This blog was Part 3 of what became known as the BeeGate trilogy. Originally published on 16 December 2014, it is the climax of the abuse of activist scientists. The EFSA decision that there was insufficient evidence to conclude neonicotinoids were not involved in the decline of bee health (reread that phrase carefully) depended on the Bee Guidance Document that was introduced by the EFSA Bee Risk Assessment Working Group. Its conditions for acceptable research were so severe that all existing field test results were thrown out (removing any evidence that rules out neonics as a risk to bee health). This new Bee Guidance Document was never accepted and remains a draft. The EFSA advice depends on this draft document. Now here is the kicker: the Working Group that established the impossible conditions to validate bee field tests had five members: two had no experience in bee research and two were activists campaigning against pesticides. I would call that a conflict of interest where activists gamed the risk assessment process and captured EFSA, the European Commission, farmers and the European public.
As EFSA is about to advise on the temporary neonicotinoid precautionary ban, I think it is a good idea to revisit this blog trilogy (also to update my blogsite archives) and remind people that the entire process was gamed by non-scientific political activists. I also will be publishing a follow-up blog where I will reply to an EFSA letter with further damning evidence to show how activists have corrupted the process and crafted the European Commission’s precautionary response that these activists had been openly campaigning for. There was definitely too much politics and no science involved in this sorry story.
The original can be found here – like Parts 1 and 2, it includes a rather robust “Comments” section with more information coming to light.
An interesting note in updating this blog from 2014: Almost every link with evidence I had provided from the European Commission and EFSA websites have been taken down. Almost every one. This is not a normal situation and suggests that the Commission had taken the original blog seriously. I used WayBackMachine to find the archived screenshots. My apologies for the lack of functionality on the links.
December 16, 2014
In the first blog, we looked at how IUCN activist scientists designed their research to follow a campaign strategy to ban systemic pesticides (neonicotinoids). The second blog looked at how these activist scientists were funded by groups with anti-pesticide and anti-industry objectives, were not quite the leading bee scientists, had unreported conflicts of interest and moved comfortably among NGOs like Friends of the Earth. This third and final blog will show how activist scientists have wormed their way onto government panels and working groups to influence the decision-making process, namely:
- Four of the five experts on the EFSA Working Group on Bee Risk Assessment (whose advice led, in part, to the 2013 precautionary ban of neonicotinoids) are either illegitimate or activist scientists involved with NGO campaigns to ban neonicotinoids.
- Activists on this Working Group are trying, within EFSA, to change the rules for risk assessments (to be in line with the activist scientists’ strategy) and game the system to make future crop protection approvals impossible.
- The European Commission has conclusive research that shows bee health is not significantly affected by pesticides and still they acted to ban neonicotinoids.
- Individuals inside the European Commission knowingly ignored their own evidence and there is a worrying indication of EU officials siding with the NGOs and activist scientists in banning the three neonicotinoid pesticides.
In 2013, I looked at the speed, determination and exigency of the European Commission’s imposition of a two year precautionary ban on neonicotinoids, and concluded that something smells rotten in DG SANCO (the EU unit regulating on health and consumer safety). This third blog ties up the story of the anatomy of a precautionary abuse, and it starts with activist science.
Pot calling the kettle black
Last week in a letter to the journal Nature, the IUCN anti-neonic taskforce scientific coordinator, Jeroen van der Sluijs, and Axel Hochkirch, chair of the IUCN Species Survival Commission Invertebrate Conservation Sub-Committee attacked the IPBES for including two scientists with ties to industry in a research document published by 40 scientists. (See text in Nature; CoI van der Sluijs) They are demanding that the IPBES provides information on the funding of researchers and declare any conflicts of interest. This is sweet hypocrisy and an unbelievable audacity coming from researchers funded by anti-pesticide groups who are not revealing the amount of money they receive or even the names of the members of the IUCN Taskforce on Systemic Pesticides (I will follow this up in 2015).
But they have one point right. Today, policymakers rely heavily on advice given by independent experts and external scientists. Power and influence is measured by the ability to get your scientists onto these advisory bodies. Activists have campaigned relentlessly to ensure that industry scientists are not allowed on expert advisory panels (in this case, two scientists from industry out of 40 is totally unacceptable according to the IUCN activists), but they would never raise the same stink if their activist scientists were to be involved. Bias has been built into the system, and this, regrettably, has gone up to the level of the EFSA expert working groups and panels.
Activist scientists on the EFSA Working Group on Bee Risk Assessment
There are five experts on the European Food Safety Authority (EFSA) Working Group on Bee Risk Assessment: Gérard ARNOLD, Jos BOESTEN, Mark CLOOK, Robert LUTTIK (chair) and Fabio SGOLASTRA. They are meant to be objective and independent as they consider the reports and guidance documents that EFSA submits to the European Commission. As it was upon the advice of these individuals (as well as the larger Plant Protection Products and their Residues Panel) that the European Commission decided to impose a ban on three neonicotinoid pesticides, shouldn’t someone look into the activities of these experts? The only measure EFSA seems to use to determine conflict of interest is if there is any industry involvement. But if you are paid by NGOs or use your credibility as a member of an EFSA working group to advance activist campaigns, this also needs to be considered as a conflict of interest and such individuals should immediately be removed from the EFSA panels and working groups.
So what do we know about the members of the EFSA Working Group on Bee Risk Assessment?
Gérard Arnold was the scientific coordinator of the beekeeper lobbying NGO, Apimondia. They were sounding the alarm on bee mortality in 2008 predicting that the European beekeeping industry would be wiped out within ten years. Alarmist indeed, but their numbers did not quite add up (80% colony losses in southern Germany?). Arnold was quoted in the New York Times Europe as attributing the losses to insecticides and the Varroa mite. He did not note his past employment in this NGO on his EFSA Declaration of Interests.
More disturbing is the content of some of the articles Arnold has recently published with Laura Maxim (the co-author of many reports with Jeroen van der Sluijs claiming financial support from the anti-pesticide foundations funding the IUCN anti-neonic taskforce). In an article in EMBO Reports entitled Pesticides and Bees, Arnold and Maxim argue that there needs to be a new methodological framework for risk assessments. The article shared inside information on what happened on the EFSA working group of which Arnold is a member, peppered with unrealistic data produced by the IUCN anti-neonic taskforce.
There might be an argument to change the EU risk assessment process, and Arnold, as well as at least four researchers from the IUCN anti-neonic taskforce are publicly lobbying for this, but you cannot lead this campaign while you are sitting on a government panel responsible for risk assessments – that borders on collusion. One of the criticisms made by the plant protection companies (see below) is that the neonicotinoid ban was based on severe field trial risk assessment expectations from a draft guidance document which the companies could not have complied with. In other words, it seems that Arnold is already applying his political objectives while on the EFSA panel. Ironically Arnold also published an article in 2012 with Maxim entitled (from French) How Conflicts of Interest can influence research and expertise (Hermès, 64, 48-59). Note that the Risk-Monger will look more deeply into the draft bee guidance document in 2015.
Fabio Sgolastra is a post-doctoral research fellow at the University of Bologna. Seriously … a post doc? The Risk-Monger also believes in trying to find work for his students, but couldn’t the European Commission find someone with just a little more experience to sit on such a panel? While Sgolastra has only published a few articles, one of them happens to be a meta-analysis with Maria Arena. Why is this interesting? Maria Arena is a senior officer in the Pesticides Unit at EFSA. Curious.
Indicative of his inexperience is how Sgolastra has been using his involvement on the EFSA Working Group on Bee Risk Assessments to further NGO activist campaigns. Sgolastra has been involved in groups like Api-organica (archived) or Pesticide Action Network (PAN). I am totally astonished that Sgolastra, a member of the EFSA Working Group on Bee Risk Assessment, would dare to add his name and signature to an activist campaign document written by PAN North America submitted last month (November, 2014) to lobby the US government to ban neonicotinoids. Inexperienced indeed and I wonder if EFSA has any guidance on how panel members should act in such lobbying situations. Note, to no surprise, that a majority of the IUCN anti-neonic activist scientists have also signed this Pesticide Action Network US lobbying document.
Also, like Arnold, Sgolastra has been campaigning to change the EU’s risk assessment procedures from within. It should also be noted that the IUCN anti-neonic taskforce has, as one of its main objectives, to “devise a better risk assessment protocol (archived and in 2017 deleted) for government approval of new pesticides”. What better place to change the rules on how EFSA assesses risks than from inside an EFSA panel!
Neither Jos Boesten nor Robert Luttik have direct bee research experience although Luttik is the chair of the EFSA bee working group. Both have been involved in programmes on pesticides and groundwater in the Netherlands and both seem to be habitual EFSA panel sitters. From their EFSA declaration of interests, they also seem to have been working together on the same projects over many years.
Mark Clook, in my opinion, is the only legitimate member of the EFSA Working Group on Bee Risk Assessment. Note that in 2012, James Cresswell was excluded from the EFSA working group because he was involved with a project funded by the private sector and Jacoba Wassenberg because she was a member of the board of the International Commission for Plant-Pollinator Relationships. See Bee WG minutes chain and later chain (archived and since removed).
Interesting, as an aside note, that Matthias Liess is a member of the larger EFSA Plant Protection Products and their Residues Panel but he did not declare his involvement in the IUCN Taskforce on Systemic Pesticides and his participation as an author in its publications (where financial support was involved). EFSA should not be relying on a blogger to follow up irregularities on activist scientist EFSA declarations of interest.
In conclusion, EFSA has created conditions to largely restrict itself from accessing credible research expertise, creating an environment ripe for activist scientists to enter onto EFSA panels and working groups to try to change the risk assessment approach to align with their post-normal scientific approach. But we need to ask some questions. Are these the best available bee scientists we have upon which EFSA can draw advice? Should these activist scientists be allowed to change the rules during the process? Has nobody else besides the Risk-Monger bothered to follow up on or verify their declaration of interests? Outside of Mark Clook, should the other members be allowed to stay on the EFSA Working Group on Bee Risk Assessment? I think not.
It is sad from the point of research integrity to think that Corporate Europe Observatory has gone over the EFSA declarations of interest with a fine comb to weed out those having received corporate funding in the last ten years, but if they find an activist, they give him or her a nod and a wink. But being funded by activist organisations and NGOs, or campaigning for them, is equally a conflict of interest and certainly Arnold, Liess and Sgolastra need to be removed from EFSA involvement immediately.
What did the European Commission know?
The European Commission has gathered a significant amount of research on the factors influencing bee health, and almost none of the evidence points to pesticides, or neonicotinoids in particular, as having anything to do with bee mortality.
Beekeepers and laboratories report insignificant pesticide influence on bee losses
A presentation last year by the DG SANCO head of unit for Animal Health, Alberto Laddomada, revealed statistics from beekeepers and research laboratories that did not attribute bee losses to systemic pesticides (archived). Of the 100+ beekeepers surveyed on bee colony mortality, most of them reported diseases and viruses as causes for their losses (see Table 1). Only three beekeepers reported pesticides as a potential cause for bee mortality. One has to ask who were all of these beekeepers protesting across all European capitals just before the precautionary ban on neonicotinoids?
The second table from the European Commission was even more telling. In consulting bee laboratories across the European Union on the main causes of bee colony mortality, only one lab cited chronic exposure to pesticides (see Table 2). That must have been the IUCN anti-neonic lab. Once again, most laboratories cited diseases and viruses for the colony losses.
EPILOBEE study attributes bee loss to cold winters, diseases and viruses
The European Commission funded a baseline study, EPILOBEE, researching bee mortality. It involved 163 bee researchers from 17 EU Member States, visiting 8572 apiaries in 2012-2013, collecting samples, data and interviews (at time of publication, 103,930 lab analyses were performed on bee samples from over 95,000 visits to colonies by 1354 bee inspectors). The study provided an excellent realistic snapshot of bee colony mortality and a solid baseline for EU policy decisions.
EPILOBEE concluded that bee winter mortality rates ranged from 3.5%-33.6% while seasonal (spring-summer) colony mortality rates are below 5% in 12 of the 17 EU countries involved in the research (see Table 3). The main causes they attributed for the incidence of bee deaths were cold winters, diseases and parasites. These numbers, with a sound scientific methodology, do not, in any way, reflect the scaremongering and data that the far fewer activist scientists have been using in declaring a bee apocalypse. In short, echoing the widely cited FAO data (see Table 4), there is no evidence of a bee crisis.
So why did the European Commission act in line with the anti-neonic activist scientists and NGOs and why doesn’t the Commission Secretariat General act to lift the ban on these pesticides? Well, as DG SANCO head of unit for Chemicals, Contaminants and Pesticides, Michael Flüh, frankly acknowledged earlier this year, the Commission knows full well that pesticides are not a main threat to bee health, but because the other problems are so intractable (climate change, loss of habitats and biodiversity, viruses and diseases, monoculture farming practices …), the European Commission had to be seen to be doing something. A pesticide ban was the easy option. So to look busy on bees, the EU has inadvertently created a situation where, to compensate for crop losses, more forests will be chopped down and meadows and other bee habitats will be ploughed under. Sweet!
Nobody is that stupid, so there must be something more sinister going on in DG SANCO. Two months ago, the head of DG SANCO, Paola Testori Coggi , had to resign for essentially being too chummy with the NGOs. But if one were ever to look for a polarising, vehemently anti-industry biased EU civil servant, they would need to look no further than SANCO director Eric Poudelet (head of Safety in the Food Chain – the directorate that includes the Chemicals, Contaminants and Pesticides Unit). As one industry representative told me, “Poudelet hates industry, point.” He announced a week in advance of the EU ban on neonicotinoids in the European Parliament that the Commission would have to “act straight away” . To many in Brussels following the pesticides ban, Poudelet is seen as the driving force of this legislation without legs.
It should be more than just a mild curiosity that the European Commission called for the precautionary ban on neonicotinoids on 31 January 2013, while just the very day before, on 30 January 2013, EFSA top management and DG SANCO hosted a meeting with leading anti-pesticide and anti-GMO bee activist NGOs (including a member of the IUCN anti-neonic taskforce, Noa Simon Delso, representing her NGO, European Beekeeping Coordination). I wonder what they talked about? There needs to be a full internal inquiry into how EFSA and the European Commission have been captured by these activists.
I understand that the new Commission is still settling in and that the internal authorities in the Commission Secretariat-General are not ready to ruffle any feathers in-house. Also, given that the first move by the new President of the European Commission, Jean-Claude Juncker, was to banish any independent scientific advice from his office, I can only conclude that we are heading into a period of sustained scientific ignorance. The only thing that could be done is to take the European Commission to court.
There is an ongoing court-case between several crop protection companies and the European Commission. The anti-farming NGOs are trying to portray it as a battle between the evil chemical industry and the rights of citizens and the environment (including bees) to not be poisoned. Nice PR flip, but the reality is that the European Commission has allegedly broken the law. Let me put it into an everyday illustration.
Imagine you are driving to work one day and a police officer stops you and informs you that your car is no longer compliant. While you insist that it is, he explains that the law has changed overnight and he then takes your car away from you. You get even angrier when you get home and discover that the hitherto unknown law the police officer referred to was only a draft proposal and had not yet been voted on. Wouldn’t you take the government to court to get your car back?
This is more or less what happened with the precautionary neonicotinoid ban. There was a draft guidance document for bee field trial test procedures that had not been approved. The EFSA experts, including the members mentioned above, used this unapproved draft document to conclude that the safety data provided by the crop protection companies under the existing legislation was insufficient. In other words, they took their car away without legal grounds.
We should add a couple other points to the analogy: As the police officer was taking your car into the station, only a minority of the other police officers supported that decision (call this the European Council), but still he insisted. Furthermore, you then discover that the experts who proposed the draft rule had clearly established interests against you (the activist scientists).
That the NGOs are trying to foment rage for an action against the crop protection companies for “seeking to get their car back”, something that any normal person would do, is irresponsible and disingenuous. But a great emotional campaign opportunity nonetheless.
It’s about the farmers
Now remove the word industry from the last paragraphs and insert the word farmers. Do you think farmers enjoyed waking up on 1 December 2013 to find that they no longer had the tools necessary to do their job? Do you think they like that the decision was made arbitrarily without consultation by a group that could not care less about their interests? After a year of crop failures and a failed precautionary principle application, the farmers should be the ones taking the European Commission to court. Sadly, the farmers have no leadership in Brussels, no voice and no serious representation. It is only the chemical industry fighting their corner, and nobody in Brussels cares about their interests.
In the Brussels Bubble, we sometimes forget that there are real people with real jobs involved. It is not about Friends of the Earth and Pesticide Action Network vs the chemical industry; it is not about some activist scientists with the IUCN vs the scientific mainstream; nor is it about the European Commission Secretariat-General trying to twist logic to defend the antics of Mr Poudelet in DG SANCO. It is about the farmers and their ability to have the tools to protect their crops. It is about food security and affordable food for EU consumers. It is about the ability of European agriculture to be able to feed European consumers and stop depending on imports from countries in Africa which may themselves have food security issues. This is indeed a moral question and the games played by the activist scientists in EFSA and in the IUCN should be held in this light.
In short, crops are failing in the first year of the neonicotinoid ban and farmers are suffering, the anti-neonic scientists are tainted by politics and conflicts of interest, the EU’s own science on bee mortality does not raise alarm-bells and the European Commission itself admits that last year’s legislation banning neonicotinoids would have no significant effect on bee populations.
So why the hell are we still having this discussion?
Front image source – slides on EFSA Bee Risk Assessment WG (worth a read!)