The Risk-Monger

Dear Dr Flüh

Congratulations on your appointment as acting director responsible for bee-health in DG Santé. Your predecessor who had campaigned long and hard against the chemical and biotech industries, and had refused any semblance of dialogue, unfortunately has left you in a very difficult position with very little room for compromise on the neonicotinoid temporary ban that is coming up for re-evaluation this year.

Excuse me for writing an open letter to you, but as I had worked for industry nine years ago, I understand that if I had sent this letter by email, you would have had a problem with anti-industry lobbyists who would attack you for even answering my mail. In the interest of transparency, please feel free to reply in the comments section.

So where do we stand at the moment with the neonicotinoid pesticide ban that is coming up for review later this year?

  • First, the precautionary ban was rushed through in record time (less than four months) without an impact assessment and despite a large number of Member States voting against it. Kudos to your predecessor, he was good at getting what he wanted!
  • Secondly, the ban was based on advice that the EFSA bee Risk Assessment Working Group gave following their proposal to change the rules on how field trials must be conducted. This bee guidance was never passed or accepted, and yet the neonicotinoid ban was justified upon this new, unworkable field trial guidance document. It should come as no surprise that this EFSA Bee Working Group has members who are either environmental activist campaigners or experts with no bee research experience (no industry bee research was considered). As this EFSA panel has been corrupted, I strongly suggest that you get the SecGen to concentrate on fixing that rot.
  • Your own science is not at all critical of neonicotinoids in relation to bee health. The Epilobee study was very comprehensive and concluded that where there were reported bee losses, it had to do with weather factors (like cold winters). Another study presented by the European Commission surveying bee researchers concluded that beekeeper error was a main problem … and not pesticides, but as your predecessor who left you in this mess was an amateur beekeeper, I suppose he chose to ignore that data. The mainstream research community is fairly certain that where there are stressors on pollinators, it has to do with colonies being exposed to the Varroa mite.
  • Many activists have received funding from organic food groups and anti-industry organisations to try to create evidence of a bee-mageddon to further their campaign against pesticides. Myself and others have exposed their activist science as less than credible, politically driven and lacking in integrity. Look at how the mainstream scientific community treats these politicised campaigners and ask yourself if this is whom you would like to align yourself and the European Commission with. Sadly your predecessor had been encouraging these groups and have left you with a cynical scientific community to draw evidence from. Even EASAC who have just released their report complained about the nature of the question your office had tasked them with (assuming a misleadingly biased question directly trying to link pollinator health only to neonicotinoids) and their report ended up saying a little of everything and a lot of nothing. It is shameful how science has been abused throughout this episode and you have a lot of work to clean this mess up.

I sympathise with your challenges Dr Flüh and you, yourself, have even admitted that the ban on neonicotinoids would do nothing to improve bee health, but given that the other main causes of potential bee decline (climate change, biodiversity loss, viruses and diseases …) were impossible to solve, acting against pesticides was the one thing your office could do to attempt to address the problem. While I appreciate your honesty, I beg to disagree.

Pretending to look busy while being aware that your actions on banning neonicotinoids would have no positive consequences is a common malaise of regulators who rely on the precautionary principle to try to wish difficult issues away. Such actions by your directorate do indeed have serious consequences (to bees, farmers and consumers) and now it is up to you to face this reality, which you honestly acknowledge, and clean up the hornet’s nest your predecessor has left for you.

Farmers matter

We saw, in the first year of the precautionary ban, a sharp decline in oilseed rape production levels in countries where there was no neonicotinoid derogation (like the UK or most recently Germany). It is likely that less oilseed rape will be planted next year, meaning there will be fewer pollen-rich crops available for bees (leading to a weakening of bees and a further stress on colonies).

But this sorry story is not about bees at all – it never was. Face it, the NGOs are only hyping up this useful opportunity to accentuate their campaign against pesticides and industry (if rats were suffering from pesticides we would all be reading texts about how important rats are to the food chain). There is ample data that acknowledges that there is no honeybee crisis (read the EASAC report carefully – they admit that) meaning the activist hype is getting very tired.

Rather, this is an issue about farmers and the means provided to European agriculture to protect crops and produce safe and secure food and feed. Your directorate’s precautionary ban on neonicotinoids (done quickly to appease a French coalition, without an impact assessment and without proper consultation and dialogue) has increased the challenges and hardship for European farming and it is up to you to address this. Have you listened to any farmers this week, Dr Flüh?

I grew up on a farm and know very well the challenges involved year-round of sowing and bringing a harvest to market. Farmers are the ultimate risk managers, facing the elements, the environmental stresses, the risks of pest or weather-related diseases … It is a constant battle and farmers must use all of the tools in their arsenal to avoid crop damage, loss of production or poor quality. Farmers face the risk of failure every day and need the support of regulators, researchers and companies to help them succeed. Nobody likes failure, but when farmers fail, the consequences on society, food safety and secure food supplies can be devastating.

Your directorate has not been helpful to farmers at all, and while we can still afford to import food from other continents and compensate farmers for losses, you are encouraging an agriculture founded on inevitable failure. That is not how farmers think – they work hard to succeed and perhaps you should consider how your actions can affect them. When a crop is lost, it hits home as if it were a child lost to the elements. If you like, Dr Flüh, I would be pleased to take you to a farm, let you speak to people whose lives you are affecting with this ban … a ban that you yourself have admitted will not change anything.

I know that environmental activists have your ear and every day they are telling you how farmers are stupid, that they do not care about dumping poisons on the land and don’t even realise that they can farm just as well without using all of those expensive pesticides. These activists are cosmopolitan idealists who merely want to win heavily funded campaigns and bash industry – the only farms they have ever seen are from their first-class window seat at 10,000m in the air. Then they find a bee-keeper who did something stupid to the hives and they march him or her to Brussels with promises of compensation. Don’t pretend you haven’t seen their disgraceful antics. It is a game to them … it is no game to the farmers who are badly struggling as a consequence.

It should be noted that farmers are also generally not supportive of the chemical industry. The crop protection materials are expensive and are hazardous to use so you will rarely find farmers standing side by side with the industry that the NGOs are really campaigning against. If they could farm with fewer pesticides, they would. If they could defend their crops against pests, fungus, mould, rampant weeds without modern day measures, keeping their soil strong and productive, they would. But they know that they need any and all tools in their arsenal to avoid failure, and this includes the best and most innovative pesticides.

Neonicotinoids have made farmers’ lives easier – using less pesticide (avoiding hazardous risks to the farmer and the soil) and saving the farmer money. This is why the anti-pesticide activist groups have thrown everything in their PR war chest at banning neonicotinoids – neonics work, are better for farmers and the environment and legitimise crop protection methods – the environmentalists’ worst nightmare. NGO activists do not care about farmers – they care about getting crop protection materials off the market so everyone can eat organic like them (at a great cost to everyone).

And ironically, by removing neonicotinoids from the farmers’ arsenal, you have made farmers more reliant on less performant, more toxic, older pesticides – the farmers will try the best they can, but you are reducing their profession to a hopeless task framed for failure. A curse on the farmers from your predecessor that you should not proudly uphold.

Your observation that banning neonicotinoids would have no effect on bee health, Dr Flüh, does not mean that there would be no effect from your directorate’s short-sighted, highly reactionary decision. Farmers matter far more than any cranky NGO activists with big budgets screaming outside of your window. Your predecessor chose not to consider farmers but you have a chance, this year, to set things right, to ignore the loud-mouthed campaigners and their corrupted activist scientists and do something positive for European farmers, consumers, the environment and, yes, the bees.

There are legitimate scientists out there, normal and professional beekeepers, hard-working farmers … all with something to say if you would care (dare) to perform an honest impact assessment. Listen to the right people Dr Flüh and this continuing crisis will not bear your name in the book cataloging the EU’s greatest precautionary fails.


Kind regards


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