regulators sign off. Capture the referee and the model is safe: the growth hormone reaches market without a label shoppers could use to avoid it; the herbicide keeps its clean cancer rating while a rival agency's review is discouraged. Neither episode needs to be a proven crime to matter — the people evaluating a company's products keep coming from, or angling toward, that company. That is the through-line into Deregulation Reality, where the downstream immunity playbook barely has to work.
▸ The Agrochemical Cartel →
▦ Ledger gaps
Help us fill these lines.
- OpenWhether the ATSDR glyphosate review was in fact delayed or altered after the 2015 contact, and by whom.
- OpenThe full roster of agrochemical-industry officials who rotated through FDA/EPA policy posts and back.
- OpenWhat internal FDA deliberations shaped the 1994 rBGH labeling guidance beyond the public guidance document.
Help fill these →