E Crop Chemophobia N T I “Crop Chemophobia offers a science-based consideration of the impact of agricultural technol - N ogy and highlights the need to give more thought to the principles guiding the regulation of E food production. This is more than an academic debate; it could save lives.” —Mike Johanns , U.S. senator for the state of Nebraska and former secretary of the U.S. Department of Agriculture “Crop Chemophobia should be required reading for policymakers. Our greatest challenge in the next forty years will be to feed billions more people on our planet with the same land resources we now use. As this important book demonstrates, we need to have science-based discussions about how to accomplish this. In the decades ahead, the greatest risk of all may be blind adherence to the precautionary principle.” Crop Chemophobia —Bob Stallman , president, American Farm Bureau Federation C r “By placing science above scaremongering, this book should stimulate a more informed and o balanced debate on the importance of pesticides in meeting the challenges posed by popula - WILL PRECAUTION KILL p tion growth and a changing climate.” —Ian Denholm , Rothamsted Research, United Kingdom C h THE GREEN REVOLUTION? “Many consumers today rely on sensationalized media reports to form their opinions on food e production. Crop Chemophobia does an excellent job of going beyond the emotional debate m over the use of crop inputs. Those concerned with a growing world population and food inse - o curity should look closely at the consequences of removing a vital tool of food production.” p —Mike Adams , host, AgriTalk: The Voice of Rural America h o “Timely and important, this book is a call to action. We cannot afford to allow a narrow, b technology-averse agenda to saddle our global food-production system with constraints that i are costly and scientifically unwarranted—not when we face the challenge of doubling food a production in the next four decades to meet expected demand.” —W. Daren Coppock , president and CEO, Agricultural Retailers Association Contributors: Jonathan H. Adler, Claude Barfield, Jon Entine, Euros Jones, Douglas Nelson, Alexander Rinkus, Richard Tren, Mark Whalon, and Jeanette Wilson ISBN-13: 978-0-8447-4361-5 ISBN-10: 0-8447-4361-5 EEDDIITTEEDD BBYY JJOONN EENNTTIINNEE Cover photos: Top: Image courtesy of Paul L. Nettles Bottom: Image courtesy of Neil Palmer (CIAT) CropChemophobia 11/23/10 11:26 AM Page i Crop Chemophobia CropChemophobia 11/23/10 11:26 AM Page ii CropChemophobia 11/23/10 11:26 AM Page iii Crop Chemophobia Will Precaution Kill the Green Revolution? Jon Entine, Editor The AEI Press Publisher for the American Enterprise Institute WASHINGTON, D.C. CropChemophobia 11/23/10 11:26 AM Page iv Distributed by arrangement with the Rowman & Littlefield Publishing Group, 4501 Forbes Boulevard, Suite 200, Lanham, Maryland 20706. To order, call toll free 1-800-462-6420 or 1-717-794-3800. For all other inquiries, please contact AEI Press, 1150 Seventeenth Street, N.W., Washington, D.C. 20036, or call 1-800-862-5801. Library of Congress Cataloging-in-Publication Data Crop chemophobia : will precaution kill the green revolution? / Jon Entine, editor. p. cm. Includes bibliographical references and index. ISBN-13: 978-0-8447-4361-5 (cloth) ISBN-10: 0-8447-4361-5 (cloth) ISBN-13: 978-0-8447-4363-9 (ebook) ISBN-10: 0-8447-4363-1 (ebook) 1. Pesticides—Environmental aspects. 2. Environmental risk assessment. I. Entine, Jon. II. American Enterprise Institute for Public Policy Research. [DNLM: 1. Food Contamination—prevention & control—Europe. 2. Food Contamination—prevention & control—United States. 3. Conservation of Natural Resources—Europe. 4. Conservation of Natural Resources—United States. 5. Food Supply—Europe. 6. Food Supply—United States. 7. Pesticides— adverse effects—Europe. 8. Pesticides—adverse effects—United States. 9. Public Policy—Europe. 10. Public Policy—United States. WA 701] QH545.P4C76 2010 363.17'92—dc22 © 2011 by the American Enterprise Institute for Public Policy Research, Washington, D.C. All rights reserved. No part of this publication may be used or reproduced in any manner whatsoever without permission in writing from the American Enterprise Institute except in the case of brief quotations embodied in news articles, critical articles, or reviews. The views expressed in the publications of the American Enterprise Institute are those of the authors and do not necessarily reflect the views of the staff, advisory panels, officers, or trustees of AEI. Printed in the United States of America CropChemophobia 11/23/10 11:26 AM Page v Contents LIST OF ILLUSTRATIONS viii INTRODUCTION: FOOD, PESTS, AND THE CHEMICAL CONUNDRUM, Jon Entine 1 Toxic Limits 3 Precautionary Politics 6 The Chapters 10 Notes 12 PART I: PERSPECTIVE 13 1. EUROPEAN PESTICIDES AND HERBICIDES IN THE CROSSHAIRS, Euros Jones 15 How Did the Legislative Process Evolve? 15 What Changes Were Proposed in the Negotiations? 17 The Hazard-Based Cut-Off (Rejection) Criteria 18 “Endocrine Disruption” 18 Which Substances Will Be Affected by the Cut-Off Criteria? 19 Cut-Offs and the Derogation Clause 19 Food Safety in a European Context 20 Science and Political Contradictions 22 EU Leading the World in Food Safety? 23 The Influence of NGOs 24 The Precautionary Principle 25 The Precautionary Principle and the Hazard Criteria 26 The Impact on Agriculture and Food 26 The Impact on Research and Innovation 28 Conclusion 30 Notes 31 v CropChemophobia 11/23/10 11:26 AM Page vi vi CROP CHEMOPHOBIA 2. THE PROBLEMS WITH PRECAUTION: A PRINCIPLE WITHOUT PRINCIPLE, Jonathan H. Adler 33 The Precautionary Principle Defined 34 The Precautionary Principle Abroad 38 Is Precaution Safer than the Alternatives? 40 Precaution and Pesticides 41 Wealthier Is Healthier and Richer Is Cleaner 43 Precaution’s Appeal 45 In Search of Safety 46 Appendix to Chapter 2: The Wingspread Statement on the Precautionary Principle 48 Notes 50 PART II: CASE STUDIES 55 3. THE CASE OF ATRAZINE, Jon Entine 57 Studies and Regulation 59 Harm versus Risk 61 The “Endocrine Disrupter Low Dose” Hypothesis Controversy 63 The Politics of Atrazine Research 66 A Precautionary Future? 71 Notes 73 4. THE TART CHERRY: PESTICIDES AND PRECAUTION, Mark Whalon and Jeanette Wilson 76 A Brief History of U.S. Pesticide Legislation 77 Regulatory Changes under the Food Quality Protection Act 79 The Impact of the Food Quality Protection Act on the Tart Cherry Industry 80 Global Long-Term Implications 86 Preempting the Precautionary Principle 87 The Future 89 Notes 91 CropChemophobia 11/23/10 11:26 AM Page vii CONTENTS vii 5. UNINTENDED CONSEQUENCES: DANGEROUS MISCONCEPTIONS ABOUT PUBLIC HEALTH INSECTICIDES, THE ENVIRONMENT, AND HUMAN HEALTH, Richard Tren 93 DDT—Setting the Stage for the Anti-Insecticides Movement 97 Dangerous Misperceptions—DDT and Wildlife 98 The EPA Takes on DDT 100 DDT and Human Health 103 DDT Use Globally 104 Anti-Insecticides Movement 106 Are There Effective Alternatives to Insecticides? 107 Conclusion 108 Notes 109 PART III: PRECAUTIONARY POLITICS 113 6. PRECAUTION, CUSTOM, AND THE WORLD TRADE ORGANIZATION, Claude Barfield 115 Precaution 116 Customary International Law 117 The World Trade Organization, the Precautionary Principle, and Customary International Law 119 REACH, the Precautionary Principle, and the “Law’s Migration” 124 Notes 128 7. FEEDING A HUNGRY WORLD: OPPORTUNITY AND OBLIGATION FOR U.S. AGRICULTURE, Douglas Nelson and Alexander Rinkus 131 Notes 141 INDEX 143 ABOUT THE AUTHORS 155 CropChemophobia 11/23/10 11:26 AM Page viii List of Illustrations FIGURES 4-1 Summary of U.S. Pesticide Legislation from 1900 to the Present 78 4-2 EPA Pesticide Reregistration Process Implemented under the Food Quality Protection Act 81 4-3 Ecological Impacts of Organophosphate-Based versus Food Quality Protection Act Insecticide Programs on Orchard Ecology 83 4-4 Trend of Average Insecticide Costs per Acre from 2004 to 2009 between Reduced-Risk and Conventional Pest Management Systems in Nine Michigan Tart Cherry Orchards 85 4-5 Diversity Trends in Different Modes of Agricultural Practice, as Compared to Uncultivated Ecosystems 90 7-1 U.S. Farm Labor Levels Relative to 1950 134 7-2 U.S. Corn Yields, 1880–1970 135 7-3 U.S. Rice Yields, 1899–1989 137 7-4 U.S. Wheat Production, 1900–2009 138 TABLES 4-1 Tart Cherry Industry’s View of the Impacts of the Food Quality Protection Act 82 7-1 U.S. Crop Losses without Insecticides 136 viii CropChemophobia 11/23/10 11:26 AM Page 1 Introduction: Food, Pests, and the Chemical Conundrum Jon Entine The plea to “save the earth” is resonant and critically important to a sustainable future. But what does that mean in practice? Every action indeed does lead to a reaction. This complex world is interlinked, and well-meaning initiatives are often twisted by unintended consequences. When it comes to public policy, prudence is important. Risks need to be examined in the light of not only rewards but also the likelihood of gener- ating new, unforeseen risks. Sometimes the balance between saving the earth and saving humans can be lost. This is a book about understanding and preserving that balance. If the loudest voices in the environmental movement are to be believed, we are on the edge of ecological Armageddon because of the threat of chemical contamination posed by modern agricultural farming. “Name a vegetable, and I’ll tell you how dangerous it is,” says Brian Hill, senior scientist for the Pesticide Action Network (PAN), the advocacy group lead- ing the campaign to ban many agricultural chemicals. I name broccoli, my daughter’s favorite vegetable. His voice turns grave. “The United States Department of Agriculture tested 671 samples in 2007,” he says. “Forty different residues showed up. Five are known or possible carcinogens; nineteen are suspected hormone disrupters; three can cause develop- mental or reproductive problems; nine are considered neurotoxins.” 1 CropChemophobia 11/23/10 11:26 AM Page 2 2 CROP CHEMOPHOBIA According to Hill, 1,100 pesticides can be found in the U.S.