The Risk-Monger


There are two toxic pesticides: Rotenone and Azadirachtin, that need to be banned in order to ensure the safety of humans, bees and the environment. There is insufficient data on either of these toxins yet they are tolerated on American and European markets merely because they are natural bio-pesticides used by organic farmers. A toxin, whether naturally or synthetically produced, is still a toxin with the intended purpose to kill and the evidence is clear – these natural chemicals kill. The hypocrisy of regulators and the organic lobby to come down only on the well-tested synthetic pesticides and look the other way on natural toxins because of the noise created by the green activists is another toxic disease that must be controlled.

Rotenone: Killer of Bees, Fish and Humans

Rotenone is a highly toxic bio-insecticide coming from a natural source (from seeds, stems and roots of several plant species) that is harmful to humans and animals, particularly aquatic species, and the environment. Research has shown it to contribute to the onset of Parkinson’s disease and it is believed to be harmful to bees (especially when combined with pyrethrins … also used by organic farmers). Although extremely persistent, it has a short active period and needs to be applied on crops quite frequently.

Rotenone can be fatal to humans but its use as a piscicide is indicative of its natural nastiness. Rotenone has been used as a traditional equivalent to blast fishing (dynamite fishing). I wish I were making this up, but by sprinkling this organic pesticide on the water, the fish lose their capacity to breathe, become immobilised and come to the surface for air, making for easy pickings for lazy fishermen. I suppose people who support organic farming do not worry about any rotenone runoff getting into the water table.

The Xerces Society came out with a clear warning to organic farmers to be careful when using rotenone because of the risks it poses to bees (“Rotenone is extremely harmful and not compatible with bees”). This warning was in 2009 but politely ignored by organic farmers who have since kept rotenone in their pest arsenal.

The American FDA and EPA do not have adequate data on rotenone since those manufacturing this organic pesticide (mostly Chinese companies) have not bothered to comply and it is kept on the market for its efficient fish elimination (please note that this blog is not a parody). Thus they are unable to properly regulate on the poison but as its source is natural, there does not seem to be the urgency to act. There is no evidence in the EU that EFSA is acting on rotenone and organic discussion forums show that rotenone is still widely used and sold in both Europe and North America.

The point is that rotenone, like any pesticide whether natural or synthetic, is designed to have sufficient toxicity to kill insects and other undesired threats to farmers. People have to stop thinking that organic farmers are using more benign products to kill their pests. They are just using products and toxins with very little research or regulatory control and this is plain stupid.

The campaign against rotenone

Well, there is no campaign. The double-standards here, where natural toxins are blindly tolerated and well-tested synthetic toxins are banned without evidence, are offensive beyond belief.

Pesticides Action Network UK came out with a sheepish acknowledgement that rotenone was really bad news for humans, animals and the environment, but tread carefully lest they appear to obstruct organic farmers from their access to toxins to control pests. Note the gobbledygook they passed off as responsible protectors of human health and the environment:

PAN UK believes that the same precautionary principle should be applied to all pesticides, and that no substance, however long-term its use, should be assumed to be safe without scientific assessment. The problems evident for rotenone – insufficient usage data, inconclusive studies, concern about unknown synergistic activity with other substances, and potential health hazards, are consistent with problems found with the majority of registered agrochemicals.

Whiskey, Tango, Foxtrot!!!

“… are consistent with problems found with the majority of registered agrochemicals” … so, what are you saying, PAN, that rotenone should have more studies? Or is it more like, well, we kind of support banning rotenone, but only if we ban all other synthetic pesticides first. Unbelievable – how foggy does PAN have to be before it becomes a complete joke? According to PAN (on the same link above), “The current regulatory system, designed for synthetic agrochemicals, impedes research into, and registration of, least toxic, relatively benign pest control substances.” So rotenone is relatively benign? It kills humans, bees and fish!!!

I stand corrected: PAN is a complete joke.

Azadirachtin: The “Natural” Bumblebee Exterminator

Those who think a natural toxin (and thus acceptable for organic farming pest control) is less damaging or toxic than well-tested synthetic pesticides are quite frankly very stupid. Cue our friends at the UK organic lobby, the Soil Association, who illegally granted special permission to organic farmers to use azadirachtin on apples. Azadirachtin is a natural pesticide (it is also called neem or neem oil after the tropical tree from which its toxins are extracted) with a long history of use in organic farming. It is approved as an organic pesticide in most EU countries despite lack of data (but not as a pesticide in the UK).

Now the problem is that last week the European Commission concluded that azadirachtin, commonly used by organic farmers in Europe, is seriously fatal to bumblebees even at “concentrations 50 times lower” than the recommended levels for organic farmers. The study showed that only 30% of the bumblebees survived exposure at any dose level of azadirachtin. Azadirachtin may be natural and promoted for organic farming but it is deadly to bees (although perhaps in an organic way).

Why then do organic farming organisations think that using these toxins are OK? See a recent article that assures organic gardeners that azadirachtin (as neem oil) is safe, non-toxic and has no effect on bees. The International Federation of Organic Agriculture Movements (IFOAM) has been lobbying the European Commission to keep azadirachtin on the market (with less stringent data requirements) because there are no other alternatives for organic fruit production. Uhm, how about safe, well-tested synthetic pesticides that do not wipe out bee populations?

I have written elsewhere how the organic industry lobby does not hesitate to use unethical practices to gain market share and public support. But if you are blinded by the belief that natural is always good, then you don’t see it as lying, you don’t see the negative consequences of your toxic pesticides and you don’t see the contradictions of your lobbying. You are just blind … and very vocal. But isn’t it sweet that the UK Soil Association has been caught supporting the bumblebee exterminator while they are one of the leading voices demanding a permanent ban on neonicotinoids “to save the bees”! Now the Soil Association say they need to retrain their staff … understatement of the year! I hope they train them to not be so blinded as to think natural toxins are better than scientific toxins.

And what do our jokesters at Pesticide Action Network have to say about azadirachtin? PAN recommends this organic bee-killer as an alternative to several neonicotinoids. So a toxic chemical used in organic farming that wipes 70% of bumblebees out at concentrations 50 times lower than the recommended organic farming levels is considered as a safer alternative than well-tested neonicotinoids. This type of lobbying should be criminalised (but large-scale bee deaths don’t count for much in a court of law).

I really don’t get this at all. When faced with the possibility that the data on neonicotinoids is not sufficient to be certain that they cause no potential risk to honeybees, the activists in DG Santé go full-frontal precaution. And yet faced with its own clear evidence of a natural pesticide used by organic farmers that literally exterminates bumblebees at very low doses, and everybody in Michael Flüh’s unit sheepishly look away. How do you spell stupid???

Potential cause for bee decline: The increased use of organic pesticides?

Time for some counter-intuitive thinking. Anti-chemical industry NGO campaigners and their activist scientists at the IUCN Taskforce on Systemic Pesticides have been claiming a correlation between the decline of bee populations and the increased use of neonicotinoids. Now the correlation is not very accurate since bee populations were falling before neonics came into widespread use and in certain areas where neonicotinoids are widely used there has been no issue of bee decline. Likewise, areas in France and Slovenia where neonicotinoids were banned did not see a re-flourishing of bee populations.

However, the correlation of declining bee populations and increased organic farming do seem, at first sight, to be more accurate. In other words, the wider use of less-tested organic pesticides like rotenone and azadirachtin may be having an adverse affect on pollinators. As activists like PAN, Greenpeace and Friends of the Earth are campaigning for more organic food, and given the highly toxic and untested pesticides that organic farmers use, there is the possibility that the health and survival of pollinators will be put more at risk.

I would like to see the organic industry activist scientists demonstrate, along the same lines of data requirements demanded on conventional crop protection substances, that organic toxic pesticides are not more responsible for the decline in pollinator health than neonicotinoids. If the organic industry can succeed in this challenge, then the Risk-Monger will cease blogging on bees or the organic industry’s perceived hypocrisy.

There is a need for further study here, but who am I kidding? The European Commission will not overturn the precautionary ban on neonicotinoids (despite the lack of any impact assessment, the devastation it has since wreaked on farmers and its well-known irrelevance to bee health) nor will they consider confronting the organic activist lobby with facts from their own studies. This is not about saving the bees, never was, but rather about hitting the chemical industry hard while running an apocalyptic fear campaign to promote organic agriculture. It seems that being a hypocrite is a prerequisite for working in DG Santé.

The need for an “Idiot Test”

The European Commission needs to impose an “Idiot Test” to be applied to all actors before allowing them to participate in stakeholder dialogue events on farming and crop protection. The Risk-Monger will volunteer his time towards drafting the questions for this entrance test. One particular question the Commission could ask would be:

Do you believe that the toxic chemicals that organic farmers use need not be judged by the same standards or data requirements as other, synthetic pesticides?

If the activists answer yes, or claim that organic farmers do not use toxic chemicals, then they should definitely not be allowed to participate in any EU stakeholder consultations. They are clearly idiots!

Perhaps regulators should also be given the Idiot Test – I can think of a few people in DG Santé who might have problems passing it.




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  1. I don’t know about Europe, but Im pretty sure that Rotenone has been banned in the US for several years for use other than to kill fish. I agree that it is a nasty pesticide.

    1. This is part of the grey area I mentioned – rotenone is fully approved in the US as an organic pesticide (if you find residues, it is still organic) but not approved by the EPA for anything other than killing fish – although it has a very grey categorisation of “allowed with restrictions”. See: But, as I had mentioned, then you find rotenone mixed with another nasty natural bee-killer, pyrethrins, and that is also OK in the US for organic farming. I did a quick search on the US Amazon site and I could buy: Pyrenon, Red Arrow and Pyrellin – all with rotenone and all organic approved. I don’t think two different regulators in the US will go to war over this one given that the toxins are natural and hypocrisy is always preferred over conflict.

  2. Risk-Monger, if you want to remain popular among green haters as a good story-teller you should make some effort on the facts behind them. Rotenone is already banned in the EU, will probably be banned in the US in 2016 and nobody is fighting to keep it, as far as I know.

    Azadirachtin is a dangerous broad spectrum insecticide, yes, and PAN should know much better than recommending it as an alternative to neonics on cereals! But as usual you only write half-truths: the Soil Association says they fired the guy who gave the permission to the two apple growers to use azadirachtin, and that they will review urgently their stance on the stuff following the new study.

    That said, the 2010 IFOAM letter is a good find, and this is the first time ever I read you asking for a ban on pesticides. Excellent. You’re slowly getting it.

    1. Thank you Sue for your comment and compliments. I am curious where you found information about rotenone being banned in the EU – I couldn’t find any information except that it is approved for organic farming. Happy to have your citation. All of your other points I totally agree with – those people should not be using such toxic bee killers or promoting them (especially as the risks, as you say, are so well known). The facts seem pretty clear so correcting me for not getting my facts straight with “they should know better” is not an argument I would advise you to use. The Soil Association is only sorry they got caught (and only after the EU published a report on the bumblebee exterminator). And I am sure you will also agree with me that the organic industry lobby behaves in a totally unethical manner pretending that their natural pesticides are not toxic to humans, bees or the environment – they are 50 times more toxic (read the Commission link) and those poor people made to be afraid of synthetic chemicals in their food are paying so much more … for untested chemicals (but “natural”) in their food. I totally agree with you – they should know better … but the bastards don’t, and that is my point.

      1. On rotenone being banned, the simplest source possible: the very EU pesticides database you used for azadirachtin

        Re the soil association, you are misquoting them and attributing them an opinion that isn’t substantiated anywhere; I don’t call that a fact – now of course you’re free to call them the way you want, it’s your opinion after all. But just that then.

        The organic industry is… an industry. Meaning they will lobby to keep their stuff on the market (and keep competition at bay) by all legal means available. Expecting morality from an industry is naive – morality is for persons, not legal fictions designed to escape responsibility… The good thing about them is that they’re a step in the right direction from an agronomic point of view – they’re forced to be much more technical than their conventional counterparts given they cannot access the whole biocides arsenal that allows conventional agriculture to grow the green deserts we can all admire around the world now. But it’s only a start, and insufficient.

        1. Thanks for the link Sue.
          I am a little disturbed by your “boys will be boys” attitude towards industry. I do not agree with your line that “Expecting morality from an industry is naive” – I have worked in industry at three levels – for a multinational, a trade association and a large PR-PA consultancy and they take very seriously their ethical codes of conduct (while they try not to make things public, I have seen many examples of employees fired or sanctioned when they did not follow the code). This is one reason I am so critical of groups like Greenpeace or Friends of the Earth who do not have ethical codes of conduct (too often, they applaud their lying and breaking laws).
          An industry is made up of all of the people who work for it, and when they behave badly (like the banking industry over the last decade), then public trust is lost and the industry suffers. Your pooh-poohing that the organic industry is an industry and thus they will not behave morally is equivalent to a woman saying that all men cheat on women so what can you do. Hell no – you can either chop it off of kick the bugger out. Tolerance of bad behaviour is equally culpable. The organic industry is lying about the risks of conventional crop protection materials, pretending their products do not have risks, funding social media gurus to spread fear and lobbying groups like Justlabelit to create misconceptions about the safety of GMOs. They are behaving totally unethically – any other industry that behaves like that would lose their right to market, but because of the double standards of the campaigners who do not feel that ethical standards apply to them (their cause is far greater and the ends justify the means), people can feel perfectly justified in looking the other way. I don’t think double standards are acceptable in public policy debates and until they learn that ethical behaviour matters, I for one won’t tolerate their lobbying techniques.
          As for the Soil Association, belief is indeed personal – if they had come clean before being exposed, I would share your belief. But if they are part of an industry that is seen as not needing to behave ethically, well …

          1. Morning Risk Monger,

            quickly, as I have to attend professional duties: your response conflates individuals and institutions. Morality is to be expected from individuals, even though of course it is always a challenge, but companies are institutions specialised first and foremost in profit optimisation. They then adapt to prevailing morality in the societies where they are, of course, but because it is a relative necessity to their profit-making activities (they maintain a good image where their clients are and don’t give a damn elsewhere, ask Congo). No judgment in that, just of fact – there are good and bad people everywhere, NGOs and industry alike – but expecting that companies behave ethically for other reasons than protecting their reputation (and this is where PR people like yourself come in handy) and hence profitability is an illusion, I think.

          2. There is no doubt that companies have to make profits (maximise shareholder value was the rather vulgar mantra from the 1990s), but one of the key ways they can do that is to attract and keep the highest quality employees. Nobody wants to work for a bad company and good qualified expertise vote with their feet if they see something unacceptable.Those Harvard MBA graduates are no longer going into the banking sector not because of a decline in job opportunities, but rather on principle. CSR is first and foremost an internal communications / HR and the whole concept of developing a corporate culture built around integrity and values was to keep good employees from voting with their feet. I worked as an internal communications manager and while I joked that I was responsible for handing out the Kool-Aid every morning, I knew that if I myself did not believe the messages I was communicating, nobody else would. Those going to work for the organic food industry already clearly have a taste for the Kool-Aid and feel they are working for a common good (that has to be the easiest internal communications job ever).
            I generally find that those attacking industry and campaigning for a denormalisation of the business sector from policy decisions (groups trying to limit corporate lobbying) have never worked for a large company and have no real idea of what goes one during office hours. A majority of Europeans and Americans do know, do understand corporate values and quite simply are confused by the attacks on their industry.

  3. I enjoyed reading this article. But I wanted to point out an error regarding your reference to the azadirachtin study.

    “…fatal to bumblebees even at “concentrations 50 times lower” than the recommended levels for organic farmers. The study showed that only 30% of the bumblebees survived exposure at any dose level of azadirachtin.”

    According to the news alert you linked, azadirachtin had deleterious effects at 50 times lower (0.64 mg/L) than the maximum recommended level (32 mg/L), but LD70 is around 20% (6.4 mg/L) of the maximum, and LD50 is above 10% (3.2 mg/L).

    Regardless, your conclusion still seems correct.

    1. Thanks Ryan for the correction – there were a lot of results in the study (also on low reproduction levels from lower exposures) – I tried to keep it short and simple and intended no short-cuts (but such is always the risk when trying not to get lost in the numbers).

  4. I am curious about Emerald Ash Borer, Gypsy Moth, Bee Deaths and the use of TreeAzin or Neemazol for systemic insecticide in Germany,UK,etc.. The Neem Oil seems to be used in areas of higher bee deaths and places where certain pesticides are banned like Ontario,Quebec,Manitoba CANADA.

    Unfortunately Nobody in Canada would care if it turned out to be Neem Oil and not neonicotinoids affecting bees. You see Neem Oil, Azadirachtin has never been registered as a pesticide here. Except since the Pesticide Bans, they use it to save Trees. It is another Organic sort of works and we have a feeling it is safe, product. Coincidently, The Canadian Federal Government (Forests) owns TreeAzin.

    They should at least take into consideration hundreds of millions of dollars of TreeAzin being injected into Trees within the same cities where massive bee deaths occured. Precautionary Principle only applies to Synthetic Pesticides or the Flavor of the Day. Activists SUCK!

    1. Thanks Ron – useful information as I am putting together a catalogue of toxic natural substances used by organic farmers. We need a word to explain the misguided belief that anything natural is OK while anything synthetic is not – how about: “natradiction”? Still looking.
      It is also a regulatory disease. Regulators don’t win points protecting man from the ravages of nature (otherwise we would have acted to stamp out malaria decades ago), but if it is a fault potentially caused by man, then look very busy!


    Journal of Animal and Veterinary Advances
    Year: 2009 | Volume: 8 | Issue: 3 | Page No.: 436-440
    Residual Toxicity of 8 Different Insecticides on Honey Bee (Apis mellifera Hymenoptera: Apidae)
    Izzet Akca , Celal Tuncer , Ahmet Guler and Islam Saruhan
    “This study evaluated acute toxicity of 7 licensed insecticides which are being used in Turkish hazelnut orchards for a long time and one azadirachtin preparations on bees in laboratory condition. Under the light of the research findings, Marshall, Oncol, Deltanate, Mesurol, Karate, Sevin XLR and Sevin WP 85 had the harmful effect on bee while Azadirachtin was environmentally friendly preparation for controlling hazelnut pest. It was clear from upper evidence that azadirachtin deserves serious consideration for inclusion into the hazelnut integrated pest management programs as a more selective approach. For this reason, in the research conducted areas, this toxic insecticides use should be avoided and Azadirachtin use should be encouraged to Hazelnut growers.”

    1. Thank you for your comments Brooke – I will reply to all of them here. I agree that verification is important and I have been attacked and threatened with lawsuits often enough to make sure I can back up what I say. I don’t know what is invalid about the source I used on Azidirachtin, published this year in the journal Ecotoxicology and validated by the European Commission. The British government obviously has its own issues for banning it but I confess I did not follow that up (I thought the evidence was pretty strong already). Even your IPM site at UC Davis put conditions on the use of Azidirachtin. As for the Turkish study that gave Azidirachtin a clean bill of health while all of the others (mostly used as organic pesticides mind you) seemed to have castastrophic consequences after 24 hours (up to 84% mortality … yikes!). I would not use a study like that personally – why? – first it is very short, its findings are quite extreme (and was presented almost as PR for the product), there is no information on the authors affiliations and the Journal of Animal and Veterinary Advances had an impact factor in 2009 was 0.176 and it has not improved much (point of comparison, the IF for Nature is 41) – this article was cited seven times in six years. Research in dodgy publications is something I refer to as 50 shades of white and I would call this pretty grey. I am open to other studies, but as the organic lobby is fighting hard to keep Azidirachtin on the market, they had better get funding more studies – regulators seem to have enough evidence to take action.

  6. In 15 minutes I find enough credible sources that come to a different conclusion on the safety of Azadirachtin and bees. While I do appreciate your intellectual direction on this highly charged issue we need to be very careful before we publish. The misinformation spread by misuse and misunderstanding of terms such as ‘natural’, ‘organic’, and my favorite…’chemical-free’ is at an all time high. But, verify, verify, verify first!

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