September 23, 2015
Also see the French translation
Dear Dr Deluyker
Today at the Corporate Europe Observatory event in the European Parliament entitled Science vs Lobbying, I asked you a question that you declined to answer. I am not sure whether you had forgotten the question or if EFSA does not yet have a policy on this issue. As I think it is a valid question, I thought I would use this open forum to ask it again.
“Of the five members on the EFSA Bee Risk Assessment Working Group, two had no experience conducting bee field test trials and two others had serious conflicts of interest. Gérard Arnold was the chief scientist for Apimondia which campaigns against pesticides and Fabio Sgolastra has been involved with several Italian NGOs and signed the Pesticide Action Network North America letter to President Obama demanding a ban on neonicotinoids. This EFSA Bee Working Group drafted the (until now not approved) EFSA Bee Guidance document on how to conduct field trials to assess the risk of pesticides on bees. This guidance document was so demanding that it invalidated all of the industry field test trials and led to the EU’s precautionary ban on three neonicotinoid pesticides (due obviously to the lack of accepted data). I know that today we are here to bash industry and for many it is good fun, but does EFSA have a policy when members of their Working Groups have clear conflicts of interest with environmental NGOs?”
Given that time was tight at the event, allow me to expand my question with a few further points:
Both Arnold and Sgolastra, while they were involved in writing the draft Bee Guidance document, were also publishing papers and making presentations on the need for the EU to change the risk assessment approach. You can find the links and the evidence of their undeclared conflicts of interest in the last of a three-part blog I had written last December. I understand this issue was discussed in Parma and Brussels as my research had attracted some attention then in what became known as “Bee-gate”.
The EFSA Draft Bee Guidance Document has still not been approved by the Member States for the main reason that its conditions for legitimate field trials are simply impossible (it would require tracking bees over the equivalent of more than 31,000 football pitches and assuming a mortality rate below the average baseline). But still, EFSA just this summer insisted on using this failed guidance document to discredit all industry field tests to draw similar conclusions for risks to bees from foliar uses of neonicotinoids. Please see my blog on that situation where I tried to understand why you are continuing to push a failed, corrupted guidance document (especially given there is an ongoing court case against the European Commission on this).
So I suppose it comes down to several questions I would like you (or someone in EFSA with responsibility) to answer:
- Does EFSA have a policy towards Conflicts of Interest for NGO activists who get their way onto EFSA scientific working groups or other bodies?
- Has anything been done to correct the situation caused by Arnold and Sgolastra?
- Given how the Draft Bee Guidance Document has been corrupted by such conflicts of interest, shouldn’t EFSA withdraw it rather than continue to use it to invalidate good available research?
- And from that, would EFSA then reconsider (withdraw) its advice in 2013 on the three neonicotinoids, which led to an EU-wide ban that has had such a negative effect on farmers, consumers and, sadly, on bee health?
I am very sorry to have to ask you these questions in such a public manner, but given the demands of transparency, if I had sent this only by private email, groups like CEO or ALTER-EU would attack you for collusion (you see, ten years ago I worked for industry which makes me persona non grata at agencies like EFSA). Also, I must confess that I do feel a little bit frustrated. EFSA responds immediately when loud-mouthed activists scream and yell about some insignificant industry conflict of interest (like involvement in a project partially funded by industry), and we saw today how good they are, and how much money they have to swing their dead cat in all directions, but if an academic with no budget or funding presents evidence that shows serious issues at EFSA regarding activist creep, he can easily be ignored. I don’t think that is fair or right … so at least, after ten months of ignoring this, you can offer me the courtesy of answering my questions. I will insert your answer at the bottom of my blog.