This is part of the book “Stéphane Foucart et les néonicotinoïdes. The World and disinformation 1” in which we analyze in depths a few articles of the corpus. All quotes are translated (by me), except the ones marked between [ ] in the french version (french quotes are to numerous to be marked in this one).

This fairly long article ( (2) July 9, 2012 : « La faillite de l’évaluation des pesticides sur les abeilles ») poses the whole of the argument that S. Foucart will develop over the next 9 years around the involvement of agrochemicals in the risk assessment procedures of pesticides.

Above all, its mechanism of affirmation by innuendo is used extensively.

1. The story

This article shows remarkably the mechanics of innuendo. Here is another reading of the story of the article, highlighting the different stages of the history that S. Foucart sells here.

a. Prelude: closing the field of possibilities

Recall the beginning of the article:

“Is the culprit rather incompetence or the accumulation of conflicts of interest? Impossible to decide. But the question now arises: how could the notoriously deficient bee risk assessment tests have been used for nearly twenty years to approve the latest generations of insecticides? ” (2)

You can see that nothing is stated clearly: one would not know whether it was “incompetence” or “conflict of interest” which would be “guilty“. We know, however, that it would either be one or the other. The author thus closes the field of possibilities.

b. Orient surreptitiously

From the start, he guides the reflection:

“This failure is all the more disturbing as some of these benchmarks were updated in 2010 …” (2)

Why would this failure be “troubling” if it was about incompetence? It would then be appalling, shocking, but not “disturbing”. This term implies that there is something hidden and suspicious… like a conflict of interest. The author thus directs, implicitly, from the beginning towards an answer to the choice presented at the beginning.

c. Build credibility and set the scene

The author then sets out the framework, recalling at length several technical aspects of the weaknesses of regulatory tests and their consequences. In doing so, he gives credibility to his speech overall, citing several technical data and scientific studies.
The message here is that the flaws are obvious, well-known, and the subject of “an increasing number of studies published in scientific journals since the mid-2000s.” Above all, this leads to the question “why?”, (= How such an absurdity can exist?) Which will be studied next.

He distills the idea of something hidden, shameful even further with the intervention of the anonymous apidologist.

  • The term “secret” refers to something secret, shameful (like a conflict of interest…)
  • The fact that he requested anonymity suggests that he would say something that could harm him, as if there were forces trying to keep these loopholes a secret. This may be overinterpretation (there are endless reasons to prefer anonymity), but this is the only time anonymity is specified; what he says is absolutely banal; this considerably reinforces the conspiracy that is distilled, as we shall see, in the article (and generally in his work).

This practice of giving the floor to others by clearly endorsing what they say is fairly systematic in S. Foucart. This allows him to clear himself (“I’m just quoting“) while clearly promoting a speech.

Finally, note an important manipulation here: regulatory tests must make trade-offs between certainty (infinitely long to obtain) and uncertainty. However, the author does not say anything about the terms of this arbitration, suggesting that the pre-marketing tests should require absolute certainty. This allows him to cover up part of the question and justify the split he posed earlier: They are either stupid or malicious.

d. The explication

The question arises very logically: “Why such inertia?” “The question already finds the beginning of an answer in the title of the part: from “generous sponsors”…
The author gives a voice to beekeepers by letting them, in essence, recount the suspicions and the steps that would have enabled them to let the cat out of the bag1: the involvement of the EPPO in the design of the test guidelines.

“Why such inertia? How, and by whom, are these test protocols for suspected severe myopia developed? “In 2006, we asked ourselves, a little late it is true, the question of how were approved at European level the substances that we suspect to be the main cause of the decline of bees, says Janine Kievits, a Belgian beekeeper, member of the European Apicultural Coordination. Reading the annexes to the European directive on phytosanitary products, we noticed that the guidelines for these tests were notably issued by the European and Mediterranean Organization for the Protection of Plants [EPPO]. ” Other guidelines are issued by the Organization for Economic Co-operation and Development (OECD) and are complementary to those of the EPPO. ” (2)

The beekeeper cited specifies that the tests would be “in particular” enacted by the EPPO. The term “enacted” refers to a regulatory power and not an advisory one. Would the EU be devoid of discretion over the EPPO decision? I highly doubt it. Note the interest of the spokesperson’s strategy: S. Foucart can always avoid this imprecision by stressing that it is not he who is speaking…

e. The EPPO’s role

EPPO would be an intergovernmental organization. Having no in-house expertise, it would delegate to the ICPBR “the task of developing the basic elements of these famous standardized tests.”

The author gives no source at this stage: the directive, the nature of the EPPO, the terms of this delegation, etc…. The ICPBR would be a “quasi-informal” structure. The author does not specify what he means by that and we do not see what it could be. However, we can clearly see a usefulness of this mention: it feeds the idea that there would be hidden, occult things.

The small group of beekeepers who had embarked on this investigation went to a meeting of this structure in 2008. It fits into the register of the investigation to uncover a hidden reality.

f. The financing from agrochemicals

This is an important point of the article: the conference would have started by thanking its “generous sponsors: BASF, Bayer CropScience, Syngenta and DuPont”. (4 companies producing fertilizers and pesticides)

“”When we heard that this organization was meeting to reform the famous standardized tests, we went to the conference, says Ms. Kievits. It was in Bucharest, in October 2008. “

The small delegation of three beekeepers therefore attended the meeting. First surprise, says Janine Kievits, “the discussions begin with a speech thanking the generous sponsors: BASF, Bayer CropScience, Syngenta and DuPont”. Contacted by Le Monde, the ICPBR working group on bee protection confirms the financial support of the main manufacturers of pesticides. But adds that the main source of funding was the costs of attending the conference. And that “without this external funding, the amount of participation fees would have been higher”, thus preventing “a maximum participation of delegates not from industry” “ (2)

This passage shows another technique of S. Foucart: his objections management. The ICPBR’s response will not be supported or repeated by any element presented by S. Foucart. On the contrary, the idea of hidden conflicts of interest is present throughout the article.

In this way, the objection is automatically passed off as the contempt of someone who is caught in the act and tries to find an excuse. Since he mentions the objection, S. Foucart is credible. On the contrary, the sheer force of storytelling, of the “flow” that it imparts to its story, undermines the objection. All without having had to discuss it a little bit.

g. The conference

Then the 3 beekeepers recount their experience of the conference:

“The three beekeepers are still attending the report of the working groups on the update of the standardized tests. “We were in a very cordial atmosphere, with very friendly people who offered things that were radically unacceptable, believes Ms. Kievits. To give just one example, one of the risk calculations presented amounted to defining a product as’ low risk ‘as long as the bee is not exposed to the chronic “lethal dose 50″ [which kills 50% of a population exposed over a long period]. Therefore the product is’ at low risk’ if it is not kills only 49% of bees! For us, it was just amazing. It was to die for! ” ” (2)

The precision “in a very cordial atmosphere, with very friendly people who proposed things that were radically unacceptable”, showing a dissociation between the atmosphere, “with very pleasant people“, and the fact that the latter offer “unacceptable things” is maybe anecdotal… or maybe not.

First of all, we do not see what it brings informally. If we look at the level of symbolism, this precision evokes a frame of reference, that of leaders disconnected from reality and able to order atrocities without batting an eyelid. It is a frame of reference which is important for the conspiracy, which we will discuss later, which is central to the overall work of S. Foucart.

Back to our beekeepers.

“On several comparable points, beekeepers are asking for the opportunity to send comments, hoping to change the final recommendations of the working group. “We sent our comments within two weeks, but not one was accepted,” says Ms Kievits. These same criticisms were addressed, in copy, to ad hoc agencies in EPPO member states. None responded, with the exception of the Swedish Chemicals Agency (KEMI). In a letter of which Le Monde has obtained a copy, two ecotoxicologists from the Scandinavian agency say they “fully” adhere to the bitter comments of beekeepers …

Why did the ICPBR not accept the requests of the beekeepers? “ (2)

This is undoubtedly the most astonishing point of this passage on several levels: S. Foucart presents as a mystery the fact that an international organization bringing together chemistry scientists and government agencies ignored the suggestions of 3 visiting beekeeper… (2 I caricature, they were members of the prestigious “European beekeeping coordination“…) He gives the answer:

““The group’s final recommendations are based on a consensus approach, with agreement being reached in plenary,”the ICPBR told the ICPBR. This consensual approach de facto places recommendations from the organization in the hands of the industry. Because the ICPBR is open to any participation and agrochemical companies are well represented. In 2008, of the nine members of the bee protection group, three were employed in the agrochemical industry, one was a former employee of BASF and another future employee of Dow Agrosciences.” (2)

Which is terrible:

  • The author does not consider any other possibility. The elements presented are therefore presented as the exclusive cause. However, he does not make it explicit. He just asks a question, then says things. It is again the strategy of juxtaposition, which consists in creating a logical link without making it explicit. Here the “because” is left entirely to the reader’s imagination.
  • His argument itself does not hold water at all. If it’s consensual, anyone can block the process. It is therefore, on the contrary, unfavorable to large groups.
  • The mere fact of being a former, current or future employee of an agrochemical company would make you its representative… The author show no evidence supporting the slightest his allegations. An employee who is not on a mission for his company has no particular obligation towards them and agrochemicals is not a quasi-mafia space where this would be the case (what S. Foucart suggests).

h. The next conference

The author moves on to a section titled “Conflicts of Interest”.

“During its last conference, at the end of 2011 in Wageningen (The Netherlands), seven new working groups were formed on the issue of the effects of pesticides on bees, all of which are dominated by researchers in conflict of interest situations. The participation of experts employed by agrochemical firms or private laboratories under contract with them varies between 50% and 75%. The other members are experts from national health security agencies or, more rarely, scientists from public research. Pesticide manufacturers therefore play a key role in the design of tests that will be used to assess the risks of their own products on bees and pollinators. “ (2)

We see here the absurd conception of conflict of interest used by S. Foucart. To be “independent”, one would have to be employed neither by the firms themselves nor by the private laboratories (why this precision?) contracting with them.

We then see the slide: the scientists who would correspond to this conception of the conflict of interest are considered to be the proxies of the companies: “The manufacturers of pesticides therefore play a decisive role …”

Finally, note that S. Foucart gives nothing to support these figures or to justify that the mere presence of said experts characterizes a “decisive role”. Indeed, we do not know exactly how these meetings are organized, what the balance of power is, etc.

i. Bucarest’s epilogue

In 2009, a few months after the Bucharest conference, the final recommendations of the ICPBR were delivered to the EPPO. But before being adopted as official standards, they are subject to review by experts mandated by each EPPO member state. Are these experts in a conflict of interest situation? Are they competent? Impossible to know. “The list of these experts is not secret: it is accessible to the governments of our member states who wish it, but it is not made public,” says Ringolds Arnitis. In 2010, the new guidelines are adopted by the member states of the organization and published in EPPO Bulletin.” (2)

Why should the identity of these experts be public? Why would the general public have anything to say about it? The author presents this as obvious, when it makes no sense. Besides, it seems to contradict what he just wrote: hadn’t he said that some of the members of the working groups had “a decisive role”? There he shows that there are other experts who have a decisive role… How many other decisive role exist?

The judgment of the experts commissioned by the EPPO member states raises a few questions. In the case of Sweden, the expert representing this country, from the Ministry of Agriculture, approved the new standards while two of his peers from the Swedish Chemicals Agency came, by letter, to bring their support for critical comments from the European Apicultural Coordination. The judgment of the experts therefore varies widely depending on their employer…” (2)

We can see here why we have to be very careful in public relations, especially with activists. The opinion of the Swedish agency’s ecotoxicologists says nothing about the agency’s opinion, or even what they themselves would have decided if they had had to choose. It is always easier to say that the loopholes are revolting, than to make a trade-off between the objectionable option and its alternatives.

Despite this, S. Foucart uses the support of two members of the agency to promote the idea that the expert chosen by Sweden would be influenced. It also implies that the Swedish ministry would defend the interests of the agrochemical industry…3

And France? The approval of the new 2010 standards was carried out under the supervision of an ecotoxicologist from the General Directorate of Food (Ministry of Agriculture) – which represents France at EPPO. However, this scientist participated in the work of the ICPBR and is none other than the main author of the recommendations submitted… She therefore assessed and approved her own work. Former employee of Syngenta (ex-Novartis), she then went through various public bodies (INRA, Afssa, Ministry of Agriculture). She is now employed by the agrochemist Dow Agrosciences. “ (2)

We can admit that it is debatable that a scientist assesses the work to which she has contributed. However, if she participates in EPPO as a representative of the ministry, why should the ministry hire someone else for this work? We have no evidence to compare this choice with practices and context.

Once again, we see the delusional conception of the conflict of interest of S. Foucart: the fact of having been in a private company would affect you with a sort of absolute, indelible and definitive stain: the “conflict of interest”.

2. Analysis

As you have seen, the article is very long, talks about a lot of things and involves a lot of manipulative processes while not giving an overall conclusion. You have to put it back flat to understand the magnitude of the manipulation.

a. The story summarized

Let’s go back to the process very quickly, removing all the details and explaining the implicit connections:

  1. There would be significant loopholes in the well-known and long-standing regulatory testing.
  2. The reason for this inertia would appear by studying “How, and by whom, are developed these test protocols suspected of severe myopia”.
  3. Three beekeepers are said to have researched, discovered the role of EPPO and ICPBR, attended a meeting of the latter and sent their criticism to its organizers, as well as to European health agencies.
  4. The reason why “the ICPBR did not accept the requests of the beekeepers” would be the influence of conflicts of interest (?) And industry due to the consensual approach of the groups. Working (?).
  5. Pesticide manufacturers would play a decisive role in the design of the tests because between 50 and 75% of the members of the working groups are “in a situation of conflicts of interest” because they are employees of said firms or laboratories. private “under contract with them”.
  6. Before being “adopted as official standards”, recommendations are subject to review by experts mandated by EPPO member states. The fact that their identity is not public would raise suspicion of conflicts of interest.
  7. The fact that an expert from the Swedish ministry approves the new tests, while 2 experts from the Swedish health agency criticized them shows that the “expert judgment therefore varies widely depending on their employer” (= a conflict of interest).
  8. The expert from the French ministry is said to be in a conflict of interest.
    You see that the fact of adding the hidden logical connectors clarifies the matter a lot.

b. Push in the answer to the original question

Overall, let us recall that the question asked at the beginning of the article is to decide whether the culprit of the fact that “risk assessment tests for bees, which are notoriously deficient, have been used for nearly twenty years to approve the last generations of insecticides” is incompetence or “the accumulation of conflicts of interest”.

However, throughout the article, he argues that it is “the accumulation of conflicts of interest” that is responsible. He doesn’t even mention that it could be incompetence or some other possibility.

The conclusion, “the accumulation of conflicts of interest is responsible”, will however remain to be guessed: S. Foucart does not explain it, he remains in the register of insinuation.

c. Structure analysis

The course therefore follows a structure where it begins by presenting the problem (the flaws in the assessment procedures), then draws on the experience of beekeepers, to unfold its response: those responsible would be the conflicts of interest.
The pivot of this article is therefore that 3 beekeepers (what is their expertise in the field of pesticides?) Are surprised that their opinion on the procedures for evaluating pesticides at an event to which they are not invited is ignored…

We actually have an extremely weak argument giving the scope of the subject dealt with. The author presents just a possibility (while presenting it as a certainty), but does not provide serious evidence to support it.

d. Conspiracy theory?

This article mobilizes a conspiracy style, consisting of having fundamentally conspiratorial statements by dressing them behind the description of a “system”. Let’s go back to the first sentence:

“Is the culprit rather incompetence or the accumulation of conflicts of interest? ” (2)

The person responsible would not even be an entity, but a phenomenon: the accumulation of conflicts of interest. However, he goes next to talk about an organization: the agrochemical industry. We see it quite explicitly in this quote:

“This consensual approach places the recommendations from the organization de facto in the hands of the industry. “ (2)

However, we remain on a very general perspective. Concretely, it always comes down to the biggest companies: BASF, Bayer CropScience, Syngenta, Monsanto, DuPont…

e. Conclusion

So, you see that the real content of S. Foucart’s article is not obvious and requires a lot of research to be explained. Even if you read the article carefully, you can miss most of the innuendo. It was only after reading all of his articles that I was able to identify some mechanics.