See the French and Portuguese translations

A group of “citizens” released an Activist Manifesto about how the European Union must change the entire risk assessment process for pesticides. A manifesto … signed by more than 100 NGOs and a dozen activist academics … calling themselves the “citizens for science” … demanding that Europe changes its policy process … with 15 demands that will exclude industry and put them in power.

Well, that’s that then. The citizen’s have spoken so the regulators have to listen to them and the rest of us should just shut up and go home.

But who are these “citizens” that have taken the responsibility to speak for all of us? They have given themselves a name: Citizens for Science in Pesticide Regulation … or is it “Citizens for Pesticide Reform” (but with a “4” – get it?). They even have their own website. European taxpayer funds once again well-spent!

I looked at the list of signatories to this grand coalition. A large number of them are activists bought and paid for by the organic food industry lobby so it should come as no surprise that they want to change the rules so all synthetic pesticides will be banned. There are no farmers representing this citizenry (OK, 12 million EU farmers may seem like a small number, but until now they have been the ones feeding us!). There are no agronomists signing this citizen’s manifesto – surely they would have something to say as they are the ones developing the scientific tools to allow farmers to succeed. As they want to re-write the rules of the game for how policies are determined, you would expect some former EU Commissioners or EFSA officials advocating the need to change the entire policy system. Nada!

It seems that almost everyone who signed this tirade shares the same naturopathic cult fundamentalism (natural is good, synthetic is evil, get rid of industry and the world will be fine) and is not interested in dialogue or compromise with other actors. The people who signed this declaration might feel their intentions are noble, but they are sadly ignorant or misinformed about the processes used in research, farming, land management and policy. But somehow these activists are arrogant enough to feel they can speak on behalf of the vast majority their little manifesto will surely affect. This is the arrogance of ignorance the closed-minded Brussels NGO community has come to embrace.

This manifesto is pure arrogance, hatched by an ignorance in full bloom. Without consulting those concerned, without engaging with experts who may have other views, these citizens have the gall to declare a manifesto to ban all the pesticides they don’t like, to exclude industry from the decision-making process and to assume they can take over as an “independent body” to control the risk assessment process. They declare it with a tone that shouts at anyone who dares question them – those who disagree had better get out of the “citizens'” way.

I have disagreed with these activist zealots in the past and in the last two years they have shut down my blogsite, physically dragged me out of their “People’s Assembly” and got me fired from a job I had held for ten years. It might surprise some that I still wish to have my say, but this little manifesto is so manifestly wrong that if no one stands up to scream “Bullshit!”, the ignorant will have their day and a lot of innocent victims will suffer consequences from their arrogance.

So here are some initial ideas on how wrong these ignorant actors are and why we should be concerned when these “citizens” speak on behalf of a small affluent population with interests that are ideological and unscientific. While these 100+ NGOs bully and scare everyone who disagrees, corralling them into marginalised, sound-proof boxes, regulators need to understand how these inter-networked cults operate. If bureaucrats in Brussels listen to their 15 little diktats and let their arrogance of ignorance influence policy, then they will have relinquished their responsibility to the true citizens in European society.

The Activist Manifesto

The indented text is taken directly from the Activist Manifesto (no text was edited). The views in the normal text are the voice of one European citizen wishing to keep some European debate open to reason. The activists will probably find another way to try to harm him, but he has given up caring about that.

The manifesto starts off with a call for nothing less than:

A full reform of the current pesticide risk assessment and risk management systems is required, as follows:

The activists are calling for a “full reform” – a citizen-led revolution of the risk assessment process. Why? Because they did not win on glyphosate? Because people who don’t think like them had a voice in the debate? Because farmers are still using pesticides and the organic lobby is having a hard time competing? Why do they demand a full reform and not a few improvements? For the activists, they have to change the rules to the game so that there will only be one winner. Industry, science and farmers want to make the world better through continuous improvement – cult-driven ideologues want revolution and power. Industry has been spending all of its time trying to comply to regulations that are “uncompliable” – they have been too busy to notice how the rules of the game keep changing.

A. PRIORITISE PUBLIC HEALTH, THE ENVIRONMENT AND SUSTAINABLE AGRICULTURE

The European Commission shall propose the approval of a pesticide substance only when all the scientific evidence shows that the substance or the final product causes no adverse effect on humans, animals, and the environment, all uses proposed by industry are considered safe by EFSA, and no safer alternative (substance or practice) is available.

This absolutism is ridiculous and indicates either the naivety or uncompromising nature of these zealots. You can only use a pesticide if you can prove there is “no adverse affect on humans, animals and the environment”. No adverse affect??? Are these people so ignorant to not understand that every human activity has an adverse affect? All food has an adverse affect on humans – that’s why we have a digestion process that has evolved over millennia, why we have developed other medicinal toxins, why we study farming to limit the effects. To have no adverse affect on animals implies an enforced veganism on Europe, but even that has detrimental effects. No adverse affect on the environment means we would have to abandon all cultivation and go back to gathering berries (in a Jainist manner). Whoever wrote this is a citizen who did not think very much.

What do these citizens consider as a “safer alternative“? Having higher prices on fruits and vegetables are not safer if you want populations to consume more balanced, cancer-fighting diets. Having to cultivate more meadows given the lower yields from organic farming practices and till more frequently to control weed outbreaks are not safer for the environment. Pure ignorance expressed audaciously.

2. The Sustainable Use of Pesticides Directive must be respected: pesticides must be used only as a last resort when all other non-chemical alternatives have been applied and failed.

Uhm … what is a “non-chemical alternative“? Chemicals are not man-made … man is made of chemicals … and so is everything else. I understand that these “citizens” do not have much scientific education and I get that what they really mean to say is: “Not made in a Monsanto lab” but it shows the level of ignorance going on here. They were probably deciding between using either “non-chemical” or “non-toxic alternative” but I suppose somebody told them that organic approved pesticides are also toxic (“but only a little bit and in a very non-offensive way”). Maybe they meant something like: “You can only use a herbicide when you run out of children to hand-weed.”

And what does “last resort” mean in this rather twisted interpretation of Integrated Pest Management? In fighting cancer, am I only allowed to take medication as a last resort when it starts to metastacise? Only after juicing and turmeric have failed? Should a farmer wait until the cabbage stem flea beetle has eaten through the oilseed rape stems before spraying? Should no-till and cover crop practices only be used as a “last resort” when the farmer’s top soil has blown away? This twisted and ignorant view of farming suggests that farmers can only protect their crops when nature is throwing a mortal blow at them. Seed treatments are designed to prevent and protect while avoiding more detrimental and less effective foliar sprays. Complex cover crops are becoming tools to inoculate soil against potential pests but only if they can be terminated with herbicides. These are preventative sustainable farming tools but the “citizens” have campaigned to leave farmers with no viable last resorts.

If these activist zealots had consulted farmers, if they had tried to understand farming, they might come across as less ignorant (and less arrogant).

3. The European Commission, as risk manager, shall operate transparently and with accountability. It must fulfil its obligation under the pesticide regulation to prioritise public health and the environment over all other considerations, such as private profit. The decision-making process – the discussions between the European Commission and the Member States, or any other entity – shall be public.

This campaign is not at all about food supply. It is not at all about farming. It is not at all about reality but rather an ideology that the well-fed elitists are trying to impose on the vulnerable. At what point is a battle against a small hypothetical risk going to lead to significant consequences? Risk managers understand that risks and benefits are related and must be measured. Destroying the European food supply will not help public health. Chasing out all agri-tech research (from crop protection to CRISPR) will not help resource efficiency. Willingly creating food poverty will not help the European economy or create opportunity for the less fortunate in society.

The present European Commission (Selmayr I) has created this monster by abandoning the Inter-service Consultation approach. Decisions affecting farmers, food manufacturers and consumers are managed solely by DG Health (from a hazard-based perspective), with no concern over how the loss of benefits will be dealt with. It is not a question about profit, it is a question on whether European farming will be viable, whether healthy food will become an elitist luxury and whether science will be able to innovate to adapt to the coming agricultural challenges. Instead, the activist zealots play a game about power … and the NGOs know they have power in a Commission that is incapable of dialogue.

4. To enable EU farmers to improve their practices without being ‘punished’ by markets, the European Commission shall not place them in a position of unfair competition and shall therefore ban imported products that contain residues of non-approved pesticides, or that contain residues of any pesticide exceeding permitted levels, with no exceptions.

I have argued this before but I fear few people have got it. The campaign to ban glyphosate in Europe was an anti-GMO campaign run by activists in Washington. GM maize and soy are allowed to be exported to the EU as animal feed under one regulation. Most herbicide-resistant grain will likely show minute traces of herbicide residue. If glyphosate is banned in the EU, then any trace residue on any feed will be turned away at the border. No worries, we all received the “Vegan Europe” memo. These “citizens” may be ignorant about basic science and farming, but they are cunning at getting what they want (however immorally and irresponsibly). It’s the rest of us who need to wake up fast.

B. ENSURE THAT DECISION-MAKERS RELY ON DATA THAT IS COMPLETE, PUBLIC, UP TO DATE, AND FREE FROM INDUSTRY BIAS 5. Safety testing of pesticides shall be carried out by independent laboratories and not by the pesticide industry itself. The process shall be paid for by an industry-supplied fund that shall be managed by an independent public body such as EFSA.

I love this paranoid view of the world underlying the anti-industry narrative. These “citizens” actually believe that Monsanto (a mid-sized seed company that no longer exists) is going around buying all of the scientists and regulators (they keep telling themselves this and so it becomes a “fact”). In the thousands of pages of research data produced to comply with the regulatory demands for pesticide risk assessments, companies do indeed use independent laboratories. Regulatory science is not cutting edge research so any company with budgetary constraints (all of them) would outsource that budget line right away. Regulators insisted on industry using Good Laboratory Practices (GLP) in the 1970s and one role for the risk assessor is to ensure that GLP has been followed. It is surprising how these anti-risk assessment campaigners have not figured this out yet (unless they just plain don’t want to). It is shameful that the regulators have not informed them and the media who repeat these falsehoods.

It’s cute that the activists are preparing to create a fund to “safety test” pesticides. (By the way, what does a non-scientific “citizen” think it means to “safety test”?) Who will pay for the tests, which company and how much? Will it be by sales volume, impact, need for more studies…? What about additives used in other applications? What about regional usage? Will it be related to the activist target lists of concerned substances? When you are just a “citizen” you can be allowed to think in a simplistic way. What the zealots really want is for the government to tax all crop protection products and give the activists the money to decide what to test. They admit that in Point 15 of this Activist Manifesto.

And as for determining which lab is an independent one, that’s easy. If they disagree with the activist campaign objectives, they are not independent.

6. To prevent cherry-picking of favourable data, all safety studies must be registered in advance. No safety study that is not registered shall be used in support of regulatory authorisation of a pesticide. 7. All experts involved in risk assessment shall be subject to a strict conflict of interest policy and rules. Any ties to commercial interests will exclude them from the process. 8. Existing guidelines on risk assessment shall be fully reviewed by independent scientists because in many cases they were designed and promoted by industry and are biased in favour of industry interests.

These things all exist and anyone who understood how the EU risk assessment process works would simply say: So what? Were these ignorant “citizens” too arrogant to consult EFSA? Or were they trying to expand a fiction?

Actually I do have one point. Why are the activists only concerned about industry conflicts of interest? Do they think their activist scientists wouldn’t have conflicts of interest or are they just blindly hypocritical? I raised a fuss about how the EFSA Bee Guidance Document was written on the advice of a working group that had three anti-pesticide activists on the EFSA panel (who had hid their affiliations with their NGOs). That bee guidance document was written in such a way as to make it impossible to produce any field trial data to comply with bee risk assessment requirements. This meant, without data, the European Commission was free to go ahead and apply the precautionary principle to ban three important neonicotinoids (and therefore “save Europe’s bees”). EFSA acknowledged these activists had undeclared conflicts of interest, but given that the word “Monsanto” was not used once in this paragraph, nobody cares (and now European farmers cannot use one of the best available crop protection tools). I still care and I do believe that hypocrites are bad people, but I am just a citizen.

9. EU-funded research programmes shall prohibit industry-linked individuals from joining projects that design or evaluate risk assessment methodologies.

The witch-hunt continues – full-frontal and unashamed. A person who did PhD research in a university that had some corporate funding (at any level of cooperation) would, under this diktat, have to be told, 30 years later: “Sorry, you are not allowed to participate in the EU research process because you are a shill“. Would an SME trying to develop a new alternative to fungicide use on potatoes not be able to share resources with the European research community? Horizon2020 intentionally tried to get industry (especially SMEs) to participate and cross-fertilise European research for very good reason: researchers need to work with innovators; technology needs investment to create opportunity; and discovery does not happen in a vacuum. That these anti-industry people actually think that burning industry at the stake is going to help EU research shows how limited and ignorant their capacity and perspective is. And what about NGO-linked researchers (should I light my torch on that one)?

10. The data requirements to assess whether a pesticide should be authorised need to be updated urgently, because major health effects, such as immunotoxicity, endocrine disruption and developmental neurotoxicity, are not adequately covered and the impacts on environmental ecosystems are severely underestimated. 11. Industry dossiers shall only be accepted into the authorisation process when all required data is delivered, including all independent peer-reviewed publications related to health and environmental effects of the pesticide. Pesticides that do not fulfil all the requirements of the regulation must be banned. 12. Formulations of pesticides as sold and used (and not just the isolated active ingredient) shall be tested and assessed for crucial endpoints (e.g. mutagenicity, carcinogenicity,developmental toxicity, and endocrine disruption) relevant to humans, mammals and all non-target species, such as bees, birds, frogs, and earthworms. 13. The cocktails of pesticide residues to which EU citizens are exposed every day must be considered when calculating “safe” daily exposure levels. Until this is implemented, an additional “safety” factor of 10 shall be applied in all pesticide risk assessments. This additional safety factor shall also be applied in the calculation of the acceptable environmental concentrations of pesticides.

Thirty years ago there were a couple biologists, statisticians and epidemiologists who made a fuss about the uncertainty of chemical cocktails, and since then the activist community has been singing the same song – everyone gets the melody but they don’t understand the words. My dinner tonight exposed me to over 10,000 chemicals, many of them combining in ways science cannot predict. My coffee had over 1,000 chemicals and of the 22 that have actually been tested, 17 of them are carcinogenic to rats. (Conclusion: Don’t feed your rat coffee!) Long-term low dose exposures to a single chemical acting to create some unknown cocktail effect does indeed sound scary but the reality is different. In those 30 terrifying years, we are living longer and healthier lives. Our food is safer than ever. According to the latest American AHS research on farm workers, farmers are healthier than the overall population. These uncertainty-mongers will not succeed, they will not raise money and they will not sell more organic food if you believe any of these facts. So they live to scare you over low exposures to safe food, of unknown cocktails and corporate conspiracies. And for 30 years, you believed these “citizens”. They have even worked it into their silly little manifesto to try to scare you some more.

C. ENABLE DECISION-MAKERS, CIVIL SOCIETY, AND THE SCIENTIFIC COMMUNITY TO SCRUTINISE THE INTEGRITY AND EFFECTIVENESS OF THE POLICY