Veterinary drugs and animal health interventions

Genetic engineering

Food additives, processing aids and packaging materials


The food 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 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.  This assumption of societal benefit is generally not tested because the food safety regulatory apparatus is not required to assess it.  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.”

Despite vast literature identifying the problems of these approaches, and some regulatory improvements over the years to address the criticisms, we are still left with systems that continue to be guided by these old concepts.

This section is about how to change regulatory approval systems and associated government programs to reduce reliance on such inputs and support the shift to more sustainable approaches.