Plausible Deniability, White Collar Bio-Crime, and The Precautionary Principle

If there isn't one already, we ought to have something like a "Law of Imperfect Information" which states that:

Willingness to utilize imperfect information to justify a course of action is directly proportional to the amount of money that can be made from the course of action.  

And, its corollary, the "Law of Scientific Insufficiency" which states that:

If enough  money is being made on a given activity, no amount of scientific evidence demonstrating damage resulting from the activity will be sufficient to stop the activity. 

Recently (new) news stories have surfaced describing research into the effects of neonicotinoid class pesticides on bee populations, both domesticated and wild.  The research by Dr. Jeffrey Pettis--which itself has been around for a few years--shows that undetectable amounts of neonicotinoid class pesticides render honeybees more susceptible to other threats such as nosema, mites, etc.  Moreover, the same poisons (largely produced by Bayer) have long-term, cumulative effects on the creatures they impact.

Long before that study, multiple other scientists cautioned that neonicotinoids are indeed bad news for bees at detectable levels of contamination.  In at least one case, responsible officials (not here in the United States) actually stopped usage of the pesticides and--get this--watched local bee populations rebound.

But, stretching back even further to the horizon of sanity, many ordinary non-scientists asked how it was possible we might believe that dumping huge quantities of insecticide into the environment would not have an adverse impact upon bees.  They didn't get a lot of play.

Understanding how big the market for these poisons is goes a long way towards explaining why.  In 2009, Bayer sold about $269 million dollars worth of Clothianidin, one of the primary brand names under which neonicotinoids are marketed.  Since 2003 in the US, Clothianidin has been widely used on corn, soybeans, wheat, canola, beets and other food crops.  In the United States last year, about 92 million acres of corn, 77 million acres of soybeans, and 58 million acres of wheat were grown, a significant portion of them with the aid of Clothianidin.  In other words, we're talking about a lot of momentum  This is the "Law of Scientific Insufficiency" in action.

If you look into the details around how the insufficiency law plays out, things get ugly.  In a 2007 memo, for example, EPA scientists warned the agency that for Clothianidin "estimated risk quotient (RQ) values exceed the endangered species level of concern for acute risk ( RQ2 0 . 1 ) to birds and acute and chronic risk to birds and mammals."  Despite the warnings, the EPA approved Clothianidin for continued widespread use.  Two years later, in 2009, when confronted with the mounting evidence surrounding Clothianidin usage, the EPA reconfirmed ongoing registration of the substance.


Knowing a little bit more about Clothianidin in particular (and neonicotinoids in general) also tells you something about how badly distorted things are.  Neonicotinoids were originally developed for a couple of specific reasons.  First, the apparent effect they have on vertebrates and mammals in particular is minimal.  In other words, while deadly to insects, visible effects on creatures that look more like we do are limited.  In this way, neonicotinoids behave just like the 50 foot wide "idiot strips" of trees clear-cutters here in Oregon leave along major roadways to hide the fact of the devastation they're wreaking from passersby unlikely to venture any deeper into what used to be the forest.

At this point you should be wondering about the EPA memo again.  The memo specifically cited danger to birds and mammals associated with Clothianidin usage.  Those are supposed to be the families of creatures  for which neonicotinoids are safe.  But, no such luck.  We already know it's bad for insects.  That's why Bayer made it.   Basically, it's bad news all around.  We lost our idiot strip....but we just keep on keeping on. Cynicism on an industrial scale.

The second major reason neonicotinoids were developed is that while nicotine itself has been used as an insecticide for about two centuries, it breaks down quickly and loses its effectiveness.  Neonicotinoids provide a "solution" to that problem because they persist in the environment for much (much) longer.  So, in the Orwellian logic of industrial agriculture, we win by permanently poisoning the biosphere.  Persistence coupled with regular use--such as yearly planting--means accumulation.  Accumulation means game over....unless you stop it.

There's more.  The way that Clothianidin is applied directly contributes to the idiot strip effect.  Rather than spraying or dusting it on (practices which almost always attract bad press), Clothianidin is applied as a coating to seeds prior to planting.  As such, people and communities present where Clothianidin is used mostly have no idea what's going on.  Unfortunately, the fact that it's applied to seeds doesn't make it any better for bees or other creatures.  A massive 2008 bee die-off in Germany which killed two-thirds of the bees in the Baden-Wurttemberg region, for example, was traced back to seed coating usage of Clothianidin.  Remarkably, Bayer claimed that the carnage was the result of misapplication of its product and that further claimed (successfully, at least as far as the EPA is concerned) that Clothianidin remains safe for bees and the rest of the environment.  Awesome.

Bayer's gyrations reveal one of the confounding mechanisms by which toxic-creating companies reap huge profits while pushing off even more massive environmental costs onto the rest of the planet.  Understanding this mechanism also helps explain the Law of Scientific Insufficiency.  It works like this:  once one of these poisons is put into play commercially, the burden of proof for taking it back off the market goes way up.  Basically, you need something like a smoking gun involving detectable levels of the toxin in a dead subject along with a causal explanation which rules out all other possibilities.

Consider this in light of the more recent research on Clothianidin and honeybees done by Dr. Pettis at Purdue which found that even at undetectable levels the substance wreaked havoc on bee colonies.  Without detection, Bayer keeps its fig leaf and continues to operate under a shroud of plausible deniability.  Clearly monstrous in its consequences, this way of weighing the evidence is also problematic for a couple of logical reasons.  First of all, if a really effective toxin (Clothianidin) is created--one capable of generating "results" at extremely low concentrations--it's also harder to detect.  The smoking gun gets harder and harder to find.  In market terms, the incentive here is clearly to produce super toxic substances that cannot be traced.  Perfect poisons.

Second, while in most scientific inquiry the best available theory is judged to be explanatory of a given phenomenon, a totally different set of rules is used to gauge evidence for removing a rogue pesticide from the market.  As with Clothianidin, it's not enough that we have substantial evidence of bee impact and can't come up with a better theory.  We actually have to find something like proof-positive.  In this regard, it's interesting to note that when bringing a product to market, for the most part the logic of the market itself is much like that used by 'normal' science:  the best available solution wins.  Products are not compared against absolute standards when considered for release, mostly only against competing alternatives.  But, when it comes time to pull a product that's causing trouble, the rules change and the burden of proof becomes much higher.  The market, like a lot of scientific inquiry, doesn't do a very good job of recognizing absolute standards such as the value of life or other 'intangibles'.

The market for toxins also neatly raises the problem economists talk about in terms of  'externalities':  real costs associated with a product, but costs which are borne by parties not having anything to do with buying or selling the product, e.g. honeybees, children, the biosphere, etc.  Even when these costs (externalities) can be demonstrated, markets themselves provide no way for anyone to get 'paid' for them.

So, let's think about Clothianidin and honeybees again, now in terms of pollination.  Even considered in the narrow human-purposed terms of pollination, there is a demonstrable cost associated with honeybee die-off.  A 2008 study in South Africa, for example put the annual cost of alternative pollination in single South  African province at approximately $350 million.  That lone province produces an almost inconsequential fraction of the world's food supply.  No one knows what the extrapolated figure would really be for a global die-off of honeybees (a real possibility), but it's probably safe to say the number would range into the hundreds of billions annually.  So, in the logic of the market, Bayer's $269 million dollar annual sales of Clothianidin trump the possibility of annual losses a thousand times that large.

The situation around Clothianidin and bees is just one spectacular (though apparently not enough so to warrant action) example of the larger logic of industrial agriculture:  increasingly powerful technology is leveraged to force very focused crop productivity from bio-systems that are by any measure failing globally under the strain.  These power moves 'work' according to the logic of the marketplace, but only because their truly massive costs are both directly subsidized ($20 billion in the US alone annually) or pushed off onto the biosphere in the form of much larger externalities.

What this amounts to is a gargantuan, annually renewing, white collar, bio-crime caper.  Imperiling a species such as the honeybee is something that all of us (humans and other creatures) will suffer for.  We have a word for this:  genocide.  The crime is committed willfully and in plain daylight by highly educated and highly paid professionals working from the safety of laboratories and offices, both in private industry and in government agencies.  You could also call it terrorism on a scale that dwarfs any of the things that supposedly sent the U.S. to war for the last two decades in places like Iraq and Afghanistan, except that a big part of the crime itself involves making us all feel OK about things.

Beating this kind of crime isn't that complicated, but it's not easy either.  It will almost certainly involve substitution of current market logic by something more like the precautionary principle which states that:

If an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action.

But, such substitutions are unlikely to occur because we just get smarter about things.  These are crimes fundamentally enabled by huge concentrations of power working in spite of both scientific knowledge and--more importantly--common sense.  They're crimes carried out by the 1% mostly against the 99% or--more accurately considered in terms which include species other than just humans--the 99.999%.  And, make no mistake about it, these crimes are fundamentally enabled by expert manipulation of scientific evidence, laws, and enforcement efforts.

The fix is going to be in communities (gardens, bee clubs, parents, farmers, food lovers) learning to call this situation what it is and learning to defend themselves against and push back the massive encroachment of industrial insanity on the shelves of the vast majority of stores everywhere.  It will come through localization of economies and the assumption of personal responsibility for land bases and watersheds.

Nobody else is going to do it for us.