I feel there is a lot of discussion about organic and a insensible amount of research comparing it to conventional farming, but very little critically addressing the legislation – EC Regulation (2008) No 834/2007 On organic production and labelling of organic products. This is important because, for what is supposed to be the EU’s gold standard eco-regulation, it is disastrously simple to make it more eco-friendly… so simple in fact that any teenagers with GSCE science could do it in a single breath. This matters, for producers, consumers and of course, for the environment and our global effort for sustainable living.
- There is a scientific fallacy written into the legislation
Can you imagine if aeronautical engineering legislation was derived from a belief that the Earth was flat? What about if regulations governing the approval of medicines were restricted based on astrological systems of thought? How many planes would fall out of the sky? how many lives would be lost as effective medicine are held back because mars isn’t in the right zodiacal house? When we allow mistaken notions of reality to drive approaches to problem solving the outcome is negative more often than not.
What about if our global effort to save the environment were based on the Appeal to Nature? Well, this is how the Organic Regulation is written.
The regulation begins:
“Organic production is an overall system of farm management and food production that combines best environmental practices, a high level of biodiversity, the preservation of natural resources, the application of high animal welfare standards and a production method in line with the preference of certain consumers for products produced using natural substances and processes”
The problem here is a big one… it is suggesting that natural substances and process are better than non-natural substances and processes, this is the famous natural=good myth and it has no place in regulation because it doesn’t exist in reality. This is a myth that the Royal Society of Chemistry think we should have grown out of by around age 14. The Royal Society (2006) teaching materials on the natural myth mention organic farming specifically.
Having a myth like this in legislation is the same as having a regulation that says “Let’s govern aviation in accordance with the belief of some consumers that the Earth is flat”. It’s nonsense. It is one thing for consumers to believe in a myth, but it is unthinkable for a piece of legislation to enforce this.
Immediately after the first sentence above, the regulation claims that “organic thus plays a dual social role”. On the one hand it gives consumers what they want – ‘natural’ products, and on the second hand wants to use ‘best environment practices’. The problem is that the two are often incompatible. ‘Natural’ and eco-friendly are often opposing forces. Making compromises on two fronts like this usually means you end up doing neither very well. This is exemplified by the surprise among consumers that organic isn’t as natural as they might think, and the disdain among many scientists that it prohibits some of our best environmental practices. You can either be the most environmental, or the most natural, but certainly not both!
The regulation really needs to be split into two separate regulations – one for eco-friendly products and one for natural products- although hopefully demand for the latter would diminish as soon as consumers realise that natural and best-for-the-environment are not synonymous terms.
The legislation bans or prohibits a number of things, not on any scientifically rational basis, but instead on consumer whim. In a sense it puts the environment in the hands of market trends. One example is the phrasing in the text prohibiting GMOs / They are banned not for environmental reasons but instead because they are incompatible with “consumers’ perception of organic products”. This is the wrong reason to ban anything, specifically if your goal is to save the environment. Banning something because consumers don’t like it is different from banning something because it is bad for the environment.
On top of this, the regulation later rules that only Organic farmers are allowed to label themselves using terms like ‘eco-friendly’, meaning that if an organic farming method is less ecological than a rational alternative, the organic farmer can still market himself as eco-friendly, while the rational farmer cannot. This is extremely unfair on both producer and consumers. The farmers I wish to buy from are the real eco-farmers, but they are hidden in the market because of the organic favouritism from the EU. This makes it very difficult for scientifically informed consumers wishing to express their ecological conscience at the supermarket to find products that share the same eco-values. Organic certainly is not that choice for precisely the same reason I wouldn’t board a plane designed by a flat-earther.
So why can’t this work? The Ideal Dilemma
This sort of irrational prohibition of anything not ‘natural’ is a problem because we know that it will always on average deliver worse outcomes than an equivalent scheme which has the fallacy removed. That is to say, both evidence-driven approaches and ideational or preference-led approaches to farming may draw on scientific knowledge to learn what the best practice’s are but while an evidence-driven approach can do whatever works, ideational approaches can only ever be equal to whatever works minus any methods prohibited by its pre-concocted paradigms and preferences. This notion was briefly touched on by Bahlai et al (2010) in a paper comparing organic and IPM, but I don’t think the importance of the statement was fully realised. Let’s take it from the top…
Start with a problem and a desire to solve it. This could be anything from ‘how to get the bus stop on time’, ‘how to solve the AIDS crisis in Africa’ or, as I will focus on, ‘how to provide enough food with minimal impacts on ecosystems’. For any given problem there may be a number of solutions or approaches. Our first move is to create a toolkit which contains all possible solutions ever proposed for a given problem, no matter how good or bad. This is the All-Approaches toolkit (figure 1a). For agriculture it contains every pest control method ever conceived for every pest that ever existed; every method of delivering nutrients, saving water, maintaining soil health; every tractor engine ever designed; every rotation thought-up; every combination of crops, cover crops and so on…
Once you have all possible solutions identified as your starting toolkit you can begin to assign various possible filters or screening criteria by which you eliminate some solutions and hold on to others, creating subsets of this initial total-toolkit. Any subset is by definition smaller than the full toolkit and wholly contained within it. You can define any subset you like – all methods beginning with the letter G, for example, or all those invented in an even numbered year and then you could go ahead an only use those methods in your defined subset. Of course, it is more common in policy to try to define subsets which have practical applications. You may want to define a subset made of only the most eco-friendly farming practices (you could, of course have other criteria such as ‘most economical’ or ‘most healthy for the consumer’ but the principle will still apply). I would argue that the first half of the EU Regulation excerpt above does just that. It defines a subset of All-Approaches which meet the criteria of “best environmental practices, a high level of biodiversity, the preservation of natural resources, the application of high animal welfare standards”. All the most eco-friendly methods devised are included in this theoretical toolkit, and everything which is 2nd best to very worst is not included (figure 1b). Just like any other subset you can name, this one will be necessarily smaller, and wholly contained by your initial All-Approaches toolkit. In terms of environmental outcomes, this is the Best-Approach toolkit.
For the purposes of reasoning it does not matter whether or not we actually have the ability to identify the best practices, all that matters is that one definitely does exist. In the same way that no-one could possibly claim to know how many blades of grass exist on Earth at a given time, nevertheless, that number does exist and we are able to talk about it.
Now ask yourself, is it possible to modify the collection of practices which have been defined as ‘best environmental practices’ to make the subset even better for the environment? Can you define a subset superior in ecological terms to this one?
No, of course not. It is literally by definition the very best possible toolkit.
EU Decision makers apparently disagree with me on this point and take the approach of applying a second filter, creating an additional subset. The second subset is defined in the legislation as:
“products produced using natural substances and processes”
To be clear, two subsets defined here – ‘best environmental practices’ and then ‘practices considered natural by consumers’. The toolkit legislated by the organic regulation can then be said to be then defined as the overlap of these two subsets (area y in Figure 1c). At any given point in our technological development the overlap between the two defined subsets will no doubt change. One year, the best pesticide for dealing with one specific pest with the least environmental impact may be something natural, the next year, a smart chemist may improve natures design, the year after some explorer could find a better natural product somewhere deep in the rainforest, and the year after, another chemist may study the structure of this new chemical and then improve it. As this ongoing process of technological change continues, the overlap will grow and shrink accordingly. In years one and three, organic will be able to use the best environmental practice, however, in years two and four it will not and it will thereby be less ecological than an equivalent regulation than simply eliminates the need for the second subset, that of naturalness.
Given that even a single farm will have many different issues to manage (soil, nutrient, many different pests, etc) it is highly improbable that the two subsets will ever be equal to each-other. That is subset a does not equal subset b, and likely never will.
The most important part of Figure 1c is the area labelled x. In terms of our subsets what does this area contain? If area y is the best practices which are also natural, area x is the best practices which are not-natural. That is to say, it is the sum of the most eco-friendly practices which are forbidden in Organic Agriculture. To be absolutely clear we now have an eco-policy which by definition prohibits some unknown portion of the toolkit of Best-Approaches.
When you apply a modifier to a toolkit which is by definition THE BEST the resulting toolkit will always be worse because it will never wholly overlap the Best-Approach toolkit, and will thus inevitably throw out some number of Best-Approaches. The net effect of this is that it reduces ability of the person using the toolkit to be as eco-friendly as possible.
How much worse the combined toolkit performs depends on the several factors which combine to form an Impact Potential, which we will look at in another blog, however this is the essence of the ideal dilemma. The organic regulation will by definition always be less ecological than an identical piece of legislation with the preference for naturalness removed.
This should be highly embarrassing for the decision makers behind the EU flagship eco-certification scheme – that it can be instantly made significantly more eco-friendly by somebody with the scientific competence of a 14 year old.
Bahlai, C. a., Xue, Y., McCreary, C. M., Schaafsma, A. W., & Hallett, R. H. (2010). Choosing organic pesticides over synthetic pesticides may not effectively mitigate environmental risk in soybeans. PLoS ONE, 5(6). http://doi.org/10.1371/journal.pone.0011250
EC Regulation (2008) No 834/2007 On organic production and labelling of organic products and repealing Regulation (EEC) No 2092/91,.
Royal Society of Chemistry (2006) ‘Natural or Man-made chemicals?’, [online] Available from: http://www.rsc.org/images/NaturalNotes_tcm18-115179.pdf (Accessed 4 September 2015).