The European Commission is holding a public consultation on pesticides. It is meant to be a review of the situation following the Sustainable Use Directive, but the survey seems to be setting the scene to justify promoting more organic food production. I have already made some comments on the lack of understanding of basic science and risk management concepts. Here is my contribution submitted today. Go to the consultation here (open until April 12). As the questions are biased, I recommend uploading your views in a file at the end of the survey.
The Sustainable Use of Pesticides Directive is Unworkable.
The Sustainable Use Directive (SUD) is built on an inappropriate conceptual framework and this has seriously affected its utility as a policy tool.
It is based on the hazard-based approach to policy, using the precautionary principle as its management tool. The hazard-based approach does not take into account exposure levels or the means to manage them via risk-reduction measures. In other words, if a hazard is identified (eg, a chemical substance that potentially has an adverse effect) then the objective is to remove it (regardless of the dose, crop protection benefits or the means to manage the exposure). The tool applied to manage the pesticide hazards is the Precautionary Principle (using the EEA version that reverses the burden of proof). This version is built on the premise that if you are not certain that a pesticide’s active ingredients are safe, then precaution must be taken. Certainty and safety are emotional concepts and in reality, nothing can be 100% safe with any certainty so the SUD virtually ensures that farmers will have no pesticides available to protect their crops when this exercise is complete.
The precautionary principle is not risk management, but uncertainty management (when uncertain, remove the hazard). In contrast to this, most other regulatory authorities use the risk-based approach for chemical management. In this case, a pesticide’s exposure (to humans and the environment) is measured and risk managers, aware of the benefits of the pesticide to food production and land management, look for ways to lower the exposure “as low as reasonably achievable” (ALARA). If they cannot lower the exposure, and the hazard is significant, then the substance should be taken off of the market. Under 91414, the Commission focused on exposures (MRLs) and aimed to progressively lower residue levels. This approach was rational (although at times the MRLs were set far too low).
In reality, exposure levels for most pesticides are very low (which explains why anti-pesticide campaigners and the organic food industry lobby shifted to the hazard-based approach). Bruce Ames showed, more than two decades ago, that there are more toxins in a single cup of coffee that what the average person would be exposed to from the pesticide residues of an entire year’s consumption of fruit and vegetables. So should we ban coffee in the EU? If we took the hazard-based approach, the answer would be: “Yes”. But if we took the risk-based approach, the answer would be: “Don’t be silly”.
Where the hazard-based approach shows its inherent failures is when pesticides are evaluated for their potential to be endocrine disruptors. The demand to prove (with certainty) that any chemical substance is 100% safe from having potential endocrine disrupting properties is impossible. You cannot prove with certainty that chocolate pudding does not have endocrine disrupting properties (and we feed that to children). But under SUD, each active ingredient coming up for reauthorisation has to prove with certainty that it has no endocrine disrupting properties. In other words, most substances will not meet the standards of reauthorisation. This is unworkable.
It gets even more ridiculous when one considers that the presence of EDCs in the environment is largely due to the flushing of residues from the use of contraceptives and HRTs (whose intention is hormonal disruption). These are known EDCs released at high levels into the environment while the European Commission is preoccupied with the low-level exposures of potential EDCs that are protecting our means to feed ourselves. More ridiculous is that we are exposed to far larger known endocrine disruptors from our consumption of soy, humus and coffee. Once again, should the European Commission ban coffee? If they took seriously the hazard-based approach, and not just to please a small group of loud activists, the answer would be “Yes!”.
So the hazard-based approach is not fit for purpose for pesticide risk management. When SUD was deliberated some 14 years ago (in the exhausted aftermath of REACH), the chemical industry lobby was discredited and the farming lobby was non-existent, allowing a few Green rapporteurs to write their own policy (while rejecting the demands for any impact assessments). The European Commission was thus burdened with a bad piece of legislation, more unworkable today than ever.
One of the core concepts regularly thrown about is Integrated Pest Management (IPM). But what does IPM mean? For the farmer, it means trying other means to control pests rather than applying pesticides as a first measure. This is common sense and no farmer would want to use pesticides if there are other alternatives (it costs money, takes time and involves personal risks). For anti-pesticide campaigners, IPM is considered the first step in the removal of all pesticides – it is considered as a promise and a roadmap to pesticide-free farming. This misperception will need to be addressed – the European Commission will need to acknowledge that there will always be pests and blights which may require suppression measures with crop protection tools.
This misunderstanding of IPM needs to be put to rest. In the last decade, the two most serious pesticide issues in the EU were built around this IPM “promise”. Farmers were using neonicotinoids systemically (as seed dressings) in order to use less pesticide overall. This was common sense, better for the environment and allowed farmers to better control devastating crop losses from pests like the cabbage stem flea beetle. For the anti-pesticide campaigners this was a clear case of where a pesticide was not being applied as a last resort – thus breaking the IPM “promise”. The other case is glyphosate, used by European farmers to terminate a complex variety of cover crops while practising no-till farming. This has extremely positive contributions to soil regeneration and sustainable farming, preventing soil erosion, promoting richer soil biota and nutrients while storing more CO2 and groundwater (but once again goes against the IPM “promise”).
Given the misunderstandings, any revision of SUD may best remove mention of IPM.
This EU consultation has been built into the context of the European Commission’s Farm2Fork strategy. I am very worried about the lack of credible scientific understanding in the questions provided in the EUSurvey. For example, the term “chemical pesticide” was used 16 times. This term is pure nonsense – everything, natural or synthetic, is made of chemicals. I would strongly recommend that the Commission officials tasked with the Farm2Fork dossier employ someone with a diploma in chemistry to advise them because most of the language in the consultation was, sorry to say, extremely embarrassing (not to mention insulting to farmers and consumers). See some examples at: https://risk-monger.com/2021/04/07/f2f-ffs-pt-1-the-eu-pesticide-survey-naive-chemophobic-and-activist-driven/.
More worrying is that the consultation and the Farm2Fork strategy is seen to be favouring organic farming as the future. This is not only, once again, scientifically embarrassing, but it will have serious implications (if implemented) on global food security. “Organic” is a marketing concept built upon a cult-religious approach to nature. With evolutions in the concept of agroecology, organic has also become a social justice, anti-industry ideology. None of this has any basis in evidence or scientific facts. Organic food is not safer or healthier than conventionally grown food. It is not better for the environment or climate mitigation than conventional practises (and many pesticides used by organic farmers are far less sustainable).
Farm2Fork, I am afraid, is based on the activist-imposed moral distinction between natural and synthetic (why, I suppose this consultation obsessed over the term ‘chemical’ pesticide). Synthetic pesticides are developed when natural approaches fail to protect crops, the soil or food quality. Both systems have strong elements and the Commission should take the pragmatic approach and favour the best available tools (and not distinguish them according to some cult naturopathic ideology). For example, Mancozeb is a synthetic pesticide that is far safer to humans and the environment and more effective than the organic-approved natural equivalent, copper sulphate. Any arbitrary favouring of “non-chemical pesticides” like copper sulphate is embarrassing.
The European Commission should lead with science and innovation, not fundamentalist dogma and politics.