Apologies in advance for the long post.  The problem with the precautionary principle is that when taken to it's logical conclusion, it yields absurd results.
 
Steve Noble wrote eloquently about the standards that he thinks the manufacturer should be held to.  Imagine briefly if honey were a relatively new phenomenon in an area and beekeepers were held to the same standard.  Who paid for the scientific studies proving that honey is a safe food product?  What about pollen and royal jelly?  What about the risks to the local population from stings?  What are the effects on the environment of displacing natural pollinators?  How about other interactions that honeybees might potentially have in a complex and interactive ecology?  Now ask how many beekeepers would take up the business if they had to front the cost of those studies themselves before they could even start selling?  Then how many would be willing to write a blank check to some independent researcher to double-check their work, still before you could even begin keeping your bees?
 
To take a single example further, honey may be associated with an increased risk of botulism.  How much testing will you pay for to prove that the risk is limited to very young children with immature digestive systems?  How will you 'prove the negative' that there is no equivalent risk to adults?  (Remember that you can't use the techniques that were actually used in that study - it depended on statistical analysis of honey use that was already widespread in the population.  The precautionary principle requires you to prove safety before people start eating it.)  How many times will you pay to rerun the analysis just because someone claims that your earlier study wasn't good enough?  By the way, the whole time you're running and rerunning these tests, your consumers are eating substitute products which are equally dangerous to young children and probably worse for adults.  You honestly believe that even if there is some small risk, your
 consumers would be better off with your product.  When do you decide that enough is enough and that it's time to go to market?  And how do you defend that decision when some new, unforeseeable circumstance presents itself?
 
If we really lived up to the precautionary principle and refused to allow anything new into the environment until it had been definitively and conclusively proven to be safe under all conditions, nothing would ever change.  And, counterintuitively, we would be far less safe as a result.  Modern pesticides have new and often incompletely-understood risks but we can already say that imidacloprid is far safer to the farmer, the consumer and the environment than the pesticides it replaced.  If the precautionary principle had been rigidly applied in the 1940s, we'd still be applying arsenic to our apples.  How many deaths and disabilities from the old pesticides should society be willing to pay while you wait for yet more tests about potential risks to honeybees?
 
Interestingly, you can apply the precautionary principle in reverse to this latter scenario.  I know that the old pesticides are killing people.  Any new pesticide might be better and result in fewer deaths.  In accordance with the precautionary principle, it could be argued that we have an obligation to use the new pesticides in order to find out if they're better.  (This is the aspect of the precautionary principle being argued in the climate change debate.  We don't yet know if any particular program will be effective but "we have to do something before it's too late.")  
 
My point is not that we should jump to new pesticides without testing or that the climate change arguments are wrong.  My point is that the soundbite 'precautionary principle' is remarkably unhelpful in giving any useful advice or rules of thumb about how to reduce total risks in the real world.
 
Should we continue to study the possible implications of imidacloprid on honeybees and other beneficial insects?  Absolutely.  New evidence should always lead you to reconsider prior decisions.  Should we withhold imidacloprid from the market until those implications are absolutely proven in every possible condition?  Not unless there is some evidence that the probability-adjusted risks outweigh the demonstrated benefits when viewed as a whole.  No product can ever be absolutely safe or idiot-proof and beekeepers don't have an inherently higher moral ground than the growers who benefit from imidacloprid and who use less alternative pesticides as a result.  Risks must be weighed based on the best evidence available at the time and social decisions must be made with what will always be incomplete information.
 
I echo Bill T's comment in support of Bayer's level of cooperation.  Let the science speak for itself.  In the meantime, conspiracy theories and calls for impossible standards are not helpful.
 
Mike Rossander
www.rossander.org/infosec


      

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