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Danger, hazardous regulations ahead


There are many risks in life, and we expect governments to protect us from those which we may be involuntarily exposed to. Since the mid-20th Century, most of us in Europe have seen a large improvement in air and water quality. Things are not perfect, but serious pollution is quite uncommon. Nevertheless, in an increasingly precautionary and risk-averse age, people continue to worry about environmental risks to health.

Inevitably, as life gets longer, safer and higher quality, once trivial concerns take on a higher profile. After all, while malnutrition and infant mortality remain major problems in parts of the developing world, not many people there are going to be too concerned about the possible long term effects of traces of synthetic chemicals.

In the European Union, the perspective is different. Fortunately, few people have to worry about malnutrition, and modern medicine easily copes with infectious diseases which were major killers a few generations ago. Premature death is now a tragedy rather than an everyday reality. In these circumstances, worries about the possible harm caused by long-term exposure to low levels of synthetic chemicals have become important to many people. Although not always clearly articulated, the view that natural is good but synthetic must be treated with suspicion is widespread, as is the concept of ‘chemicals’ being entirely a manmade phenomenon. This underlies the view of so-called organic produce being healthier than conventionally-grown equivalents.

It also informs the general attitude to pesticides. Quite rightly, these potent bioactive materials are subject to stringent control, with rigorous safety testing and assessment by experts resulting in approval for use only under controlled conditions, with regular marketplace monitoring to ensure compliance. Clearly, it is in no one’s interest to use these chemicals without care or thought of the consequences.

From time to time, new evidence of environmental harm may emerge – normally an unwanted effect on untargeted insects or other wildlife – and certain classes of compound may be withdrawn. Atrazine, a widely-used herbicide in many parts of the world, is banned in the EU, for example, because of concerns about environmental impact. But normally concerns raised relate to supposition or apparent ‘links’ between pesticides and certain conditions rather than any hard evidence.

Despite this, pesticides overall are of enormous benefit to humans. Although the exact figures will vary from year to year, it is estimated that the global harvest of wheat, maize, rice and potatoes is nearly doubled through use of pesticides. Being able to control all pests would give perhaps another 50% increase on top of this, all from the same land area. This provides an ample supply of affordable food (although poverty and lack of infrastructure together keep nearly a billion people short of food, mainly in Asia and Africa).

In the developed world, this makes a diet with plenty of fruit and vegetables easy for people to achieve, and the health benefits of this are widely promoted (for example, via the ‘Five a day’ message). These fruit and vegetables may contain tiny traces of synthetic pesticides but present no health risk (other than food poisoning if contaminated, an entirely different issue).

This illustrates an important point: pesticides may present a hazard, because a large enough exposure to them can be harmful, but the actual risk of harm is tiny. Any substance, whether natural or synthetic, can cause harm at a high enough concentration. That includes salt, Vitamin D and other essential components of our diet. But there is little risk if consumption is normal.

In the case of pesticides, EU regulation has been stringent but rational; it has been the actual risk of harm in use which has determined approval. If contact with the skin can cause irritation or lead to absorption into the body, the risk can be managed by wearing simple protective clothing. If pesticide sprays can drift onto neighbouring fields, then application should only take place in calm weather (as is required by regulation).

However, apparently in response to the vocal precautionary lobby, the latest pesticides regulation is based on hazard rather than risk. Even if a pesticide can be used perfectly safely with simple precautions, the fact that it presents a hazard in laboratory testing is enough to prevent its approval and use. The unintended consequences of this misguided approach will be to reduce the options a farmer has to control pests, increase the likelihood of resistance developing and increase the chances of yield losses (and so higher food prices).

But there will be no safety benefit for consumers or farmers. The sole exception would be farmers who do not take normal handling precautions. Protecting people from the consequences of their own bad behaviour should not be the role of regulations of this sort. Having set the precedent for pesticides, the EU may choose to use hazard as a basis for regulation in other areas, which will be to no-one’s benefit. It is time for scientists to make legislators aware that regulation should be based on science rather than the unhelpful and discredited precautionary principle.


A reader has pointed out that last week’s newsletter encouraging nuclear ‘waste’ to be viewed as a resource contained some inaccuracies, which I am happy to correct. In particular, reprocessing of spent fuel separates out about 3% of highly radioactive actinide fission products. Currently, these would still need to be disposed of in a secure underground storage facility, together with much larger quantities of fuel cladding and similar components (intermediate level waste). However, there are projects in progress to develop ways to use these actinides as fuel also, so in the longer term even they should not be regarded as waste.

Figures from the Nuclear Decommissioning Authority show that the UK had 4.7 million cubic metres of nuclear waste in 2010. However, 94% of this was low level, 6% intermediate-level and less than 0.1% high level waste, which accounts for about 95% of the total radioactivity. The small volume of HLW is because a reprocessing strategy has been adopted.