When rational, scientific-minded policymakers take irrational decisions, there is usually something going on behind the scenes: an influential lobby or special interest, a power play or a personal conflict. Such seems to be the situation in the European Commission where a series of policy positions on pesticide approvals are so illogical and so far from basic common sense as to be laughable were it not for the terrible consequences for European farmers and consumers.

This blog will look at the EU’s incapacity to conduct rational policymaking on glyphosate and neonicotinoids and ask the simple question: who or what is stopping sensible, logical scientists from taking obvious decisions? This is an inquiry into the germination of Stupid.

A Tale of Two Stupids

Regular readers of this blog know that I set out to write a book 18 months ago called: “How to Deal with Stupid” and serialised two thirds of it until I came across two living case studies of Stupid: the poor EU management of the glyphosate substance re-authorisation and the 2013 precautionary ban of three neonicotinoids in order to “save the bees”. About 40 blogs later, I am still mesmerised by how smart people can curate such stupid ideas.  I think I found the answer.

Some brief bullet points to the logic of lunacy Brussels is suffering under.

On Glyphosate (Sources)

• Glyphosate is the main active ingredient in popular herbicides like Monsanto’s Roundup
• It has been on the market for more than 40 years, off-patent, it is inexpensive and still very efficient
• It has a very low toxicity (LD50 of 5600) – far less than chemicals commonly found in coffee and cookies
• It has a low environmental impact, binds well to soil and breaks down in a matter of days
• It is widely used in conservation agriculture, allowing farmers to better manage their soil with no-till farming and complex cover-cropping.
• Certain GMO seeds are glyphosate resistant and this makes NGO activists apoplectic, enough to willingly lie and spread fear and uncertainty about glyphosate in order to make farming with GM technology less attractive (although companies like Monsanto have patented alternatives to glyphosate and won’t be too sad to see this inexpensive substance go)
• The Environmental Defense Fund sent an activist scientist, Christopher Portier, to work with IARC and “co-author” a hazard-based monograph suggesting glyphosate may cause cancer
• No other scientific body supported the weak arguments made by Portier and IARC (and even the authors whose publications they relied upon disowned their activist science)
• The EU’s three scientific bodies charged with studying the safety of glyphosate after the IARC report (EFSA, BfR and ECHA) have roundly rejected IARC’s findings and behaviour
• The NGOs, led by Portier, have run an impressive fear campaign (largely funded by the organic industry lobby) and have managed to make a no-brainer substance renewal into a policy minefield
• The consequences on EU farming of a ban on glyphosate are unimaginable, but no one in Brussels seems to be standing up for farmers’ interests
• After the contrived Monsanto Papers “scandal”, Commission Andriukaitis has hinted that he may reopen the glyphosate assessement, despite reassurances from his scientists at EFSA and the BfR that the claims are baseless.

On Neonicotinoids (sources)

• Due to a combination of environmental, practice and economic influences over a decade ago, there was a rise, in certain areas (notably California), of honeybee declines and colony collapse disorder
• Most scientists concluded that the main cause was the rise of Varroa mite exacerbated by variations in land use and an increase of hobby beekeepers with poor hive management skills
• NGOs and a group of activist scientists (many without any education in entomology) formed into the IUCN Taskforce on Systemic Pesticides with the objective of finding some evidence to use bee health decline to run a campaign against neonicotinoids
• Several activist scientists with affiliations to anti-pesticide NGOs were heavily involved in EFSA’s Bee Risk Assessment Working Group that drafted the 2013 proposed Bee Guidance Document that set guidelines to how bee field trials must be conducted.
• The Bee Guidance Document remains a draft, rejected by most European Member States because its parameters for valid field tests are ridiculously unworkable
• EFSA is aware that experts involved in the production of this guidance document had associations with NGOs that qualified as conflicts of interest
• On the basis of the draft guidance document, EFSA could not consider any field trial data that showed little to no effect on pollinators in contact with neonicotinoid-treated plants, and could only come to a conclusion of insufficient data
• Led by Eric Poudelet, director of the Pesticides Unit in the then DG Sanco (himself an amateur beekeeper and a darling of the environmental NGO groups), the European Commission rammed through a precautionary ban on three neonicotinoids in 2013 in a record time of two months
• Given that the Bee Guidance Document was not legally approved (and still has not been), three pesticide manufacturers have taken the European Commission to court
• The Commission promised to review the precautionary ban after two years. DG Santé Commissioner Andriukaitis went so far as to say the neonic ban had nothing to do with bee health (perhaps his lawyers made him say that)
• Andriukaitis delayed his decision on what to do until the Commission’s Joint Research Centre (JRC) released a study (end of 2016) he had commissioned to see if farmers were suffering from the neonic precautionary ban
• The JRC study shows that farmers across the EU were spending more money and time, using much larger volumes of older pesticides to treat insect infestations on maize, sunflowers and oilseed rape, with lower yields and having achieved no improvements in bee populations
• The European Commission chose not to publish this publicly-funded study even after the JRC presented their findings to the European Parliament. Politico leaked the document here.

Clearly only misguided fools, ideological zealots or morally compromised individuals would support regulatory actions against either glyphosate or neonicotinoids. Activist groups like Friends of the Earth, Pesticide Action Network and Corporate Europe Observatory receive funding from the organic food industry lobby, so we can understand their “Creationist-minded” motivation to spread fear and lies on glyphosate and neonics. But I have a hard time believing that European Commission officials, many of whom are scientists, can be that stupid.

The deeper I got into the disconnect between facts and common sense on the one side and an EU policy constipation on the other, the more I became aware that the intelligent people put in positions at EU agencies like EFSA and ECHA or the Commission’s JRC or DG Santé were not being allowed to take decisions based on a sound mind. Who was responsible then for the mindless policy disasters these poor, well-educated individuals are now forced to curate (… until they can salvage their battered integrity and move on to more meaningful employment)?

The Sugar Bomb

If you had thought, from the analysis above, that Stupid was running out of control within the European Commission, … well, … hold on to your hats. Last month, Pesticide Action Network leaked an internal European Commission document outlining plans to extend the neonicotinoid ban from the present restrictions on flowering crops like maize, sunflowers and oilseed rape to all applications of neonicotinoids. (See the leaked draft proposition by the European Commission here.) The European Commission claims in this draft that the honeybees are under threat (this is false based on the Commission’s own research data) and that there are data gaps with neonic research (due to their application of the unapproved draft bee guidance document which was designed by anti-pesticide activists to throw out most legitimate research).

Such a total ban on all neonicotinoid applications would cover about one third of pesticides in use in the EU today and importantly would remove the main means of protecting many staples like potatoes and sugar beets from insect infestations. These are largely non-flowering commodity crops so the risks to bees are minimal. Given that options for protecting sugar beets, for example, are limited (and unlike the US, European farmers cannot enjoy the benefits of GMO sugar beets … another regulatory face palm), such a ban will have significant consequences for all Europeans from farmers to consumers.

First, many farmers will simply take sugar beets out of their crop rotations. As oilseed rape is slowly being removed from European rotations (due to the steady rise of cabbage stem flea beetle infestations post neonic ban and mounting yield losses), there are fewer options for farmers to restore soil nutrients. Add to that the anticipated lower sugar beet yields and we can expect supply shortages and sharp price increases affecting a large part of European food production. I wonder whether the European food industry might want to wake up from its usual myopic slumber and start taking stresses in the rest of the food chain seriously (Mella?).

Did DG Santé officials actually consult the European food manufacturers before venturing down this path of Stupid? Perhaps an impact assessment would have been a good idea. I’m pretty sure, when the big boys in the food industry wake up, that this nonsense will be put right. But who knows, given the disconnect in the food chain coordination, they have slept through other agricultural time-bombs.

A shock to European sugar production caused by the completely useless neonic ban extension would not only hurt farmers, their soil management practices and European food consumers, it would also lead to another pointless search for alternatives. Other pesticide options involve older technologies that are less efficient (and let us not forget that overuse of one technology risks increased pest resilience). The search for alternative sugar sources will likely lead to more sugar cane production in Africa (right – that will certainly be better for the environment!!!) causing a disruption in African land allocation and food production, leading, of course, to increased stresses on food security – in other words, increased famines.

This is Stupid on a scale never before seen by any regulatory historians and the European Commission should rightly be ashamed of their brutally careless behaviour. Everyone is going to suffer from a policy decision that flies in the face of facts, basic science and common sense.

• Food companies will no longer be able to manufacture or compete on a global scale
• Farmers will run out of options for sustainable soil management and profitable agriculture
• The environment will suffer from the need to use large amounts of less efficient pesticides
• Pests will thrive as they grow more resilient to the farmers heavy reliance on fewer, weaker insecticides
• The bees will suffer under the widespread spraying of harsher chemicals (but it was never about the bees, let’s call that spade a spade)
• The European economy will falter through increased costs of imported foodstuff, increased costs to farming and lower yields
• The European consumer will pay the price at the supermarket checkout and at the loss of employment in the food manufacturing industry.

Whiskey Tango Foxtrot???

The EU pesticides policy, evidently driven by activists, has not only become an economic, social and environmental disaster, but also a moral train-wreck. What the hell is going on here???

Who is leading this Class A Stupid?

Where is all of this Class A Stupid coming from? I had sometimes thought that Ségolène Royal was running EU health and environmental policy … but that would only make the European Commission look like a hopeless bunch of idiots. I have too much respect for them to make that conclusion (and Princess Ségolène will soon have to look for a new meaningful job … perhaps in a UN agency?). Then I speculated that the aging flower children in the European Environment Agency were secretly pulling strings but work from Copenhagen shows how they have succeeded in making themselves irrelevant and untrustworthy. No, this recent bout of Stupid had to be coming from somewhere else. But where?

Since the Sugar Bomb, I have been asking people in the know where the European Commission officials were getting their information. Quite simply, no reasonable person would take a broken policy situation like the precautionary neonic ban and escalate it to completely abolish agri-technology and European farming. Who was giving EU officials advice and who was running the show on EU food safety policy?

Here is where we know this stupid advice is not coming from:

• Bernhard Url, the head of the European Food Safety Authority, EFSA, completely washed his hands of both sorry shameful acts of regulatory recklessness. On glyphosate, Url has lashed out on the unscientific antics of activist campaigners like Christopher Portier (his famous Facebook Age of Science outburst) and the irresponsible behaviour of the unhinged IARC lobby machine. On neonicotinoids, he recently acknowledged in a speech to the European Parliament that the draft bee guidance document (which is not legally accepted) was only being used by EFSA because someone in the European Commission has told him to. So Url knows the guidance for accepted field trial data is useless, but he is being forced to use it. Ouch!
• DG Santé Commissioner Andriukaitis tried many times to push an extension on glyphosate through and even tried to buy time by sending glyphosate to the European Chemicals Agency to give the substance the legitimacy it needed to get through (hopefully after Royal and Gabriel were voted out of office). On neonics, Andriukaitis went so far as to commission the JRC to produce data to show farmers are suffering from the 2013 ban (assumedly to give him a means to rescind the ban and return to reasonableness).
• The European Commission Joint Research Centre was crystal clear that neonicotinoids were less dangerous than other options farmers were forced to use, that the ban was damaging farmers, wasting their time and money and hurting the environment while not at all helping bees. If ever you want to see a clear declaration of a regulatory mistake, the JRC study on the effects of the neonicotinoid ban is the benchmark!
• The European Chemicals Agency was tasked with providing the deciding voice on the safety of glyphosate. The Commission gave its best regulatory scientists on chemicals 18 months to come up with advice – they came back in half of that time with a resoundingly clear “Glyphosate is safe” statement. End of discussion!

So if all of the European Commission scientists were lining up on the side of reason and facts on glyphosate and neonicotinoids, where was the problem? Why could the European Commission not move in a logical manner and renew the glyphosate authorisation and lift the disastrous ban on neonicotinoids? It can’t be because of NGO activist influence. While Brussels might be a circus, I trust that it is not managed by the clowns. Who was throwing EU agriculture, health and environment policy down the path of Stupid?

The Fish Rots from the Head

Just as I was running out of legitimate sources for who could be behind the latest bout of Stupid, and a few days after the leak of the Sugar Bomb, the President of the European Commission, Jean-Claude Juncker, dropped a bomb of disbelief (as reported in Politico).

“I’m the best-known friend of the bees in Luxembourg,” the European Commission president proudly told his team of commissioners Wednesday, according to sources in the room, just hours before the U.K. officially informed the EU of its intention to leave the bloc. … Days before Juncker’s plea to save Europe’s beleaguered pollinators, the Commission president had made known his displeasure at press leaks of draft proposals to ban pesticides suspected of killing bees.

Could it be possible that the President of the European Commission was the one telling EFSA to use the illegitimate Bee Guidance Document (against the EFSA chief, Bernhard Url’s better judgement)? Could Juncker have instructed Commissioner Andriukaitis to throw glyphosate back into regulatory deep grass even though both the heads of the BfR and EFSA had publicly stated that there was no influence from Monsanto in the glyphosate risk assessments? Could the President be the one to have stopped the publication of the JRC study showing how badly farmers have suffered from the neonic precautionary ban? Could Juncker have instructed the European Commission to extend the neonicotinoid ban to all applications (even though it looks likely that the Commission will lose the court case on its previous ban), without consulting its scientists or farmers? Could there have been a deal with certain Member States (eg, Princess Ségolène) that trumped scientists’, farmers’ and consumers’ interests?

All of these questions seem absurd until one looks at Juncker’s track record of disdain and disregard for regulatory science.

“Junck-Science”

What we have seen in Jean-Claude Juncker’s Brussels is a simple single strategy of expediency – to work hard to make issues go away – not solve them or create a better EU project, just to move problems somewhere else. This includes those issues with facts, evidence and data that may be troubling to expedient policy platforms, ie, those issues supported by clear science. One of Juncker’s first moves as President of the European Commission was to remove the position of a Chief Scientific Adviser. He replaced it with a board of scientists – a form of tall grass, into which he could kick any issue with the hopes of getting it lost in scientific debate for as long as it could be ignored. Just imagine if Anne Glover had told the famously anti-biotech Juncker that GMOs were perfectly safe – he would be forced to listen to her. No, no, no, that just would not help in the politics of expediency. It would be better to assemble a group of scientists and make sure they are incapable of arriving at any clear position. Then facts could be easily ignored or hidden in the murky swamp of contrived scientific disagreement or uncertainty.

It is time to introduce another term to the Brussels Euralect!

What we have been suffering under for the last two years is “Juncker-science” or Junck-science for short – the art of creating scientific disagreement so that undesired evidence and facts can be ignored and kept out of the policy process for as long as possible. NGOs have mastered this rejection of rationality by arming petty activist scientists with PR machines to spread weak uncertainty challenges (from Seralini to Portier to Goulson to Kortenkamp). Juncker’s goal, when expedience demands, is to elevate activist scientists with microphones so that issues that may be too hard to solve (like NBTs, acrylamide or GMOs) can go back to the academia for perpetual further study while the status quo is maintained (at least until Juncker’s term expires). There is no interest in receiving scientific advice but of a disdain for facts or evidence.

Junck-Science: the art of creating scientific disagreement so that undesired evidence and facts can be ignored and kept out of the policy process for as long as possible. There is no interest in receiving scientific advice but of a disdain for facts or evidence.

Junck-science is a consequence of the blind application of the precautionary principle in a hazard-based regulatory climate. This idea is simplistic: call for precaution for anything causing “regulatory irritation”, embrace expedience, and assume that actors will go away and find alternatives. The stench of precaution is enough to blacklist a substance, application or technology for good, making actual scientific evidence unnecessary or impotent. With fear and uncertainty, science, where undesirable, can easily be ignored until we have forgotten the benefits that the regulatory cowards had eliminated.

Unfortunately, not all science can be tactfully (or tacitly) ignored and with both glyphosate and neonicotinoids, the facts and evidence are starting to test Junck-science. Commissioner for Health Andriukaitis was ordered to kick glyphosate back into the deep grass of the European Chemicals Agency for 18 months (while Juncker reformed Comitology so that the issue would be managed away). They did not anticipate that ECHA would see how obvious the facts on the safety of glyphosate were and make such a quick, clear decision in favour of the herbicide of the century. The ever-expedient proponents of Junck-science will have to find somewhere else to send that dossier until they find another way to make glyphosate’s re-authorisation go away. Perhaps the fabricated nonsense of the “Monsanto Papers” will give the Health Commissioner the excuse to apply the Junck-science principle. Andriukaitis is not an idiot so why would he say something that stupid? The only explanation I can make for Andriukaitis’ inexplicable intervention is that this is Junck-science – Juncker is making political deals and telling his scientists and science-minded Commissioners to go stuff themselves.

Neonicotinoids is making Junck-science look even more ridiculous. Commissioner Andriukaitis kicked the failure of the “Save the Bees” ban into the deep grass (his own researchers were confirming in 2013 there was no “beepocalypse”) by denying that the neonic ban was ever about the bees. But rather than lifting the failed neonic ban that was strangling European farmers, the EU Commissioner for Health, in 2015, was forced to apply Junck-science again and request and then ignore a further study to see whether farmers were actually being strangled.

Asking for a further study could buy the Commission a couple more years, within which time shit-disturbers like that Mr Monger fellow would go away. Well, … no! Despite his failing health, the Risk-Monger is determined to live long enough to highlight another EU precautionary principle fail.

The JRC study commissioned by Andriukaitis indeed showed, without a doubt that farmers were paying more, using more (older and inefficient) pesticides, working harder to control pests, losing yields to increased infestations and not seeing any benefits at all to beneficial insect populations like bees. In short, the European Commission’s own research, concluded in large letters, that the 2013 precautionary ban of neonicotinoids was a magnificent and total failure. So what did the European Commission do? They refused to release this publicly funded study. This is true to the spirit of that lamentable Junck-science. It was however released in a raw form here.

I read this internal JRC document, the convincing data that screams out over the miserable strain put on farmers, the environment and, yes, the bees, and I thought to myself, why would smart people continue to do such stupid things? Why would they extend the neonic ban when the evidence is so clear that it has been a total failure? I can only come up with one conclusion – the political interference of Jean-Claude Juncker and his backroom deal-making.

Frankly Junck-science exemplifies what is wrong with precaution-based regulations. It exhibits a total disrespect towards regulatory science. Juncker’s meddling is turning European regulatory science into the equivalent of Eurovision Song Contest kitsch – and DG Santé has become the equivalent of the French entry – tasteless and with no chance of success. If I were a scientist working in the European Commission, I would speak out. If I were Commissioner Andriukaitis, I would keep my integrity and get out (but bring that vision-less little deal-maker down with me).

How to deal with Junck-science?

Things are out of control. There is apparently even a rumour that the Commission’s plan to ban all neonics is meant to be in exchange for the activists and Green’s benediction of a glyphosate re-authorisation. That Commission officials are even considering such a thing shows how little these regulators know about farming and how their regulations will affect them and even less how little they know about the rabid dictatorial character of the NGOs who have no concept of compromise. These hyenas have invested too much in banning glyphosate and they smell blood. Words cannot express how ridiculous this pathetic attempt at a compromise will be.

The first thing that any thinking person would recommend is to move pesticide regulations out of DG Santé and into DG Agriculture so that it could be managed by people who actually have an idea what farmers do. That we have Juncker possibly cutting backroom deals with Ségelène Royal without consulting people who know what farmers need is utterly absurd!

Farmers have to speak up and demand reasonable regulations. Relying on policymakers to have common sense or Copa-Cogeco to stand up for them is not an effective strategy. Getting compensation for increasing numbers of failed crops is not a way to farm and as more agri-technology is denied to them, EU farming will become less of a profession and more of a heritage activity. Dairy farmers marched in Brussels and the Commission cowered almost instantly (granted, they brought a few stressed-out bulls with them). I would like to invite European farmers to join me for a BBQ on the Place Schuman for a small “Stop the Stupid” demonstration. Bring your tractors!

And finally, simply put, Juncker has to resign. His personal issues are already affecting his capacity to make clear decisions. With Brexit, sovereign debt, diminishing trust in the EU and a crisis of legitimacy, that Juncker would preoccupy himself with imposing his will on bee health while being so badly advised as to the actual science is a clear indication he is not fit to lead. I for one have run out of patience for his charming uselessness. How long before Juncker transforms all of Brussels into a cheap version of the Eurovision Song Contest?

Nul point for Team Juncker!