Many environmental activists, some politicians and a handful of newspaper editorial writers have long been in a collective swoon over the way the European Union defers to the precautionary principle when regulating chemicals. The idea has a certain intuitive appeal: why not ban something if there might be a risk?
To many, if not most, scientists, the principle is irrational and unscientific: you can never prove something is safe with 100 percent certainty, and you need to balance the risks of banning something against the risks of not banning something. There are always two sides to this equation, and what seems, intuitively, to make sense may result in consequences far worse than the problem you were aiming to address.
This could well be the result if the European Union decides to push ahead this year with introducing the precautionary principle into regulating pesticides, switching the way they are regulated from risk to hazard assessment. This means that instead of having to demonstrate that the pesticide in question poses a high probability of being actually toxic as it is used, it simply needs to be demonstrated in a lab as having the inherent potential for toxicity. The problem is that both these concepts are interrelated: just when does the inherent potential for toxicity turn into a measurable probability for an adverse effect? Everything is poisonous if you consume enough of it – but that doesn’t mean everything is poisonous in the way that we use or consume it. Naturally-occurring pesticides in plants can be every bit as toxic as synthetic pesticides, but that doesn’t mean we are being poisoned by the presence of either.
But there is a more immediate problem: the United Kingdom is refusing to endorse the legislation because the EU hasn’t conducted an impact assessment of the regulation on food production. As the U.K.’s regulatory body for pesticides, the Pesticides Safety Directorate (PSD) notes,
“Without such an assessment, the EU risks taking measures which would have significant adverse impacts on crop protection but secure no significant health benefits for consumers.”
The United Kingdom’s objection is not merely theoretical. The PSD’s conducted an impact assessment of what the new regulations could mean for British agriculture and its analysis is alarming: 15 percent of current pesticides could be banned resulting in 20 to 30 percent yield losses for cereal crops. The PSD warns that:
“If the full potential impact of the current Parliament proposals were realised, conventional commercial agriculture in the UK (and much of the EC) as it is currently practised would not be achievable, with major impacts on crop yield and food quality.”
One of the key scientific problems the PSD has with the European Union legislation is that it stresses the need to protect people from endocrine disruption without offering “study guidelines” or “assessment criteria” for determining what chemicals, realistically, are likely to cause disruption. The absence of scientific clarity here could mean that triazole compounds , the leading fungacide for treating the major disease in wheat, could be banned, with a potential for 20-30 percent loss in crop yields. The PSD identifies numerous other front-line fungacides, herbicides and insecticides which might be banned and for which there appears to be few if any alternatives presently available.
The other problem identified by the PSD’s impact assessment is that if the European Union dramatically reduces the range of chemicals currently available to farmers, it could undermine resistance management and pest management. If farmers have a smaller arsenal of weapons against crop diseases and pests, these weapons will have to be used in ever greater quantities, and that will speed up resistance in both. The effects could be devastating beyond Europe, says the PSD:
“The scale and magnitude of the potential losses, particularly from the [European] Parliament’s proposals, would undermine both resistance management and IPM [Integrated Pest Management]. The former could also have implications for pest management on a global scale if resistance strains selected as a result of intensive use of surviving active substances spread from Europe, either directly or via the transport of plant material or food produce.”
In other words, in order to protect the public from what might be purely hypothetical risks, the EU could not only cripple European agricultural output but endanger the world’s food supply at the same time.
If that sounds overblown, it is entirely in keeping with the logic of EU regulation – using the precautionary principle to evaluate the use of the precautionary principle. After all, the most important thing to remember about precautionary thinking is that it is inherently hazardous.