Pesticide regulation, product innovation and public attitudes

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Pesticides in Perspective

Introduction

Over the last 20 years or so the agrochemical industry has become one of the most regulated of all of the chemical industries. In the early days this was driven by scientist's concerns about certain events, such as pesticide accumulation in the environment and human toxicity. Such events have been focused upon by certain organisations and were partly responsible for raising consumer concern over the use of agrochemicals, and ultimately led to pesticides getting a bad name. In more recent times consumer concerns have almost demanded that governments move away from reactive legislation and adopt a more precautionary measure, which is not evidence-based. The current article elucidates the way in which pesticide regulation has evolved and what the key drivers and influencers have been. It also details the attitude of the public to pesticide use and gives some insight as to why such attitudes have developed in the way that they have.

The author of this article is Joyce Tait, who has an interdisciplinary background, covering natural and social sciences. She has specialised in user-focused approaches to complex issues in the contexts of innovation and environmental management in a range of areas including risk assessment and regulation, policy analysis, technology management in the agrochemical and biotechnology industries, sustainable development, public attitudes and communication, strategic and operational decision making in companies and public bodies, and land use and crop protection.

Joyce is currently Director of the Scottish Universities Policy Research and Advice Network (SUPRA). Prior to this she was Deputy Director of the Research and Advisory Services for Scottish Natural Heritage. She has been/is involved in a host of research and consultancy projects in collaboration with the ESRC, MAFF, the European Commission and others. She was a Member of the UK Government Advisory Committee on Genetic Modification, a Member of the ESRC Risk and Human Behaviour Steering Committee, and is currently a Member of the EC Expert Advisory Group for the 5th Framework Programme, Key Action 5, Agriculture, Forestry and Fisheries, and she is President of the Society for Risk Analysis – Europe, 1999–2001 to name just a few.

Joyce has published widely, too many to list but the reader is advised to look up her most recent publications, some of which are cited in her article. From the above it is clear that Joyce is ideally qualified to contribute such an article and I hope that you all enjoy reading it.

Dr. Terry Clark
Syngenta, UK.
E-mail: terry.clark@syngeta.com

Pesticide regulation, product innovation and public attitudes

Pesticide regulation as an evolutionary process

Since the 1960s when the regulation of modern pesticide-related risks was first seriously considered, regulatory systems have become gradually more stringent. At both national and international levels, in response to the concerns of scientists and, perhaps more often, members of the public, pesticide policy makers and regulators have pioneered approaches to regulation that were subsequently applied in other areas. The national and international systems that regulate the production and use of pesticides and the presence of pesticide residues in food have been developed in close interaction with multinational agrochemical companies. Indeed, in many important respects it has guided the evolution of the industry.

One of the first major targets of regulatory attention was the organochlorine group of insecticides. The attribute of persistence in the environment had initially been seen as desirable from the farmer's point of view because it prolonged the effectiveness of the active ingredient. However, demonstration of the accumulation of organochlorine insecticides in food chains and the resulting threats to many wildlife species saw the introduction of regulations to replace the organochlorine insecticides with other active ingredients.¹ From that point, persistence in the environment was no longer seen as desirable and any new chemical with this property was likely to be eliminated from further testing at an early stage in the R&D process.

The regulatory system evolved in a reactive manner to control the impacts of new chemical groups as they reached the market. For many of their uses, the organochlorine insecticides were replaced by the organophosphates and the greater acute toxicity of that group of chemicals focused more regulatory attention on the safety of spray operators. In moving from organochlorines to organophosphates, a trade-off was made between environmental harm and human toxicity. The subsequent introduction of the pyrethroid insecticides with their generally lower human toxicity raised yet another set of regulatory issues because of their toxicity in the aquatic environment. Several more recent groups of insecticides now on the market are claimed to be much safer in many respects than their predecessors, for example, abamectin (a low dose rate acaricide/insecticide, derived from natural products and produced by fermentation, which is useful in integrated pest management (IPM) programmes) and pymetrozine (an anti-feedant active against aphids and other sucking pests; also useful for IPM and integrated resistance management programmes) both produced by Syngenta.

The history of pesticide regulation could thus be written in terms of a process of gradual replacement of one chemical group by another which often exhibited a different set of problems. Generally the properties of new active ingredients were well enough known to be anticipated by the regulatory system before they were introduced to the market. However, there were some unexpected impacts as, for example, with the toxicity to geese of carbophenothion which was introduced as a replacement for dieldrin seed dressings.

Given the range of chemicals involved and the complexity of their potential interactions with the environment and food production systems, it is not a simple matter to demonstrate that this evolutionary approach to regulation is indeed leading to safer pesticides. It is often claimed that a reduction in the quantity of active ingredient applied to achieve a given effect means that newer pesticides are safer than their predecessors, but this could merely be an indication that they are more potent toxins. However, where research has taken account of a broader range of variables, it seems that the environmental and public health performance of pesticides is indeed improving.²

Reactive and precautionary risk regulation

The regulatory approach adopted for pesticides has been described as ‘reactive/preventive’³ or ‘risk-based’,⁴i.e., the system responds to damaging impacts for which there is reasonably convincing evidence and takes regulatory action to ensure that similar impacts do not arise with new generations of chemicals. This approach relies on quantification of probabilities and outcomes, the development of quantitative models and the use of cost–benefit analysis as a basis for scientifically rational decision making.

Pesticide regulation and its failures, as perceived by the public, were among the main stimuli for the emergence of a new approach to risk regulation in Europe, the precautionary principle. It has been described in the following terms.

Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation (1992 Rio Conference on the Environment and Development; Rio Declaration, Principle 15).
Where levels of uncertainty are high, where potential impacts are very large, and/or where those impacts may be irreversible, there are grounds for adopting a precautionary approach until such time as we have sufficient scientific knowledge to make a risk-based decision.⁵

Although the precautionary principle has been discussed to some extent in the context of pesticide regulation, one of its first and most extensive areas of application has been in the regulation of genetically modified (GM) crop development. Agrochemical multinational companies have been the first industry sector to take part in the precautionary regulation of its products (GM crops) from the earliest stages of research and development.³

This 15–20 year European policy experiment to develop precautionary systems of risk regulation has not been an unqualified success. GM crop regulation in Europe is currently in a state of suspended animation from which there is still no clear exit. One of the difficulties has been the unanticipated use of the precautionary principle as a component of the argument in debates that extend beyond straightforward risk regulation, bringing in issues of ethics, quality of life and globalisation.⁶ One industry manager has compared pesticide and GM crop regulation in terms of trained armies moving across a battlefield in the first case, and guerrilla warfare in the second.

One symptom of this process is that, for pressure groups it is becoming customary to demand the application of the precautionary principle for all risk-related issues, redefining the principle to suit their purposes, involving degrees of precaution ranging from cursory to crippling. Debates on risk issues often revolve around the definition of the principle and when and where it is applicable and the concept itself is in danger of becoming meaningless.

An important strand in discussions on the development of the precautionary principle is the ongoing debate about whether it is compatible with the scientific basis of risk regulation. One consistent aspect of all interpretations of the principle is the requirement to take regulatory or policy action in advance of scientific evidence, so in this sense it clearly can not be based on science. However, as the two descriptions outlined above imply, application of the principle can be treated as a temporary measure, to allow scientific evidence to be collected where this is warranted by the severity of the potential risks involved. Certainly to be implementable in combination with evidence-based approaches to risk regulation, the precautionary principle needs to be capable of being linked to the scientific process.

The precautionary principle is becoming an increasingly well entrenched feature of European regulatory systems and it is unlikely to be abandoned now. However, there is much still to be done to make it effectively operational. There is not much evidence so far that the precautionary principle will be a useful adjunct to decision making on risk related issues.

Precautionary regulation of pesticides

Although still clearly founded in the reactive/preventive approach, pesticide regulation has begun to exhibit characteristics that are claimed to be precautionary in some of the details, in the sense of taking regulatory action which is not strictly ‘evidence-based’. This can be illustrated by two significant pieces of legislation, one European, the other American, both of which have been criticised by some industry managers as being excessively ‘precautionary’.

A major focus of attention in the EU has been water pollution by pesticides, particularly contamination of drinking water. Directive 80/778/EEC lays down mandatory quality standards for drinking water, set for pesticides at 0.1 µg l⁻¹ per active ingredient. This legislation is precautionary in that it seeks to avoid water contamination by pesticides, regardless of the toxicity of the chemicals involved (which can vary by up to a thousand-fold) or their mode of action. The level of precaution applied is thus inconsistent among chemicals.

There is no reason why the Drinking Water Directive could not be evidence-based since the provision of detailed information on dose–effect relationships is part of the registration process for all pesticides. We have the information to devise a chart ranking all the pesticides whose residues may appear in drinking water according to the degree of precaution implied in the Directive. However, precaution in this case is stimulated, not by scientific uncertainty, but by the publicly emotive nature of chemical contamination of drinking water.

The second example of the precautionary principle applied to pesticide regulation is the US Food Quality Protection Act (FQPA), 1996,⁷ whereby the Environmental Protection Agency expedites the review of ‘reduced risk’ compounds. The FQPA departs from the reactive/preventive approach in adopting a new standard, reasonable certainty of no harm from dietary and other routes of exposure to a pesticide, in addition to pre-existing standards for worker and environmental risks.

Organophosphate insecticides were placed high on the priority list for replacement by new ‘reduced risk’ chemicals. The FQPA is precautionary in taking positive action to replace currently approved chemicals in advance of evidence that they are causing harm if used according to recommendations.

The precautionary principle is also beginning to appear in international discussions and negotiations relevant to pesticides. Codex Alimentarius standards set maximum residue limits for pesticides approved through national regulatory systems on food products traded internationally. The Codex is primarily a science-based activity, involving experts and specialists from a wide range of disciplines to ensure that its standards withstand rigorous scientific scrutiny (Understanding the Codex Alimentarius, www. fao.org/docrep/w9114e/). Strictly interpreted therefore, the precautionary principle would not be applicable in this arena.

However, there are cases where a precautionary approach is demanded by individuals or pressure groups, e.g., where a pesticide is presumed more hazardous, or where the members of the public are presumed more vulnerable, than shown by available scientific tests. Some individual countries impose higher standards than those recommended by the Codex. For example, the EU and the US national regulatory systems generally adopt nationally more stringent standards than the Codex and any attempt to impose uniform worldwide standards would result in a lowering of the standards in these two important regions.

Since 1995, Codex standards have been used by the World Trade Organisation (WTO) as reference points for a series of agreements outlining legitimate restrictions on trade. The agreement most relevant to pesticide risk issues is the application of Sanitary and Phytosanitary Measures which acknowledge governments’ rights to take action at the national level to protect human, animal or plant life or health. Nevertheless, the measures taken must still be based on scientific principles and governments cannot discriminate by applying different standards to different countries without scientific justification.

The anomalies and tensions inherent in some of these agreements are likely to place increasing strains on international relations in a variety of areas.⁸ One outcome of the linkage between WTO and Codex standards and the resultant introduction of the precautionary principle into debates is that the previously scientific Codex process is becoming politicised.⁹ Also an acrimonious relationship is developing between the WTO and non-government organisations around issues of trade liberalisation, its impact on transboundary environmental and health risks and our ability to control them at national and regional levels. The dominance of world food production systems by multinational agrochemical and seed companies is an increasingly important concern in these international debates and pesticides and their role in supporting intensive farming systems are contentious features, often linked to demands for the precautionary principle to be applied.¹⁰

Evolution of pesticide innovation processes

The use of policy and regulatory instruments to guide industry innovation systems in more socially desirable directions has been widely used in some industry sectors¹¹ but this has not been regarded as a formal purpose of pesticide regulation in the agrochemical industry and it also has not been subject so far to this type of analysis. Nevertheless, despite the lack of formal direction, the types of pesticide reaching the market are heavily influenced by regulatory regimes, particularly of the EU and US.

Developing new pesticides has never been easy or straightforward. A successful new molecule today has to have a complex array of attributes that are dictated by markets and regulatory systems.¹² In market terms it has to be able to: survive the spraying regime (sunlight, rain, high temperatures); penetrate into a leaf; get to the target site and kill the plant if it is a weed or not kill it if it is a crop; survive metabolism in the plant; beat the competition; and be easy to manufacture. In regulatory terms it has to: be safe to non-target organisms (including wildlife, domestic animals and people); not be likely to appear in ground water at levels of more than 0.1 ppm; be capable of being manufactured in a safe chemical plant; be transported safely worldwide; and be applied safely in a range of climatic conditions, without leaving significant residues on food crops.

Together, market constraints and regulatory demands have been responsible for the large increase in the number of chemicals that need to be put through industry screening processes in order to have one viable pesticide on the market, from 10000∶1 in 1972¹³ to approximately 200000∶1 today.¹²

In marketing terms, the pesticide industry has become increasingly ‘mature’ since the 1980s and industry managers have faced major challenges to retain their position among high value-added, R&D intensive multinational companies, rather than becoming purveyors of commodity chemicals. The molecules or chemical groups which were easiest to discover and to develop and were active against the most commercially important targets were the first to be exploited. Over time the pool of new chemicals has gradually become ‘fished out’ and the market has become saturated with effective pesticides, many of them off-patent and relatively cheap compared to new, patented products.

Most major agrochemical companies have used fundamental scientific research and technological innovation to develop new pesticide discovery systems for research and development.¹² Biotechnology in the form of functional genomics and proteomics is applied to identify potential new pesticidal active ingredients, often based on natural products. High throughput screening systems involving complex robotics enable companies to test over 100000 potential active ingredients per year against living whole organisms or tissues. Combinatorial chemistry is used to satisfy the resulting demand for new molecules to be tested in the high throughput screening systems. As a result of such efforts, most companies hope to be able to maintain a success rate of one new blockbuster chemical every one or two years.

Links between innovation and regulation

The large increase in the number of chemicals screened for each active ingredient that reaches the market as a new pesticide is seen in the industry as an indication of the improved quality of the resulting products in terms of both market and regulatory performance. However, improved quality alone will not necessarily give automatic access to new markets. Farmers are unlikely to switch to new improved pesticides where older, cheaper, off-patent products are still available. Creative approaches to pesticide regulation can be used in such circumstances to push the market towards product substitution by ‘cleaner technology’ but this will generally involve at least an element of the precautionary principle, as noted above.

The EC Drinking Water Directive discriminates among pesticides only on the basis of mobility in soils so it is not effective in improving the quality of pesticides by any other criterion. Even in the context of soil mobility it will only have a beneficial effect if some other action is taken to discriminate against older pesticides which are mobile in soils. Likewise, ‘reduced risk’ pesticides reaching the market more rapidly as a result of the FQPA, will only realise this advantage in the market place if they can compete effectively, particularly on price, with existing products and this is not a foregone conclusion.

Pesticide regulation is widely recognised as having been beneficial to multinational companies in most respects: it has opened up markets for new high value added products when older, off-patent products are banned. Also, the high financial cost and knowledge resource required to comply with regulations has created a barrier to entry for new firms.¹⁴ However, for policies to be effective in encouraging product substitution policy makers need to have a strong sense of how policies will affect their targets, the links between policies and how they interact with one another and with industry strategies.

A range of policy initiatives are in place or are being considered in Europe but few of them have had much impact so far on pesticide usage patterns in intensive farming systems.¹²

Speeding up the process of regulatory review of pesticides and withdrawal of some older pesticides from the market will open up market niches for new products but there is a very large backlog of chemicals waiting to be reviewed.
Pesticide taxes are either in place or being proposed in many European countries as an approach to reducing pesticide usage. Taxes are widely regarded as one of the least effective means to achieve this objective, and a blanket tax may even be counterproductive, encouraging farmers to use cheaper, older pesticides. Where taxes discriminate against older pesticides, they may encourage a switch to more modern products but the level of taxation needed to achieve this aim is likely to be unacceptably high.
Some European countries (particularly Northern European) have set ambitious targets for reductions in pesticide use, some of which have been superficially successful due to replacement of chemicals that are applied at a high dose rate by those requiring very much lower levels of application. Effects are much less dramatic when recorded in terms of number of pesticide applications to each crop.
Most European countries are also promoting the adoption of IPM programmes, with a view to reducing the levels of pesticide use. IPM is another term, like sustainability and the precautionary principle, that is subject to frequent re-definition as various groups interpret it according to their own interests and values. Many multinational companies are developing products with IPM systems in mind but they are generally operating with a much more restricted vision of the concept than would be held, for example, by an environmental pressure group.
Food processors and supermarkets are among the most effective influences on farmers' pesticide usage through the contracts they issue to growers. Approximately 30% of pesticide usage in Europe is specified, often in terms of requirements to comply with IPM systems, somewhere along the food chain and this can be in terms of quantity of pesticide, number of applications or nature of active ingredients.
The single most effective means of reducing pesticide usage would be the introduction of GM crops, but this is unlikely in Europe in the foreseeable future.

Experience in pesticides, as in other areas, is indicating that provision of incentives to industry that discriminate in favour of products with a desired range of characteristics is a much more effective policy lever than creating indiscriminate disincentives to continue with the status quo. The FQPA is an example of the kind of instrument that works very well in this way. However, what is also needed in the policy arena is a more integrated approach to the full suite of policy instruments currently in place and planned in Europe and internationally so that they work more effectively in synergy rather than in opposition to one another.

Public attitudes to pesticides: interactions with industry and regulators

There are important links, not always straightforward, between pesticide hazards and their regulation and public attitudes and opinions. The chemical industry’s initial reaction to the claim that organochlorine insecticides were causing damage to wildlife was to defend the status quo, holding on to this view for some time after it had been accepted by many reputable and impartial scientists and regulators.¹ This industry response triggered a decline in public attitudes to, and trust in, the chemical industry from which it has yet to recover.¹⁵ Such attitudes, once formed are very difficult to reverse and the subsequent gradual improvement in the environmental and health impacts of pesticides has instead been seen by many members of the public as evidence that ‘technical fixes do not work—they merely create new sets of problems for which we have to invent new fixes’.

As outlined in the above analysis, the European risk regulatory scene has two major strands: evidence-based (as generally applied in the context of pesticides) and precautionary (as applied in the context of GM crops and also in some cases for pesticides). In an ideal world these two approaches would be treated as complementary with guidelines developed on the applicability of one or the other approach in different sets of circumstances. However, in practice they are diverging—each is regularly used by different sides in risk debates to attack the quality of the evidence used by others. The criteria in such cases are often whether data are based on ‘sound science’ or ‘mere speculation’, backed up by arguments from the social sciences about the extent to which science itself is a social construct.

Such issues are spawning numerous academic papers from both sides of the fence but there is still no sign of resolution of the underlying problems or even of more clearly understanding their cause. Why do significant numbers of members of the public ignore some risks and focus heavily on others which may be less damaging? Why are they happy to delegate the tasks of risk management to regulators in some contexts while demanding ‘stakeholder involvement’ at every stage of the process in others? Why do some risk issues remain dormant or smouldering in the public consciousness only to be triggered by a relatively trivial event, or by an event in an unrelated context, into issues of raging public controversy (a process that has been described as social amplification)?

We study public attitudes, opinions or values in order to understand better the relationships between attitudes and behaviour and by implication to predict behavioural outcomes. Scientists and industrialists are heavily committed to the view that the solution lies in better public understanding of science, despite numerous social science studies showing that this is not the case. Once people have made up their minds to take an overt position on a particular issue, they will use science actively to support that position and ignore the science that does not support it.

A recent paper claims that if we want, not only to understand such risk conflicts, but also to make progress with their resolution, we need to adopt a different basis for enquiry and consider the extent to which people are approaching the issue from interest-based or value-based perspectives.⁶ Most people respond to risk issues on the basis of a mixture of interests and values. However, where the response to a risk issue is largely dominated by individual or group interests, it is likely to be restricted to specific developments, to be location specific and locally organised, and to be resolvable by information provision, compensation or negotiation; on the other hand where it is dominated by fundamental values, it is likely to spread to related (and even scientifically unrelated) developments and issues, to be organised on a national or international basis and to be extremely difficult to resolve by any of the conventional means.

Looking at these differences from the perspective of pesticide risks, a largely interest-based conflict would arise where a farmer spraying a herbicide damages some plants in a neighbour's garden and the neighbour demands compensation. Any resulting dispute is likely to be local, context specific and resolvable by the provision of information or compensation. For example, the farmer may be able to explain that the herbicide being used was not toxic to the species of plant claimed to be damaged, or alternatively may offer to pay the cost of replacing the plants. In either case it is hard to imagine the dispute attracting attention other than locally. Even where larger numbers of people are involved, say where a pesticide proves to have an unexpected defect some time after its market launch (e.g., a fungicide demonstrates unexpected herbicidal properties) this is likely to be resolved by negotiation between affected parties and is unlikely to attract public attention.

A largely value based response on the other hand would have very different characteristics. Many of those members of the public who oppose the use of pesticides, in principle, do so from the perspective of opposition to intensive farming systems and the multinational agri–food businesses with which they are associated. For them it is a much broader question of life-style, rather than, or sometimes in addition to, concerns about the health or environmental impact of particular pesticides.

Seen from this perspective, any information which provides useful ammunition for activists in opposition to intensive farming systems will be seized upon and used. On the other hand, information which may indicate that intensive farming systems are not damaging to the environment will be ignored or its source discredited.¹⁶ Thus the promotion of better public understanding to science can be useful in largely interest-based conflicts, but most of the situations where it is being advocated as a solution are value-based conflicts.

Another important characteristic of value-based conflicts is the bringing together of issues that can be convincingly related in the systemic sense but are not necessarily connected in reality, at least not in the manner implied. The European public reaction to the introduction of GM crops is a good example of this phenomenon. Many of the most active protesters against GM crops will admit that they do not necessarily see GM crops themselves as damaging; indeed the potential of GM crops to make intensive farming systems more sustainable by reducing the use of pesticides is, for them, a negative attribute as it could undermine some of the more general arguments against intensive farming systems. Environmental activists thus seized the opportunity to associate GM crops in the public mind and in the media with all the negative aspects of intensive farming systems and the globalisation agenda. The linkage of GM crops with the BSE crisis in the UK was another example of this phenomenon in action.

This alternative perspective linking risk conflicts related to pesticides with others that may not seem to be directly related can explain many aspects of public attitudes to pesticides that seem puzzling. For example, there is often an expectation that dealing with a risk issue that is causing public concern will lead to a diminution of concern. However, in a value-based conflict it will be seen as a victory, encouraging protagonists to greater efforts in the broader conflict. Various forms of stakeholder dialogue are currently being embraced as a means of reducing conflicts over issues like pesticides and GM crops, but once again this approach can have unexpected effects in situations involving value conflicts. Those engaging in stakeholder dialogue from a purely value-based perspective will not be satisfied by compromise; for such groups, information is viewed as propaganda, compensation as bribery and negotiation as betrayal.

This suggests that one of the first requirements in dealing with a risk-related conflict would be to discover the extent to which various protagonists are approaching it from an interest- or value-based point of view. One problem in the GM crops controversy was that industry responded in interest-based terms to an argument that was primarily based on public values. Social scientists could develop such methods although they have not yet done so, and they would have to bear in mind that participants in a conflict may not willingly collaborate in the exposure of their underlying motivations. Despite this latter factor, the clues to the nature of the conflict are usually to be found in the arguments made in the writings, press releases and public debates engaged in by protagonists.

It is important also to acknowledge that the above points do not apply only to public interest groups and members of the public. They are equally applicable to multinational companies, managers in industry and scientists in general. Regulators, and indeed managers themselves, need a better understanding of their own motivations if we are to begin to resolve some of the complex issues raised by risk regulation in modern societies.

References

1. N. W. Moore, The Bird of Time: the Science and Politics of Nature Conservation, Cambridge University Press, Cambridge, 1987.
2. D. H. K. Davies, Technology Developments in Weed Control and Targeting for Reducing Environmental Impact, Brighton Crop Protection Conference, Weeds, 1995, British Crop Protection Council, Farnham, Surrey, 1995, pp. 613–622.
3. J. Tait and L. Levidow, Proactive and Reactive Approaches to Risk Regulation: the Case of Biotechnology: Futures, 1992, pp. 219–231.
4. J. D. Graham and J. B. Wiener, Risk vs. Risk: Tradeoffs in Protecting Health and the Environment, Harvard University Press, Cambridge, MA, 1997, pp. 337.
5. Communication from the Commission on the Precautionary Principle, CEC, Brussels, 2000, COM(2000) 1..
6. J. Tait, J. Risk Res., 2001, 4, 175.
7. R. Tinsworth, J. Environ. Monit., 2000, 2, 63N.
8. J. Tait and A. Bruce, Global Change and Transboundary Risks, Commissioned by The Society for Risk Analysis for the International Symposium on ‘Risk and Governance’, Warrenton, VA, USA, 2000, SUPRA Paper No. 21, http://www.ed.ac.uk/rcss/supra/.
9. J. Braithwaite and P. Drahos, Global Business Regulation, Cambridge University Press, Cambridge, 2000, p. 403..
10. J. Tait and A. Bruce, Health, Risk Soc., 2001, 3, 99.
11. R. Williams, A. Clayton and G. Spinardi, Policies for Cleaner Technology: a New Agenda for Government and Industry, Earthscan, London, 1999..
12. J. Tait, C. Chataway and D. Wield, Final report, PITA Project—Policy Influences on Technology for Agriculture: Pesticides, Biotechnology and Seeds, TSER Programme, European Commission–DG Research, Project No. PL 97/1280, Contract No. SOE1-CT97-1068, 2001, SUPRA Paper No. 22, http://www.ed.ac.uk/rcss/supra/.
13. M.B. Green, Pesticides: Boon or Bane?Granada Publishing, 1976..
14. J. Tait and R. Williams, Sci. Pub. Policy, 1999, 26, 101.
15. A. Bruce, C. Lyall and J. Tait, People's Values in Relation to Chemicals and their Effects on Humans and the Natural Environment: a Literature Review, report to the Royal Commission on Environmental Pollution, 2001, SUPRA Paper No. 23, http://www.ed.ac.uk/rcss/supra.
16. GM on trial, Greenpeace, London, 2000..

Joyce Tait
University of Edinburgh, Edinburgh, UK.
E-mail: joyce.tait@ed.ac.uk

Footnotes

† The opinions expressed in the following article are entirely those of the author and do not necessarily represent those of the Royal Society of Chemistry, the Editor or Editorial Board of JEM, Syngenta or the Column Editor.

‡ This paper is based in part on a research project studying strategic decision making in agrochemical and related industries, ‘Policy Influences on Technology for Agriculture’ (PITA) EC Framework Programme 4, Targeted Socio-Economic Research Programme, project No PL97. Selected reports on this project can be found on http://ed.ac.uk/rcss/supra/and the full set is available on http://technology.open.ac.uk/cts/pita/

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