Silent Spring #5- Reflections on the Precautionary Principle

by Sarah Janes Ugoretz
After spending the last several weeks exploring the implications that pesticides like neonicotinoids and glyphosate have on our pollinators and other beneficials, this week we bring the precautionary principle into the conversation. Now more than ever, we can be brutally honest and ask ourselves: how did we get here?

The precautionary principle (PP) was first formulated and invoked in the 1980s, primarily through the implementation of the Montreal Protocol. Its basic tenant mandates that: “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically” (Raffensperger, 1998). In the event that this is true, the burden of proof falls to those who endorse and promote the activity, not the general public. For example, in accordance with the PP, instead of waiting until people become sick, the responsibility of the U.S. Food and Drug Administration (FDA) is to extend to the public a reasonable expectation that we are shielded from danger. An informed, transparent, and democratic process must accompany the application of the PP, and the possibility of taking no action (as in, not moving forward with the marketing, sale, and widespread use of a potentially harmful pesticide) must be given equal weight when considering the range of alternatives (Raffensperger, 1998).

Unfortunately, as we touched on in our earlier conversation about glyphosate, the FDA is often presented with industry studies—studies that are conducted entirely by corporations like Monsanto and Dow Chemical Company and that are, apart from FDA review, classified. By attaching a commercial-in-confidence label to these reports, corporations manage to side step having to offer up their studies for review and assessment by external scientists, researchers or even the general public—groups who are less likely to be burdened by any conflicts of interest (Leu, 2014). As the Union of Concerned Scientists has noted, “By creating obstacles to independent research on its products, [corporations like] Monsanto make it harder for farmers and policy makers to make informed decisions that can lead to more sustainable agriculture” (Union of Concerned Scientists, 2012).

In the U.S., we depart starkly from Europeans, Canadians, Australians and others who tend to subscribe to the notion that it is better to prevent damage than to repair it. As Mark Bittman has commented, “We ask not whether a given chemical might cause cancer but whether we’re certain that it does” (Bittman, 2015). For an interesting contrast, let’s take the European Commission, which, in 2013, voted to impose a two-year ban on the use of certain neonics. Faced with incomplete data and uncertainty as to whether neonics are irrefutably related to the decline of bee populations, the European Commission erred on the side of caution in imposing the ban. The U.S., on the other hand, is still reviewing the evidence. According to Jim Jones, Assistant Administrator for Chemical Safety and Pollution Prevention with the U.S. Environmental Protection Agency (EPA), the EPA is allowing science to inform the regulatory actions they do and do not take. Operating in this manner allows them to “make sure that [they] make accurate and appropriate regulatory decisions as opposed to [doing] things that could lead to meaningful societal cost without any benefit whatsoever” (Plumer, 2013). As Plumer has commented, where the European Commission is siding with the environment on this one, the U.S. is clearly letting economic considerations take center stage. “It’s still not clear that neonicotinoids are to blame, and pesticides are a billion-dollar industry, so regulators are moving slowly in setting restrictions” (Plumer, 2013).

Unsurprisingly, there are many in the U.S. who question the usefulness and the practicality of the PP. These critiques primarily fall in line with the question of weighing risks. Michael Specter, longtime staff writer at The New Yorker, insists that we “…have to be aware of blindly invoking the ‘precautionary principle’” (Specter, 2015). After all, risk is subjective and safety is difficult to prove. But when we really get down to it, what truly needs protecting here? The economy, silly! As we know (and as we can deduce from Mr. Jones’ comment above), the pesticide industry is a billion-dollar entity and in the U.S., we’re hooked on industrial agriculture, quick fixes and cheap food. All of these things are intimately tied to the convenience that comes with agro-chemicals. To move away from pesticides like neonics and glyphosate would be to unravel the model of agriculture we’ve worked so diligently to put in place since chemical fertilizers first appeared on the scene after World War II and Earl Butz so tenderly cooed, “Get big or get out” (Philpott, 2008).


Over 20 years ago, Farmer Richard spent some time in Holland. During this time, he met with several Dutch farmers, a majority of whom grew vegetables in greenhouses using hydroponic methods. They recounted to Richard that some months before, they had noticed a decline in the aquatic life and, by extension, the water birds that lived near and fed from the canals that traversed their region. The farmers quickly traced the problem back to their hydroponic systems—the water that was being discharged was making its way into the canals, and it was taking the farmers’ fertilizer and other chemicals along for the ride.

Despite being competitors in the same marketplace, these farmers came together to collectively recognize the problem and identify a solution. Though the cost was considerable, the farmers decided that the most effective solution would be to install recycling systems, which would work to clean the discharged water. Driven by the conviction that making this change was the right thing to do, and having faith that consumers would be willing to pay a few cents more for their produce, the farmers invested in the necessary infrastructure. Before long they began to notice that, in the absence of polluted water, the canals’ rich aquatic life had begun to rebound, along with other valuable species like birds.

This “do the right thing” mentality and attitude made a lasting impression on Farmer Richard—one that he has carried with him over his many years of farming. Where the Dutch farmers recognized the need for and ultimately embraced change, many farmers in our country tend to stick to the status quo—despite the fact that we need to adjust the overarching principles that drive large-scale conventional agriculture. As Farmer Richard has noted, here we are more likely to see farmers banning together in opposition to change. In advocating for “right to farm” laws (often with backing from the Farm Bureau), it becomes less likely that farmers will have to take a serious look at and acknowledge the detrimental impacts some of their farming practices are having on the health of their families and friends, employees, pollinator helpers and their own land.


In reflecting on our current state of affairs—our country’s ongoing dependence on pesticides and our populace’s relegation by the FDA to the de facto status of guinea pigs—I found this commentary by Mark Bittman (2015) particularly appropriate: “We don’t need better, smarter chemicals along with crops that can tolerate them.” Rather, Bittman argues that what we truly need is fewer chemicals and a heavy infusion of agroecology—intercropping, crop rotation, organic fertilizers, cover crops and other methods that are ecologically informed, environmentally safe, and demonstrated to be economically beneficial.
We should hold tightly to this image, as a future reality to strive for. In the meantime, however, at a time when our regulatory bodies are slow to take preventative, protective action on our behalf, we can use our own knowledge and understanding in deciding whether or not to apply the precautionary principle on a personal level, a household level or, as we’ll see next week, on a city-wide level….because it’s the right thing to do.

References

Bittman, M. (2015, March 25). Stop making us guinea pigs. The New York Times. Retrieved from http://www.nytimes.com/2015/03/25/opinion/stop-making-us-guinea-pigs.html?_r=0

Leu, A. (2014). The myths of safe pesticides. Austin, TX: Acres U.S.A.

Philpott, T. (2008, February 8). A reflection on the lasting legacy of 1970s USDA Secretary Earl Butz. Retrieved from http://grist.org/article/the-butz-stops-here/

Plumer, B. (2013, May 3). Why are bees dying? The U.S. and Europe have different theories. The Washington Post. Retrieved from http://www.washingtonpost.com/news/wonkblog/wp/2013/05/03/why-are-bees-dying-the-u-s-and-europe-have-different-theories/

Raffensperger, C. (1998). The precautionary principle: A fact sheet. Science & Environmental Health Network. Retrieved from http://www.sehn.org/Volume_3-1.html

Specter, M. (2015, April 10). Roundup and risk assessment. The New Yorker. Retrieved from http://www.newyorker.com/news/daily-comment/roundup-and-risk-assessment

Union of Concerned Scientists. (2012). Eight ways Monsanto fails at sustainable agriculture. Retrieved from http://www.ucsusa.org/food_and_agriculture/our-failing-food-system/genetic-engineering/eight-ways-monsanto-fails.html#.VcoKzzBViko

Silent Spring Series #3: Neonicotinoids, Part 2

By Sarah Janes Ugoretz

After a brief hiatus, we return this week to our Silent Spring series as we look deeper into the arguments surrounding the rapidly expanding use of neonics. Before we dig in, I want to mention that in August we’ll bring this series to a close by considering where we go from here. That is to say, although reading these articles might leave you with a deepening sense of despair, we promise to provide you with positive examples of individuals, communities, states and nations taking proactive steps to push back against the use of neonics and other similarly harmful agents. In the meantime, our goal is to present you with as much information as possible so that you have the knowledge and the resources from which to steer your own course of action.
In February 2014, Forbes ran a piece in which the author opines that those who are concerned about the connection between neonics and—in this case—the plight of the bees are comparable to “…the fictional parents in the edgy comedy show South Park who blame Canada for all of their woes” (Entine, 2014). In other words, this author would like for us to get over it and move on. After all, he assures us that compared to organophosphates, neonics have a “comparatively benign toxicological profile.” Fortunately for those of us who take empirical evidence seriously, we have a mounting collection of independent, science-based studies to counter with.
Going back to 1992—just one year after the first neonic compound was introduced—the U.S. Environmental Protection Agency (EPA) found that sparrows that consumed very small amounts of imidacloprid had difficulty flying. As this dosage increased, they quickly became immobile (Bittel, 2014). Fast-forward to today, and researchers have had decades to collect data and build an even stronger case against the use of neonics. Take, for example, the recent findings of the Task Force on Systemic Pesticides (TFSP), a group made up of 29 multi-disciplinary, independent scientists whose self-imposed mandate is to “provide the definitive view of science to inform more rapid and improved decision-making.” After reviewing more than 800 scientific, peer reviewed studies on the uses an
d implications of neonics, the TFSP concluded that: “…neonicotinoids…are causing significant damage to a wide range of beneficial invertebrate species and are a key factor in the decline of bees.” They further concluded that there is sufficient evidence to “trigger regulatory action” (TFSP, 2014). The peer reviewed report, entitled Worldwide Integrated Assessment of the Impact of Systemic Pesticides on Biodiversity and Ecosystems (WIA), lists bees, butterflies, lizards, earthworms, snails, fish, water fleas and birds as being among those at great risk.
If you do a 5-minute Internet search on this topic, you’ll quickly find that skeptics often point out that there are numerous factors that could be contributing to the deaths of pollinators and other beneficials like earthworms. Caspar A. Hallmann—an ornithologist and population ecologist with SOVON, the Netherlands’ Radboud University and lead author on a monumental new study recently published in Nature—says that “…when [his] team looked at the data, none of these [other possible] explanations held up.” Instead, Hallmann is confident that the evidence against neonics is mounting (Bittel, 2014).
But hang on a minute—we have good news! Spokespersons with Bayer CropScience assure us that we really have nothing to worry about, as long as we follow instructions. “Neonicotinoids have gone through an extensive risk assessment which has shown that they are safe to the environment when used responsibly according to label instructions” (Bittel, 2014). Of this point, Bayer is “convinced” (Bayer CropScience, 2013). Unfortunately for neonic advocates, independent peer reviewed studies have found the opposite.
Among the long list of neonics’ discontents, there is one characteristic that most others can be traced back to—their persistence in our environment. Let’s look to water contamination as an example. Researchers with the U.S. Geological Survey found that among sampled Midwest rivers and streams, imidacloprid was present at an average of 32.7 nanograms per liter. Research has confirmed that this compound is toxic to aquatic organisms at levels ranging from 10 to 100 nanograms per liter. Levels of clothianidin and thiamethoxam—the second and third most used neonic compounds—were measured at 257 and 185 nanograms per liter, respectfully (Henein, 2014). What this study suggests—that contaminated water is toxic to wildlife—is further corroborated by Caspar A. Hallman and his team of scientists. After gathering long-term data on farmland bird populations and surface water contamination, they found that in areas where water contained certain concentrations of imidacloprid, bird populations tended to decline by 3.5 percent each year (Bittell, 2014).
The persistence of these compounds in our environment equates to the ongoing exposure of target and non-target organisms to neonics. While exposure can be instantly lethal—as in the case with bees exposed to airborne neonic particles (Bittel, 2014)—it can also be chronic and sublethal, as we saw with the EPA’s 1992 study on sparrows. In the event of the latter, organisms typically experience a wide range of impairments. A range of outcomes may befall this toxic organism: it may be consumed by and contaminate another organism; the impairments—such as an inability to fly or an increased susceptibility to disease—may lead to death; or the cumulative build-up of neonics within the organism may eventually kill it. In emphasizing the gravity with which to approach even a sublethal dose of a neonic compound, scientists with the TFSP have stated that metabolites—the compounds which neonics break down into—are often “as or more toxic than the active ingredients” (TFSP, 2015). With this in mind, TFSP has reported that certain neonics are five to ten thousand times more toxic to bees than DDT (TFSP, 2015).
We must also consider one additional factor—non-agricultural applications. Hopwood et al. (2012), focusing their attention on the management of ornamental and landscape plants, outline another grave point of concern. Their research found that neonic compounds are often administered at an alarmingly higher rate—potentially 32 times higher—than those approved for agricultural crops. This data has led Lowe’s—a large retail chain—to plan for a complete phase-out (though not until 2019) of plants treated with neonic compounds (Reuters, 2015). Although we have focused primarily on the impacts of neonics on non-human organisms, it is certainly worth mentioning that we humans may not be immune to these compounds. While our own EPA does not draw firm connections between neonics and human health, the European Food Safety Authority has stated that these compounds may “…adversely affect the development of neurons and brain structures associated with functions such as learning and memory” (European Food Safety Authority, 2013).
Proponents of neonics have long argued that these compounds are a crucial component of farmers being able to control the various pest populations that threaten their crops. After the European Commission voted to impose—beginning in 2014—a two-year moratorium on the application of certain neonics throughout Europe, Bayer CropScience was quick to express its grave concern for what this would mean for European farmers. “Restricting the use of these neonicotinoids…will put at risk farmers’ ability to tackle the destructive pests that can severely damage crops and restrict their capability to grow abundant, high quality, affordable food” (Bayer CropScience, 2013).
Yes, it’s true—conventional farmers are struggling (Gray, 2014). Without the neonics they have come to rely upon, they’re scrambling to find ways to protect their crops and their livelihoods. This highlights what Quarles (2014, p. 3) has pointed out over and over again—that these pesticides “allow growers to ignore good farming methods and IPM [integrated pest management] approaches in favor of systemic protections.” In a troubling turn of events, some farmers—in their struggles to phase out neonics—have turned to alternative pesticides like pyrethroid sprays, which are generally recognized as being more environmentally damaging (Gray, 2014). Dave Goulson, a professor of biology at the University of Suffolk, recognizes that finding ways to support farmers in identifying less harmful pest control methods is a priority in need of immediate attention. “You have to sympathize with farmers who have lost their crop, [but you also] have to weigh up the damage of [using] neonicotinoids over many years” (Gray, 2014).
As we conclude for this week, I’ll leave you with a quote that I believe really gets to the heart of the matter for us as eaters and as environmentalists. Dr. Jean-Marc Bonmatin, one of the lead authors of WIA, states that: “Far from protecting food production, the use of neonics is threatening the very infrastructure which enables it, imperiling the pollinators, habitat engineers and natural pest controllers at the heart of a functioning ecosystem” (TFSP, 2014). When all is said and done, if we protect these pollinators and beneficials, we will essentially be taking strides to protect ourselves (Quarles, 2011).
In two weeks’ time, we’ll turn our attention to glyphosate (better known as Roundup) as we consider the impact this pesticide is having on our environment and our invaluable ecosystems.

Article Sources

Bayer CropScience. (2013). Decision to restrict use of neonicotinoid-containing products will not improve bee health [Press release]. Retrieved from http://beecare.bayer.com/media-center/press-releases/press-release-detail/decision-to-restrict-use-of-neonicotinoid-containing-products-will-not-improve-bee-health

Bittel, J. (2014, July 9). Second silent spring? Bird decline linked to popular pesticides. Retrieved from http://news.nationalgeographic.com/news/2014/07/140709-birds-insects-pesticides-insecticides-neonicotinoids-silent-spring/

Entine, J. (2014, Feb. 5). Bee deaths reversal: As evidence points away from neonics as driver, pressure builds to rethink ban. Retrieved from http://www.forbes.com/sites/jonentine/2014/02/05/bee-deaths-reversal-as-evidence-points-away-from-neonics-as-driver-pressure-builds-to-rethink-ban/

European Food Safety Authority. (2013, December 17). EFSA assesses potential link between two neonicotinoids and developmental neurotoxicity [Press release]. Retrieved from http://www.efsa.europa.eu/en/press/news/131217.htm

Gray, L. (2014, October 1). Neonicotinoid ban hit UK farmers hard. The Guardian. Retrieved from http://www.theguardian.com/environment/2014/oct/01/neonicotinoid-uk-farmers-rapeseed-crop-bees-pesticide

Hallmann, C.A., Foppen, R.P.B., van Turnhout, C.A.M., de Kroon, H., & Jongejans, E. (2014). Declines in insectivorous birds are associated with high neonicotinoid concentrations. Nature, 511, 341-352.

Henein, M. (2014, July 31). Contaminated water: Neonics detected in Midwest rivers. Honey Colony. Retrieved from http://www.honeycolony.com/article/neonicotinoid-pesticides-detected-major-midwest-rivers/

Hopwood, J., Vaughan, M., Shepherd, M., Biddinger, D., Mader, E., Hoffman Black, S., & Mazzacano, C. (2012). Are neonicotinoids killing bees? A review of research into the effects of neonicotinoid insecticides on bees, with recommendations for action. The Xerces Society for Invertebrate Conservation.

Pesticide Action Network UK. (2015). Neonicotinoids. Retrieved from http://bees.pan-uk.org/neonicotinoids

Quarles, W. (2011). Protecting bees, birds, and beneficials from neonicotinoids. Common Sense Pest Control Quarterly, 27, 1-4.

Quarles, W. (2014). Neonicotinoids, bees, birds and beneficial insects. Common Sense Pest Control Quarterly, 28, 3-10.

Reuters. (2015, April 9). Lowe’s to stop selling neonicotinoid pesticides that may be harmful to bees. Huffington Post. Retrieved from http://www.huffingtonpost.com/2015/04/09/lowes-pesticides-bees_n_7035208.html

The Task Force on Systemic Pesticides (TFSP). (2014). New four-year scientific analysis: Systemic pesticides pose global threat to biodiversity and ecosystem services [Press release]. Retrieved from http://www.tfsp.info/wp-content/uploads/2014/06/WIA-PR-REL.pdf