Introduction
Pesticides
Fertilizers
Veterinary drugs and health products
Genetic engineering
Food additives, processing aids and packaging materials
Introduction
A large body of literature has established that the conventional ood system is too dependent on inputs implicated in health, environmental and socio-economic problems. These inputs have evolved from research processes and scientists with minimal understanding of agroecology (see Goal 3, Public research, The problems of the dominant research and extension model). Unsurprisingly, the negative secondary effects of their adoption and use were not anticipated. Had they been, and with regulatory processes to identify them, many of these inputs would not likely have been approved. But the research systems of food have long served the needs of industrial capital and industrial approaches to high-yield agriculture (Albury and Schwartz, 1982), which means that the economic imperative has always driven food system technology development and approval.
Equally problematic is the way scientific information is interpreted by regulators. As described by MacRae and Alden (2002), at the core of the current system for reviewing the safety of technologies is the scientific assessment of hazard identification and risk management. The Network for Environmental Risk Assessment and Management (NERAM) defined risk management as “the means by which governments and other standard-setting organizations seek to define a rational level of acceptable or tolerable risk for an environmental hazard by considering the severity and probability of harmful health effects, the amount of environmental exposure experienced by human populations, the sources and means of control for the contaminant, and the expected costs and benefits of various risk reduction strategies.” (McColl et al., 2000).
But, “the science [policy-makers] seek is one that is capable of being justified and explained to a wide variety of publics.... It must facilitate clear choices. It must represent a body of evidence on which decisions can rest and be seen to be rational.” (Salter et al., 1988). As such, regulators attempt to minimize the likelihood of concluding there is an effect when one doesn’t exist, avoiding the possibility of “over" regulating (known in statistics as minimizing the possibility of a Type I error). However, this approach increases the likelihood of a different error: concluding that there is no effect when one actually exists (or a Type II error) (Tickner, 1997). In some studies, its been found that Type II errors have up to a 50 per cent possibility of occurring (Schrecker, 1984). Consequently, policymakers may claim that a risk doesn’t exist when it does, and this would occur more frequently than the other way around. Policy-makers usually seek a high level of certainty before acting. But, “basing regulations on scientific data is not always clear-cut since it may take years before scientists generally agree about results of controversial studies.” (Congressional Research Service, 1999). Rather than deal with such ambiguity, regulators often treat the absence of fully confirmed evidence as proof there is no relationship. With this approach, the possibility that the effect has yet to be observed because we do not know how to “see” it is not well considered (MacRae et al., 1989). These problems are more apparent when examining the chronic effects arising from long-term, low-dose exposures. Risk assessments in this latter category often fail because of a lack of data, incomplete methodologies, and/or an inconsistent application across studies (see Cooper et al., 2000). While there has been some progress on appreciating uncertainty and the precautionary principle, these approaches are still not dominant in technology assessment and decision making.
These problems are compounded by the reality that many hazards are associated with products and services deemed essential (at least by powerful actors) to society. Whether they are is a larger question about values, needs and wants and the nature of modern capitalism, beyond the scope of this section. Applications for approval are typically put forward by the producers of the goods and services, who present them as "innovations" to provide benefits. Decision makers, in turn, often trumpet innovation agendas that re-inforce the status quo. Social benefits of such innovations and societal necessities are often assumed, assumptions generally not tested because the food safety regulatory apparatus is not required to do so. The dominant view appears still to be consistent with a government statement from 1994 (Government Response to the Report of the Standing Committee on Agriculture and Agri-Food, “rbST in Canada,” August 1994):
“The standard procedure in Canada and other industrialized countries is to regulate products based on scientific principles... Once safety and effectiveness have been reviewed, it is the marketplace in Canada which then decides on the market acceptance of the product, based on benefits such as price and individual values and preferences.”
This represents a modern day version of the historical integration of science and technology with industrial capitalism. Related to this reliance on the market is the premise that regulators largely respond to "innovations" put forward by industry. They do not actively shape, at least in the food system arena, what inputs are being proposed. Again, there is no attempt to identify what is socially beneficially, and then encourage innovators to submit applications with such products.
Despite vast literature identifying the problems of these approaches and the inability of the market to properly value human and environmental health, and given the many questionable products approved, albeit with some regulatory improvements over the years to address the criticisms, we are still left with systems guided by these old concepts.
A related problem across all input categories is the setting of Maximum Residue Limits (MRLs), post-market surveillance, inspections and enforcement, primarily under the authority of the Canadian Food Inspection Agency (CFIA). Considerable resources have been devoted to these programs, often with significant benefits, but they are not commensurate with the scales of the challenges as food system complexity and distancing have increased. Programs have been criticized for (based on MacRae's extensive work on these issues in the 2000s):
- MRLs in some contaminants that don't account for chronic low level exposure, aggregated impacts across residue classes, or residue cocktails
- small sample sizes (especially when compared to other jurisdictions such as the EU and Japan),
- limited numbers of contaminants monitored in some categories
- testing protocols that often result in foods being consumed prior to contaminant identification,
- conflicts of interest regarding import and export promotion versus food safety,
- complaints-based investigation rather than proactive monitoring,
- and insufficient resources devoted to inspection and enforcement.
- weaknesses in labelling and traceability that sometimes mean there is no way to link consumption to health impacts,
- failure to properly support market basket studies like the Total Diet Studies carried out periodically by Health Canada( cf. Conacher et al., 1989; Conacher and Mes, 1993; Environmental Defence Canada, 2003), but not necessarily well analyzed for lack of funds; such studies suggest that contaminant problems are higher than regulators want to acknowledge because the implications for how the food system functions are significant.
While significant, these problems are not the focus here as the priority is identifying ways to reduce reliance on and use of these inputs, and thereby take some pressure of post-market surveillance systems. Given that many problems are associated with imported foods, that the initiatives proposed here are also about building domestic self-reliance will also take some pressure of import monitoring.
This section is about how to change federal regulatory approval systems and associated government programs to reduce reliance on such inputs and support the shift to more sustainable approaches. The sustainability, health promotion and equity framing of food system change allows for more intrusive interventions in market function, a recognition that the current reliance on markets to determine input acceptability is a flawed interpretation.
