See the French translation.

Last Friday, the EU Standing Committee on Plants, Animals, Food and Feed (PAFF) voted through the European Commission’s proposed ban on all outside applications of three main neonicotinoids (imidacloprid, clothianidin and thiamethoxam). This capped off a four-year ordeal which pitted industry and farmers on one side and activists and the organic food lobby on the other. The European Commissioner for Health, Vytenis Adriukaitis, celebrated the vote as evidence of the consistent use of science in EU policy. It was nothing of the sort, and the sad thing is that the Commissioner knows this.

It was never about the science

The EU Commissioner for health knows full well that pollinator health is a complicated issue and he has some of the best scientific advice at his disposal … that he managed to completely ignore.

His own DG Santé (then Sanco) directors were presenting evidence at the time of the first neonic ban that contradicted the claim that pesticides were a significant risk factor in pollinator health. The Commissioner had funded several Epilobee studies that performed comprehensive surveys of pollinators across Europe and concluded there was no decline in overall honeybee hive numbers, and where there were declines, it was due largely to cold winters.

Andriukaitis very publicly said he was waiting for the Commission’s Joint Research Centre (JRC) to publish its findings on the effects of the provisional 2014 neonic ban before making a decision over the permanence of the ban.

The JRC report was leaked last year and the findings were stark: farmers were by and large forced to use older pesticides, sprayed more frequently, most having a more harmful effect on pollinator health. Farmers costs and time were increasing and they needed to spend more time walking through the fields for early warning signs of insect infestations. This is code for: “plant something else next year” meaning there would be less variety in the crop rotation and thus less sustainable soil management.

By the time the JRC’s review was completed, the evaluation was renamed a “study” so the Commissioner would not need to comment on or even publish it (they could just ask the JRC to go back and study some more!). I sadly see no evidence to suggest that anyone of any importance in DG Santé had even bothered to read the excellent JRC “study” or the paper published last year. In any case, the situation had changed by then – Andriukaitis was ordered to ban all neonic applications (not just the ones that might affect pollinators) so the JRC study seemed just that little bit “uncomfortable”.

I am mystified trying to understand why Commissioner Andriukaitis, with clear evidence from the JRC of a failed precautionary ban to save the bees, would then turn around and propose to ban highly advanced crop protection tools for non-flowering crops like potatoes and sugar beets. Both are essential agricultural staples European food manufacturers depend on; both are less likely to be grown with less sustainable agricultural tools. See a sugar beet farmer explain why seed-treated neonics are essential and there are no comparable alternatives.

Maybe by science, Commissioner Andriukaitis only meant the European Food Safety Authority (EFSA).

Policy-driven Science: How to exploit an agency

EFSA’s assessments on the three neonics were an excellent case study into policy-driven science: of creating conditions to force the science to justify a desired position. Almost a decade ago, then DG Sanco director, Eric Poudelet, an anti-industry, amateur beekeeper, got EFSA to set up a bee risk assessment working group to draft a guidance document to determine how data should be collected for pesticide field test trials.

We know today (including EFSA’s top management) that this small external working group had three anti-pesticide activists working on what became known as the Bee Guidance Document (BGD) – one of whom, Gérard Arnold, hid his conflict of interest and tried to cover his online tracks.

Unsurprisingly, the BGD was made to be so ridiculously strict in its conditions that any field tests where bees were exposed to pesticides in real situations could not comply with the BGD requirements. It demanded a bee mortality of 7% during trials (normal average bee mortality is 15%) and insisted researchers track the bees over fields of at least 168 km² … a contiguous field too large to imagine in Europe!  Thus, all field data produced by industry in the previous risk assessments were rejected as inadequate (what the BGD was designed to do) and EFSA was only left to consider the data supplied by lab feeding tests, where a number of bees were kept in a small cage and fed pesticides. Based on insufficient evidence of merely lab feeding test results, EFSA could only recommend precaution on neonics.

Now it gets worse. The horridly corrupted Bee Guidance Document was never accepted by the Member States – the conditions were too severe and irrational. This means that the EU decision to ban the three neonics in 2014, following the draft BGD, was not based on any legitimate (legal) document. We are still waiting for the results of the case brought against the European Commission by Syngenta, BASF and Bayer. EFSA’s director, Bernhard Url, went so far as to admit in the European Parliament that he was being told to use the unusable Bee Guidance Document in his assessments of the three neonics. Why would a European Commission official speak so openly against the policy of his hierarchy if he were not begging for this madness to stop? Url is responsible for the reputation and global credibility of EFSA.

Sure enough, with the draft BGD as the determinant of evidence to be allowed in the EFSA risk assessments, EFSA’s policy-driven science was manipulated according to design. Commissioner Andriukaitis knows all of this and yet he praised the Standing Committee for following the science-based policy proposed by his office. That poor soul must just be counting the days until the end of the Juncker Commission when he can go back to a world that respects the scientific method.

It gets even worse! The DG Santé director once responsible for bee health, Michael Flüh, went so far as to admit that banning neonics was not going to help bee health at all. But the other stresses (climate change, biodiversity, Varroa mite …) were just too difficult to solve, so by banning neonics, the European Commission managed to make themselves look busy working on the issue. Yeah, and the European Commission just last week has managed to make themselves look like a band of idiots on the global stage.

The sad thing is that if the Commissioner had really been committed to science (and not just making friends with activists in bee costumes), he would have directed funding into how to deal with the Varroa mite issue (what most credible entomologists acknowledge to be the main stress on bee populations), how to improve overall bee health through biodiversity strips which industry had been proposing and how to improve education and communication among the burgeoning class of European amateur beekeepers. Instead of helping improve bee health, Andriukaitis played politics with the anti-industry activist lobby and gave in to their demands to ban a class of modern insecticides with an excellent sustainability profile. Everyone knows this activist campaign was not about saving the bees (and that the consequences will likely be far worse for pollinator health).

Even Commissioner Andriukaitis knows the neonic ban was not about saving the bees. He said that in the European Parliament.

It was never about the bees

The bees were never under any threat and the great NGO beepocalypse is just one more textbook fabricated crisis the activists used to launch a campaign, create fears and raise funds (the Risk-Monger is considering writing a history documenting overblown manipulative activist fear campaigns called: “Late Lessons from Zealot Warnings”). A bit of history on this most recent activist deception.

Before any perceived bee calamity made headlines, activists were critical of neonics as seed treatments claiming they violated the spirit of integrated pest management (only using pesticides when all other crop protection measures had failed). But given how seed-treated insecticides dramatically reduced foliar spraying and only targeted insects attacking the plant, such applications were more sustainable and effective. It could be said that seed-treated neonics made conventional farming more sustainable than organic farmers forced to use multiple pyrethrin applications (worse for bees and the environment). No wonder the organic food industry lobby poured millions into the anti-neonic campaign.

Then came what those in the anti-industry activist lobby would call a “stroke of good luck”. Since 2006 there have been several outbreaks of honeybee colony collapse disorder (CCD) affecting both professional and amateur beekeepers (with many factors but largely attributed to Varroa mite outbreaks).  In Germany in 2008 there was a significant bee die-off following a mistaken release of neonic dust during planting. This was the smoking gun the activists were searching for and they then set out to create an “End of Days” perception if we continue to use neonics. They even imported a warning from none other than Einstein about the end of humanity and by 2013 got Time Magazine to make it real! A year later, and only a few months after the EFSA assessment, the European Commission rushed through a precautionary ban.

Around the same time, a group of post-normal scientists (essentially sociologists annoyed at not being treated like real scientists) and a few fringe entomologists got together and decided to form a union of bee experts. They set up the IUCN Taskforce on Systemic Pesticides led by Jeroen Van der Sluijs (who previously had been a climate change expert). Getting funding from the organic food industry lobby, this group set out to publish a series of articles that would show that neonics were responsible for the bee declines the NGOs had been forecasting. Some blogger in Brussels then exposed how they were not using a very scientific method, and not much was said about them for a couple of years. Then they got some financing from the activist groups like David Suzuki Foundation and SumOfUs to cover the cost of publishing in pay-to-play journals, but not much was discussed about their positions (unless you follow SumOfUs).

When honeybee populations were not going down in the numbers that had been prognosticated, in fact hives were increasing, the activists then switched to the argument that neonics were a threat to wild bees. Since we really had no reliable numbers on them at all (or even how many species there were), the activists could then say whatever they wanted. Some poor correlation research relying heavily on volunteer bee-watching associations was published and that was enough for activists to keep saying: “Neonics? Bad for bees!”

But in reality, the activists really didn’t even need to bother with the science. They just needed to stick to their playbook and keep repeating the following:

• This is a pesticide manufactured by big industry;
• We really don’t know with certainty what it does to bees;
• The “poisons” are used by conventional farmers. We can all easily farm with agroecology;
• We are going to keep protesting until you ban it!
• Oh, and not that it matters, but here is some research we funded and published on our website.

Who in Brussels was going to stand up for farmers, scientists or consumers when a couple dozen activists show up on Place Schuman in bee costumes? If any regulator were to consider common sense, he or she would be accused of being in the hands of industry. Not worth the bother.

No Consultation inside the Commission

What is remarkable here, and I have written on this before, is how the Juncker Commission has abandoned the inter-service consultation approach to policy management. I had spoken to a civil servant from DG Agriculture who acknowledged the potential threat to soil health in the EU if farmers take too many crops like sugar beets out of their rotation. EU Commissioner for Agriculture, Phil Hogan, has defended neonics on several occasions. But DG Agriculture, the voice of farmers, is mute in this discussion. It is DG Santé alone who has jurisdiction here and their mandate is uncompromising: to protect the health of humans and animals.

If there is a remote risk to bees, then DG Santé is single-minded in its mission: protect them at all costs.

• If that means hundreds of millions of euros added to the consumers’ food budget, so be it.
• If that means destroying farmers’ means to successfully farm and feed Europeans, so be it.
• If that means damaging the environment through farmers spraying older pesticides, so be it.
• If that means limiting the potential crop rotations and depleting soil nutrition, so be it.

DG Santé’s responsibility here is solely for protecting bee health.

This, of course, is madness when you consider that it is only a remote possibility that neonics are harming bees (and Europeans are going to thus sacrifice our means to produce food, manage an economy and allow for sustainable consumption based merely on a “what if”). On twitter several activists have been feeling quite proud of themselves on my feed, saying how they saved the bees, adding that even if it is not the only issue, we have now removed a potential stress on bees. OK … car emissions also stress bees so let’s ban all cars. Electromagnetic fields can affect bees so, following this Age of Stupid logic, we must ban power lines and mobile phones. The only difference is those hypocritical zealots like their cars and phones … so farmers got thrown under the bus … for a “what if”.

But then again, maybe DG Santé’s real mission is to just get through difficult legislation as easily as possible. There was a rumour going around Brussels that the proposal for a total ban on neonics was part of a compromise deal with the French for the extension of the glyphosate authorisation. This would be pure nonsense: “I’ll trade you one herbicide in exchange for banning of an insecticide”, but then again nothing in Brussels at the moment makes sense (nor in France for that matter).

Who failed whom?

Clearly there was a failure in leadership, not just in DG Santé, but at the head of the Commission.  A non-evidence-based policy was pushed through to appease special interests in Member States and among a flimsy coalition of activist groups. Farmers and consumers were not represented in the process and scientists were not consulted. EFSA had its hands tied, forced from above to use an illegitimate Bee Guidance Document that was a lamentable example of bad policy-driven science (a strategy of forcing science through a sieve for the purpose of justifying some politically-motivated regulatory malice).

Without any inter-service consultation, large European stakeholders were not represented. The European model of engagement has been replaced by Selmayrean shadow deception. In this case, since it was the pesticide industry, there was no interest in regulators being held accountable. Activist scientists behaved badly, spreading bad research funded by NGO groups while feeling no qualms over lying about the risks to bees and the environment. The entire five-year attack on a technically advanced insecticide family has distracted EU debate and funding on the real issues affecting pollinators. Farmers were left on twitter trying to explain to a disinterested pack of zealots why these insecticides were essential. The organic food industry lobby funded campaigns and scientists to continue the deception and fabricate fear at apocalyptic proportions.

In the vacuum of leadership, irresponsible and unethical actions flourished.

And will the bees be thriving when Commissioner Andriukaitis gets back to work this Wednesday? Hardly. Nobody in Brussels, no less the good doctor, ever believed this was about saving the bees. And this is where Brussels is losing its legitimacy. The precautionary principle allows civil servants to act without accountability. Leaders make decisions that, while unpopular, are right and in the public interest. Cowards make decisions that are expedient and avoid any risk of being judged. Precaution is a policy tool for cowards. Next year, when we will have a new EU Commissioner for Health, how many of us will go back to 27 April 2018 and judge this decision for the negative consequences it no doubt will produce … for farmers, consumers, the environment and, yes, for bees?

The Risk-Monger will.

After five years of writing on this, around two dozen blogs and several threatened lawsuits, I once again am feeling rather lonely in Brussels. For the second time in six months, I find myself apologising to European farmers even though I am not in any official channel representing them. People have a right to be furious.

But I am not angry at the expedient cowards in official positions. I understand how the activists are biased to the point of feeling they can justify their lies and cherry-picking. I get that there are many under-employed and unappreciated scientists who were attracted to the attention and money from the NGO anti-pesticide community. I have long given up on the organic food industry lobby ever adopting or following an ethical code of conduct. I am not surprised by any of the bullshit these groups can claim responsibility for.

What surprises and disappoints me is how the food manufacturing industry sat back and did nothing as the farmers who supply them got strangled by the naturopathic cult machinery. The big food companies depend on a reliable supply of agricultural yield to produce the food Europe is famous for and yet, to my knowledge, not one of them stuck their neck out to defend farmers and the tools they need. The word “neonicotinoid” did not appear once on the FoodDrinkEurope website nor among their main members.

Perhaps the food industry doesn’t think the plight of European farmers is important. If costs go up, so will their margins. If European farmers can no longer farm, will Nestlé and Danone simply import more food from another continent? Were they so afraid of how a small band of activist zealots might activate a twitter storm on their brand pages that they decided to step back and pretend that evidence did not matter? Would they rather sell unsustainable food than try to educate European consumers on the science behind reliable crop technologies? In their hunger for higher organic margins, are food manufacturers willing to see those less fortunate go hungry?

These are the real cowards … and they’re disgraceful!

As the European neonic saga closes, the real victim is leadership. Europe has made failure its objective, cowardice its political virtue and ignorance its culture.