What follows is the base text for a presentation made at the BAFSAM general assembly in London on 17 May 2018. As the presentation was delivered without notes, the actual content may differ slightly.
Happy 50th Birthday!
50 years may only be one monarch in the UK, it might only be a blink of the eye since The Risk-Monger had entered grade school, but it is two full generations and a world of change for farming. What has happened to the feed additive industry over the last 50 years? What has your half-century of technology advances done for the world? How have you helped advance farming and food security since your parents’ time? … since your grandparents pioneered the advances in food and feed technology?
Our Grandparents’ World
The world of farming and food production of our grandparents was quite different from what we see today. Increasing food production following the Second World War and reconstruction was imperative. Farming intensified as did demand. Our grandparents had limited technologies but global threats. Populations, post-war, began to grow and the fear of a population bomb loomed over us with the ghost of Malthus finding voice in modern-day doomsday prophets like Paul Ehrlich. Frequent famines in Africa and the Asian subcontinent accentuated the sense of purpose to produce more. Enter agronomists and plant biologists, like Norman Borlaug, working to find solutions to farming’s needs. The farms themselves began a transformation… economic pressures put many small farmers out of business, larger investments were needed as farming became a business. Heavy machinery and automation started to replace labour and herds became livestock operations. With this came the need for larger volumes of feed material and the arrival of feed supplements. Governments were finding ways to help our grandparents ensure a stable and more abundant food supply, help them to expand and manage costs. As over-production in some sectors loomed in Europe, regulators paid farmers via CAP to leave fields fallow.
Our Parents’ World
By the time our grandparents handed the land to our parents, there were far fewer of their generation to take to the fields. Technology and scientific solutions made yields surge and farmhand numbers plummet. Agrochemicals, fertilisers, advance plant breeding and feed additives were addressing the challenges and improving farm output and food security. Our parents had to operate in the world of risk and public risk fears. The miracles of science and the wonders of chemicals were replaced with risk management processes as many crises, particularly in the 90s, started to raise concerns that the synthetic approach to food production had its limits. GMOs, BSE, MMR, acrylamide, dioxins … it seemed that technology was leaving a trail of uncertainty that left consumers confused and vulnerable. People started to speak about trust in the food chain.
Our parents’ governments were concerned about food safety, of limiting disease outbreak and improving calorie and diet diversity. If dioxins found their way into the eggs or cows got wobbly, then governments themselves would wobble. The public was waking up to the evolutions in farming, but our parents were not very concerned about PR or public trust issues. There was work to be done, and farming margins were still very tight.
Their generation saw the rise of the NGO – of idealists demanding a better way for farming, without the chemicals and technologies (and without experience or understanding of farming). Adjectives like organic, natural, pure, free-range, cruelty-free and grass-fed started to find their way onto food labels and marketing strategies, attracting a dedicated, albeit, small niche following. Stakeholder dialogue and consultation became the key means to govern and build trust, but activists soon started to take their pressure tactics inside governments.
Our parents left us with a much better world than our grandparents could have imagined. Production yields have skyrocketed, markets have stabilised and supply chains have advanced to a point where a crop failure or disease outbreak has no effect on global food supply. It is getting difficult to remember the last food security scare or famine. The growing population has also become affluent, consuming more protein from a wider variety of sources. We are now feeding large aquaculture operations with soy and developing insect-based cattle feed.
Farming has changed as well, becoming as focused on environmental management as food production. CAP funding, following the Austrian model, goes to managing hedges and wastewater, while soil remediation and pollinator habitat preservation are high on farmers’ challenges as is limiting CO2 emissions.
Perhaps our parents’ success has left us forgetting that farming entails risks – we are now in a world of a hazard-based regulatory approach. Our parents managed risks by reducing exposures to hazards. Food and feed were tested for maximum residue levels (MRLs) and regulators aimed at reducing these levels to as low as reasonably achievable (ALARA). Today, exposures don’t seem to matter – if a substance is deemed as hazardous, regardless of how low, these uncertainties need to be eliminated under a tool called the Precautionary Principle.
The Precaution Perversion
The Precautionary Principle, within a hazard-based policy approach, has changed the way the agritech regulatory process has evolved. While most of our generation still think in terms of evidence-based risk assessments, those in government are using other, non-rational tools. Precaution follows a different, non-scientific logic with concepts that are open to political interpretation and manipulation. An example. On this fine day, with the sun shining, I look in my bag and I see that I brought an umbrella (a very precautionary action). Was I right to bring my umbrella on this sunny day? No, I was not right. But, was I wrong to bring my umbrella? No … I also was not wrong. In fact, I will bring it tomorrow, even if the forecast is for further sun. With the precautionary principle, logic is turned on its head: not being right is not the same as being wrong – or to be more precise, with precaution, I am never wrong. Now, if you were a policymaker with an interest in a long career, you would begin to appreciate the free-from-responsibility nature inherent in the use of precaution on sensitive policy issues. For scientists though, who believe you are either right or wrong (and assume that if you are right, then you have the right), this can be infuriating.
The second thing precaution has done to our generation’s chemical policy madness, is cement subjectivity into what should be an objective process. Precaution is normative – we only apply it on issues that are perceived to be unwanted. The recent precautionary ban on all neonicotinoid insecticide applications was not based on any overall assessment of which crop protection materials were better or worse. It was targeted by a group of activists planning a long-term strategy to remove all synthetic pesticides. No one considered how the alternatives to neonics, including pesticides approved for organic farming, would be far worse for the farmers, consumers, the environment and, yes, bees. No one had to consider this because, remember, with the precautionary principle, you are never wrong (just, as in the neonic case, really not right). Michael Gove based his anti-neonic strategy on good intentions and political opportunism, not scientific advice.
The worst thing about precaution (yes, it gets worse!) is how it can be manipulated to ban anything and everything. Brussels uses what I call the David Gee definition of precaution, reversing the burden of proof. Unless you can prove to me that your substance, additive or process is safe, you do not have the right to use or market it. What is “safe” in a hazard-based approach? Safe for a foetus? Safe if the only person exposed to the hazard is using proper protective equipment? Safe over a long term of low doses? Safe means anything and nothing depending on the person using the concept, and as an emotional concept, can be manipulated in a fear-based campaign. And even if you can show how your substance is safe, an activist can simply mutter: “Not safe enough!” One of the most benign chemicals, glyphosate, was determined, in a weak hazard assessment by a politically-compromised UN agency to not be 100% safe to agricultural users. It did not take too long for activists to exploit the hazard-based definition to turn the herbicide of the century into the root of all evil and the cause of all consumer health problems.
This lamentable process can be played out on any substance that any activist may not like. What will be the next glyphosate? Do you have a new breeding technique that can create a much more nutritional and economical feed additive? Sorry, I’d call that a GMO, and since “we” can’t be certain it is safe, your innovation won’t be helping farmers any time soon!
Our generation let precaution become the main policy tool in a hazard-based regulatory approach … no wonder our farmers are getting nervous. But look at the pedigree of our policymakers today and you will no doubt begin to see how things have started to unravel.
The regulator we face today differs from that of our parents. It is no longer a service that attracts our experienced and talented who had achieved in their professional lives and would retire by giving back through public service. Their concept of governance was minimalistic – if industry could propose a voluntary initiative, then regulators were happy to leave the process as is.
Now the halls of power are populated by young graduates of policy studies (I have seen many of these young idealists pass through my lecture hall). They arrive in government eager to regulate, to use the tools their professors talked about and to realise their true goal of public service: to protect the public and save the planet. As generalists with neither experience nor expertise, these young pups have never been interested in the boring details of evidence or impact assessments. Industry was not going to get a chance to influence the process – transparency became the sole political virtue and hazard-based precautionary principle the main policy tool.
The last decade has seen the policy transformation remove many of the technologies our parents had benefited from. Idealists in Europe have banned GMOs, the most advanced crop protection technologies and certain feed additives. Farmers have had to go back to older technologies, work harder and face bigger challenges. Still we are benefiting from agricultural abundance, but in Europe, this is increasingly coming from imported food and feed.
Our Children’s World
So what will the world that we will give to our children be like?
Our children’s world might be, by our present standard, more chaotic. The stakeholders who sit around the table today will be gone, replaced by random communities (social media tribes) driven by a fluttering, guru-led idealism. Trust will be collective, what I call “blockchain trust” where everybody watches and verifies everyone’s actions and the algorithms tell us how to proceed. The most emotional and impassioned communities will be the most successful in influencing the policy debate, where policy-makers will abandon consensus and dialogue and declare their decisions to be the democratic will of the people.
Decisions on feed and farming will be made by policy agitator professionals, lawyers and idealists who, while never having been on a farm, will feel confident in the advice they receive from agroecologist dreamers. In any case, meat consumption will decline in Europe (for the common good) with supplements and alternative proteins gaining prominence. The tribes pushing for veganism, climate reductions, animal welfare, health and wellness concerns and agri-revisionists will predominate a new form of agriculture policy focus in Europe.
This “people” will determine the risk assessments, with citizen scientists funded by activist organisations posing as the experts of the people. The public will be informed of all chemical additives and substances and a voice of the people will emerge through the community process. All other scientists will be ostracised as part of some industry conspiracy to poison us. Our children will no longer have Monsanto to beat up on but the ghost of that organisation will often be called upon. Large corporations will have to present themselves in myriads of small units of green, local and good cottage industries.
The religion of organic food will be redefined and diluted (with the fundamentalist puritans respected and politely tolerated but kept out of the influential communities). Food manufacturers and retailers will become agritech’s worst enemy, looking at giving the “people” whatever they perceive as demands, regardless of the feasibility of the food production requirements. They have been able to get away with their anti-science marketing tricks thanks to the supply chain achievements of our parents. Can’t raise enough organic, grass-fed beef in the UK? No problem! We can source it from Australia.
European capitals will become idealist-driven policy incubators dominated by American activists who see no hope of policy change in Washington but fertile ground in the precaution-based climate around Place Schuman. These carpetbaggers come to Europe with the hope of handicapping agricultural technologies here, then using their illogical policy gains to disrupt the value chain. Trade barriers will be demanded and pressure will be put on global retailers and food manufacturers to adopt the activists’ favoured alternatives. American markets will fall into line even if Washington remains science-based and risk-management-driven. I’m afraid Brexit won’t insulate you from this wave of stupid.
What will this do to farmers and food production? Nobody seems to be talking to them. Our generation has allowed expertise and experience to slip away from the policy process. I can only begin to imagine how this zealot-driven madness will affect food production and yields for our children. Our grandparents would be turning in their graves thinking we willingly embraced the world of their uncertainty, food insecurity and hard-worn sweat.
Oh dear … I seem to have painted an awful future for our children. And on such a lovely day … on such a lovely boat.
Future-proof the Present
Before we pull into the dock, let us imagine ways to stop this tragedy from unfolding. How can we leave a world for our children better than the one our parents have left us?
Clearly, doing nothing or hoping things improve is not a solution.
The tools the activists have put in place were designed to handcuff innovation, technology and industry. The hazard-based approach is neither scientific nor practical. IARCgate and the glyphosate debacle was the watershed moment where the EU risk assessment process needed to be reinforced. The precautionary principle (as the reversal of the burden of proof) is intended to remove risks rather than manage them – it should be a tool of last resort (when risk management has failed) and not the first and only regulatory tool. The democratisation of the risk-assessment process will only lead to activist-manufactured fear campaigns influencing the decision-making process. All of these tools need to be limited and put within a rational, evidence-driven, risk-based regulatory structure.
You will need to go out and build up your communities of farmers, scientists, consumers and reasonable people, get into the mud of social media and highlight the risks and mal-intentions of the activist campaigners. We need many more standing up for science in a world where activists spread their bile often unopposed and unquestioned. As we are being dragged into the Age of Stupid, should we continue to do nothing, allow our regulators to embrace ignorance and encourage our farmers to fail?
I look around the room and I see opportunity. This association is not only 50 years old, it is the sum of its parts: innovative, motivated and resourceful. This community is comprised of millions of scientists, developers, manufacturers across the food chain. You need to take the bull by the horns, create a wall of reason to distract the precautionary opportunists, demand service and responsibility from our regulators and call them out when they abuse the process for their political gain. Let us commit today to addressing the activist-driven tools that will only continue to choke farmers, reduce yields and increase animal suffering.
Our children do not have to inherit a world dominated by manipulative fear-mongers and weak, expedient leaders. I fear, as many parents today, that my children will likely leave Europe for better opportunities. Let’s give them a Europe worth calling home, a world with prosperity and a community that will defend their interests.