December 16, 2008

Hazard vs. Risk
Since last June, the EU has been in the process of implementing a major revision of its pesticide laws. As a result, the use of several of the most common agricultural pesticide ingredients in Europe may soon be phased out - perhaps beginning as soon as January. Which would, naturally, cause the END OF THE WORLD AS WE KNOW IT. Or so says the UK Crop Protection Association. I'll let you guess who they're really protecting.

The world will only end, of course, if the ban goes through without significant weakening. From what I can tell, the law will pass in some form or another. It's mostly a question of who ends up in the driver's seat. The bill has over the last six months been a political football (being Europe, this would presumably be the round kind) kicked between the national-level politicians, who try to weaken it in order to aid their farm lobbies, and the European Parliamentarians who try to strengthen it.

One interesting element is that the law doesn't actually delineate a set of banned substances. Rather, it changes the way the EU assesses the threat posed by a particular chemical. As Reuters explains:
The new rules would push Europe towards a hazard- rather than risk- based approach, meaning that pesticides could be banned if they are dangerous at any dosage. At present, they can be allowed if they are safe at the level at which they are used.
That sounds like a good idea to me. Given that scientists have repeatedly misjudged "safe" levels of exposure for various chemicals, traditional risk assessment for this sort of thing deserves to be shelved. More often than not, when it's time to determine acceptable levels of human exposure to a given chemical and the precise science is lacking, regulators just make a graph with zero exposure on one end and deadly exposure on the other. Then they draw a line from the former to the latter. Somewhere close to but not quite at zero becomes the acceptable limit.

The current disasters with melamine, which now appears to be ubiquitous in the US food system, along with bisphenol-A (in every food and drink can lining, baby bottle and most plastics) are prime examples. And now, as Enviroblog tells us, having discovered that melamine is indeed in baby formula here in the US, the FDA has simply declared this existing level of contamination to be "safe" since babies here are clearly not all going to the hospital with melamine poisoning. The logic is simultaneously inescapable and deeply flawed.

As for that European pesticide law, in the event it passes as currently proposed, it will represent both a huge victory as well as a wonderful agricultural experiment. There is, after all, general agreement between supporters and opponents of the ban about one thing. In Europe at least, farming based on heavy use of the banned chemicals will no longer be possible. Whether that will lead to total armageddon or not depends on your point of view.

If the UN is to be believed (not to mention the Rodale Institute), weaning farmers off of chemicals should have no great effect on yield. But you wouldn't know it to hear the complaints from the European farm lobby - chemicals may be icky, they say, but you can't farm without them. At the same time, they readily admit that the greatest risk from the ban lies in the existing immune resistance to many pesticides among pests. These folks act like soldiers down to their last bullet with a marauding horde at the gates. Just using one pesticide isn't enough, the conventional farmers declare - it takes multiple products to keep those yields nice and high. To listen to them is to hear the addict's plea - the dose may be high, but it needs to be to have an effect.

If the European Parliament can withstand the farm lobbyists (and agricultural ministers') onslaught, Europe will provide a big test for proponents of organic (or even other farming techniques, such as Integrated Pest Management). If the yields don't collapse, one of the main pillars supporting the logic behind conventional agriculture will. Hopefully, Tom Vilsack will take note.

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