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The European Commission is holding a public consultation on pesticides in order to review their Sustainable Use Directive and to legitimise their Farm2Fork (embrace organic) strategy. With a wee bit of a wince, the Risk-Monger thought it worthwhile to participate.

But the questionnaire was so loaded with chemophobic bias, silly mistakes (that any science fifth-grader could correct) and activist-laden propaganda that the entire process seemed as fair to farmers and agronomists as a European Parliament public hearing organised by Green MEPs on behalf of Friends of the Earth and Pesticide Action Network. This article is not satire, but if this EUSurvey is a reflection of the level of understanding and respect the European Commission has for science and agriculture, then I would advise European farmers to sell their land and move to countries that have a modicum of respect for the most important element in the food chain.

The EU Farm2Fork strategy was an add-on Ursula von der Leyen imposed, with limited scientific advice, on DG Santé to put more meat on the Green Deal bones. But this public consultation should have provided the Commission officials with the means to quietly limit the carnage that von der Leyen’s cabinet was inflicting on European farmers and consumers (let alone global food security). That nobody stepped forward to “do a JRC” implies that there is no longer any scientific expertise (or backbone) within DG Santé.

So before I publish my contribution to the EUSurvey (next article), I thought I should analyse the chemophobic assumptions and simple scientific mistakes laced throughout the European Commission’s public consultation. What follows are screenshots from the questionnaire, then broken down with a few Mongerish comments to highlight the lack of intellectual … ‘attention’ that our public servants have given their Farm2Fork strategy.

Given the importance to the future of European agriculture, I urge those with an interest in farming and food production to take time to call out the European Commission on their naïve endorsement of an ideological campaign against agritech. This is too important to let activist zealots completely influence the process while leaving Europeans dependent on others to feed them.

Go to the consultation here (open until April 12). As the questions are biased, I recommend uploading your comments in a file at the end of the survey.

Those Nasty “Chemical” Pesticides

After the organic food industry lobby got outed – that organic farmers also used pesticides – they started to wordsmith their way out of their little lying corner, declaring that organic food contained no synthetic pesticides (also a lie) or no toxic chemicals. Anybody with the most basic scientific education would understand that everything is composed of chemicals and that all substances must be measured by their toxicity and exposure levels. A cup of coffee, for example, contains over 1000 chemicals and most of the ones we’ve actually tested have proven to be highly toxic to mice.

Why then does the European Commission think they can use the term “chemical pesticides” to refer, I assume, to synthetic crop protection tools and for some reason think they could be conceptually differentiated from less-tested, natural-based pesticides used by organic farmers? This is ridiculous even for a fifth-grade science student but that such a naïve term was allowed to make its way into a European Commission public consultation (16 times!) is not only embarrassing, it is, quite frankly, mind-numbingly idiotic.

Is DG Santé trying to appease the chemophobes? Was this consultation questionnaire written by an activist NGO organisation or a rogue Commission civil servant with political objectives? Are we supposed to exclude organic pesticides (which are often far more toxic to humans and the environment) from the EU’s Farm2Fork strategy because, according to some civil servant in Brussels, they are not … “chemicals”?

How can the scientific community take the European Commission seriously?

Non-chemical techniques could include actions like hand-weeding instead of herbicides or introducing natural predators, but the survey chose the term: “non-chemical pesticides”. What does this mean? Are they 100% safe and non-toxic? Why then would anyone use something that is so benign and friendly if the goal of applying a pesticide is to eradicate a threat to a crop? If the term is meant to refer to the natural chemicals approved for organic farming, then how do we know these are “risk-free” (as many organic-approved pesticides are not stringently tested)? Mancozeb, for example, a so-called “chemical pesticide” is far safer for humans and the environment than its “non-chemical” equivalent used by organic farmers, copper sulphate. Sorry, but is the Risk-Monger the only one who sees how totally absurd this word-play is? Is the Risk-Monger the only one who gets that the artificial dichotomy between natural and synthetic is of no practical value to farmers, the environment or food security?

Is there anyone in DG Santé with an undergraduate diploma in chemistry?

The follow-up questions listed above aren’t much better. Every farmer would like to use fewer pesticides if they could. As risk managers, every farmer would like to reduce the risk of pesticides on crops, their soil or themselves. From the first section of the consultation, it has become apparent that the DG Santé officials responsible for this survey know absolutely nothing about European farmers and the challenges they face (let alone basic notions of chemistry).

Yes. … and …

… and that is a good thing because some pests prove to be more difficult and destructive than others. In many situations, you need stronger chemicals to protect against more serious threats. Any risk manager knows that hazardous chemicals need to be managed properly by reducing exposures as low as reasonably achievable. If you buy into the hazard-based approach (that all hazards are harmful and must be removed regardless of exposure levels or benefits) then you would easily be swayed by the doctrine that anything not 100% safe and risk-free must be removed from use (regardless of the potentially negative consequences). Some activists call this the “precautionary principle” and think it should be used instead of risk management.

After 20 years of relying on the precautionary principle, should it surprise anyone that European Commission officials have no idea what basic tools are needed for risk management? With COVID-19, we witnessed the devastating consequences when our government officials proved incapable of managing risks, resulting in having to force populations into repressive and debilitating precautionary lockdowns. With no understanding of risk reduction measures, scenario-building or exposure management, should we really be empowering hazard-based precautionistas to manage a Farm2Fork strategy (imposed upon them for other purposes)?

Not in my Backyard

The European Commission consultation then put out a question to appease the self-righteous activist zealots who feel that their views matter more than any benefits for the greater good.

Every non-scientific chemophobe filling out this public consultation will take the bait and click “Yes, certainly” to this loaded question. But let’s take a few examples to highlight how ridiculous and unworkable of a situation this public right to know would be. If I notice that my plum trees in my front yard are being devoured by an insect infestation (they love plums), would I have to wait until everyone in the apartment building across the street from me has been informed before I address the problem? Most parks are surrounded by thousands of people so if a groundskeeper notices slugs eating through the flowerbeds, would treatment be suspended if someone in Building 34G, Unit 135 is concerned about the risk?

Anyone living in a rural community, on moving day, signed on to the fact that they were living next to farms and should accept that farmers need to protect their harvests. As for the couple with a second home in rural France who thought they could sue a farmer for the noise his rooster made every morning, the answer is simple: Move back to the city you cosmopolitan zealots!

That the European Commission even included such a silly question in this public consultation shows where they live and what they think of farmers.

“Farmers are Stupid”

In reading the questions in the European Commission’s public consultation, I had a sense that what our authorities are focused on is the use of pesticides by amateur gardeners and the general public – people with no experience, no training in chemical risk management and no understanding of alternatives. The only other explanation is that our civil servants think European farmers are stupid.

The activists behind the drafting of the EU’s Farm2Fork strategy are deceptively using consumer ignorance at the garden level as a veil to remove agritechnologies from the European fields and greenhouses supplying our food chain. When a campaign to ban a herbicide focuses on the green bottles at my local DIY, it is not just affecting me – I can easily bend over and pull out that weed – it is taking a beneficial component in European soil management out of farmers’ hands, making millions of hectares less sustainable and less fertile.

Honestly, there would be little problem if the EU decided to ban most direct-to-consumer pesticides while allowing farmers to continue to properly use these essential tools. But the idea that we ban all “chemical” pesticides to the agricultural sector because Mr John Brown, living at 27 West Lane, did not properly dilute his insecticide when spraying his roses is about as idiotic as banning all plastic packaging because someone carelessly tossed a wrapper on the street. … OK, fine, it is what it is, but why does the European Commission have to contribute to this absurdity?

How about the cost to humanity of not having food security, the cost of lost biodiversity due to the increased demand for farmland to feed a growing global population with less efficient agricultural technologies, the cost to the economy of increased prices and food imports or the cost to human health for those unable to afford five daily servings of fruit and veg? This proposition was written by an ignorant, rich urbanite with no idea how food is grown. It reflects the ideology found in the True Cost of Food campaign. As the activists behind that campaign were taken to court and found to be lying, why then is the European Commission still echoing their propaganda?

Do we really need to “inform” EU citizens about the harmful effects of pesticides? I assume someone in Brussels actually still thinks the organic food industry lobby hasn’t already done a good enough job terrifying European consumers into paying much more for their luxury food label.

I would like to think that any such plan would include a communications campaign that would alleviate fears and provide some scientific literacy (eg, that there are more carcinogens in a single cup of coffee than in all of the pesticide residues on an entire year’s consumption of conventionally grown fruit and vegetables – Bruce Ames). But then I saw the phrase “potential harmful effects” and realised that the European Commission is planning to up the chemophobic rhetoric and scare the public into its Farm2Fork strategy.

This text has to have been written by an NGO activist since only a zealot would use such arrogant vocabulary. What does it mean to “educate” someone on their practises? Only an activist would conclude that those stupid people who don’t know better need to be fixed.

There are already less hazardous “non-chemical” pesticides (translation: pesticides permitted for organic farming) widely available on the market. The problem is that they don’t work very well so anyone with a little experience in protecting crops won’t buy them.

And this is what the Farm2Fork strategy wants all of Europe to revert back to? Whiskey, Tango, Foxtrot??? That would be like demanding that all Europeans revert to only using Commodore 64 computers.

At first I thought this was a great idea. That the European Commission was thinking of a more integrated agritech strategy including allowing, for example, herbicide-resistant seed development. A 2008 NIAB study shows how over 50% of agricultural yield increases have come from better seed technologies … so I would definitely vote for that.

But then I saw the word “chemical pesticides” and realised the question was not about better seed technologies but about the precautionary principle. Each pesticide ban (with no better technology to solve the pest issues) has resulted in farmers abandoning affected crops (as we have seen with the rapid decline in OSR production following the EU neonicotinoid ban). The European Commission is actually asking its citizens here if they would accept only growing crops in the EU that would not need pesticides (like alfalfa, grass and some trees). They should have been more forthcoming and ask: In order to have a (chemical) pesticide-free Europe, would you be OK importing all of your fruit and vegetables and most grains from other countries (mainly Africa where millions of smallholders can feed your family provided they take their children out of school to hand-weed and control infestations)? That would have been an honest question.

For several generations now, our farmers have sent their children to university to study a variety of agricultural sciences. There they study chemistry and risk management. I wonder how European farmers must feel when they read such a sentence written by a European Commission official with a Bachelor’s in Art History who thinks farmers are stupid. Most EU Member States have requirements that any farmers applying pesticides must be certified. That Commission official is paid to know that.

What is even worse is the underlying assumption that farmers must just enjoy dumping chemicals down the throat of Mother Nature and that they simply don’t know any better as they willingly destroy the source of their own livelihoods. This type of horrific insult can be expected from affluent, green activists hypocritically spreading their fear, outrage and fundamentalist dogma, but this is a publication of a European institution seeking input from its population. The claim that farmers use pesticides because they don’t know any better represents the official thinking of the European Union.

Given the time I have spent meeting European farmers, walking their fields with them, sharing their concerns over Zoom calls, given the conversations I have observed between farmers and their agronomists, given my own experience, it is safe to say that if there is any ignorance going on or any need for training and guidance, it is with European Commission civil servants who clearly do not understand the people they represent and those who will suffer badly from the consequences of this uninformed prejudice.

Stella Kyriakides should apologise to European farmers and retract this insulting document.

The Dream of a (Chemical) Pesticide-Free Europe

Somewhere along the way (since the Delors presidency), European institutions have put their dreamers in charge of EU policy. Somewhere in DG Santé, there is an activist who dreams we can feed the world without crop protection tools, fertilisers or seed technologies. The stark reality of agriculture is that our crops, soil and yields are becoming increasingly more vulnerable to the ravages of nature. With growing global populations demanding more affluent diets (amid increased climate stresses), we need more sophisticated crop protection tools, better seed technologies and better soil management if we are to achieve the necessary sustainable intensification of crop yields. We don’t need more dreamers thinking we can feed the world if we just remove all of the technological innovations of the last 70 years, stop industry research and take a more spiritually holistic (agroecological) approach to the land.

I don’t share that dream. That is, however, who seems to be determining the policy direction in the European Union at the moment (and the consequences will prove to be devastating at a global scale).

With the dreamers in charge, the European Commission is driving forward with a Farm2Fork strategy that will falsely assure its Docilian populations that their food will soon be 100% safe and chemical-free (I wish I were making this up). Now they are arguing that European farmers can feed the world with organic food and that it will be better for the environment. None of this is scientifically valid but these ideologues had never based their dreams on evidence.

Once we ban all of the technologies, we can just throw money at the problems we have created. (I fear that sentence has just summed up the failure of European precaution-based leadership over the last two decades.)

Nice idea. This is probably why it is already being done as most pesticide manufacturers in Europe have introduced take-back policies for their empty drums and containers. With precision farming technologies, pesticide companies are introducing means to only apply pesticides in areas of fields where crops are vulnerable (increasing their effect while decreasing their volume). New dosing systems ensure that farmers can get the right mixture while avoiding any spillage or contact.

But the people advising the European Commission officials responsible for this consultation (ie, anti-pesticide activists) neglected to inform them that these tools and practises are already available to European farmers. And it appears that the European officials never bothered to consult industry themselves to learn what they have been developing over the last decade (apparently they are no longer allowed to meet with company officials except via trade associations).

Seriously??? How little does the European Commission understand about the basis of risk management? Pesticide management is not like measuring sugar content on sweets or dessert items. Colour codes would imply that some pesticides would not need special care, going against everything farmers are trained to practise. All chemical exposures need to be managed properly … Point!

Once again, this might work in the DIY for the average gardener but this is not the main concern of the Farm2Fork or Sustainable Use legislation. And once again, more hazardous pesticides are designed to address more difficult infestations and therein lies their value.

The idea of using a pharmaceutical-based system to reduce use and restrict access via prescriptions would not work here. Farmers often have to battle pernicious outbreaks, made peculiar by variations in soil, seed, pest and weather conditions. Arbitrarily telling farmers that the pesticide quota has been reached, the strongest products would not be available to them or that they would have to just let the crop go is like telling a cancer patient they can’t use the best medication for their treatment … but here, take two Aspirins and call me in the morning.

How could any European Commission official think a prescription-based system is a good idea when every farm and every crop situation is different?

There are different interpretations of what Integrated Pest Management (IPM) actually means. Farmers consider IPM as common sense – try other means to prevent crop loss before applying pesticides. For activists, IPM means the first step to a total ban of pesticides (and why they vociferously battled to ban neonicotinoids and glyphosate despite their positive benefits to agriculture). For the European Commission, it seems they are now interpreting IPM as the means for a total ban of “chemical” pesticides so that Europe can go fully organic.

So the European Commission solution, again: Let’s just throw more money at a bad idea.

Total … unmitigated … madness.

The first question that needs to be considered is whether the organic marketing label and cult ideology is actually sustainable enough to be worth promoting. There is much more dogma than science behind organic food so such a suggestion worries me. Should any reasonable person (or institution) dare promote organic food?

It is widely agreed that most organic crops yield on average 40% less than conventional crops meaning we would need to plough under more meadows and natural habitats to meet our growing food needs. As organic produce is much more expensive, poorer segments of the population will not be able to afford a proper daily dietary balance that includes at least five servings of fruit and vegetables. Without herbicides, it will be increasingly difficult for farmers to regenerate their soil via no-till farming with complex cover crops. From a social justice perspective, promoting organic food in the EU will lead to more suffering by smallholders and their families in Africa as they prioritise European food exports. Land will also be expropriated from farmers, as is the case in Rwanda, in order to grow flowers to manufacture organic (“non-chemical!“) pesticides (rather than food for local communities). (See my 20 Reasons article for more arguments and sources on why organic food is bad for humanity and the planet.)

Only the most naïve dreamer with no regard for facts or concern for human well-being and environmental sustainability would consider promoting organic farming or even think it is worthwhile to delineate a false moral dichotomy between natural and synthetic / organic and conventional.

… and that leads us to the European Commission’s Farm2Fork pro-organic strategy (the main objective, I believe, of this cynical public consultation pantomime).

F2F FFS

This consultation is a thinly veiled attempt to legitimise the European Commission’s Farm2Fork strategy. The questions are all loaded to favour organic farming. There were no questions on the risks to human health and the environment from organic-approved (non-chemical?) pesticides. There were no questions about the benefits consumers would be willing to surrender or the costs they would be willing to pay. The tone in the survey reflects, sadly, a contempt toward consumers and farmers and an adulation toward those fighting to remove chemicals. The bias in the consultation frames conventional farmers as ignorant and happily dumping hazardous chemicals into the environment. The EU’s Online Public Consultation on Sustainable Use of Pesticides was juvenile, non-scientific and simply put, an embarrassment to the European Commission.

The last section wonders whether there will be an impact from introducing a radical new set of demands on our food production system. It is almost as if the European civil servants don’t get the potentially catastrophic risks such an endeavour would entail. Then again, these are the same people who think that we need to stop “chemical” pesticides, so perhaps we should not make too many assumptions about their capacities. Ideologues don’t care much about consequences; naïve dreamers guarantee those consequences will be severe.

Asking about the potential impacts to the Farm2Fork strategy with merely a tick-box is an indication that the European Commission does not take very seriously the potential consequences of imposing political ideology on a scientific challenge. I decided to answer this section with some brief comments.

Forcing a major policy shift like the Farm2Fork strategy that will have profound effects on how Europeans feed themselves just so it could fit neatly into a Green Deal agenda that focuses on climate change posturing is, well, probably not a very smart idea. Insisting on pushing it through in the midst of a pandemic that threatens to strangle the European economy and a large population’s livelihoods is simply irresponsible. There will be millions of human casualties from Brussels’ Green Deal governance failures. Given the dire determination of several of the personalities in the present European Commission cabinet, I would not be surprised if the consequences of this pig-headed policy agenda does not further break up or dilute the European Union.

Never have I seen Brussels being led with such a high level of incompetence, intransigence and incoherence. The state of the Union is in tatters