Following the 1962 publication of Rachel Carson’s Silent Spring, many people in society became more aware of, and concerned about, the choices made by introducing unanalyzed technologies and products into our environment, economy and society. Government agencies in the US and elsewhere responded. The US Environmental Protection Agency (EPA), for example, was created in 1970 with an explicit mandate to regulate chemicals and other pollutants and to “protect human health and to safeguard the natural environment—air, water, and land—upon which life depends”. Although risk assessment and analysis was not yet a formally recognized process, the EPA completed its first risk assessment document in December 1975 and in 1976 issued its first directive on procedures and guidelines. In 1980, the EPA produced water quality criteria documents for 64 contaminants, the first EPA document describing quantitative procedures used in risk assessment. In 1983, the National Academy of Science published Risk Assessment in the Federal Government: Managing the Process commonly referred to as the ‘Red Book’. This book, for the first time, laid out the context for a systemic, comprehensive process for risk analysis.
In the following decades, risk assessments and analysis became a standard component in the commercialization of new products and processes. The standardization of the risk assessment methodology was grounded in science, with robust evidence required for analysis and rigorous risk evaluation metrics capable of providing reliable results. With the risk assessment system rooted in science, it was free from political influence or interference. However, over the past 25 years, some governments have sought to politically interfere with risk assessment systems, weakening the robustness of decisions.
Politics within the European Union have resulted in numerous inefficiencies within its agricultural regulatory system over the past 25 years. This first appeared in the EU regarding the commercialization of genetically modified (GM) crops in Canada, the USA and Argentina in the mid-1990s. Regulators in these three countries assessed the risks of GM crops, concluding they posed no difference in risk from the production of non-GM crops. Rather than accept the scientific evidence on the lack of risk from GM crops, the EU chose to adopt a strict interpretation of the Precautionary Principle. The Precautionary Principle essentially states that if full scientific certainty of safety cannot be guaranteed, it is acceptable to reject new products or technologies. Even though expert regulatory scientists and Canada, the USA and Argentina concluded there was no evidence to support an increase in risk from GM crop production, the EU decided to ban their commercialization.
This politicization of scientific risk assessment by the EU has had disastrous environmental consequences. The adoption of GM crops contributes to reduced tillage (Figure 1) and lowers greenhouse gas (GHG) emissions. The EU’s rejection of GM crops results in EU agriculture releasing more GHGs than otherwise would have been the case. The EU could have lowered its agricultural GHG emissions by 7.5% had it not politicized the risk assessment process for GM crops.
With the EU having recklessly restricted the sustainability benefits from the adoption of GM crops, it has now adopted a nefarious strategy to try and force its political interference on the rest of the world. It is attempting to do this through a process known as ‘Mirror Clauses’. Because the EU has politicized its risk assessment process, it has banned numerous chemicals that are safely being used in virtually the rest of the world. This places EU farmers at a distinct competitive disadvantage compared to farmers in other countries. To try and compensate for this, the EU is further politicizing the risk assessment process by demanding chemical ban ‘mirror clauses’ in trade agreements. What this means is that rather than respecting the scientifically determined maximum residue limits (MRLs) for pesticide residues on traded agricultural commodities, which have been used for decades to facilitate the safe trade of commodities, the EU is now demanding there be a level of zero MRLs of pesticides that have been banned by the EU’s politicized pesticide registration process.
Pesticide MRLs are scientifically determined and are set far below levels that could cause harm. When the level of harm is scientifically established through laboratory experiments, the MRL is set that rates well below 1% of the harmful level. This enables food products to be safely consumed, as an individual would have to consume hundreds of pounds of a food item in a short period of time before there would be a harmful effect. As an example, a person eating lentils would have to consume over 1,300 pounds within a few weeks for there to be any danger from MRLs.
Rather than reply on robust scientific facts and evidence, the EU has globally been pushing an agenda of politicized risk assessment processes. This was well established around the turn of the millennium with the bans of GM crops and has progressed to include other aspects of agriculture, including the establishment of MRLs. The EU’s unwillingness to regulate based on scientific evidence has put their farmers at a competitive disadvantage to farmers in other countries, so their solution is to try and force other countries to ban the use of safe pesticides. The EU is now actively trying to push the politicization of risk assessment to other countries. These actions will hurt consumers as it will needlessly drive up the cost of importing food.
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