With coronavirus splashed across the world news, science and its role in policy-making has been thrust into the spotlight. We should use this spotlight to examine the science behind other parts of our life: namely the environment and agriculture regulation.
Though it seems like eons ago, there was a time when Brexit and the UK’s trade relationship with the EU dominated the news. In 2017, Michael Gove was explicit in setting out his position on environmental standards. Gove said:
“Outside the EU, we have an opportunity to learn from both the Commission’s successes and failures. We can develop new institutions which do a better job and hold us to higher standards.” He went on to explain his wish for an environmental standards body, independent of government. This body’s “ambition will be to champion and uphold environmental standards, always rooted in rigorous scientific evidence.”
Gove was getting tangled in tautology here: for any environmental assessment rooted in science would automatically be a higher standard than the regulatory system in place in the EU.
A core element of EU environmental law is the precautionary principle (PP), which theoretically requires regulators to err on the side of caution when there is a lack of full scientific certainty. To many this may sound eminently sensible, but the reality is that it allows for biased and politicized decision making, and often results in counterproductive measures.
In the first instance, the idea that regulators will be able to achieve full scientific certainty is itself flawed. Science doesn’t have an end point. It is process of continuous attempts to disprove what was previously thought to be true as new data emerges. Another problem with the PP is that it only works in one direction, examining the potential harm from a new technology. It fails to take into account the harm of sticking with the status quo and not having that new technology.
For a fine example of how politicized and biased the EU’s regulatory system can be, one need look no further than its assessment and regulation of agricultural pesticides. Neonicotinoids, or neonics, are a relatively new insecticide that held the promise of controlling agricultural pests, while limiting environmental harm and farm worker exposure. A key advance with neonics was the fact that seeds could be coated in the insecticide, so that it is contained within the plant during key growth phases, avoiding the need for widespread spraying.
Some environmental activists believed neonics would pose a threat to pollinators, such as bees and butterflies, which feed on the plant’s nectar. The idea that this new insecticide would harm bees was certainly not implausible and deserved scientific inquiry. However, as David Zaruk, an environmental health risk policy analyst has described in exhaustive detail, what took place was anything but scientific.
Based on documents unearthed by Zaruk, the International Union for Conservation of Nature (IUCN) orchestrated a campaign with the goal of proving neonics were harming bees and other pollinators, and then putting pressure on the EU to impose a total ban. The IUCN and its collaborators then set out to find the evidence to prove their case, turning the scientific process on its head.
Conveniently for the IUCN, in some parts of the world bee colonies were dying, which was reported on widely in the media. Inconveniently for the IUCN, these deaths were unrelated to the use of neonics. Die-offs similar to Colony Collapse Disorder, as they syndrome came to be known, had been recorded throughout history, including a famous outbreak on the Isle of Wight in 1906, long before the invention of neonics or any other modern pesticide. To further complicate matters, bee colony numbers had been rising in Europe and indeed every other habitable continent in the world since the time neonics came on the market in the mid-1990s. According to the UN Food and Agriculture Organization, which tracks these numbers, there are about 25,000 more honeybee colonies in the world today than in 1995, an increase of almost 20%. In reality bee colony health was influenced by a range of factors, such as the spread of parasites, fungi, and viruses.
What should have been inconvenient data for the activists, however, did not deter the IUCN. According to Zaruk, the IUCN effectively took over the production of the European Food Safety Authority’s (EFSA) Bee Guidance Document (BGD), which spelled out the criteria by which the EFSA would authorize or outlaw neonics. Allowing activists to highjack this process could only ever result in a skewed and unscientific process. The BGD set standards for field tests of neonics that are in some cases literally impossible to meet, such that studies demonstrate no more than 7% reduction in hive strength when natural variation is as high as 21%.
The EFSA first issued a temporary neonic ban in 2013 and then five years later it made the ban permanent. But as science writer Jon Entine has explained, the agency never made a positive finding of harm to bees. As they stated in the final review, the EFSA banned neonics because “a low risk could not be confirmed.” In other words, the regulators first arbitrarily excluded all the studies showing neonics’ low risk to bees, and then ban the pesticides because they didn’t have the data to demonstrate a low risk to bees.
Initially the UK resisted this abuse of science. Under the direction of then Secretary of State for the Environment, Food, and Rural Affairs, Owen Paterson MP, neonics remained available to farmers. Paterson’s lonely stand for science, rational regulation and UK farm incurred the wrath of the environmentalists. The Cameron government, buckling to intense political pressure, removed him from his position and brought in more amenable Ministers willing to kow-tow to the EU.
The impact of the neonic ban on UK farmers was almost immediate. Since 2012, the acreage planted with oilseed rape (a critical rotation crop for wheat and other cereals) has declined 23% and farmer income from sales is down over 35%. In a dramatic illustration of how counter-productive such “precaution” is, surveys of farms since the ban have also shown an increase of spraying with older pesticides known to be harmful to bees.
According to a European Commission brief on the PP, “any regulatory measures introduced as a result of the [PP] should also be subject to review in light of new scientific data, and may have to be modified or abolished as new scientific data become available.” The EU it seems, is going in the opposite direction, presently negotiating with environmentalists on how strictly to apply the impossible requirements of the Bee Guidance Document to the approval of other insecticides too.
The UK is going to need all the help it can get as it emerges from the coronavirus slump. That will mean giving farmers the tools they need to increase production and control harmful pests. If Gove and the new Tory government are serious about implementing higher standards, they will stick to sound science and urgently revisit the neonic ban.
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