The Risk-Monger

In the first blog, we looked at how IUCN activist scientists designed their research to follow a campaign strategy to ban systemic pesticides (neonicotinoids). The second blog looked at how these activist scientists were funded by groups with anti-pesticide and anti-industry objectives, were not quite the leading bee scientists, had unreported conflicts of interest and moved comfortably among NGOs like Friends of the Earth. This third and final blog will show how activist scientists have wormed their way onto government panels and working groups to influence the decision-making process, namely:

  • Four of the five experts on the EFSA Working Group on Bee Risk Assessment (whose advice led, in part, to the 2013 precautionary ban of neonicotinoids) are either illegitimate or activist scientists involved with NGO campaigns to ban neonicotinoids.
  • Activists on this Working Group are trying, within EFSA, to change the rules for risk assessments (to be in line with the activist scientists’ strategy) and game the system to make future crop protection approvals impossible.
  • The European Commission has conclusive research that shows bee health is not significantly affected by pesticides and still they acted to ban neonicotinoids.
  • Individuals inside the European Commission knowingly ignored their own evidence and there is a worrying indication of EU officials siding with the NGOs and activist scientists in banning the three neonicotinoid pesticides.

Last year I looked at the speed, determination and exigency of the European Commission’s imposition of a two year precautionary ban on neonicotinoids, and concluded that something smells rotten in DG SANCO (the EU unit regulating on health and consumer safety). This third blog ties up the story of the anatomy of a precautionary abuse, and it starts with activist science.

Pot calling the kettle black

Last week in a letter to the journal Nature, the IUCN anti-neonic taskforce scientific coordinator, Jeroen van der Sluijs, and Axel Hochkirch, chair of the IUCN Species Survival Commission Invertebrate Conservation Sub-Committee attacked the IPBES for including two scientists with ties to industry in a research document published by 40 scientists. (See text in Nature; CoI van der Sluijs) They are demanding that the IPBES provides information on the funding of researchers and declare any conflicts of interest. This is sweet hypocrisy and an unbelievable audacity coming from researchers funded by anti-pesticide groups who are not revealing the amount of money they receive or even the names of the members of the IUCN Taskforce on Systemic Pesticides (I will follow this up in 2015).

But they have one point right. Today, policymakers rely heavily on advice given by independent experts and external scientists. Power and influence is measured by the ability to get your scientists onto these advisory bodies. Activists have campaigned relentlessly to ensure that industry scientists are not allowed on expert advisory panels (in this case, two scientists from industry out of 40 is totally unacceptable according to the IUCN activists), but they would never raise the same stink if their activist scientists were to be involved. Bias has been built into the system, and this, regrettably, has gone up to the level of the EFSA expert working groups and panels.

Activist scientists on the EFSA Working Group on Bee Risk Assessment

There are five experts on the European Food Safety Authority (EFSA) Working Group on Bee Risk Assessment: Gérard ARNOLD, Jos BOESTEN, Mark CLOOK, Robert LUTTIK (chair) and Fabio SGOLASTRA. They are meant to be objective and independent as they consider the reports and guidance documents that EFSA submits to the European Commission. As it was upon the advice of these individuals (as well as the larger Plant Protection Products and their Residues Panel) that the European Commission decided to impose a ban on three neonicotinoid pesticides, shouldn’t someone look into the activities of these experts? The only measure EFSA seems to use to determine conflict of interest is if there is any industry involvement. But if you are paid by NGOs or use your credibility as a member of an EFSA working group to advance activist campaigns, this also needs to be considered as a conflict of interest and such individuals should immediately be removed from the EFSA panels and working groups.

So what do we know about the members of the EFSA Working Group on Bee Risk Assessment?

Gérard Arnold was the scientific coordinator of the beekeeper lobbying NGO, Apimondia. They were sounding the alarm on bee mortality in 2008 predicting that the European beekeeping industry would be wiped out within ten years. Alarmist indeed, but their numbers did not quite add up (80% colony losses in southern Germany?). Arnold was quoted in the New York Times Europe as attributing the losses to insecticides and the Varroa mite. He did not note his past employment in this NGO on his EFSA Declaration of Interests.

More disturbing is the content of some of the articles Arnold has recently published with Laura Maxim (the co-author of many reports with Jeroen van der Sluijs claiming financial support from the anti-pesticide foundations funding the IUCN anti-neonic taskforce). In an article in EMBO Reports entitled Pesticides and Bees, Arnold and Maxim argue that there needs to be a new methodological framework for risk assessments. The article shared inside information on what happened on the EFSA working group of which Arnold is a member, peppered with unrealistic data produced by the IUCN anti-neonic taskforce. There might be an argument to change the EU risk assessment process, and Arnold, as well as at least four researchers from the IUCN anti-neonic taskforce are publicly lobbying for this, but you cannot lead this campaign while you are sitting on a government panel responsible for risk assessments – that borders on collusion. One of the criticisms made by the plant protection companies (see below) is that the neonicotinoid ban was based on severe field trial risk assessment expectations from a draft guidance document which the companies could not have complied with. In other words, it seems that Arnold is already applying his political objectives while on the EFSA panel. Ironically Arnold also published an article in 2012 with Maxim entitled (from French) How Conflicts of Interest can influence research and expertise (Hermès, 64, 48-59). Note that the Risk-Monger will look more deeply into the draft bee guidance document in 2015.

Fabio Sgolastra is a post-doctoral research fellow at the University of Bologna. Seriously … a post doc? The Risk-Monger also believes in trying to find work for his students, but couldn’t the European Commission find someone with just a little more experience to sit on such a panel? While Sgolastra has only published a few articles, one of them happens to be a meta-analysis with Maria Arena. Why is this interesting? Maria Arena is a senior officer in the Pesticides Unit at EFSA. Curious.

Indicative of his inexperience is how Sgolastra has been using his involvement on the EFSA Working Group on Bee Risk Assessments to further NGO activist campaigns. Sgolastra has been involved in groups like Api-organica or Pesticide Action Network (PAN). I am totally astonished that Sgolastra, a member of the EFSA Working Group on Bee Risk Assessment, would dare to add his name and signature to an activist campaign document written by PAN North America submitted last month to lobby the US government to ban neonicotinoids. Inexperienced indeed and I wonder if EFSA has any guidance on how panel members should act in such lobbying situations. Note, to no surprise, that a majority of the IUCN anti-neonic activist scientists have also signed this Pesticide Action Network US lobbying document.

Also, like Arnold, Sgolastra has been campaigning to change the EU’s risk assessment procedures from within. It should also be noted that the IUCN anti-neonic taskforce has, as one of its main objectives, to “devise a better risk assessment protocol for government approval of new pesticides”. What better place to change the rules on how EFSA assesses risks than from inside an EFSA panel!

Neither Jos Boesten nor Robert Luttik have direct bee research experience although Luttik is the chair of the EFSA bee working group. Both have been involved in programmes on pesticides and groundwater in the Netherlands and both seem to be habitual EFSA panel sitters. From their EFSA declaration of interests, they also seem to have been working together on the same projects over many years.

Mark Clook, in my opinion, is the only legitimate member of the EFSA Working Group on Bee Risk Assessment. Note that in 2012, James Cresswell was excluded from the EFSA working group because he was involved with a project funded by the private sector and Jacoba Wassenberg because she was a member of the board of the International Commission for Plant-Pollinator Relationships. See Bee WG minutes chain.

Interesting, as an aside note, that Matthias Liess is a member of the larger EFSA Plant Protection Products and their Residues Panel but he did not declare his involvement in the IUCN Taskforce on Systemic Pesticides and his participation as an author in its publications (where financial support was involved). EFSA should not be relying on a blogger to follow up irregularities on activist scientist EFSA declarations of interest.

In conclusion, EFSA has created conditions to largely restrict itself from accessing credible research expertise, creating an environment ripe for activist scientists to enter onto EFSA panels and working groups to try to change the risk assessment approach to align with their post-normal scientific approach. But we need to ask some questions. Are these the best available bee scientists we have upon which EFSA can draw advice? Should these activist scientists be allowed to change the rules during the process? Has nobody else besides the Risk-Monger bothered to follow up on or verify their declaration of interests? Outside of Mark Clook, should the other members be allowed to stay on the EFSA Working Group on Bee Risk Assessment? I think not.

It is sad from the point of research integrity to think that Corporate Europe Observatory has gone over the EFSA declarations of interest with a fine comb to weed out those having received corporate funding in the last ten years, but if they find an activist, they give him or her a nod and a wink. But being funded by activist organisations and NGOs, or campaigning for them, is equally a conflict of interest and certainly Arnold, Liess and Sgolastra need to be removed from EFSA involvement immediately.

What did the European Commission know?

The European Commission has gathered a significant amount of research on the factors influencing bee health, and almost none of the evidence points to pesticides, or neonicotinoids in particular, as having anything to do with bee mortality.

Beekeepers and laboratories report insignificant pesticide influence on bee losses
A presentation last year by the DG SANCO head of unit for Animal Health, Alberto Laddomada, revealed statistics from beekeepers and research laboratories that did not attribute bee losses to systemic pesticides (neonicotinoids). Of the 100+ beekeepers surveyed on bee colony mortality, most of them reported diseases and viruses as causes for their losses (see Table 1). Only three beekeepers reported pesticides as a potential cause for bee mortality. One has to ask who were all of these beekeepers protesting across all European capitals just before the precautionary ban on neonicotinoids?

Table 1: Only 3 beekeepers

The second table from the European Commission was even more telling. In consulting bee laboratories across the European Union on the main causes of bee colony mortality, only one lab cited chronic exposure to pesticides (see Table 2). That must have been the IUCN anti-neonic lab. Once again, most laboratories cited diseases and viruses for the colony losses.



Table 2: Only 1 lab

EPILOBEE study attributes bee loss to cold winters, diseases and viruses
The European Commission funded a baseline study, EPILOBEE, researching bee mortality. It involved 163 bee researchers from 17 EU Member States, visiting 8572 apiaries in 2012-2013, collecting samples, data and interviews (at time of publication, 103,930 lab analyses were performed on bee samples from over 95,000 visits to colonies by 1354 bee inspectors). The study provided an excellent realistic snapshot of bee colony mortality and a solid baseline for EU policy decisions. EPILOBEE concluded that bee winter mortality rates ranged from 3.5%-33.6% while seasonal (spring-summer) colony mortality rates are below 5% in 12 of the 17 EU countries involved in the research (see Table 3). The main causes they attributed for the incidence of bee deaths were cold winters, diseases and parasites. These numbers, with a sound scientific methodology, do not, in any way, reflect the scaremongering and data that the far fewer activist scientists have been using in declaring a bee apocalypse. In short, echoing the widely cited FAO data (see Table 4), there is no evidence of a bee crisis.

Table 4: No bee colony collapse

So why did the European Commission act in line with the anti-neonic activist scientists and NGOs and why doesn’t the Commission Secretariat General act to lift the ban on pesticides? Well, as DG SANCO head of unit for Chemicals, Contaminants and Pesticides, Michael Flüh, frankly acknowledged earlier this year, the Commission knows full well that pesticides are not a main threat to bee health, but because the other problems are so intractable (climate change, loss of habitats and biodiversity, viruses and diseases, monoculture farming practices …), the European Commission had to be seen to be doing something. A pesticide ban was the easy option. So to look busy on bees, the EU has inadvertently created a situation where, to compensate for crop losses, more forests will be chopped down and meadows and other bee habitats will be ploughed under.

Nobody is that stupid, so there must be something more sinister going on in DG SANCO. Two months ago, the head of DG SANCO, Paola Testori Coggi , had to resign for essentially being too chummy with the NGOs. But if one were ever to look for a polarising, vehemently anti-industry biased EU civil servant, they would need to look no further than SANCO director Eric Poudelet (head of Safety in the Food Chain – the directorate that includes the Chemicals, Contaminants and Pesticides Unit). As one industry representative told me, “Poudelet hates industry, point.” He announced a week in advance of the EU ban on neonicotinoids in the European Parliament that the Commission would have to “act straight away” . To many in Brussels following the pesticides ban, Poudelet is seen as the driving force of this legislation without legs.

It should be more than just a mild curiosity that the European Commission called for the precautionary ban on neonicotinoids on 31 January 2013, while just the very day before, on 30 January 2013, EFSA top management and DG SANCO hosted a meeting with leading anti-pesticide and anti-GMO bee activist NGOs (including a member of the IUCN anti-neonic taskforce, Noa Simon Delso, representing her NGO, European Beekeeping Coordination). I wonder what they talked about? There needs to be a full internal inquiry into how EFSA and the European Commission have been captured by these activists.

I understand that the new Commission is still settling in and that the internal authorities in the Commission Secretariat-General are not ready to ruffle any feathers in-house. Also, given that the first move by the new President of the European Commission, Jean-Claude Juncker, was to banish any independent scientific advice from his office, I can only conclude that we are heading into a period of sustained scientific ignorance. The only thing that could be done is to take the European Commission to court.

Kangaroo court

There is an ongoing court-case between several crop protection companies and the European Commission. The anti-farming NGOs are trying to portray it as a battle between the evil chemical industry and the rights of citizens and the environment (including bees) to not be poisoned. Nice PR flip, but the reality is that the European Commission has allegedly broken the law. Let me put it into an everyday illustration.

Imagine you are driving to work one day and a police officer stops you and informs you that your car is no longer compliant. While you insist that it is, he explains that the law has changed overnight and he then takes your car away from you. You get even angrier when you get home and discover that the hitherto unknown law the police officer referred to was only a draft proposal and had not yet been voted on. Wouldn’t you take the government to court to get your car back?

This is more or less what happened with the precautionary neonicotinoid ban. There was a draft guidance document for bee field trial test procedures that had not been approved. The EFSA experts, including the members mentioned above, used this unapproved draft document to conclude that the safety data provided by the crop protection companies under the existing legislation was insufficient. In other words, they took their car away without legal grounds.

We should add a couple other points to the analogy: As the police officer was taking your car into the station, only a minority of the other police officers supported that decision (call this the European Council), but still he insisted. Furthermore, you then discover that the experts who proposed the draft rule had clearly established interests against you (the activist scientists).

That the NGOs are trying to foment rage for an action against the crop protection companies for “seeking to get their car back”, something that any normal person would do, is irresponsible and disingenuous. But a great emotional campaign opportunity nonetheless.

It’s about the farmers

Now remove the word industry from the last paragraphs and insert the word farmers. Do you think farmers enjoyed waking up on 1 December 2013 to find that they no longer had the tools necessary to do their job? Do you think they like that the decision was made arbitrarily without consultation by a group that could not care less about their interests? After a year of crop failures and a failed precautionary principle application, the farmers should be the ones taking the European Commission to court. Sadly, the farmers have no leadership in Brussels, no voice and no serious representation. It is only the chemical industry fighting their corner, and nobody in Brussels cares about their interests.

In the Brussels Bubble, we sometimes forget that there are real people with real jobs involved. It is not about Friends of the Earth and Pesticide Action Network vs the chemical industry; it is not about some activist scientists with the IUCN vs the scientific mainstream; nor is it about the European Commission Secretariat-General trying to twist logic to defend the antics of Mr Poudelet in DG SANCO. It is about the farmers and their ability to have the tools to protect their crops. It is about food security and affordable food for EU consumers. It is about the ability of European agriculture to be able to feed European consumers and stop depending on imports from countries in Africa which may themselves have food security issues. This is indeed a moral question and the games played by the activist scientists in EFSA and in the IUCN should be held in this light.

In short, crops are failing in the first year of the neonicotinoid ban and farmers are suffering, the anti-neonic scientists are tainted by politics and conflicts of interest, the EU’s own science on bee mortality does not raise alarm-bells and the European Commission itself admits that last year’s legislation banning neonicotinoids would have no significant effect on bee populations.

So why the hell are we still having this discussion?


Author :


  1. « It’s about the farmers »?

    Yes, but it is also about bees.

    Firstly in terms of exposure to pesticides other than neonics that are required as a substitute to control pests.

    Secondly in terms of foraging if (as is likelynext year) OSR is replaced by other crops providing no food for bees.

    1. Too true Wackes – I was considering what goes on in Brussels – a city I once referred to as a town where nobody works and where the only bees you’ll likely find will be carrying a protest banner. I sincerely hope that the Commission finds reason before the next planting season but I expect that the starvation of the bees will be used as a means to justify a permanent ban on neonicotinoids.
      What I don’t get – and this is speculation here – is why the anti-pesticide arguments have always focused on the least logical angle. When I was a child (more than 40 years ago) we used to carpet-bomb the soils with some hostile chemicals, and people were campaigning against MRL exposures (annual toxic equivalent ingestion below that of a single cup of coffee). Industry finds a solution to reduce the risk to the environment and campaigners get all over it. My speculation is that internal fear polling showed that individuals reacted more to chemicals in their bodies (even at insignificant levels) than to the environment. And for a long-term strategy to remove pesticides completely, any improvement in pesticide technology (to reduce real risks to the environment) would be a threat to their winnability. So the fact that farmers have to revert to older pyrethroids is music to their ears. Otherwise, I cannot understand their logic.

  2. Risk-Monger.

    You’re not improving. What you “report” here is

    – very serious accusations on individuals for which you have no evidence : scientific fraud (nothing new here, cf. your responses to my previous comments) or, in the case of this Poudelet guy, anti-industry bias (“one industry rep told me…” what is that for a source! don’t you at last have a reference to a public comment or a document??).

    – very serious accusations against EFSA’s hiring practices (systematic exclusion of industry) which you build from two cases within a working group of five (and we won’t know anything about the composition of the broader pesticides panel which also looked at this) whereas EFSA employs thousands of experts,

    – very serious accusations against the Commission (that they ignored their own research) whereas the EPILOBEE project did not study at all the impact of pesticides on bee health and your table is the answer to a mere survey of a few dozens of beekeepers…

    The only bits I found interesting in your piece were the missing bits in these experts’ declarations of interest (does the EFSA still not check anything there after all the scandals they had?) and the section on farmers, who, as usual, pay the price several times, first for being forced to use these neonics because pests have become resistant to everything else, second because indeed now they’re screwed.

    That makes it for two valid paras in this long, long text. Pardon me but: as far as I can see you’ve written a nice story which will content paranoid minds and the pesticides industry, but that is essentially only that: a nice story. Doing quite exactly what you reproach these guys of doing, actually: story first, piecemeal and incomplete evidence afterwards. Unless you would have additional material which would substantify your criticism, seriously this time?

    1. Sorry to disappointed you Sue. EPILOBEE first and foremost showed that, outside of cold winters, bee mortality rates were not significant (less than 5%). How does that not impress you? No one from the IUCN taskforce, to my knowledge, have used this report – EPILOBEE has tested over 100,000 samples to date in 17 EU countries – it is a general bee health study – if we only focus on pesticides, then we have worked bias into our research and should not be surprised to get biased results.
      I worked for industry 9 years ago – I am excluded from EFSA – even scientists that have worked on projects funded in part by industry are excluded (see the EFSA minutes I included). Why do you think they have to find inexperienced post-docs to sit on these important expert panels. Are you telling me it is fair that people receiving money from anti-pesticide organisations, or involved in NGO campaigns can sit on EFSA boards (and design guidance documents to screw industry) and those who have worked with companies that innovate and create valuable technologies and services are treated likes rapists? The last two blogs have tried to highlight this hypocrisy – I am not sure why that did not impress you.
      These are serious accusations because these activists have done some serious things. I look forward to them challenging me because they will then have to defend their actions – normally they think they can behave in an unchallenged manner. Perhaps because they have been able to get away with it.

  3. This is the message I just sent to EFSA :

    « Over 97% of foods in EU contain pesticide residues within legal limits »

    Madam, Sir,

    Are you sure your title reflects reality?

    Among the 97 % that allegedly « contain pesticide residues within legal limits », there 54 % which contain no detectable residues.

    I would suggest a correction would be more than appropriate.

    Best regards,


    Not totally unconnected with this article. A previous EFSA press release contained patent discrepancies between the three versions.

    How will Joe Sixpack read the title? O Gee! Over 97% … contain…

  4. Is it really fair to equate industry scientists with NGO scientists? The former work for commercial bodies whose aim is to sell more product. The latter work for organisations whose aim is to protect the environment. That includes minimising or eliminating the use of harmful chemicals.

    You calling NGOs “anti-pesticide groups” shows up your bias.

    Secondly, it’s disingenuous to suggest that anyone is saying that NEONICS KILL BEES. It’s more complex than that. If a bee has been weakened by a chemical, but then succumbs to a pathogen or parasite, it’s recorded as a death by parasite. But would it have survived without the chemical exposure (or, indeed, the loss of its favourite flowers)? It’s all part of the matrix. The presentation and report you link to talk about these interdependencies, they don’t exonerate pesticides

    1. Thank you for your comment SG – you might be surprised to learn that I do not disagree with you at all, but that we are approaching the question from different perspectives. I am not defending industry scientists – in an earlier blog, on Who is a scientist, I joked that industry scientists don’t matter at all in the equation – they have been firmly ostracised from any decision-making processes – even if there are no other scientists or individuals with field trial experience. I think there needs to be a recognition though of the double-standards here. What is the difference between a for-profit researcher whose salary and funding are paid by industry to come to certain conclusions and a researcher who is paid by a foundation or organisation (like Triodos or Adessium) aimed at reaching their desired conclusions? Hint, one of the two groups of scientists sign an ethical code of conduct and is obliged to follow Good Laboratory Practice and the other group thinks that “protecting the environment” is a noble enough gesture to avoid public scrutiny. By the way, calling these NGOs anti-pesticide is not bias – PAN exists to remove pesticides. The anti-pesticide organisations I referred to are banks promoting organic farming and food (a business decision) who have found a group of scientists who agree with them and have paid them to provide a base for policy change (which will benefit their client base – I don’t know if you read Dutch or German, but go to those banks’ websites and see where their markets are). What is the difference between what Triodos is doing and what Exxon-Mobil did by funding some scientists they agree with? We all want facts to align with our beliefs, but it doesn’t give us the right to assume double standards. The activist scientists, who are very politically active, need to be excluded from decision-making processes just as industry scientists are (or change the process).
      Now, the question of the quality of the science then comes up (my previous blog showed how they could not publish their work in a high-impact journal, but rather in one with a very dodgy peer review process). I don’t see the IUCN bunch campaigning for research into Varroa or parasites – they all focus on one issue only – so we agree that it is disingenuous and still they put neonics front and centre (just read the titles of their books and their predictions of a biodiversity Armageddon!). I agree with you that bee mortality is complex and involves many stressors – most important according to the tables and studies released by the European Commission being weather, diseases and parasites. We should also add loss of habitat and monoculture farming. The tables show how the mainstream scientists consider systemic pesticides as minimal. But by banning neonicotinoids, crop losses are up significantly – especially in oilseed rape – next year farmers won’t plant this pollen-rich plant, further weakening the bees, or ploughing under more meadows and bee habitats to compensate for crop losses. Tell me how this makes sense?
      You want to believe that I sleep with a jar of pesticides under my pillow. Fine, I cannot change what people want to believe. I grew up on a farm – I know pesticides are dangerous to use, have consequences on the environment and cost a lot of money. I also know, despite the cute attempts by Dave Goulson, that they work! So industry have introduced neonicotinoids because they are more effective with less harm to the environment. Removing them only means we go back to the older, much nastier pesticides that are less effective (as they did this year with the OSR crisis in the UK). You think I am exonerating pesticides – I think I am being rational. We have different perspectives but I appreciate the chance to engage with you.

Leave a Reply