This week the US Department of State, together (nominally) with the Department of Health and Human Services, effectively discredited any scientific decisions coming out of the International Agency for Research on Cancer (IARC). Their media note from June 8 concluded that IARC’s hazard assessments were inconsistent, not transparent, and not applicable to any real-world situations. In other words, its science was junk and any IARC findings should not be treated as “definitive” in the United States. Every country should come to this same conclusion.

While I am very pleased with these pronouncements that echo what I have been arguing for over a decade, I somehow cannot imagine that RFK Jr actually signed on to this decision. The former tort lawyer’s law firm, now called Wisner Baum, has pocketed millions of dollars from glyphosate lawsuits solely based on the corrupted IARC Monograph 112 – the only scientific agency document to have claimed that glyphosate was probably carcinogenic.

Surely RFK Jr could also not possibly accept the criticisms of IARC in the Department of State media note. Here are some of the more damning charges:

• “Too often, broad classifications based on limited or theoretical risks can create unnecessary public confusion, undermine confidence in everyday products and industries, and lead to policy outcomes that are disconnected from actual exposure and modern scientific standards.” In other words, IARC’s junk science only creates public fear and distrust of actual exposure levels and modern science.

• “IARC’s findings and monographs often blur the line between hazard and true risk, while diminishing independently verified findings of other research institutions.” That means to say that IARC’s hazard assessments have repeatedly undermined conclusions from regulatory risk assessment agencies like the US EPA and FDA.

• “Furthermore, IARC’s research provides diminishing returns on scientific enterprise, while advancing politicized narratives that are often cited for U.S. domestic legal contexts.” The Department of State has recognized that IARC monographs are misused by the US litigation industry. The politicized narratives” refer to activist NGO fear campaigns built upon IARC claims.

The phrase “diminishing returns on scientific enterprise” implies that IARC’s monographs are political, activist driven and opportunistic – anything but scientific. These quotes seem to suggest that people in the Department of State had read the recent monograph on IARC by Nathan Schachtmen (see the Firebreak’s review of this damning report).

A Post-IARC World

As IARC seems to finally be done and dusted, we need to ask what a post-IARC world will look like. In reality, it will look quite good.

Fewer Predatort Extortions. Without the influence of IARC’s manufactured evidence on the US litigation industry, there will be fewer bogus lawsuits filed solely on claims that a WHO cancer agency has determined a substance to be carcinogenic (spoiler alert: all IARC monographs conclude carcinogenicity). There would never have been the hundreds of thousands of glyphosate or talc lawsuits had IARC been a responsible research agency.

Fewer Corrupted Scientists. With the loss of lucrative funds for “litigation consultants” (averaging more than $500 an hour), scientists will lose interest in being involved with or supportive to the monograph program. As IARC becomes stigmatized, fewer opportunistic scientists will also be involved with the Collegium Ramazzini, an organization that is now also struggling to survive.

Less Fearmongering Activism. As IARC pronouncements become meaningless, NGOs, law firms and special interest groups will not be able to manipulate the public, regulators or the media with bogus, fear-laden claims based on useless hazard assessments. You will no longer hear claims like: “The WHO cancer research agency has declared…”

Less Ignorance. IARC monographs have been used as a basis for disinformation campaigns by opportunistic Predatort lawyers, activist NGOs and controversy-driven journalists. The fear their monographs have produced has resulted in a rush to alternatives (often more harmful), a distrust of industry and pointless public disquiet. Fear leads to misunderstanding, so the muting of IARC will reduce ignorance.

One interesting point worth noting. No one is arguing that a world without IARC will have negative consequences for our understanding of carcinogens or the advances in finding cures. Most significant research and development in cancer detection and treatment comes from industry, and IARC has prohibited any involvement with any scientist remotely tied to industry. Nothing positive will be lost when IARC shuts down.

Slowly but surely, other IARC member countries will pull back their funding and involvement, and budgets will have to be slashed. The IARC Monograph Program will likely be forced to take the WHO’s tobacco control route and rely fully on philanthropist project funding to survive. And like the decline of the Framework Convention on Tobacco Control, expect lower quality science and even higher political inputs as IARC has to submit to some special interest foundations and billionaires to pay the rent.

How Did This WHO Agency Go Off the Rails?

There are many reasons why IARC’s decline evolved to the state it is in today.

Corrupted, Politicized Activist Science. At one point in my IARC curation, I catalogued 30 scientific integrity transgressions. I called it IARC’s Dirty Thirty, but I was more stunned that these activist scientists felt they could operate with impunity. Shortly after that, the head of IARC’s monograph program, Kurt Straif was “hurriedly retired”, but it seems with recent monographs like gasoline and talc, that they are back to their same old shenanigans.

Close Ties to the US Litigation Industry. It was impressive that the Department of State media note expressly mentioned the role IARC has played in providing doctored evidence bespoke for law firms suing industries, in what has been called the La Jolla Playbook. The close ties between IARC (Ramazzini) connected scientists and the law firms that employ them to produce research, documents and testimonies has tarnished the reputation of the cancer agency. It is absurd to think that IARC was actually compelled to hold a supplementary monograph meeting on benzene because the law firms the IARC-networked scientists were working for had a large number of plaintiffs that needed a report that links benzene with a certain type of cancer.

Overly Zealous Cancer Classifications. IARC’s hazard-based approach has been misused to produce an excessive number of carcinogenic classifications that have become meaningless from a practical point of view. But one could argue that a hazard assessment is the first step in a risk assessment (if only IARC had considered that their role ended there). However, ten scientists tied to both IARC and the US litigation industry, pushed the classification process too far and too fast with their Ten Key Characteristics of Carcinogens (that was then rushed into the IARC Preamble). This checklist approach allowed any substance to be classified as a carcinogen, allowing IARC to “upgrade” its past classifications to make substances more convincingly carcinogenic in a court of law. There was no scientific value to this checklist and the Department of State has finally taken notice.

IARC may survive for a few more years as a hollowed shell, providing shared data on cancer rates and organizing a conference or two each year. The monograph program will be cut back into obscurity, and the organization will lose its platform for activist Ramazzini scientists to run their campaigns for their clients. IARC will soon be forgotten.

A personal note

To close on a personal note, many people know how long I have been challenging IARC’s activism, the consequences I have suffered and the walls of silence in the media I have been confronting. Several have asked me how I feel after seeing this statement by the US government that confirms what I have always been working toward. My feelings haven’t changed from that day nine years ago when I first discovered how an IARC insider, Christopher Portier, had worked as a liaison between IARC, Ramazzini and the US litigation industry to produce evidence for hundreds of thousands of glyphosate lawsuits, earning billions for the litigation industry (but not for the plaintiffs). That exposé broke the image of IARC as a credible research agency, so perhaps my reaction on that first day is still suitable today, as IARC is facing the coming end to its days.

IARC has intentionally caused such a colossal waste of time, money and energy. I won’t feel sad when that dreadful WHO agency finally shuts down.

Last month, a monograph entitled IARC’s Precautionary Science: How the WHO Cancer Research Agency Misinforms Regulation and Litigation was published. The author, Nathan Schachtman, counsel to UB Greensfelder and Columbia law professor, roundly criticizes the state of the cancer agency’s monograph classification process. He sets out in a clear structure how the WHO’s International Agency for Research on Cancer (IARC) has created a process that misleads regulators, courts and the media on the presence and risk of potential carcinogens.

Schachtman begins with a history of how IARC’s emergence in the 1970s coincided with the massive increase in environmental health regulatory agencies, the use of the precautionary principle within many of these agencies, and the environmental NGO movement. Scientific papers also evolved around this period, at a time when literature reviews were still not considered as legitimate research contributions. It does not take much to add the elephant in the room, that from these evolutions, the US litigation industry has, since then, grown into the Hydratic monster it is today.

With IARC’s Precautionary Science, Nathan Schachtman meticulously details everything that has gone wrong with IARC, its use of precaution and the corruption of scientific evidence used in the US litigation industry. With Nathan’s clear biting style and borderline satire, perfected in his must-read website, Tortini, it becomes evident how far from science and evidence the international cancer agency has strayed. Every line echoes my thoughts ... a book I wish I had written.

Precaution is not science

Schachtman’s focus is to demonstrate how IARC, likely due to its ties to the Collegium Ramazzini ideology, has taken a precaution-driven approach to carcinogen classifications.

“The precautionary principle diverges dramatically from the U.S. legal system in which persons claiming to have been harmed must prove, among other things, the harmful nature of the defendants’ conduct or products, by a preponderance of evidence. The precautionary principle also diverges from science, where scientific claims are established with ample evidence after severe testing.”

Regulators may choose to take precaution, but that is a policy decision, not a scientific one. IARC, in taking a precautionary approach, is not forthcoming in its political interests and strategies. A good part of Schachtman’s work seeks to shine a light on how the precautionary bias manifests itself in their classification distortions, abuse of the risk-hazard distinction, and their checklist approach.

Hazard and Risk

Schachtman identified IARC’s ongoing ambivalence toward its role in merely providing hazard assessments (the initial step in the risk assessment process). Given IARC’s outdated prestige assumption, they seem to expect environmental health agencies to automatically adopt their monograph hazard classifications into national regulations. But in saying a substance is a hazard does not mean much on its own. Risk assessors need to consider if the exposure to these hazards is relevant and if risk-reduction measures can mitigate the threats.

“In IARC parlance, cancer risk requires a finding that an agent is a cancer hazard, that it can cause cancer, but identifying a cancer hazard without more information does not equate to any cancer risk. The assessment and quantification of cancer risk typically requires that we know the route of exposure, the actual conditions under which the agent is used, the level of exposure, peak exposure, and cumulative exposure to humans, the metabolic fate and distribution of the agent in humans, and toxico-kinetics of the agent (rate at which the agent is metabolized or cleared from the human body), the exposure-outcome gradient, and the existence of thresholds of exposure for any risk. The IARC classifications provide little to no information about the sorts of data needed to determine and characterize risk. To the uninformed public and media, hazard sounds a lot like risk, and the two concepts would naturally be confused.”

On their own then, hazard assessments are not very useful. Schachtman rifles off a series of IARC hazard classifications of substances they had classified as carcinogenic that are also produced naturally in the human body like formaldehyde, ethylene oxide, testosterone… “Encapsulating people or putting warning signs on people’s faces will not really help prevent cancer.” IARC’s hazard-based precautionary approach is “devoid of scientific meaning” and the contradictions in IARC’s monographs, from coffee to red meat to crystalline silica (sand), render them practically useless. Unless you are an opportunistic tort lawyer.

Schachtman cites a term I believe he coined to describe one of IARC’s cottage industries: tortogenesis.

“Although IARC’s classification of a carcinogen cannot inform us whether specific exposure circumstances increase risks of cancer, the classification can and does result in ‘tortogenesis’. IARC classifications have been known to spark mass tort claims in the United States, and elsewhere. Careless expert witnesses have been known to misrepresent IARC hazard classifications as risk determinations.”

This is the beauty of Schachtman’s thinking and resultant prose. Tortogenesis is the act of initiating and promoting events that lead to mass tort lawsuits. IARC’s reclassification of glyphosate leading to hundreds of thousands of lawsuits is a prime example of tortogenesis. The cancer agency has spawned a new breed of scientist who is ‘tortogenetic’ by nature, producing research that is jury-ready. At that point in the book, I was on the edge of my seat as Schachtman brought me into the bosom of the Collegium Ramazzini - the place where tortogenesis was suckled.

The Ramazzini Ideology

Schachtman shows how IARC and the US tort industry were interconnected with Collegium Ramazzini fellows, and how their ideology of using research to prosecute industry and to promote precautionary regulations was exploited.

“In science, as in the law, the burden of showing that an agent is carcinogenic resides with those claiming causation. The precautionary principle, sometimes subtly, more often overtly, shifts the burden to those claiming non-carcinogenicity. The Collegium and its members are committed to the precautionary principle, which poses a major ideological conflict of interest when its members publish, testify, or participate in the IARC monograph process. The list of the Collegium’s American fellows reads like a Who’s Who of expert witnesses for the lawsuit industry. ... Many of the Collegium fellows have had important roles in the IARC program.”

Almost without fail, all of the scientists Nathan charged with having hidden their conflicts of interest were Collegium Ramazzini fellows.

I have covered the Ramazzini campaigns far too often, describing it as a private club for politically driven activist scientists. Ramazzini science is weak, with like-minded fellows peer reviewing each other’s papers to be published in their own journals. Schachtman hones in on the unscientific precautionary ideology at the core of the Collegium but he could have expanded on their volumes of poor methodology, non-transparent funding (like the Russian involvement) and hidden conflicts of interest.

If I may make a minor criticism though. Of the 16 scientists Schachtman cites as actively working within the Ramazzini – IARC – litigation industry nexus, I was surprised that he had missed Philip Landrigan, long-time head of the Ramazzini scientific board and litigation industry entrepreneur. And a chapter on Linda Birnbaum, the Ramazzini bank clerk, would not have been deemed inappropriate. But this can be overlooked as there are just too many conflicted researchers in this activist scientist pantomime.

Ten Key Characteristics

In several recent articles on IARC, I had been struggling with how the cancer agency’s recent conception of the Ten Key Characteristics (KCs) of Carcinogens could be considered as scientific. Nathan’s chapter on the Ten KCs assured me that they are most definitely not scientific.

“The group touted its identification of KCs as a way of organizing and understanding carcinogenesis, but they also advocated using KCs to predict carcinogenesis in the face of insufficient epidemiology and even insufficient animal evidence. The KCs working group was dominated by members of the Collegium Ramazzini and like-minded scientists who seemed frustrated with the inability to identify more carcinogens, more rapidly.”

Schachtman cited several cases where IARC then intentionally revisited past monographs using their newfound key characteristics to “upgrade classifications” to higher levels of carcinogenicity (noting how the lawsuit industry has found this “check the boxes” approach very opportunistic). I should add that my investigation into how IARC revisited its talc monograph a third time (solely to deliver a more litigation-friendly conclusion with the key characteristic strategy) came out while this book was in the publication process. Nathan’s conclusions more than confirmed the suspicions in my exposé.

Schachtman’s Recommendations

As much as Schachtman condemns IARC for its broken monograph methodologies, conflicts of interest, precautionary, Ramazzini bias … he makes many valuable recommendations that might be useful in rehabilitating the cancer agency, namely:

• Stop pretending that the monographs are part of a consensus process and open the deliberations to a wider range of views. “If IARC were to adopt this approach, and engage with adversarial points of view, it might have fewer consensus monographs, but more credible conclusions in the end.”

• Be transparent and root out all conflicts of interest. “While complaining about “vested interests,” IARC’s leadership and many of its working group members have special interests because of their membership in the Collegium Ramazzini. Many of the Collegium’s membership work in service of the American lawsuit industry as consultants or testifying expert witnesses. Given the ideological and positional conflicts of interest rife throughout IARC, it should be opening its deliberative process to inspection, not trying to shame stakeholders into silence.”

• Peer review the monographs. “The myriad systematic reviews published each year in higher quality journals undergo peer review of varying quality. IARC, however, remains steadfast in rejecting external review of its monographs before publication.” Schachtman though wonders if IARC monographs will ever be able to reach the same quality of the systematic reviews now available in the scientific literature.

But in the end, given the political bias, conflicts of interest, undue prestige and secretive process, Nathan feels that reform of IARC’s monograph program is futile. “When we add to these considerations, the redundancy, inaccuracy, and unscientific nature of IARC classifications, the simplest solution is to abandon the entire enterprise of IARC hazard classifications.”

Cynically, Schachtman concludes that IARC has achieved one thing.

“The IARC classification process clearly is a known litogen and tortogen, with a clear ability to create personal injury and environmental litigation. The lawsuit industry, made up of lawyers who pursue such litigation, along with their litigation lenders and funders, and aligned with environmental advocacy groups constitute a loud and persistent, rent-seeking, support group for the IARC classification process, with its precautionary principle leanings.”

In six lines, Nathan summed up the Predatort Playbook, something that took me a decade to figure out.

As a fellow writer on the need to protect scientific evidence from the onslaught of special interests unleashed within the IARC – Ramazzini – litigation industry nexus, I find Nathan Schachtman’s meticulous book extremely valuable. While his chronologies and timelines are precise, in reading his case study of the glyphosate fiasco, I couldn’t help but wonder if his research had been published a decade earlier, how different the world would have been.

Schachtman’s “IARC’s Precautionary Science” provides the teaching; we need to demonstrate the learning.

A recent campaign by the UK-based Copper Sustainability Partnership (CuSP) chose not to advance trust in the industry’s products by stressing the sustainability of copper but rather attacked what they perceived to be the unsustainability of competitive alternatives. Worse, the Copper Sustainability Partnership relied on cheap activist-style fear campaigns to make consumers distrust alternative products. And worst of all, they built their campaign on poor scientific research while hiding similar, if not worse risks from copper. Citing activist journalist reports is not science.

An Awful Campaign

The copper industry campaign asks if you would trust plastic with your planet. The cover image focuses on a child (emotional image) standing in front of a dark pile of trash (emotional image) with text written in scaremonger font (emotional image).

The message is clear. The copper industry wants you to believe that plastic is not a sustainable product and by exclusion, that copper is better.

Other images the copper industry used include those of bees struggling to get pollen in dark, dystopian settings suggesting that bees and other pollinators are contaminated with microplastics. This is a very common activist tactic to amplify fear but it is disheartening to see such abysmal conduct from an industry trade group. While the campaign does not focus directly on pollinator health, it cites a study led by Simon Potts, a British activist scientist who was once busy claiming pesticides were killing all of the bees (until, apparently, they weren’t).

Bees are the environmental equivalent of using children in activist health campaigns. Both are deemed vulnerable, essential and emotional. Bees and children’s issues go beyond facts and measurable dose-related data, making them perfect for fear campaigns. The bee campaign tactic started with the sudden die off of honeybees some 15 years ago that activists then linked to exposure to certain insecticides (it was later concluded that any die off was due to several cold winters and the Varroa mite). When honeybee populations started thriving again, the anti-pesticides campaign simply shifted to risks to pollinators in general and certain wild bees under pressure. The beauty here is that we have very limited data on certain pollinators so activists can adopt them in any campaign they want.

The copper industry then used another activist technique of stacking campaign issues, amplifying the fear of a beepocalypse with the widespread detection of microplastics in the environment. But they are a bit late to the scare party as The Firebreak reported, most research papers on microplastics, according to the European Food Safety Authority, have been determined as junk. A recent study has concluded that the microplastics detected in many of these studies more likely came from gloves and lab equipment than from the samples tested. But still, the copper industry persevered with their claims.

What is most stunning here is the blatant hypocrisy of the copper industry for even raising these fears. Chris DeArmitt, in a LinkedIn discussion, reminded the copper trade association that dust from copper pipes is far more toxic to the environment, humans or bees than any possible microplastics could ever be.

Confronted with facts, like any NGO, the belligerents merely changed the subject.

The key motivation of the copper industry’s anti-plastics campaign is to show how plastic water pipes are unsustainable (especially when compared to copper pipes). This is an important question at the moment given the US legislation to replace all remaining lead water pipes. The US Congress created a $15 billion opportunity for whichever pipe material is determined by regional authorities to be more favorable. Plastic water pipes are far cheaper, more efficient and easier to install than steel or copper pipes, so it comes across as an act of desperation for the copper industry to wage an intensive mudslinging campaign against the safety and sustainability of plastics.

There is a deeper concern here. One of the key activist groups in the water pipe debate is Beyond Plastics, a feral group that has been leading a campaign against PVC water pipes. The Firebreak revealed how Beyond Plastics is a phantom NGO. It does not exist as a legitimate organization but is only a “project” run by a fiscal sponsor (Bennington College in Vermont). This means not only that these anti-plastic activists cannot be held accountable for the claims they make against plastics, but also, that they do not have to declare who is funding them (since they don’t, technically, exist outside of some passive liberal arts college). Given how ethically compromised the copper industry has revealed themselves to be through their direct attack on plastics, it would come as no surprise if they were also funding this rogue NGO to run campaigns against their competitors.

The Beyond Plastics 2023 report: The Perils of PVC Plastic Pipes advocated for copper pipes in the replacement of lead water pipes.

It’s All About Trust

Nobody wins when two industries openly fight with each other. The public does not calmly examine the facts and determine which product is better. They see the confrontations, focus on the negatives and pull away. When activist NGOs attack industry, the public, to a certain degree, accepts that the NGOs are expressing a bias and filter their claims. When one industry attacks another, like the copper industry has, then this has a greater impact on the loss of trust, not just on plastics, but on all of industry. This is why there is a code of conduct within most industries to always present a positive position on the benefits of their products and not get into the mud with competitors.

What has the copper industry achieved with their campaign? They claim they just want to create an open discussion about the sustainability of the products, but using fear-triggering language and images is hardly beneficial to any open discussion. The Copper Sustainability Partnership have reinforced several activist campaigns against plastics (and the NGOs surely thank them), but the audience has not turned around to trust the metals industry. Environmentalists, seeing the ecological impact of copper mining and production, will not become the copper industry’s new best friend. Who are they kidding? The only thing they achieved is a further erosion of public trust in all industries.

Would public procurement officers deciding on pipe infrastructure projects look at the risk of microplastics to bees and then choose copper over plastic? One quick look at price and installation costs of both products would put that question to rest. They will endure the protests of the anti-plastics organizations, even with the apparent support of the copper industry.

Several years ago, I wrote a series called the Industry Complex, where I implored that industries need to work together against the activist onslaught against business, capitalism and innovation. As an industry is being devoured by hungry lions, too often other industries continue grazing, business as usual, oblivious to the fact that tomorrow they will be the slowest zebra. This is not a sustainable business strategy. But the copper industry, by throwing a competitor to the activist lions, is taking the industry strategy to a much darker place. Shouldn’t wider business associations speak up and enforce basic ethical standards or codes of conduct (or throw them out)?

The copper industry needs to apologize, immediately cease this destructive activist campaign and start to behave ethically.

VarHar does not read the comments or Community Notes attached to his X posts, correcting the continuous flow of misinformation like his belief that nicotine causes cancer (it doesn’t), that vaping is not effective as a smoking cessation tool (the Cochrane study confirmed it is) or that e-cigarettes are as harmful as cigarettes (a UK government study concluded it is 95% less harmful).

Like the WHO / Bloomberg echo chamber, and like the Trump administration, facts don’t really matter in advancing a political agenda. Add to that the curious sideshow that Várhelyi is a Fidesz leftover from the Orban regime, fighting for his political survival, and the TPD revision is taking on an absurd plot.

May 31^st was World No Tobacco Day and VarHar’s press release was a case study in confused statements and contradictory policies.

The Commissioner begins by repeating the opinion that Europe’s tobacco policy - or the restrictive parts of it at least - have been responsible for progress made in reducing smoking rates. But this statement has already been debunked by the Commission’s Better Regulation watchdog itself, which says that claim can’t be supported. Not a good start.

Várhelyi continues:

“But while traditional smoking is decreasing, new tobacco and nicotine products are increasingly reaching a new generation. Adolescents and young adults aged 12 to 29 are particularly exposed. More than half of nicotine pouch users are under 40, one in five consumers of tobacco and nicotine products aged 15 to 19 years started by regularly using e-cigarettes, and nearly one in ten young people aged 15 to 24 has already used heated tobacco products.”

Let’s break this down line by line.

“But while traditional smoking is decreasing, new tobacco and nicotine products are increasingly reaching a new generation.”

Why doesn’t Várhelyi acknowledge that traditional smoking has decreased due, in large part, to the increased use of lower harm nicotine products. The Swedish government, the only EU member state to attain smoke-free status (less than 5% of the population smoking) has recognised that.

“Adolescents and young adults aged 12 to 29 are particularly exposed.”

The ages Várhelyi is using for young people make no sense at all. In the public consultation, young people were defined as those between the age of 10 and 24.

This is a very wide classification ranging from very vulnerable children, to free-thinking teenagers with access to information to responsible adults going well beyond the “age of consent”. VarHar then pushed the age limit up to 29 in this statement. This is an age when most smokers begin to consider the need to quit and should be given access to effective smoking cessation tools like e-cigarettes and nicotine pouches.

In the next sentence, he seems to push the age of vulnerability up to 40.

“More than half of nicotine pouch users are under 40, one in five consumers of tobacco and nicotine products aged 15 to 19 years started by regularly using e-cigarettes, and nearly one in ten young people aged 15 to 24 has already used heated tobacco products.”

This is pure “VarHar speak”, just throwing out numbers and products with no concern for reason or common sense. It resembles the Trump “Weave”, but the European Union has to manage policy with more responsibility. What is he talking about here? Pouches? Vapes? Heated tobacco?

And which age groups? 15 to 19 years old? 15 to 24? Or those under 40?

Like Trump’s Truth Social posts, VarHar’s single sentence here is just too nonsensical to even begin to try to unpack.

The press statement continues:

“This month we published both a call for evidence and public consultation on the revision of the EU Tobacco Products Directive and Tobacco Advertising Directive. We welcome all contributions to inform how we can tackle the health consequences of tobacco across the EU.”

The words “public consultation” is misleading when you consider that most of the questions are leading, meaning that the participants cannot actually express their position most of the time but are trapped by the bias of the consultation architects. In an analysis we undertook, we found that it’s impossible to express views consistent with tobacco harm reduction: advocating strong rules on cigarettes, but a permissive stance towards safer nicotine products.

That’s because safer nicotine products like vapes and nicotine pouches are grouped together with cigarettes, assuming that their safety profiles are the same and that the regulations will be applied equally to all of the various products.

When Várhelyi says he welcomes all contributions from all stakeholders, we should be reminded how, in past consultations, when thousands of ex-smokers took the time to fill out the form and declare how they were finally able to quit with the support of e-cigarettes, their contributions were downgraded as being part of a tobacco industry lobbying campaign. Stakeholders only matter when they agree with VarHar’s political agenda.

Europeans look on with horror as an imperial dictator destroys the US political establishment, replacing it with a regime of policy by diktat. But they don’t have to look that far to see a similar political manipulation in Brussels. It is time for the President of the European Commission to demand the resignation of Oliver Várhelyi.

Peter Beckett is the editor of Clearing the Air. This article was published in coordination with Clearing the Air.

A recent US Department of the Treasury announcement that organizations claiming tax exempt status (NGOs, foundations, universities and some media groups) will have to be transparent about their project and campaign funding has changed the rules of the US policy game. The news went largely unnoticed, but the Firebreak celebrated how this little adjustment to the tax declaration process will force activist groups to declare billions of dollars in dark campaign funding (which will likely deter secretive interest groups from funding further covert operations via activist groups, foundations, universities...) The environmental-health policy playing field has just been levelled, eliminating the means for NGOs to so easily control the narrative, media and public opinion.

Another Silver Spoon NGO

If anyone needs an example of abusive activist behavior from dark, special interest funding, they need to look no further than the hundreds of millions of undeclared funds pouring into the coffers of Earthjustice. Earthjustice is a law firm / NGO founded in 1972 as the Sierra Club Legal Defense Fund (changing its name in 1997). While it functions like a law firm, Earthjustice is structured as a tax-exempt (501(c)(3)) NGO.

Looking at this non-profit’s latest IRS 990 declaration and its website, some curious things emerge. In 2025, Earthjustice had a revenue of over $207 million. But as a law firm, only $5 million of that amount came from court awards while the rest came from donations and investments. With 150 ongoing litigations in 2025, this implies that they are losing most of their cases (or have a very bad cash management system). There are two possible justifications:

1. As an NGO, they exist to sue industries as flanking strategies in support of other activist campaigns. Its clients are mostly other NGOs like the Sierra Club, Wilderness Society and Natural Resources Defense Council, as well as local conservation groups and native tribes. In other words, their goal is to continually file nuisance lawsuits against companies and governments, clogging up the US legal system with no intention of winning their cases. Much like the foundation-funded law firm, Sher Edling, lawfare is their business model.

2. The other possible explanation is that Earthjustice staff and management are living too high off the hog. Their IRS 990 declaration reveals that the top ten managers in the NGO pay themselves annual base salaries ranging from $620,000 to $360,000 - or from $50,000 to $30,000 per month (see image below). From the $207 million in 2025 revenue, $167 million went into salaries and wages.

Given how unsuccessful Earthjustice’s legal outcomes have been, and that they are functioning as an NGO, the tolerance of these unhinged salaries, like Bloomberg’s flotilla of anti-nicotine NGOs, implies that billionaire philanthropists are operating behind the scenes and allowing such largesse.

If only these foundations and NGOs would have spent this kind of money planting trees, we could finally say they are doing something positive for the environment.

Foundations and Special Interests Hiding in the Shadows

While Earthjustice chose not to be transparent on which foundations or special interests are funding their lawfare activities, a quick scan of the websites of large foundations that tend to fund NGOs to conduct similar lawsuits did show a considerable network of well-connected funders.

• The Ford Foundation was one of the initial founding donors of Earthjustice. Does it really make sense for a philanthropy built on a century of auto industry profits to be funding an NGO suing the fossil fuel and tire industries? The Ford Foundation remains a funder but there has been no disclosure of recent donations.

• The MacArthur Foundation has made 11 grants to Earthjustice totaling almost $15 million. Most of those payments have come in the last six declared years.

• Other foundations that have listed support for Earthjustice include the Sandler Foundation, Packard Foundation, Rockefeller Brothers Fund, and the Hewlett Foundation, to name but a few (source: InfluenceWatch).

Earthjustice claims that only 17% of their funding comes from foundations, but they do not provide details. Until the Department of the Treasury announced changes to the tax declaration process, they did not have to. In their IRS 900 declaration, they list the top two donations in 2023 from two individuals, one for $15 million and the other for $14.05 million (see image below). The identity of neither donor was declared, but we can assume these individuals have means (and probably very special interests).

Why is transparency important in this matter? First of all, transparency is always important from the perspective of credibility. As long as NGOs like Earthjustice think they don’t need to reveal the interest groups operating from behind the curtain, they will never be considered as credible. How do we know that neither of the anonymous $14 million or $15 million donations in 2024 from private individuals weren’t from billionaires who would benefit from an alternative product once a competitor succumbs to relentless litigation? As these individuals would stand to profit nicely should the courts order that an industry stop using a product, then Earthjustice has a fiduciary duty to declare this conflict of interest. But they don’t.

From the 2025 financial statements, almost $25 million of Earthjustice’s net assets are donor restricted, meaning the residual funds remain earmarked for certain cases. That Earthjustice is taking these marked millions and keeping quiet is a clear indication of how morally compromised these activist zealots have become. Normal people must be wondering how these corrupted environmental campaigners sleep at night? Like most tort lawyers, they must need “very well-padded” pillows.

Even worse, Earthjustice is reportedly receiving funding from the Chinese Communist Party via an aligned Chinese energy foundation. An investigation by the Pelican Institute For Public Policy revealed that Earthjustice received donations exceeding $6.5 million from Energy Foundation China to file lawsuits against American fossil fuel energy interests. Chinese industries would benefit both from the sudden increased market for renewables and batteries in the US and from handicapping US energy and industrial capacity. Did Earthjustice file a FARA registration for foreign funding? Of course not. Like every other donation, the NGO kept its funding non-disclosed. The US government should shut Earthjustice down as an enemy of the state.

Conflicts of interest are only recognized as conflicts if the activist organizations decide to declare them. Zealots, though, think the objectives of their campaigns are more important than any ethical codes of conduct, so declaring their special interest funding will only happen if they are forced to. With the recent changes to the US IRS 990 form tax requirements, Earthjustice can no longer maintain these secret, dark alliances.

In a case like this, saying: “Trust us, we’re an NGO!” just doesn’t cut it. Especially when top directors are already enriching themselves and have an obvious interest that goes well beyond any so-called justice for the earth.

Shoddy Reporting

The Daily Mail was one of the few mainstream media groups to cover last week’s Greenpeace report. In an article spookily entitled: “The pesticides lurking in your roast dinner: Scientists discover a cocktail of over 100 dangerous chemicals in the Sunday staple – with onions and leeks harbouring the most”, the journalist, Shivali Best, applied Chemophobia 101 rules without reserve:

• focus on the contamination of common foods eaten during a weekly family tradition,

• cite how these baddies are lurking and ready to attack you and

• stress the presumed chemical cocktail of dangerous chemicals.

Shivali Best claims the title of the Daily Mail’s “Science and Technology Editor”, but she missed the point in the very title. I suppose Greenpeace should have done a better job proofreading the final copy. It is not 100 dangerous chemicals (there are a thousand dangerous chemicals in a cup of coffee) waiting to attack us, but rather more than 100 pesticides. Perhaps a chemical and a pesticide are the same thing to a naive chemophobe. Best also warned the Daily Mail readers about the existence of “PFAs” or “forever chemicals” in your dinner (I think she meant to say “PFAS”).

Such scientific illiteracy is just what Greenpeace is looking for when they push their research garbage through the media meat grinder. But is this the best the Daily Mail can find as their “Science and Technology Editor”?

The Daily Mail article did add a small dose of reality in the reporting:

“Most samples contained pesticides residues below the maximum residue level (MRL), which is the amount legally allowed on food or in animal feed. Officials say these are set usually well below the level considered safe, applying to food both grown domestically and imported from abroad.”

But the journalist quickly questioned whether the MRL levels were actually safe, especially when other chemicals from “drinking water, plastic packaging and a range household products” were added to this apparently toxic cocktail of industrial poisons.

This tangent to all sorts of other chemical exposures was not in the Greenpeace report. Shivali Best clearly wants to be running her own anti-chemicals campaign, but her day-job pays the rent, for now.

The Methodology?

The Greenpeace report itself is only 24 pages (much like a second-year university term paper in both effort and quality) with a very simple data-gathering methodology.

Greenpeace came to its conclusions by filtering through a public database that lists all pesticides allowed for use on these seven food staples. That is all they did (as well as creating some rudimentary infographics for their media amplification). They did not explain how and when these 102 pesticides are applied, if at all. They did not compare them to the chemical usage in organic farming or to the levels of exposure found on the crops. It was merely a numbers game to create a shocking headline to feed to the chemophobic faithful.

The reality is that farmers use pesticides only if and when needed. More than risk, it is a question of time and money. If the summer is excessively damp, they will need to use fungicides to protect crops from the elements. They won’t need to use them in a dry summer. Certain areas and weather conditions leave crops prone to insect infestations, so it is good for farmers to know they have certain tools in their crop protection toolbox to use if needed.

Greenpeace isn’t interested in that reality. They want to show the number of 102 pesticides (which is really quite a small amount to protect every potential threat to seven staple crops) and claim that they are being repeatedly doused on crops, destroying the environment and causing unnecessary health risks.

The Rhetoric BINGO Card

Greenpeace packed a significant amount of emotional rhetoric into such a small report. Here are some of the NGO’s more spine-chilling classics:

“Everywhere we look, nature is barely hanging on. The struggles of our moths and butterflies are anything but unique. They reflect how the foundations of our environment are crumbling.”

“Imidacloprid and fipronil have been banned in agriculture because they are so potent, but they remain in heavy use in the UK as part of popular over-the-counter flea treatments for our millions of pet dogs and cats. A single monthly dose for a large dog is enough to kill 25 million bees.”

Wait, so treating Fido for fleas kills 25 million bees a month??? Why doesn’t Greenpeace just campaign to ban dogs (they are also a major contributor to greenhouse gas emissions)? By the time a reader comes across this claim, reality has been sufficiently numbed.

The chemophobic rhetoric hasn’t changed much over the last three decades I have been watching the evolution of Greenpeace campaigns. It is, however, now no longer just fear of chemicals and pesticides poisoning our land. Almost every paragraph in the Greenpeace report was amended with the inclusion of “artificial nitrogen fertilizers” or “synthetic fertilizers”. Their anti-fertilizer campaign has to qualify the threat from synthetic or man-made fertilizers because, like pesticides, organic farming also needs to enrich the soil. Greenpeace is attacking an essential agricultural tool while assuming that natural cow dung releases no harmful chemicals into the soil and groundwater. Greenpeace wants to have their poisons and eat them too.

So why is natural, animal-based fertilizers more preferred by these cosmopolitan zealots? According to the report, these synthetic, industrial fertilizers are just too efficient. I wish I were making this up.

“Artificial nitrogen fertilisers are very different chemicals. They boost the nutrient content of the soil far beyond natural levels, rather than killing animals and plants. But in doing so they also disrupt our environment.”

This is all about industrial agriculture, getting more from the soil, and that goes against the activist, post-capitalist orthodoxy.

It also goes against common sense and social justice.

It also goes against the goal of the report to show how seven UK food staples are dripping in pesticides. The constant references to fertilizers, their burden on the environment and their increased financial costs given the recent wars in Ukraine and Iran, shows how Greenpeace is unable to focus their campaigns on a coherent message. They just like to rant.

There were no quotes from experts or other views. Greenpeace did not attempt a balanced review and they did not consider the pesticide load on organic vegetables (which use equally toxic pesticides approved for organic farming). This is activist science – the goal is not evidence or discovery, it is about advancing a campaign.

But the NGO cannot help itself – it is in its activist DNA. But the Daily Mail should have sought out expert views beyond the prepared Greenpeace script. Shoddy journalism in the true style of the Daily Mail (one of the only media groups to cover this campaign, except for an X post from GMWatch).

The Conflation Tactic

Fear is stronger when it can be associated with other, unrelated fears. NGOs like Greenpeace saw how effective that conflation tactic could be in likening ultra-processed food production to Big Tobacco, trying to claim the same researchers are up to their old tricks. Piling fear and outrage of one known industrial malfeasance on top of the targeted scare campaign creates a perception of a relentless industry playbook to harm consumers and the environment and a complicit government to corrupt to bother to stop the continued destruction.

In this case, pesticide use is conflated with Big Tobacco and Big Oil. The report executive summary states:

“Yet for too long the government’s response has been ponderous. Agribusinesses have used tactics previously employed by tobacco and oil companies, systematically undermining scientific evidence of the damage they inflict.”

This is not about actual toxicity or risk to human health and the environment, but rather about how big business is controlling our food supply.

The NGO has also not missed the opportunity to conflate pesticides with PFAS even though the term represents over 10,000 fluorine-based formulations and the one often cited as being used in agriculture, TFA, has been determined to be harmless. But it’s PFAS, it’s a chemical, so it’s bad.

How these tired scaremongers continue to operate without critical scrutiny or public disgust is beyond me.

If you’ve been following the Firebreak’s running investigation into how U.S. foundations use fiscal sponsors, NGO networks, and compliant journalists to reshape entire industries in their own ideological image, then Marc Gunther’s piece this week in Inside Philanthropy (“Yanqui Go Home: Chilean Salmon Farmers Say U.S. Foundations Are the New Colonialists”) will feel immediately familiar. The David and Lucile Packard Foundation, headquartered in Los Altos, California, is funding a coordinated network of NGOs, legal groups, journalism programs, and certification bodies systematically working to shut down Chilean salmon farming, an industry that generates $6.3 billion in annual exports and supports between 60,000 and 86,000 workers across the Araucanía, Los Lagos, Aysén, and Magallanes regions of southern Chile.

Gunther tells the story well, but the scale of the operation is such that one can’t capture it in a single feature piece. One of Gunther’s sources, a letter sent from the Chilean Salmon Council to Packard’s Board several months ago—a copy of which the Firebreak has obtained—is rife with detail about that foundation’s work that didn’t make the cut.

Here’s some of what was left out.

Where the “green colonialism” comes from

Juan Carlos Tonko Paterito is the president of the Kawésqar Indigenous Community in Puerto Edén, a remote fishing settlement deep in Chile’s Patagonian channels. In July 2019 he published an open letter in the ICCA Consortium’s Latin America bulletin titled “Indigenismo y colonias verdes”: Indigenism and Green Colonies. He was writing about what he had watched happen to his territory after the Tompkins land donation put Magallanes on the international conservation map, and the NGOs followed.

“Diverse organizations of environmentalists have appeared here for the business of conservation, humiliation and submission,” he wrote. He described how they arrived with maps already drawn, dividing territory between them—“an NGO here, another there.” One representative told him Magallanes should become “a climate refuge.” Tonko Paterito asked the obvious question: for whom? Not for the Kawésqar, who already lived there. “They are trying to depopulate forever a huge territory,” he wrote, “as a ‘climate refuge’ for rich green people.”

He called indigenous communities that cooperated with the NGO network “the new yanaconas”—a charged historical reference to the indigenous people who served as auxiliaries to Spanish colonial forces. “The new yanaconas are now digital and globalized at the hand of the green colonialists.” He was not writing in support of the salmon industry. He was writing about the loss of his people’s sovereignty over decisions affecting their own land. “Our counterpart are the States, not the NGOs,” he concluded. “It cannot be that we are at the mercy of organizations we don’t know, ones for which the Chilean citizens have not voted to govern our destinies.”

That is the precursor of the phrase “philanthro-colonialism” that the Chilean Salmon Council’s letter deploys.

The boat that wouldn’t dock

In April 2023, a local media group, Patagonia Ambiental, reported on how Greenpeace and Oceana sailed the yacht Witness through the channels and fjords of southern Chile on a campaign they called “Patagonia sin salmoneras”—Patagonia without salmon farms. The campaign was well-funded, well-publicized, and designed to document the industry’s environmental footprint from the water.

When the Witness arrived at the pier in Puerto Natales, it was met by a protest. Artisanal fishermen, processing-plant workers, and representatives of the Kawésqar community had turned out on the dock with banners. Among them was Amil Caro, a Kawésqar elder, holding a sign that read: “Greenpeace won’t pay my bills.” He had tried to approach the vessel to speak with the crew. The crew chose not to disembark. Port authorities had to prevent protesters from approaching the boat.

According to Chilean journalist Claudio Andrade, it was the first time Greenpeace had encountered this kind of reception in the region. Greenpeace raises significant funds presenting itself as the protector of indigenous communities. That April, a Kawésqar elder walked to the dock to speak with them. They stayed on the boat.

Carlos Odebret, president of the Magallanes Salmon Farmers Association, told the trade publication Salmonexpert afterward: “There is no possible improvement if activists, like Greenpeace, without asking anyone, seek to leave the people of Magallanes without opportunities.”

The legislation the NGOs are weaponizing

The letter to Packard devotes considerable space to a regulatory mechanism that hasn’t gotten much attention in English-language coverage: the ECMPO, or Coastal Marine Space for Native Peoples (Espacio Costero Marino de los Pueblos Originarios), established under Chile’s Lafkenche Law. The law allows indigenous communities to petition for coastal exclusivity over traditional-use areas—a legitimate protection mechanism that, the letter argues, is being systematically deployed by NGO-funded legal teams as an industrial chokehold.

In Chiloé, ECMPO applications covering more than 621,000 hectares have been filed on behalf of just 36 indigenous people. The math: roughly 17,000 hectares of marine exclusivity per person. Marcelo Lipka, VP of the Multi-Union of Salmon Farming Workers, described it plainly: those 36 people “now get to say who works in their areas and who does not, thus impacting our work.” Gerardo Balbontín, General Manager of Blumar, said the NGOs had found a way to “trap” salmon farming by overwhelming the regulatory system with ECMPO requests faster than it could process them.

Packard has funded this directly: $836,100 to FIMA, Chile’s foremost environmental litigation firm, with one 2025 grant explicitly labeled a “civil society communications campaign.” FIMA has won five consecutive environmental tribunal rulings against named salmon farms. Packard separately gave $226,000 to Observatorio Ciudadano to build a “legal network for indigenous communities”—the mechanism that connects the litigators to the indigenous plaintiffs whose standing the lawsuits require. The lawfare is coordinated, not coincidental.

What it produced in practice: In May 2023, tens of thousands of workers marched from Biobío to Magallanes against pending legislation that would have further restricted salmon farming in protected areas. The marches stretched the length of a country. Signs read: “¿Sin salmoneras quién nos paga el sueldo? ¡¿Las ONGs?!”—“Without salmon farms, who pays our salary? The NGOs?!” The protest in Puerto Natales alone drew 2,000 people and a vehicle caravan four kilometers long. Participants included not just salmon workers but artisanal fishermen, shellfish farmers, truck drivers, and indigenous community members.

Chilean Senator Fidel Espinoza captured the mood with a tweet directed at the government: “Stop governing from Ñuñoa and from comfortable positions.” Ñuñoa is a wealthy Santiago suburb.

The response from Packard? The letter reports that not one of the workers, union leaders, indigenous representatives, or elected officials mentioned in its pages has ever met anyone from the foundation, received a call, or received a reply to correspondence.

The NGO transparency bill they’re trying to stop

One consequence of all this that hasn’t been reported in English at all: Chile is on the verge of passing landmark legislation requiring NGOs to disclose their foreign funding. Deputy Miguel Ángel Calisto, who represents Aysén—the region most affected by the regulatory campaign—authored the bill.

Calisto’s stated rationale cuts to the heart of what Gunther’s piece describes: many NGOs “mask negative intentions, such as undermining industries like salmon farming, behind positive rhetoric,” he said, and use regulatory mechanisms to “trap” the sector. “There are some organizations labeled ‘indigenous’ but some are disguised to hide their true intentions. We need to know how many NGOs are in the country and who finances them.”

Greenpeace Chile Director Matías Asun gave the Senate Environment Committee an unintentionally useful piece of testimony in 2024. He told the committee that his organization had “so many economic resources that he could easily stop projects of industries like salmon for up to 2,000 days.”

Packard’s website promises “engaged sensitivity toward the communities its work impacts.” It promises to “work with those communities to develop and carry out solutions” and to ensure “communities have a meaningful voice in decisions that impact their lives.” It is a reasonable aspiration. The gap between that language and what Tonko Paterito described in Puerto Edén, what Amil Caro experienced at the Puerto Natales dock, and what the workers marching from Biobío to Magallanes were protesting—that gap is so big not even Gunther’s carefully reported piece could capture it all.

Will Packard Defend Its Actions?

The Packard letter from which most of these details come is signed jointly by the Chilean Salmon Marketing Council and El Instituto Tecnológico del Salmón, and runs to several thousand words. It is addressed directly to Jason K. Burnett, Chair of Packard’s Board of Trustees, with the full board copied.

It closes with three questions: 1) Whether the board believes Packard’s conduct in Chile meets its own stated ethical standards for community engagement. 2) Whether it is troubled that a comprehensive range of Chilean stakeholders feels deeply insulted by the campaign it has underwritten. and 3) Whether the board will commit to visiting the affected communities in person for direct dialogue.

The Firebreak has spent three years documenting a specific and repeating pathology in the world of big-philanthropy-funded environmentalism: the substitution of communities’ own expressed interests with the preferences of distant, wealthy institutions that claim to speak on their behalf. We’ve tracked it through agricultural policy in Europe, through fisheries debates in the North Atlantic, through the quiet defunding of inconvenient science. The Chilean salmon story is—so far—the most completely documented single case of the pattern we’ve found anywhere. This is what the Firebreak exists to document: not the lofty stated goals of these institutions, but the real-life consequences for the people in the communities where their money lands.

Clarification / Editor’s Note:

Firebreak has received an email from Oceana declaring the organization “had no involvement whatsoever with the yacht Witness or with the “Patagonia sin salmoneras” campaign, contrary to our reporting. Oceana points to a passage in our article that, “In April 2023, Greenpeace and Oceana sailed the yacht Witness… on a campaign they called ‘Patagonia sin salmoneras’” insisting that was incorrect.

Our characterization was based on Chilean news outlets (such as this article in Patagonia Ambiental) that reported on the Greenpeace and Oceana campaign against the salmon farming industry and described local demonstrators as being outraged at both groups. Here is a key passage from that Patagonia Ambiental article, reporting contemporaneously from the scene of those demonstrations.

“Two environmental organizations, Greenpeace and Oceana, are carrying out a plan of action against the continued presence and installation of salmon farms in the region. Aboard the Greenpeace yacht Witness, they are traveling through the channels and fjords of southern Chile until April 22. According to their statements, their task is to document the activity of the salmon farming industry in the region and how it affects the environment.

This campaign affected their arrival in Puerto Natales, where people who earn their income from the activity turned out to demonstrate. Artisanal fishermen, representatives of the Kawésqar community, and employees of several processing plants received them with banners in which they defended salmon farming activity, opposing the environmentalists’ intention to ban the industry throughout Patagonia.Faced with this situation, the crew of the yacht — among whom are journalists, scientists, and Greenpeace campaigns coordinator Estefanía González — decided not to disembark to avoid conflicts. Port authorities, meanwhile, prohibited protesters from approaching the vessel.”

We can assume that Oceana has already contacted the Patagonia Ambiental media group with a similar complaint, but they seem to be standing by the evidence they reported on.

It’s worth noting also that, over just five years, Packard has given Oceana close to $1 million, according to Packard’s financial disclosures — while both organizations operate as part of the same coordinated multi-funder coalition driving anti-salmon-farming advocacy in Chile.

We are glad to note here, however, that Oceana explicitly disavows any involvement in the Greenpeace yacht or the Patagonia sin Salmoneres campaign — and we have modified that portion of our article to reflect the original attribution to Chilean news outlets.

What would happen if the health zealot policies imposed against tobacco harm reduction strategies were to be applied to a greater addictive activity: food consumption? We would, for one thing, make far greater health advances and see important reductions in noncommunicable diseases. As a dogmatic health zealot, I am ready to take the lead in imposing this on our ignorant, addictive consumers.

Food is addictive by nature. The food industry deliberately makes food sweet, tasty, flavorful, attractive in presentation (via colors and packaging), aromas and textures. Because of this manipulation, consumers find pleasure in food, overeat, become obese and expose themselves to an enormous number of diseases like cancer, diabetes and cardiovascular diseases. As consumers easily become addicted to food and the pleasure of eating, and as they cannot be trusted to make good food decisions by themselves, others like myself need to step in and control how and what they eat.

Such interventions into food choices are based on the belief that all addictions are bad and must be prevented by those righteous enough to assume leadership and enforce their views on others. Such techniques have been used to prevent smokers from taking up reduced harm alternative nicotine strategies like vaping and nicotine pouches so its success against food addiction is, well, baked in.

To this end, I am introducing a “Safe Food” concept restaurant that will prevent food addiction and promote healthy eating that is also better for the planet. The menu and restaurant will have the following features:

No Flavors

Bland, tasteless food prevents people from overeating. Our sustainable cuisine involves removing all spices, salt and sugars from the few plates on offer. It is hard to imagine people wanting to eat more flavorless foods than what is necessary for sustenance. This will contribute an enormous amount to fighting food addiction and improving public health. Banning food flavors will perhaps be the greatest health advance humanity has ever seen as it will immediately curb food consumption. We will focus this food revolution on the young, who will be less resistant to the removal of tasty food or long dining experiences (as they tend to see meals as interruptions in their gaming endeavors … another addiction we will soon have to address).

No Bright Colors

Food arranged in a pleasant or attractive presentation creates an emotional bond before the first bite is taken. Tests have shown that bright colors add to food addiction (not to mention the health risks from unnecessary food coloring). This is how children get hooked on bad food choices. All of our restaurant food will be dull, brown and unpleasant to look at. It will essentially be a consolidated mash. Our takeout food will be covered in plain packaging with no attractive logos or convenient wrapping.

No Aromas

Anyone who has walked by a Belgian frituur or waffle house on an empty stomach knows how smell influences how addictive food can be. Engineering food to smell nice contributes to making food attractive, so this practice will need to be regulated out. Our goal within the next five years is to move to food legislation towards ensuring they emit a repellent aroma (with soapy or stale notes) to ensure that people only eat when they have to.

No Textures

Part of the addictive attraction to food is the texture food may have in the mouth (as in crunchy vegetables, smooth creams, fatty meats and food that is warm to the tongue). This contributes nothing to the nutritional value of food but only makes it more pleasant to eat. Pleasant dining encourages food addiction. By banning all food textures, we will also reduce food waste, food preservation costs and energy use. Everything just gets thrown into the blender.

No Choices

Giving consumers choices increases consumption and encourages marketing techniques. These are the pillars of the industrial food system and cannot be tolerated in our post-capitalist world where degrowth and sustainable food chains are more important than consumers thinking they can get what they want at any expense to the planet. With fewer choices, people will eat less as the banality of the culinary experience will remove the addictive attraction of the joy trap. People will learn that it is better to eat to live rather than to live to eat.

No Comfort or Celebrations

There was a time when people would over-consume at a table with friends or family, eating and drinking for hours at a time. It usually involved a large roast or some other farmed livestock, where the cruelty of animal slaughter was actually celebrated. With our new, sustainable, healthy approach to food, the comfort of a meal as a feast will be replaced with the recognition of the selfishness of such abundance. People will learn to feel better when they eat better for the planet and their health. Our restaurant will have hard seats and small tables, but guests will be encouraged to stand while eating (to promote digestion and enable a faster customer turnover).

More Expensive

Based on the thought experiments performed by the good people at the True Cost of Food, our restaurants will double the price of food, first because we have been promoting a heavy taxation policy on food consumption and secondly, because the ability for the food chain to support the alimentary needs of a growing population without crop protection technologies means we needed to disincentivize certain food production methods and markets. While higher taxes on tobacco and alternative nicotine products have proven to be a dismal failure leading to increased black markets and gang violence, we believe that higher food taxes will be different. Certain foods will be taxed to the point of prohibition, leaving the healthier, more sustainable and less addictive foods to fill the void. Let them eat mash.

Postscript:

Our first Safe Food restaurant had to close almost immediately after opening as it appears no one was interested in eating our non-addictive selections. This was surprising because when we imposed these very same tactics on the vaping and smoking communities, the nicotine addicts just shrugged their shoulders and adjusted to the new situation (with many going back to smoking). We also received a lot of unwanted verbal abuse, which is sad because we see ourselves as very good people doing very good things to save humanity and the planet. In any case, we will not relent. We are presently seeking funding from several billionaire philanthropists to re-open on a larger scale. There is this former New York mayor with emotional baggage about past food fights that seems quite interested.

The US litigation industry is constantly trying to find the next Big Tobacco. As the number of tort law firms grow, with the increasing costs of multi-district mass tort litigations, the amount of debt multiplying via the litigation finance loan sharks, law firms have become desperate to find the next big carcinogen or extend the longevity of existing caseloads. Central to this search is their scientific community of litigation consultants involved with the International Agency for Research in Cancer (IARC) and the Collegium Ramazzini.

IARC has been prone to publish monographs that “coincidentally” have an important influence on the evidence needed for big ticket lawsuits. The best known case is the IARC glyphosate monograph, that had litigation industry fingerprints all over it before the agency’s scientific panel of experts had even met to determine the herbicide’s carcinogenicity. IARC has also been used to produce further evidence to expand the number of ongoing lawsuits like benzene (where litigation consultants forced IARC to go back and perform an extra week-long monograph expert panel meeting to manufacture a link between benzene and non-Hodgkin lymphoma). Such is the case with the third, and most recent monograph on talc where IARC was seen to be working on behalf of the litigation industry.

The Three Talc Monographs

Talc is a naturally occurring mineral known for its smoothness and softness. Most will know talc in its fine powder form as talcum powder, but it has a very wide number of uses, including many cosmetics and personal care products, in pharmaceuticals as fillers, carriers and lubricants, in food as anti-caking and polishing agents and many industrial uses from ceramics to paints, plastics and paper. Talc is also used in school products like chalk, sculpture materials and crayons.

Talc and asbestos are both silicate minerals often found in the same geological deposits, suggesting a risk of cross-contamination during mining. Industries have assured consumers that their talc has been asbestos-free since the 1970s but recent Predatort lawsuits have tried to cast doubt on that assertion. The first IARC monograph on talc in 1987 looked at the occupational hazards of talc with and without asbestiform fibers, concluding that only talc with asbestos was carcinogenic (Group 1).

The second IARC talc monograph in 2010 again looked at talc with and without asbestiform fibers, but focused on the use of talcum powder from the perspective of inhalation versus perineal applications. They found there was limited evidence for carcinogenicity (Group 2B) for the perineal use of talc-based body powder.

It is important to note that in 2010 there were already a number of lawsuits against talc mining companies and personal care companies like J&J. But the successful cases against J&J linked mesothelioma cancers to the talcum powder with potential asbestos contamination. There were thousands of other plaintiffs with cancers that did not fit the asbestos link. If only there could be some evidence linking these cancers to talc.

The third IARC talc monograph in 2025 only examined talc without asbestiform fibers, and unlike the previous two monographs, “succeeded” in classifying this uncontaminated form of talc as Group 2A – probably carcinogenic to humans. (A Group 2A classification was the minimum needed for legal wordsmiths to convince a jury of a link between talc exposure and cancer, allowing Predatorts to increase their plaintiff pool with a wider range of cancers.)

Irregularities with IARC’s Third Talc Monograph

One could assume that the differences in the outcomes of these three talc monographs were due to better research and more data to prove a link to certain cancers. But there were no new studies that threw overwhelming evidence to move talc from a Group 3 classification (inadequate evidence of carcinogenicity) in 1987 to Group 2B (possibly carcinogenic) in 2010 and finally, in 2025, Group 2A (probably carcinogenic). Rather, there were a series of irregularities that suggest the third talc monograph was produced with ulterior motives.

• The 2025 IARC talc working group relied heavily on the 1993 NTP animal study, claiming it provided sufficient evidence of carcinogenicity. The problem here is that the 2010 IARC talc monograph considered this very same study to be inadequate and lacking relevance.

• The 2019 IARC Advisory Committee considered talc as a priority substance for the upcoming monograph meetings. Among thousands of potential substances that had not yet been considered by the monograph program, and given there were no significant studies since the last talc monograph, was there really any justification for bumping talc again up the priority list?

• IARC rushed the publication of the talc part of the IARC expert meetings to June, 2025 instead of waiting and publishing the full monograph together in September of that year, together with the chapter on acrylonitrile. There was no reason to break with standard publication protocol and publish a partial document only to republish it in full three months later.

• Importantly, there was significant dissent against the conclusions of IARC’s 2025 talc classification. While IARC never publishes dissenting views (considering them as abstentions) and pretends their monographs represent a scientific consensus, the dissenting talc working group experts did not stay silent (see below). Taking their views into account, the 2025 IARC talc monograph should have classified talc, at best, as Group 2B, possibly carcinogenic.

The only rational justification for these actions is to look at IARC’s decisions through the “litigation lens”. In 2019, when the IARC Advisory Committee bumped talc up the priority list, law firms were amassing tens of thousands of lawsuits against J&J on talc, but with only a few of them relying on the mesothelioma asbestos link.

The 2019 IARC Preamble revision also made it almost certain that talc without asbestos contamination would be classified as probably carcinogenic (see below). Rushing the publication of the talc part of the full monograph before the final report was complete would only make sense if you consider the high number of talc lawsuits in front of juries at the time.

But perhaps the most damning indictment of IARC’s indentured servitude to the US litigation industry is how a group made up mostly of scientists working as litigation consultants to US tort law firms worked to revise the IARC Preamble, the guidance document for how IARC classifies carcinogenicity. They basically ensured that IARC monographs would be “litigation-ready”.

IARC Moved the Goalposts

In 2016, a group of scientists closely linked to IARC or the Collegium Ramazzini published a paper linking cancers to Ten Key Characteristics. By 2019, this strategic approach was adopted into the revision of the IARC Preamble (the guidance document for monograph classifications). See the Firebreak’s analysis of IARC’s Key Characteristics strategy.

The “key characteristics” concept claims that cancers share many of the same characteristics. If a substance, for example, is genotoxic, alters DNA, induces oxidative stress or chronic inflammation … then there is a higher likelihood it is a carcinogen. The logic is that the more of these characteristics a substance shares, the more carcinogenic it is. If benzene, for example, shares seven of the ten key characteristics, there is strong confidence that it is carcinogenic. Note that IARC merely conducts hazard assessments, so a finding like “glyphosate is genotoxic” does not consider at what dose or level of exposure such a hazard might become an actual risk.

The problem with this checklist approach is that any substance can fall under a certain number of these characteristics and still not be carcinogenic. A paper published by Becker et al found the 10 Key Characteristics to be so open as to not be able to discriminate between a carcinogen and a non-carcinogen. Becker tested the Ten Key Characteristics against 248 substances (of which 54 were carcinogens) and found the IARC checklist could not distinguish the non-carcinogens.

Once the goalposts had been moved with the Preamble revision, IARC could go back and reassess a number of substances that had not delivered litigation-friendly classifications (like talc). But not every scientist on the IARC working group panels appreciated the lawsuit expediency of such strategies. Not every scientist on IARC expert panels worked for the US litigation industry.

The EPA’s Andrew J. Ghio was a member of the third IARC talc monograph panel and wrote a letter to the editor to the American Journal of Respiratory and Critical Care Medicine in February, 2025. He noted that the different classifications between the 2010 and 2025 IARC talc monographs were not made on the basis of any new research or evidence, but because IARC had updated their Preamble – the rules for determining the carcinogenicity of a substance.

As a member of this working group, I suggest that this conclusion conflicts, in part, with a previous IARC classification that provided that inhaled talc not containing asbestos or asbestiform fibers was a group 3 carcinogen (“not classifiable”), while perineal use of talc-based body powder was a group 2B carcinogen (“possibly carcinogenic”) (2). These evaluations were conducted by two working groups that included some of the same experts who reviewed much of the same data (1, 2). The dissimilar conclusions of the two groups may reflect the impact of an amended IARC monograph preamble, delivered between the two classifications, that was intended to provide a stronger and more transparent method for the identification of carcinogenic hazards (3).

For this reason, Ghio and other working group members dissented. But IARC did not address their concerns in the monograph report.

IARC in Service to the US Litigation Industry

At least ten of the 19 scientists involved in the IARC 2012 workshop to establish the Ten Key Characteristics have worked as litigation consultants, including the lead author and main architect of this checklist strategy, Martyn T Smith. They knew the value a simple checklist would have in convincing a jury of a link between a substance and a cancer.

The Key Characteristics approach is not scientific, avoids having to deal with epidemiology, or even the difficult rodent evidence of carcinogenicity, and turns the science into an automated process. There is no scientific justification for the Ten Key Characteristics of Carcinogenicity to have ever made its way into the IARC guidance document for cancer classification.

IARC monograph program managers, namely the head, Kurt Straif, and the later acting head, Kathryn Guyton, were complicit from the start in the conception and integration of this key characteristics strategy. SlimeGate has reported how these two scientists were very active in pushing the IARC glyphosate monograph into the political / policy realm and how they used dirty tactics against other scientific agencies that disagreed with their conclusions.

Many of these scientists are also Collegium Ramazzini fellows, a type of closed-membership club of activist scientists closely intertwined with IARC. Several of the scientists have been involved in developing the concept of adversarial regulation. The logic, following the La Jolla Tobacconization Playbook, is that regulation does not work at curbing the power and pollution of industry, so it is better for scientists to work with Predatort law firms and sue the hell out of industry until they submit (or, better, go bankrupt). It worked to bring Big Tobacco to its knees and is now being applied against the fossil fuel, pesticide, chemical, plastic and food industries. And with the IARC / Ramazzini network, it has also made a certain select group of scientists very wealthy.

A logical argument would be to simply retract the IARC monographs that have been shown to be corrupted. Every national risk assessment agency that has looked at IARC’s evidence on glyphosate has rejected the conclusions and kept their regulations on the herbicide unchanged. That should be enough to retract IARC’s glyphosate monograph (let alone the corruption revealed by Reuters in IARC’s post-meeting document production). The dissenting views of the 2025 IARC talc monograph that went unattributed is sufficient reason to retract that document.

But retracting these monographs would imply that IARC monographs have a scientific value. It seems, more and more, that their only value is found in the courtrooms.

As the new Hungarian Prime Minister, Péter Magyar, begins to dismantle the corruption of the former Orbán regime, removing VarHar must be on his “to-do” list. There are many good reasons to justify removing him from office.

• He has already been deemed incompetent by the European Parliament given they would only approve his second posting as Commissioner for Health and Animal Welfare if certain responsibilities (oversight of the Health Emergency Preparedness and Response Authority, as well as safeguarding sexual and reproductive health rights) were removed from his mandate.

• Várhelyi is a lawyer and career diplomat. Unlike his predecessors, he is neither a medical doctor nor public health specialist. He is as qualified to run the European Health Directorate General as RFK Jr is at the Department of Health and Human Services.

• His previous post, as European Commissioner for Neighbourhood and Enlargement from 2019 to 2024, was widely criticized. He was accused of bias towards Serbian interests while meddling in internal Bosnian politics.

• He has repeatedly shown disrespect to Members of the European Parliament, at one time calling them “idiots” on a hot mic.

• Even worse, when he was the Hungarian ambassador to the European Union, there were reports that he was running a spy ring out of his Brussels office. A recent European Parliament investigation into Várhelyi concluded that his actions “demonstrate a pattern that is incompatible with the standards of accountability, reliability and sound administration required of a Member of the Commission.”

VarHar has no experience in health issues and carries a stench of corruption wherever he goes while his mistakes and missteps seem to confirm his incompetence.

Inexperienced and Incapable

Almost two years on, it is clear that Olivér Várhelyi has failed to reassure anyone that he is capable of carrying out any health-related responsibilities. He has made a large number of claims that have embarrassed the European Union within the health research community.

Outside of implementing the strategies from the previous European Commission, VarHar has only taken the lead on one new regulation: the revision of the European Tobacco Products Directive (TPD), and there his inexperience and lack of knowledge has been troubling. In February, a group of 23 scientists and professors wrote the President of the European Commission an eight-page letter outlining Várhelyi’s “false and misleading European Commission statements about novel nicotine product safety”.

Some further examples of VarHar’s false and unscientific claims:

• VarHar falsely declared on an X post that nicotine causes cancer (see image below). As nicotine is widely known to not be a carcinogen, the post was quickly taken down when someone with some scientific literacy corrected him. But since then, he has been making claims like vaping and nicotine pouches being as harmful as tobacco, or relying on a series of questionable studies to falsely claim that these tobacco harm reduction strategies cause a wide number of diseases, including even obesity. Hmm…

• A recent report to guide the upcoming EU Tobacco Products Directive revision was subcontracted to a group of anti-nicotine NGOs and the statements were so biased and unsubstantiated that the Regulatory Scrutiny Board (RSB) rejected it (see image below). Várhelyi ignored the concerns of the RSB and the European Ombudsman and published the report without revision. He regularly references parts of the report out of context. Since then, the management of the TPD regulatory process has been quietly moved to another more science-oriented unit within the Health Directorate.

• VarHar’s attitude to the upcoming consultation on whether alternative nicotine products should fall under the most stringent tax and regulatory measures as tobacco products has been curious to say the least. He stated during a recent speech that it is clear for him that e-cigarettes and nicotine pouches were as harmful as tobacco products. Going into a consultation on the revision of the Tobacco Products Directive, Várhelyi stated: “But the winner must be sure when we start this whole exercise. It has to be, it has to be the consumers. It has to be the young generation.“ So will VarHar just cancel the consultation requirement and impose his views? Or will he patiently wait until the “idiots” finish? That seems to be what he has been doing all along.

As Orbán’s man in Brussels, combative and scandal-prone, should we still be asking these questions or should VarHar be sent packing?

How do you remove a European Commissioner?

There are different ways to remove an ineffective, corrupt and embarrassingly ignorant European Commissioner like Olivér Várhelyi.

• The Commission President can force a resignation. This is the easiest and cleanest option, but like so many other issues, Ursula von der Leyen does not seem to have the stomach for such a fight.

• The Court of Justice of the EU can force VarHar’s removal arguing that he no longer meets the conditions for office or is guilty of serious misconduct. The Brussels spy ring scandal or his meddling in Serbian and Bosnian politics could allow a case to be made, but this will take years and the combative Orbanist will certainly fight it out.

• The European Parliament can only remove the whole Commission (like they did in 1999 with the Santer Commission over the misconduct of the Commissioner for Research, Édith Cresson), but as they would need a two-thirds majority vote, they would have to be very angry. After VarHar called the MEPs “idiots”, I think they are close.

• The new Hungarian Prime Minister cannot remove a commissioner who is now in office as an EU official. Once confirmed, Member States have no formal control over their Commissioner appointments. But there is no doubt that Péter Magyar has discussed a possible new Commissioner with von der Leyen who does have the power. Likewise, Magyar’s Tisza party, as part of the European People’s Party, is putting pressure on the EPP to persuade Ursula von der Leyen, a member of the EPP, to have her take the easy route. Manfred Weber won’t be able to keep betting on this lame horse for much longer.

The reality though is that an embattled Commissioner, fighting to stay in power amid claims of spying, an Orbán legacy, incompetence and corruption is not doing a service to the European Commission. Worse, he is becoming a folk hero to Commission-haters on the far right that welcome dysfunctional governance.

VarHar seems to think that the best defense is a good offense. He thinks his war against tobacco harm reduction strategies will distract from his personal issues. But that would require him being equipped for such a battle. At the moment, VarHar, like MAHA in the US, is shooting blanks and further embarrassing his administration.

This is Part 4 of the Firebreak’s Big Change series. It is a case study of how philanthropists working with NGOs, a United Nations organization and the media can control global health policy.

Summary

• Michael Bloomberg has invested $1.6 billion (with commitments for a further $400 million) into global tobacco and nicotine control programs.

• He has created a complex web of at least 15 NGOs that interact with and interfund each other, while trying to disguise their intertwined relationships around Michael Bloomberg

• These 15 NGOs are coordinating to implement a WHO program. This program has no funding outside of Michael Bloomberg, making this UN organization compliant to the billionaire’s views and initiatives.

• This dependence has compelled the WHO to attack tobacco harm reduction strategies like vaping and nicotine pouches, pressuring its members and bodies like the European Commission to fall in line with Michael Bloomberg’s rhetoric, despite the lack of scientific evidence.

This is a case study of how Big Change philanthro-capitalism can control a global health policy agenda and a UN agency program.

How to Waste $2 Billion

What would you do with $2 billion? If you want to spend it on dominating a global policy issue, you should take a lesson from Michael Bloomberg.

With his latest $400 million round of commitments, an even $2 billion is how much Bloomberg’s two main foundations have spent to single-handedly direct the global tobacco and nicotine control campaign, shaping it to fit his puritan, prohibitionist strategy. This is a case study in how the Big Change movement can be controlled by one wealthy billionaire with ambition and a complex network of organizations.

Calling Michael Bloomberg a “philanthropist” would be a mistake. A philanthropist is someone who donates to organizations with the intention of supporting vulnerable populations, easing suffering and improving the world. He is more of a “philindustrialist”, directing his funding to make an impact that forwards his political objectives, personal ambitions and need for self-aggrandizement.

More often than not, Bloomberg creates organizations that he actively controls via fiscal sponsors. Many of these projects are not legal entities, but merely front groups for the campaigns that advance Bloomberg’s global status. The Firebreak has looked at several of his creations like a media implant called The Examination that writes reports on health campaigns his other projects are campaigning on. He has invested more than $100 million into fiscal sponsors and universities to run campaign projects like Beyond Coal, Beyond Petroleum and Beyond Plastics.

How the money is spent is neatly hidden behind a web of intermediary organizations with little to no transparency, accountability or fiscal controls. These organizations only exist so long as Michael continues to write the checks, and so long as they continue to promote Bloomberg’s image and his interests. What is fascinating is the complexity of Bloomberg’s philanthropic endeavors. He does not donate to an organization or a campaign, he creates or takes over organizations he then integrates into a web of activism and policy domination.

The best example of this is how Michael Bloomberg created a complex web of organizations to essentially take over the World Health Organization (WHO) program on tobacco control, and now uses it to advance his strategy and ambition at the global level to remove tobacco harm reduction strategies like vaping and nicotine pouches.

Strategic Control Within the Bloomberg NGO Flotilla

In an earlier article, parts of Bloomberg’s flotilla of tobacco control NGOs was mapped out, how they coordinated with each other and redistributed funding from Bloomberg Philanthropies and Bloomberg Family Foundation. For example, Michael Bloomberg’s tobacco control funding is usually first channeled through the Bloomberg Initiative to Reduce Tobacco Use Grants Program, which is jointly managed and run by The International Union Against Tuberculosis and Lung Disease (The Union), Vital Strategies and the Campaign for Tobacco-Free Kids (all Bloomberg-funded or created groups). They then, in turn, fund groups and programs like Global Health Advocacy Incubator (GHAI) – an initiative of Bloomberg’s Campaign for Tobacco-Free Kids. GHAI then makes grants to different organisations like the Coalición América Latina Saludable. Each of these groups is beholden to the views and whims of Michael Bloomberg.

Each NGO also takes a slice or commission of the funding as a pass-through and this keeps them engaged, enriched and duly compliant. This commingling and coopting of NGOs also distorts the true depth of control the philanthropy exerted on these organizations. Only a few people would catch or care that these NGOs are all funded by the same activist philanthropist or are all ordered to dance to Michael’s music. This includes the WHO.

It is curious why Bloomberg has spent so much time trying to deflect his involvement in his activist campaigns. The Firebreak has explained how this technique of hiding behind fiscal sponsors or universities frees his funds from being subject to rules of transparency, accountability or liability. So when Michael Bloomberg speaks out against alternative nicotine products like vapes and nicotine pouches, rejecting them as credible tobacco harm reduction strategies, a large number of seemingly independent organizations promote and implement his strategy. This includes the WHO.

While Bloomberg’s puritan view against tobacco harm reduction is controversial and lacking in scientific support, his flotilla has had no choice but to fall in line, supporting his views and translating them into campaigns. And, again, this includes the WHO.

Bloomberg’s Strategic Control of the WHO

A Firebreak exposé showed how 15 of the 29 NGOs allowed to attend the WHO’s Framework Convention on Tobacco Control (FCTC) COP11 last December were Bloomberg organizations (including a project that does not even exist as a legal entity).

Bloomberg’s tobacco control NGOs work in coordination to create an image of policy consensus and multi-pronged attack strategies on threats to their political goals. They present themselves as multiple organizations with different interests, but as they are all feeding from the same funding trough, their strategic consensus is one borne out of necessity. As they are so intertwined, it would be suicide for any organization to dare speak out in favor of vaping and nicotine pouches as two effective means to reduce cigarette consumption and harm.

To say there is consensus against tobacco harm reduction products simply means that one billionaire believes it to be so. But shouldn’t someone in the World Health Organization look at how these alternative nicotine products have succeeded in reducing smoking rates in countries like Sweden and New Zealand? Especially when they make these claims very loudly at international conferences? That would be basic common sense, except that these Bloomberg-funded organizations all exist, essentially, to run different parts of the WHO tobacco and nicotine control strategy via a Bloomberg-funded program called: “MPOWER”.

What is MPOWER?

MPOWER is the WHO technical initiative providing a series of measures designed to help countries implement the WHO Framework Convention on Tobacco Control (FCTC).

It is an acronym that includes six measures to implement tobacco and nicotine control: Monitor, Protect, Offer help, Warn, Enforce bans, Raise taxes.

The WHO claims ownership of the program and provides the framework, but the funding for implementation comes from external donors, the largest of which is Bloomberg Philanthropies.

a) What is the WHO’s role in MPOWER?

The reality is that the WHO does not directly fund MPOWER implementation. They have no budget outside of being able to produce a webpage with three lines of text. The African WHO MPOWER report says a bit more, claiming they provide: “technical guidance, global monitoring and policy frameworks”, but what does that mean?

The Framework Convention on Tobacco Control (FCTC) aims to reduce tobacco and nicotine use at the member state level, meaning FCTC signatories set targets via the MPOWER initiative. But the WHO does not finance country‑level implementation, nor do they get involved.

To implement the FCTC/MPOWER targets, member states rely on: government budgets, philanthropic funding and NGO‑managed grants. It is important to understand that most lower and middle income countries can’t afford large budget allocations to such programs, so they depend on philanthropies and NGOs to comply with the WHO targets. Enter Michael Bloomberg.

b) What is Bloomberg Philanthropies’ role in MPOWER?

Bloomberg Philanthropies is the primary global funder of MPOWER implementation, via the Bloomberg Initiative to Reduce Tobacco Use, which explicitly supports countries in adopting MPOWER policies. They claim that more than 100 countries now have at least one MPOWER policy in place due to this funding and they are expanding the initiative with Michael Bloomberg committing an additional $420 million to expand MPOWER implementation over the 2023–2027 period.

Does MPOWER actually exist as a real WHO programme or is it an externally run sub-contract. UN agencies like the WHO have very little budget and with recent funding cuts from (former) member states like the US and EU countries, they have been forced to rely more on philanthropists and their global NGOs to design and run their programs. This can have a serious negative influence on global policies. A few other cases:

• Why, for example, is the UN’s Food and Agriculture Organization spending so much time promoting a backward peasant farming ideology like agroecology? Well, the Agroecology Fund has 100 million reasons for that.

• There can also be an effect on the long-term survival of such global programs. Like MPOWER, the UN Environmental Program played a symbolic role in the Net-Zero Asset Management Initiative or the Net-Zero Banking Alliance, marginally managing the program. It quickly fell apart when all of the funders and activist leaders left for “greener” pastures.

How beholden is MPOWER to Michael Bloomberg, and would it meet a similar fate should the emperor lose interest (or run out of funding)?

To understand this, we need to recall how Bloomberg does not fund a philanthropy, he manages a complex web of organizations directed to deliver his strategy.

c) How does Bloomberg money fund MPOWER?

Bloomberg funds MPOWER implementation via his flotilla of NGOs. It is important to realize that there is zero funding going directly to the WHO. Michael keeps tight control over what the WHO can say or do on tobacco control.

So how does Bloomberg fund his NGO flotilla to control and implement the WHO strategy? Here it gets curious.

Recall that MPOWER is an acronym for six services or strategies to implement tobacco control. Bloomberg NGOs are slicing up MPOWER implementation in a way that certain NGOs from his flotilla are responsible for different measures in the initiative which they, of course, then coordinate between themselves.

• Monitor tobacco and nicotine use via surveillance systems developed by the CDC Foundation (via a $360 million Bloomberg fund for tobacco control support)

• Protect individuals via smoke‑free laws implemented by the Campaign for Tobacco-Free Kids that runs programs for advocacy and legal support

• Offer help via cessation services provided by Vital Strategies’ cessation programs and media campaigns

• Warn on the risks of tobacco and nicotine products via Bloomberg’s STOP (Stop Tobacco Organizations and Products) watchdog

• Enforce advertising bans and other restrictions is managed by the Campaign for Tobacco-Free Kids which proudly identifies itself as the “enforcer NGO”.

• Raise taxes through the International Union Against Tuberculosis and Lung Disease’s tax modeling support

It would be impossible for the WHO to cut this Bloomberg Gordian knot and still have a program. Most of Bloomberg’s $2 billion that keeps his flotilla afloat is directed toward this interdependent MPOWER strategy, with a centralized control nerve center.

There is no WHO involvement here, because, well, Bloomberg funding is always about control. To be fair, it is his money and he can decide how to spend it … but then don’t pretend that MPOWER is a WHO program developed by a large number of separate NGOs coming together to provide a consensus view …. and don’t pretend that the WHO Global Ambassador accolade wasn’t anything more than cheap ribbon awarded by a broke international agency.

How MPOWER (ie, Michael Bloomberg) influences tobacco reduction strategies in developing countries?

As mentioned earlier, MPOWER implementation depends on funding from governments, philanthropies and NGOs. Most developed countries can afford to fund their own programs and their leaders are intelligent enough to recognize how harm reduction strategies using alternative nicotine products like vaping and nicotine pouches can dramatically reduce smoking and its health consequences. But many lower and middle-income countries cannot afford such programs and remain captive to Bloomberg-funded puritan dogma.

That being said, the Bloomberg MPOWER pixie dust also rubs off on wealthier nations. The European Commission awarded €3 million to a consultancy to produce a report to guide the upcoming revision of the EU Tobacco Products Directive, and several Bloomberg NGOs were directly involved. Given how the EU’s Health Directorate is committed to obeying the WHO’s diktats, much of the report’s advice had parroted the Bloomberg rhetoric against alternative nicotine products.

But Bloomberg NGOs are generally focusing their funding and activism in developing countries where they can make a bigger impact. They often award individual grants that can reach hundreds of thousands of dollars per project. As these cash-strapped governments often lack the budget or expertise to implement the MPOWER / FCTC strategies, the Bloomberg groups often manage the show in regions where that kind of money speaks loudly.

The WHO is merely a shadow behind the curtain in these developing countries while a global health program has been effectively outsourced to a billionaire with a messianic complex.

And Michael Bloomberg does enjoy the limelight on the global stage. In helping lower and middle income countries reach MPOWER targets, Bloomberg Philanthropies then gives out awards to countries that achieve certain goals. At last year’s celebration gala, government ministers from India, Mauritius, Mexico, Montenegro, the Philippines, and Ukraine were able to pose for photos with Michael at the World Conference on Tobacco Control.

Time was when Michael Bloomberg was a candidate for President of the United States, but now he has found another stage for global attention.

How the WHO became subservient to one billionaire

The Big Change series has shown how the well-funded groups behind the campaigns are more concerned about winning than about advancing human health or improving the environment. The MPOWER debacle shows how one billionaire can pretend he is saving lives in a simple black or white issue while his prohibitionist strategies are actually forcing so many to continue smoking due to his failure to understand the complexities of the issue.

Bloomberg’s flotilla of NGOs is determining global tobacco-harm reduction strategies and policies, against the evidence of scientists, academics and wealthier governments not reliant on the billionaire’s money.

The regulatory reactions against nicotine harm reduction strategies like vaping and nicotine pouches is mainly based on activism run by Bloomberg NGOs in the name of the WHO. It is now creeping into regulations like the EU Tobacco Products Directive which is planning to submit to the WHO by imposing restrictions and higher taxes on e-cigarettes and nicotine pouches.

The WHO is powerless to intervene – they do not control the funds or the policy implementation and can only accept what Michael Bloomberg tells them to say. Their scientists have to systematically reject each study that shows how vaping and nicotine pouches are far less harmful than smoking. They have to turn the microphones off on member states at FCTC COPs when they demonstrate how promoting tobacco harm reduction strategies have significantly helped reduce smoking levels. They have to raise fears on Big Tobacco funding aimed at the youth to deflect from the reality of the exponentially higher Bloomberg funds they are receiving.

The WHO is left powerless and forced to provide Michael Bloomberg with a veil of legitimacy that he uses to promote himself and gain facetime and photo-ops with national leaders when they celebrate MPOWER achievements. For the WHO, the only thing worse than this is for Michael Bloomberg to suddenly get bored with the WHO and stop writing the checks. If that happened, the WHO MPOWER and FCTC websites would be taken down within weeks.

Conclusion: What can be done?

This case study shows a serious abuse of Big Change, but there are measures that can be taken.

• The UN needs to clean out the activist cobwebs from its agency programs and remove its dependence on billionaires, foundations and interest groups. The UN needs to downsize and rely on member states for their program initiatives.

• UN member states need to define clear guidelines for non-state actors they choose to collaborate with. Rather than celebrating billionaires like Michael Bloomberg, they need to impose limits to their influence. If Elon Musk funded the UN peacekeeping program and started directing blue berets to war theatres of his own liking, would the UN support this? Would they be in a position to stop this?

• The US needs to impose stricter tax and transparency regulations on foundations run by billionaire philanthropists, especially when they are operating outside of the US and often against US interests. Bloomberg’s NGO flotilla are not doing humanitarian work in the same way an NGO like GAVI is, but are simply running activist lobbying campaigns and extorting governments in developing countries.

• Finally, we need to differentiate between NGOs and other civil society non-profits that do humanitarian work and what I have referred to as APEs (Alternative Policy Enterprises) that manage large lobbying and litigation budgets as fronts for interest groups and billionaire “philanthropists”. Bloomberg’s flotilla are more APEs than NGOs.

Otherwise, the only other alternative is to wait until the billionaire runs out of money or his interest wanes and common sense on tobacco harm reduction can return. Given how Big Change operates to preserve itself, that may be a long wait where far too many people will believe the anti-harm reduction dogma and continue smoking.

A Missouri jury is shortly to be asked to sit in judgment on the environmental standards that ought to apply to a smelter in the Peruvian Andes. The plaintiffs—more than 2,800 Peruvian citizens—are represented by American trial lawyers who recruited them in Peru. The defendant is not the Peruvian operating company that actually ran the facility, but its American parent, Doe Run Resources. Peru itself has twice protested to the United States that the proceedings infringe its sovereignty and breach the letter and spirit of the bilateral Trade Promotion Agreement.

The case is a textbook study in how well-intentioned environmental litigation can produce perverse outcomes. A clear-eyed risk-benefit analysis shows that Doe Run Peru’s stewardship of the La Oroya complex delivered measurable improvements in emissions, employment, and community conditions relative to the disastrous pre-1997 baseline—progress that the litigation now threatens to erase.

Critics contend the company’s record fell short in some areas, but the evidence indicates the story is more complicated: Doe Run Peru inherited a toxic legacy it did not create, invested far beyond its contractual obligations to clean it up, and kept the local economy alive while doing so. The litigation itself now does more harm than the emissions it seeks to punish.

Nationalized industry: “A vision from hell”

La Oroya sits at 12,300 feet in a narrow Andean valley. The metallurgical complex there began operations in 1922. For three-quarters of a century it was run first by a private American firm and then, after nationalization in 1974, by Centromin, a Peruvian state-owned enterprise. Emissions controls were minimal. Lead, arsenic, sulphur dioxide, and other metals poured into the air, water, and soil. By 1997, when the Peruvian government privatized the asset, the surrounding area was, in the words of one contemporary report, “a vision from hell.” The soil was contaminated; rivers ran with industrial waste; vegetation had largely disappeared.

Doe Run Peru, the new owner, inherited that legacy. Under the purchase agreement it accepted a detailed environmental remediation plan (known locally as a PAMA) that required roughly $110 million of spending over several years. The Peruvian government, for its part, retained responsibility for cleaning up historic soil contamination and agreed to indemnify the buyer against claims arising from pre-1997 operations. This division of labor was not generosity but commercial realism. No rational investor would have accepted open-ended liability for three generations of unregulated pollution by the state itself.

Private cleanup begins

What happened next is instructive. Doe Run Peru spent more than $300 million—nearly three times the original estimate. It built a new industrial wastewater-treatment plant, replaced antiquated slag-transport systems that had dumped waste directly into the Mantaro River, installed modern arsenic-handling facilities, upgraded air-pollution controls (including electrostatic precipitators and baghouses), and constructed sulphuric-acid plants to capture sulphur dioxide and metals from the lead, zinc and copper circuits. Fugitive emissions were tackled with enclosures and dedicated filtration. A closed-circuit television system allowed real-time monitoring and rapid response.

These were not cosmetic gestures. Lead emissions from the main stack fell substantially—by roughly 68-74% according to company and operational data—and overall air and effluent quality improved markedly in monitored parameters. Effluent discharges that had routinely violated Peruvian standards were brought substantially into compliance with the PAMA requirements Doe Run was obligated to meet.

Crucially, the company kept the complex running while it upgraded it. That mattered because La Oroya’s economy revolved around the smelter; closing it would have been an immediate social disaster. Instead, Doe Run Peru employed thousands, raised wages, built schools and clinics, ran hygiene programs for children, renovated homes to reduce lead-dust exposure, and funded nutrition and health initiatives.

Blood-lead levels among workers and residents, while still elevated by rich-country standards, fell markedly during its stewardship from the extreme pre- and early-privatization highs. The improvements were real, measurable, and achieved in one of the harshest industrial environments on earth.

Pragmatic investment vs punitive nostalgia

The risk-benefit ledger therefore favors Doe Run Peru’s approach. The pre-1997 baseline was decades of uncontrolled emissions under mixed private and state ownership. Doe Run Peru accepted a polluted asset, invested heavily in abatement technologies that its predecessors had never bothered with, and delivered measurable reductions in exposure while sustaining employment. The alternative—leaving the complex in state hands or selling it to an operator with lower environmental standards—would almost certainly have left the community worse off. That is the logic that has guided successful clean-ups of legacy industrial sites from the Ruhr to Pittsburgh: pragmatic investment beats punitive nostalgia.

Yet the Peruvian government did not honor its side of the bargain. It failed to remediate the historic soil contamination for which it had explicitly accepted responsibility. When the global financial crisis struck in 2008-09, it refused a modest extension to finish the final PAMA project. Doe Run Peru was forced into involuntary bankruptcy. The complex has been largely idle ever since. Thousands of direct and indirect jobs evaporated. No new operator has stepped in while the threat of American litigation hangs over the asset. The people now suffering most are the very residents the plaintiffs purport to represent.

Litigation compounds the injury

Two groups of American lawyers traveled to Peru to solicit clients. They enlisted a nun and a priest as “next friends” to lend moral authority in a devout community. The Peruvian entity that actually operated the smelter was not sued, only the Missouri parent and its executives. This is a deliberate attempt to keep the case in an American courtroom where damages can be larger and procedural hurdles lower.

Peru has objected formally, arguing that a Missouri jury has no business setting emissions standards for a Peruvian smelter or second-guessing the regulatory choices of a sovereign government. The US-Peru Trade Promotion Agreement expressly bars America from undertaking environmental law-enforcement activities in Peru. Allowing tort damages to function as de-facto fines for breaches of local standards comes uncomfortably close to doing exactly that.

Imagine the absurdity if the sovereign jurisdictions were reversed. Would the United States ever tolerate a foreign court ordering which regulations apply to a Missouri factory?

Evidence from whistleblower testimony and internal documents supplied by Doe Run describes forged official stamps, fabricated records, bribes to officials and coercive recruitment tactics—promises of dietary supplements withdrawn if families refused to sign. Critics of the company may downplay these issues, but the allegations cannot be waved away; they must be tested in court, and they raise serious questions about the integrity of the plaintiff recruitment process. Nor can the fact that the plaintiffs’ own experts have undermined the central jurisdictional theory: that St Louis executives “controlled” day-to-day operations at a complex 4,000 miles away. Real-time metallurgical decisions in the Andes are not made by video conference from Missouri.

The broader stakes are larger still. Foreign direct investment in extractive industries in developing countries is already politically fraught. Investors weigh political risk, commodity-price volatility and regulatory uncertainty. If American courts can retroactively impose their own environmental norms on projects that were openly negotiated with host governments, the calculus changes. Companies will either demand iron-clad indemnities (which Peru has shown it will not honor) or simply stay away.

The losers will be the very communities that need the capital, technology and managerial know-how to improve their environments. La Oroya’s experience is a cautionary tale: the only party that ever spent serious money cleaning up the site is now bankrupt; the complex it modernized is idle; the government that promised remediation has done nothing.

None of this is to deny that lead, arsenic and sulphur dioxide are serious hazards. Heavy-metal exposure carries well-documented health risks, particularly for children. Public policy must manage those risks. But risk management is not risk elimination at any cost. It requires weighing costs and benefits in context. In La Oroya the context was a legacy of 75 years of neglect by the state and prior owners, a high-altitude industrial valley with few other economic options, and a host government that both invited foreign capital and then failed to meet its own obligations. Against that backdrop, Doe Run Peru’s record—substantial emission cuts, sustained employment, community investment—represents genuine progress that no amount of litigation can replace.

Conclusion

A Missouri jury cannot usefully decide what the “correct” emissions standard for a Peruvian smelter should have been two decades ago. Nor can it fairly apportion blame when the host government has walked away from its contractual duties. The claims belong in Peru, where the facts can be examined by judges familiar with local conditions, the regulatory history, and the trade-offs inherent in any industrial operation.

For the last ten years, the Big Change activist movement has benefitted from unlimited dark funding coming from billionaire philanthropists, funneling hundreds of millions of dollars into their networks of NGOs, law firms, large media groups, academics, scientists and influencers to control public policy. A large part of this money was undeclared, non-transparent and free from scrutiny as Big Change bought control of the public narrative, from climate hysteria to chemophobia, from fast food to pharma, from the microplastic mania to the arbitrary rejection of vaping and nicotine pouches as tobacco harm reduction tools…. Forcing their needless transitions on consumers, affecting western economies and prosperity, Big Change then moved to the task of dismantling capitalism and industrialization … that is … until somebody pulled the plug on the party.

Yesterday (April 23), the US Department of the Treasury announced that organizations claiming tax exempt status (NGOs, foundations, universities and some media groups) will have to be transparent about who is funding their projects and campaigns. The Firebreak has spent three years exposing a series of egregious violations where foundations were spending hundreds of millions of dollars creating NGO front groups, false research centers and media reporting organizations to advance their interests. Today we celebrate this announcement as the first step in a return to fairness in the policy arena.

This does not mean the misuse of foundation funding will end, but that it can no longer enjoy tax exempt status (ie, paid for by taxpayers). As billionaires hate to pay taxes, it will force most activist funding out into the light of day. The press release notes how fiscal sponsorship has been misused to hide abusive activist behavior.

“Fiscal sponsorship is an umbrella term for several longstanding and lawful structures through which a tax-exempt organization may support charitable projects and initiatives. Recent congressional oversight has raised concerns that some fiscal sponsorship arrangements may be used to obscure who is operating a project, who controls project funds, and how those funds are being used.”

The fact that fiscal sponsorship hides funding sources is one issue, but activist groups also pretend to be NGOs or legal entities when they don’t actually exist outside of the fiscal sponsoring organizations. As they are not legal entities, there is no accountability. In the Department of the Treasury’s press release, Scott Bessent states:

“When bad actors misuse charitable structures, directors and officers should understand that transparency can lead to scrutiny, accountability, and liability under the law.”

Big Change should be able to understand this given how NGOs like US Right to Know or Corporate Europe Observatory demand that industry be transparent. As these two NGOs are, themselves, funded by dark, donor-advised funds, the hypocrites actually thought the rules did not apply to them.

A good example of this was in the three-part Firebreak exposé on Beyond Plastics, a phantom NGO run out of a tiny academic institution in Vermont, Bennington College, acting as its fiscal sponsor. While there is no declaration of how much Beyond Plastics receives (as it only exists as a project sponsored from within Bennington College), it is known that Bloomberg Philanthropies has committed $85 million to the Beyond Plastics and Beyond Petrochemicals “projects” (and that the foundation is a donor to Bennington). But worse, how can a phantom NGO be held accountable if they don’t exist? When Beyond Plastics published false claims about the safety of plastic (PVC) water pipes, the industry body wanted to file a complaint, but to whom?

Bennington simply ignored the complaint and put Beyond Plastics’ false claims down to “academic freedom”.

Even more ridiculous is that the head of Beyond Plastics, Judith Enck, was allowed to testify in front of Congress representing this phantom NGO to advance her campaign. Judith must be exhausted after having to cover up so many years of deception.

A Call Finally Answered

The Firebreak has been regularly calling for the removal of the tax exempt status of any non-transparent donations, arguing it would reduce corrupt campaigns and the manipulation of policy debates. See below, for example, our recent recommendations to end conflicts of interest within the scientific community (where researchers are paid dark money to generate studies creating a baseless fear of microplastics).

Why is this Important?

Activist groups have been using this dark money loophole to hide funding, conflicts of interest and accountability for their claims. People can easily be bought (sorry) and some bad actors have destroyed the good will and public trust of NGOs. This is why The Firebreak proposes a distinction between humanitarian-based civil society NGOs and policy lobbying non-profits (that should be called: Alternative Policy Enterprises).

Take, for example, the smoke and mirrors show at Earthjustice. Registered as an NGO (tax exempt), this organization functions like a law office, filing lawsuits to support other activist campaigns. They have an annual budget of over $200 million although they only earn around $5 million in awards from successful lawsuits, which means not only that they must not be very good lawyers, but that the rest of their budget must come from donations or investments. But donations from whom?

The NGO is not at all transparent. A look at their 2023 IRS Form 990 shows that they received two donations from two “persons” totaling over $29 million. Earthjustice does not have to declare who paid this pseudo-law firm such large, kind grants. The only thing we are allowed to know is that this funding was tax-deductible (so a part of these millions was courtesy of the American taxpayer).

It is not correct for an organization that functions as a law firm, filing lawsuits against industries (and thus in favor of the interests of other industries), to take any anonymous donations … of any size. But this illustrates how corrupted the practice has become. Earthjustice no doubt believes that they are doing “God’s work” and can be trusted with such dark money, without having to reveal what earmarks or which interest groups were involved in $29 million worth of lawsuits. But in reality, whoever donates $15 million to a law firm has a clear interest in the outcome of the lawsuit (likely for some alternative product that will benefit if its competition is banned or bankrupted).

But don’t think for a moment these activists will just give up and come clean. They are not willing to go back to begging for funds or not controlling the narrative. They are not willing to give up the private jets and move back into the strip mall. Big Change organizations still have other tools at their disposal to hide donations from special interest groups, like dark donor-advised funds. The Firebreak will continue to expose these violations until a certain degree of fairness and transparency returns to the policy arena. But for now, let’s celebrate this win.

Scientists tend to get bogged down in the technical details when they try to explain something to a non-specialist. If I want to know if it is safe to eat an apple, I don’t want to know about maximum residue levels, LD50s or long-term, low-dose effects. I am searching for a simple message I can trust and relate to.

Where the scientists fail, the activist fear campaigners excel by simply saying: “There are chemicals on your apple that are banned in the EU. They will give you cancer and cause you to suffer a slow, painful death!!!” And if we try to explain the high levels of safety, their clear, simple message is: “Well, that is industry data. We just don’t know for sure what is an acceptable dose level so it is better to be safe than sorry!”

How do we deal with this message deficiency?

Too often the scientists get caught in the refutation trap: “No, this does not cause cancer!” or “There is no proof that this chemical causes autism.” These are not positive messages that the public is looking for. And the more you deny, the guiltier you look, falling into an unwinnable trap by merely associating the product with the risk. Trust is an emotional judgement and a positive message goes far in building confidence.

We tend to forget that the public does not want a comprehensive explanation or a science lesson. They are not looking for the facts. They are looking for a simple explanation, an image or story they can easily hold onto. Trust is built on information people can understand and relate to. They just want to know, with a reasonable confidence, that something will not harm them, so they can go on with their day (without fear and uncertainty). If that reassurance cannot be given to them in a way they can hold onto, then they are left with doubt, and are vulnerable to believe one of the many claims thrown at them by relentless fear-mongers.

The message game is played on uneven terms. The scientist has to be right, with certainty. The activist only has to get you to doubt something is certain. The science communicator has to respect the science and get the audience to reject the seeds of doubt.

I used to refer to activists as watchdogs. My dog could bark at the moon 99 times out of a hundred, but that one time it stops a threat, it justifies its worth. If a scientist or a company is wrong one time in a million, it is unacceptable. Trust is built on the intention of care and concern. My watchdog cares for me, that company researcher wants to profit from me.

I have been active in science and risk communications since the 1990s, well before the 2000 House of Lords Third Report on Science and Society. Back then, the number of experts in this field, across Europe, could be counted in single digits. While the fields of science and risk communications have changed over the last three decades, as well as the communications technologies, the messages and the framing remain largely the same.

Allow me to share the top twelve messages I have used to try to reassure the public on environmental health risks.

Child’s Play

All of the messages need to be simple, clear, relatable and immediately reassuring. They have to be easy enough for a child to understand yet complete enough to assure trust and confidence. Aim for common sense reasoning that can stick in people’s minds. Most importantly, the messages have to be short and direct – people lose interest after 15 words. They also need to get at the misconception leading to the fear and doubt.

To this day, my greatest achievement has to have been a children’s book for scientists on risk communication I had written in 2005. Truth be told, it took me 45 minutes to write the “Do’s and Don’ts” down in a scrap piece of paper in a bar in Thessaloniki. Perhaps that is why it remains so special to me.

Please feel free to use these twelve messages in conversations with your friends and family who might be trying to spread fear and uncertainty with you. Don’t get angry with them – your goal is not confrontation but reassurance.

Some of them have been borrowed from others far smarter than me.

Twelve Messages for Science Communicators

1. Chemicals are not man-made. In fact, man is made of chemicals.

2. Just because it’s natural doesn’t mean it is good. Ebola is natural.

3. There are more carcinogens in a single cup of coffee than in the pesticide residues of an entire year’s consumption of fruit and vegetables. (Bruce Ames)

4. There are over 1000 chemicals in a cup of coffee. We have only tested 28, and 19 of which are carcinogenic to rats. (Bruce Ames)

5. There are around 10,000 chemicals in a single meal, causing the body to deal with the cocktail effect on a daily basis. That’s what the body does.

6. Contextualize numbers: A part per billion is like a drop of water in an Olympic swimming pool. Or: A part per billion is like 1 second over 31 years. Or: This is equivalent to the size of Belgium.

7. The dose makes the poison. (Paracelsus). One aspirin can do a lot of good; 100 … not so good. Or: To reach a minimum level of daily risk exposure, you would need to eat 20 boxes of cereal per day.

8. Correlation is not causality. The presence of a chemical does not mean that it caused a disease any more than the rooster’s crowing caused the sun to rise.

9. Risk management is part of daily life. When we cross the road, we are managing a large number of risks. Why? Because we want the benefits. Risks have uncertainties but they are also tied to benefits and opportunities.

10. This chemical is produced naturally in the body. Or: This chemical also exists in nature. Or: This chemical has been synthetically produced to remove impurities.

11. Science doesn’t care about how you feel or what you believe. It seeks to discover the truth. Or: Science isn’t democratic. It respects the facts and evidence.

12. If the science is proved wrong, it will adapt and test the next best hypothesis. Does your dogma or belief system do that?

I could go on, but I like round, established numbers (not very scientific, I know).

When you communicate with non-scientists, be patient and empathetic. They may be misinformed or ignorant, but most of all they feel vulnerable. These issues concern them and they are afraid. Open up, share your own feelings and listen to them.

At the Forum for the Future of Agriculture, Kurt Vandenberghe, the European Commission European Commission Director General for DG CLIMA, presented the EU’s recent “Carbon Removal and Carbon Farming” regulation. From the perspective of climate change regulators, it seems that farmers exist to grow carbon stores, not food. After Kurt’s keynote, the bean counters all came out with their own agriculture carbon calculations. Afterall, if you can’t measure it, you can’t manage it. But what exactly are they managing? The financialization of soil, carbon and nature are just further examples of how detached leaders are from what farmers actually do. Their metrics reminded me of the “Quick Fix Doctors” from the carbon emission trading scheme, building great solutions to answer the wrong questions.

My favorite quote of the conference came from Martin Stuchtey, the founder of the Landbanking Group, saying that “nature needs to be treated like an infrastructure project”. This reminded me of the optimism of the geo-engineers ready to take on the climate and “fix” Mother Nature. Once again, a great solution to answer the wrong question.

So what is the right question? Why didn’t anyone at this conference ask the farmers what they need? As in years past, a full day of speakers and panels at the Forum for the Future of Agriculture did not include a single farmer to voice their concerns. No, the experts and gurus thought they could speak on behalf of the agricultural sector and the food chain, shaping farmers’ needs to fit their own dogma while ignoring the interests of the most important link in the chain.

At times, some of the comments toward conventional agriculture at this Brussels event were downright offensive. Sandrine Dixson-Declève, the Global Ambassador for the Club of Rome and Executive Chair of Earth4All, did not earn any compliments from discussions during the coffee break when she crowed that organic produce is now cheaper than conventional (due to the high price of fertilizer following the US-Iran war). But what did we seriously expect? No one in the room was expecting a speaker from the Club of Rome to be sensitive to the plight of real people.

In the same way that Big Change failed to listen to the concerns of consumers and real people in crafting their solutions to the wrong questions on their climate campaign and energy transitions, the dreamers, idealists and activists plotting out their food system transition are working from their echo-chamber and not asking the farmers for their advice. Big Change’s cosmopolitan opinions of farmers are even more demeaning than the climate campaigners view of consumers: “Just pay them a short-term subsidy and that will be enough to make them go away and keep their tractors away from my office.”

To Big Change, farmers will just have to adapt to the new rules as we all set out on implementing our food system transition. Consumers will have to change their eating habits (maybe only meat on Mondays?) and the food industry will have to retool to adapt to the new reality. What could possibly go wrong?

It might not be a bad idea for Big Change activists to be asking the farmers what they need and want, and maybe these activists should also expand the sources of the advisers they are listening to. … And it would probably help if they were a little less arrogant in approaching the issue.

What do Farmers Want?

Farmers want to earn enough to make a living, protect their soil and land and safely bring the harvest in. They don’t wake up in the morning and think of how they can contribute to the great food system transition. They would love to save money using fewer inputs and less labor, but they also need solutions that will work. If they try something and it fails to perform, they will not use it again. They want better seeds, fewer weeds and a secure access to water and fertilizer. One thing most farmers absolutely hate is the amount of paperwork and delays they face with regulatory compliance, as they seem to spend more time at a desk than in the field.

So what is Big Change promising farmers? More paperwork, especially if their main job is now “carbon farming”. The Big Change campaigns to block GMOs and gene editing will restrict farmers from the best available seed technologies. Their strategy to ban herbicides like glyphosate not only restricts weed control, it also inhibits a farmer’s means to protect the soil with complex, multi-species cover crops and no-till farming (so they will release more carbon and moisture via tillage while requiring more fertilizer … unless, of course, if Big Change succeeds in restricting fertilizer use). As for access to water and irrigation, essential in a warmer climate, let’s not forget the almost annual attacks in France by militant peasant groups on farmers who try to build irrigation ponds to capture the winter rain. So the Big Change food system transition campaign will make it harder for farmers to make a living, to protect their soil and land and to bring in the harvest – the opposite of everything farmers need.

“It’s a sacrifice I am willing to make”

Farmers are not the only ones who will suffer from the Big Change food system transition.

• Consumers will have to pay more (just like the energy transitions consequence).

• People will eat fewer fruits and vegetables, not because of fear of Big Change’s contrived pesticide risk campaign, but because of high prices and lower food production supply.

• This will have a knock-on effect on public healthcare costs as diets deteriorate.

• As more farmers abandon their land or shift to agroforestry (exactly what Big Change wants in their campaign to re-wild farmland), rural communities will suffer as more economic activity leaves these agricultural regions.

• The food processing and manufacturing industries will struggle to maintain secure supplies, not just from fewer farmers but also from increased risks from crop failures. Costs will go up.

• This will affect retailers as they face longer supply chains, less price stability and access to quality produce.

All of this because a small group of well-funded activists just wanted to ban GMOs and pesticides. Big Change clearly does not realize how integrated the food system is.

What is infuriating is not only that Big Change is ignoring all of these issues, but that they will celebrate many of the negative consequences as they advance their transition strategy toward their real goal: a short-chain, local, organic food system without industry scale and involvement. Agroecology is essentially Marxism applied to the food chain. This transition is presented as inevitable and urgent, a foregone conclusion everyone has to accept, and Big Change, once again, does not care about the consequences, but only about winning this campaign.

Big Tech to the Rescue

Big Change is imposing their ideal-driven transition on the food system, without science-driven innovation. But given the dogmatic handcuffs these activists have placed on farmers (affecting the rest of the food chain), Big Tech is trying to find solutions and quick fixes.

Rather than fighting the finality logic of the food system transition, like the transition to renewable energy, researchers are trying to introduce new technologies to help adapt to the appropriated agricultural solutions (that are now deemed unacceptable by the self-appointed transition architects). Like the Smart Grid that was developed to deal with renewable power production inefficiencies (that benefit the affluent at a cost to the average consumer), farmers are now being offered high tech solutions to deal with what used to be minor problems.

A new era in agriculture is being rushed forward, including precision farming with AI decision-making tools and on-site sample analyses, drones to spray and measure yields, self-driving combines to better utilize land use … When a Big Change activist mentions vertical farming or digital labelling, everyone gets excited. These are all amazing emerging innovations to deal with problems that had never been serious or considered until Big Change started to obstruct how farmers farmed.

Like the expensive energy transition solutions, if you are wealthy ag-pioneer, own your land outright and like to play with new gadgets, these transition technologies will do the trick. But most farmers are struggling to make it to the next harvest. They cannot afford to invest in all of these Big Tech solutions for a low-tech operation. And by the way, how certain are we that Big Change peasant farmers, the ones who stormed French irrigation ponds as symbols of some undefined agro-industry, won’t start shooting drones out of the sky because of unfair competition with their tiny, permaculture or biodynamic plots?

Like the transition to electric vehicles, a great technology whose time has not yet come, Big Change will force the (too early) adaptation of these emerging agriculture technologies to speed up their transition timeline. As they develop and the food system adapts, then these technologies can be gradually implemented with continuous improvements and innovations (what industry production stewardship advocates consider as a “transition”). And they will develop according to what farmers need, and not to what some well-funded activists want.

Sure, Deere and Co, Microsoft and other major companies (all sponsoring the Forum for the Future of Agriculture events) will do well when these emerging technologies are widely adopted (when every farmer has a fleet of drones). But most farmers won’t or will suffer from the setbacks of developing emerging solutions that should have been given more time to evolve into an affordable, practical and successful solution to real problems. Once again, Big Change, with its “No Time to Lose” transition urgency, won’t let that happen.

So will the food system transition go the same way as the climate crisis energy transition? Surely some good things will come from it, but they would have in any case, just in their own time. But more farmers will go deeper in debt, abandon the fields or rotate to other, less consumer oriented crops. Markets will suffer supply shocks, affecting consumers and the rest of the food chain.

The campaign to impose a food system transition is just one further example of how the arrogance and hubris of Big Change puts humanity on another unnecessary collision course. Like the demise of their climate campaign, the public will react negatively to Big Change’s demands. It won’t just be tractors in front of government offices. Food and energy are seen in the West as basic rights. Nobody wants Big Change to go into their cupboards any more than they wanted them to turn down their thermostats.

While no one in the environmental movement wants to admit it, the rhetorical days of climate crises, net-zero and carbon-free solutions have become part of political history. This should not have happened given how hundreds of millions of dollars of dark foundation funding were poured into climate campaigning, paying off the media and driving ESG and corporate social responsibility goals. So what went wrong?

Neo-Marxists and environmentalists used the threat of climate change as the opportunity to refocus their campaign against industry and capitalism. They framed it as an existential crisis, centering on the urgent necessity for an energy transition away from fossil fuels toward renewables. There was “no time to lose” so targets were rushed forward to decarbonize western economies. Transition to renewables, transition to electric vehicles (EVs), transition to a net-zero industries – all of these massive green infrastructure transitions became imperative, with target deadlines set for 2030 (or 2035 at the latest).

It was a moral imperative. Millions of children were marching in the streets, there were theatrical street shows, closures of airports, movies on the climate movement and cultural events. If an academic wanted to publish a paper in a journal like Nature, it had to mention the climate crisis. Companies had to frame their press releases within the new theological dogma. And every news story was reported as a climate story. The narrative was so seamless that no one even asked who was funding this show. This is the perfect example of how Big Change was at work in the background, controlling the campaign, the narrative, the networks…

Fatal Assumptions

Since the impact of severely disrupting western economies would be inevitable, Big Change started to advance to concept of “degrowth” in a post-capitalist world. Rather than exhausting the word “transition”, Big Change referred to this period as “late-stage capitalism”, assuming that the fate of the economic/financial system had already been sealed.

There was one little problem. Nobody asked consumers if they were ready to give up social and economic goods, accept harder times and pay more for lower quality products.

• The transition to renewables meant higher energy costs, colder homes and risks to a secure energy supply.

• The transition to EVs meant more expensive cars with battery technologies that would be obsolete within a couple years.

• With wealth disparity near record levels, western consumers were then told that growth, jobs and progress were not longer part of the plan.

Should anyone have been surprised with the results of the elections of 2024-25 when consumers were asked what they actually thought of all of this?

People don’t want to give up social and economic goods for some idealistic transition. The climate campaigners had been drinking their own Kool-Aid and convinced themselves that saving the planet was a far greater calling than a warm home or affordable personal mobility. Change was inevitable, they argued, and the only question was how fast the transition could be imposed. These activists could afford the sacrifice and did not consider the effects such cutbacks would have on the less affluent. Worse, they believed the studies they had funded that reassured them that the transition would not lead to any short-term decline, and could even deliver benefits.

In the business community, there was a clear set of assumptions that no one could question: that the days of fossil fuels were over, that capitalism had entered its late, final stages, and that deindustrialization was a beneficial part of the degrowth strategy. Asset managers were rating companies according to their commitment to decarbonize, earning ESG points was a core corporate strategy and every event, every decision, had to be climate motivated.

Pure Madness

In hindsight, the demand from Big Change to rapidly decarbonize was pure madness. Government subsidies for offshore wind farms were driving the public purse deeper into debt, farmers converted valuable agricultural land to solar farms and targets for EVs were well ahead of production capacity or recharging infrastructure.

The financial community bought into the transition as a new business opportunity, new products and new investments. In their ESG world, old heavy industries were being challenged, threatened, blacklisted for not falling in line. Davos lost a decade of business leadership defining itself by climate interest groups and an angry Swedish teenager.

If the climate campaigners had just slowed their transition demands to incremental changes (which the industry concept of product stewardship called “continuous improvement”), they would still be leading the movement towards a greener, lower carbon economy over the coming decades. But Big Change is about creating opportunities to push a transition as fast and as binding as possible.

“Compromise” does not exist in the Big Change lexicon.

The Big Money Behind this Big Change Transition

Once climate change was declared a crisis, assumedly by the UN at first but repeated so often that no one (except Bjørn Lomborg) actually questioned the claim, Big Change was able to orchestrate large volumes of government and foundation funding channeled through their networks. With big money comes bigger networks of paid-off lawyers, scientists, journalists, lobbyists, consultants, celebrity influencers and slicker media campaigns. The Firebreak covered the party (even if we weren’t invited to the punchbowl).

• Florence Autret’s excellent investigation into the European Climate Foundation showed how foundations pumped hundreds of millions annually into a high-level fiscal sponsor to represent their interests at high levels in the European Union, UN and the World Economic Forum while paying off a network of NGOs. As part of the Big Change movement, they don’t feel they have to declare how much they receive from whom, and how much they regrant to whom (ECF’s 2023 income was €279 million).

• Perhaps the most egregious case of Big Change abuse was when a number of US-based foundations funded Canadian and international NGOs to run campaigns to try to “landlock” the Canadian province of Alberta to prevent them from being able to export their fossil fuels. The Firebreak reviewed the Albertan government’s official inquiry into the extent of the extremist campaigning, all orchestrated by foundation fund managers in the United States.

• The Agroecology Fund was a sleepy organization supporting peasant farmers on a budget of around $1 million a year until they changed their fiscal sponsor. Our Substack showed how the Global Greengrants Fund repackaged agroecology as a means to mitigate climate change (it doesn’t). They then tapped into their network of tech billionaires and within a couple years increased the funding to around $100 million for advocacy campaigns against conventional agriculture. Although they don’t disclose the amounts (because they only exist as a Global Greengrants Fund project and thus don’t have to), the Agroecology Fund seem to be running a lot of programs with the UN’s Food and Agriculture Organization (FAO).

• The Firebreak ran a series of investigations into the Carbon Disclosure Project (CDP), showing how support from the investment banking community allowed them to build a massive database of industry CO2 emissions (that the investment bankers then used as inside information to package into financial products). When the CDP started to diversify into other environmental disclosure products, the writing was on the wall.

• The UN nominally sponsored the Net-Zero Banking Alliance and the Net-Zero Asset Management Initiative to use the power of the financial industry to move the developed world toward a net-zero economy. The Firebreak showed how these bankers were the first to abandon the Big Change ship when they started to see how much they could earn selling AI Data Center investment funds (built on fossil fuels). By the 2025 World Economic Forum meeting in Davos, the climate crisis was a distant memory.

• Big Change invested a lot into controlling the media and the climate narrative. The Firebreak exposed how foundations, via discreet fiscal sponsors, set up a project called Covering Climate Now, to regrant millions of dollars to “train” journalists to report every news story as a climate story. The money was flowing so freely among reporters, with foundations like Bloomberg Philanthropies creating their own investigative reporting arms, that the climate crisis narrative should have been cast in stone.

One of the tragedies from this manipulation of reality was the reappropriation of development aid. To meet UN imposed climate commitments, many government aid agencies simply refocused their funding and redirected their programs toward climate-related issues. There was no new money. If you are running a family planning charity or a community health service in a developing country, you had better shift to planting trees to be able to avail of aid funding. I, myself, was involved in a rural development project that had its German government funding yanked because it did not meet their new climate-driven parameters. Once again, Big Change does not care about the actual consequences of their campaigns so long as they are successful.

Unravelling Big Change

Project Climate failed, with their ambitious agenda rolled back, the net-zero strategy derailed and the return to a fossil-fuel based economy entrenched, likely well past 2035. The activists should have listened, engaged and compromised. But Big Change did not think like that, dismissed opposition and only listened to their own expert advice.

There is a thinly veiled arrogance from activists and academics who suffer from the patriarchal belief than anyone who does not think like them is stupid and that their concerns should simply be ignored. Since the ignorant public adds no value to the discussion, campaigns, cutbacks and hardships should just be imposed on them. If governments, knowing full well of a potential consumer backlash, do not comply with the activist demands, then Big Change pumps even more resources into attacking the regulators.

Giving these activists money and power just amplifies their arrogance (I call it the “Robert Malone Effect”). And if someone like me were to challenge their dogmatic activism with facts or a rational counter-arguments, I would just be ringfenced or branded an “industry shill”. In blissful ignorance, they can carry on with their campaign without the need for reflection or revision.

On the climate campaign, the idealists behind Big Change abruptly met hard reality during the elections of 2024-25. Will other Big Change campaigns suffer the same demise? In Part 3 of this series, Big Change’s food system transition will be evaluated.

With tens of millions in foundation funding and fiscal sponsor participation, with programs coordinated with the litigation industry and with a disproportionate influence on the media, academe and regulators, these change leaders could no longer be called NGOs. I coined the term: APEs (Alternative Policy Enterprises) to reflect how they have become a big business and could not be considered like other humanitarian NGOs and civil society groups committed to helping others. And to reflect their excessive size, like Big Pharma, Big Tech, Big Tobacco … this movement should be called: Big Change.

Big Change

Big Change refers to an industrial-grade complex of activist forces and interest groups that implement continuous transition strategies to attain massive social, economic and political disruption. It has become a force seeking to dominate and control human behavior through their transformation of society. As a movement, Big Change does not seek consent, but rather, out of a sense of urgency, it imposes restrictions upon its publics.

They used to be a fringe movement of a handful of environmentalists climbing smokestacks and shouting outside of offices, but then, shifting to a foundation-funded model, their budgets increased exponentially, allowing them the cash to integrate media and academics into their campaigns. Activism is always about change and as the activist movement grew more powerful, more influential and more wealthy, it became Big Change. Now, standing beside their foundation billionaires, law firms and interest groups, they give speeches at UN conferences, Davos forums, US Congressional hearings and European Parliament meetings.

The narrative of Big Change is continuous transition away from the societal norms and laws, and it purveys most policy dialogues today. The world is changing at an incredible pace so we need to change or die. These campaigners are not looking at incremental change, but always revolutionary, systemic change.

“Transition” is the keyword used by Big Change campaigners.

• On energy, they have attempted to impose a transition away from fossil fuels.

• On chemicals, Big Change have used fear campaigns to transition toward “nature-based” alternatives.

• Conventional farming is coming under intense pressure from Big Change, working with Big Organic to restrict farmers’ ability to use synthetic pesticides, fertilizers and gene-edited seeds. A transition to agroecology is their only solution.

• Big Change wants to impose transitions away from livestock farming as well as putting arbitrary llimits on most food processing technologies.

• On economics, Big Change wants to see a transition from growth, global trade, capitalism and industry.

We need a “happiness index” instead of a GDP growth metric, they argue, and Big Change won’t be happy until capitalism is dead and their degrowth strategy is adopted. This is extreme-left socialism – Marxism without the proletariat. The wealth and technology that capitalism has produced will be redistributed: industry without factories, produce without production, work without labor… I once called this “Foundation Capitalism” but it is something far larger than just the inside influence the activists have on a handful of billionaires.

This is no longer a movement of tree-huggers with clipboards seeking donations from passersby on sidewalks or telemarketing for membership dues. That 1980s financing model is long gone. The Firebreak has been cataloguing some of the revenue streams Big Change has been non-transparently amassing.

• We translated an investigation by Florence Autret on the European Climate Foundation, an NGO that earns over €270 million per year they then quietly redistribute to almost every European NGO working on climate change campaigns.

• The Firebreak showed how the Agroecology Fund spends over $100 million a year advocating (ie, lobbying) against conventional farming practices. We had to go to the foundation pages to track the amounts as the Agroecology Fund a) does not exist as a legal entity, and b) does not, therefore, have to disclose its balance sheet.

• Bloomberg Philanthropies has created a flotilla of Big Change NGOs to fight, on behalf of the WHO, against tobacco harm reduction products like vaping and nicotine pouches. With $1.6 billion in funding (plus an extra $400 million committed) this is a classic textbook case study of how these Bloomberg NGOs are no longer merely stakeholders.

• Michael Bloomberg has also created operations like Beyond Plastics and Beyond Petroleum to lobby against plastics and fossil fuels. He has reportedly donated at least $85 million, with more from other foundations, but as he set them up via fiscal sponsors, where neither campaign operation is a legal entity, the actual income and campaign expenses remain in the dark.

Big Change prefers to operate with Big Secrets.

Idealists and Pragmatists

Idealists speak of values to guide their decisions. Pragmatists look for the best practical answers to solve the problems we face. Nature/natural is a strong value for the activist community, so these idealists will impose preconditions like:

• farmers only being allowed to use natural-based pesticides even if synthetic alternatives are more efficient and better for the environment.

• Natural products like steel and glass are favored over plastics even if plastic alternatives have been found to be more sustainable in almost all applications.

• Solar and wind are seen as nature-friendly forms of energy regardless of the horrible environmental impacts of their production and the limitations to their power generation.

The values guiding Big Change are held as immutable, regardless of the negative consequences of their implementation. In other words, Big Change is a movement run by zealots more concerned with winning (imposing their changes) than making progress or improving human well-being or the environment. Transparency and honesty are not important values for Big Change activists.

While it is clear that pragmatists should have long-term goals supported by a commitment to shared values, they serve as guidance more than diktats. Where situations change, as they often do, or alternatives prove to be less efficient or appropriate in certain conditions, then the values of flexibility and pragmatism should influence the decision-making process.

As discussed in an earlier article, there is a significant difference in how Big Change understands transition compared to industry.

• For the idealists and activists, transition is certain and urgent, with change to be implemented as soon as possible. It is not a process for improvement but a euphemism for revolution. And once Big Change launches a transition campaign, there is no going back, no room for discussion and no compromise.

• For industry, transition is a progressive evolution of change built on innovation, development and continuous improvement (product stewardship). Like activists, industry is very interested in reducing energy costs and pollution, but this does not mean they force an arbitrary transition to meet some ideological dogma. They are pragmatic and seek progress and evolution rather than disruption.

Change as progress is a force for good providing societal benefits. Change as a political strategy is a force for power demanding societal sacrifice. Big Change is about power and control.

Date: March 1, 2026, 10:00 am

Location: UCSF, San Francisco

Attendees: Don, Joanna, Robbie, Sam, Susan, John

Subject: Finding new targets for MDLs

Don: Thank you for joining us today. The purpose of this meeting is to find new chemicals and companies to focus our next wave of litigation efforts on. It has been an amazing time for our industry. We moved from being the joke of the legal profession, the greedy strip mall ambulance chasers, to becoming the wielders of social justice by: shaping societal narratives with our influence on regulators, the media and filmmakers; having the ability to fund studies to create courtroom-ready evidence; and being the true public defenders protecting humanity from the excesses of industry and capitalism. With billions in fees from recent headline lawsuits, we have built an empire of power and control.
… But we are also vulnerable, as the expenses and debt of our industry has grown faster than our opportunities. For some time now, we have needed much more revenue and, quite frankly, we are running out of credible cases on talc, glyphosate, fossil fuels and benzene. I think we have exploited these issues as far as we could but our budgets and debts keep multiplying. Bottom line: Given our cost structure, we urgently need big health issues to harvest new revenues from.

Robbie: I thought we were moving on paraquat? We invested a lot in that EWG journalist to promote the “Paraquat Papers”.

Susan: No, the science was really weak there and the bellwethers were an embarrassment. I thought we had bought that judge, but she really ripped into our strategy. And in any case, Syngenta, our primary target, announced they were going to stop producing the herbicide. That means the punitive damages part of the court decisions would be lower. That is always our best fee source.

Joanna: But herbicides are a real money spinner. We have built a strong network with the Moms, the NGOs and Big Organic behind us, most of the public will believe anything we say about the risks of herbicides and almost everyone except farmers think they’re unnecessary.

John: Didn’t we fund a group of scientists around that Benbrook fellow to test urine samples of pregnant women to track the correlation between herbicides and neonatal issues? That was sure to be a blockbuster, plus the researchers were eager to refer plaintiffs to us and act as litigation consultants. What did they call themselves?

Sam: They were called “Heartland Something Something”. I heard they folded operations after failing to get government recognition and funding. Then their new director had a rather public meltdown after he discovered the rules the scientists were breaking and what they were actually doing for us. He kept going on about them needing more integrity and some ethical procedures.

John: That’s too bad – Our law firm invested a lot of money into them via their donor-advised fund.

Don: Look, I am not going to have to remind you how urgent this is. Speaking for our firm, the litigation finance interest rates are really starting to bite. One more appeal on talc and we will have to ground one of our jets.

Robbie: Yeah, I hear ya. We’re selling off caseloads and had to cut our plaintiff settlement contributions to under 10% … some clients have even complained to the press … in breach of our NDAs. Thank goodness our media groups kept that off the news. … What are your loan rates, if I may ask?

Don: 25% annual interest and 25% of the payout or settlement. But they keep rolling the debts over, never question new loan applications or follow up on how we actually expense the cash.

Joanna: That’s pretty good. Can you give me their number? … What about climate change issues. Couldn’t we sue Big Oil for hiding the facts and causing climate change? Foundations will give us millions to file these climate nuisance cases so we don’t have to invest much into trying to win.

John: No, been there, done that. New Ventures Fund tried to group foundations together to support Sher Edling. They haven’t won a bloody thing and wasted too much cash on celebrities. The idiots were even plagiarizing their arguments.

Joanna: But Sher Edling were trying cases on behalf of State governments who were only interested in political posturing. What if we try to get plaintiffs who lost their homes to storms and wildfires to cry in front of juries?

Don: Those would give us peanuts. How much is a house worth? 10 mill, plus 100 more in punitives? That won’t even cover our ad spend and expert witness fees. The foundations were funding Sher Edling’s lawsuits just to harass the fossil fuel industry – they never planned to win.
No, we need something big, where we can file hundreds of thousands of cases to extort a large corporation to settle for tens of billions of dollars. It is the only way we can pay off of our debts and open up a new cash line with the finance firms.

Joanna: Whatever happened to those scientists and NGOs we had been funding to create doubt on artificial sweeteners? Didn’t we have Coke against the ropes to be the next Monsanto, with aspartame as the next glyphosate?

Susan: I thought so too but the industry groups finally got up and did something. They got the governments of Japan and the US to push IARC into a corner. We only got a “possibly carcinogenic” classification from their aspartame monograph, and that wasn’t enough to sway even the most outraged jury. I fear industry is finally catching on to our IARC playbook.

Don: That’s bad news. Can someone please tell me why we are paying those Collegium Ramazzini scientists so much if they can’t deliver a simple 2A classification? I mean, it’s only a hazard assessment for Christ’s sake.

John: Yeah, Fiorella doesn’t have the same influence as she used to. I blame the Russians.

Don: And Chris, Martyn, Philip and Bernard are getting on in age. We need some young blood to take over there. Daniele was good but he got himself into a little bit of a scandal and lost his job – does anyone know if we were found out in that scandal?

Joanna: I’ll check with Jennifer at Mercury Films. She’s always been very discreet. In any case, it wouldn’t help Ramazzini to expose us, so they are doing a good job keeping the media at bay.

Sam: I was reading somewhere that vaping might have health issues. Should we take another swing at Big Tobacco. Juries love to hate them.

Susan: Not gonna work. The science isn’t there, nicotine does not cause cancer and the harm reduction advocates have a compelling argument.

Sam: But we don’t need science, never did. Look at how Michael Bloomberg has made it rain. He is coming up to two billion in funding his campaign against tobacco harm reduction alternatives, has the WHO in his pocket and has an entire flotilla of highly-paid activist NGOs following his directions. Surely we can tap into some of that loose cash pile.

Don: At most we could only get a billion from them, nowhere near enough to move the needle. In any case, Big Tobacco is so last century. We need the next new Big Tobacco. Has anyone lunched with Naomi lately? I should give her a call.

Joanna: Well, didn’t we pay a group of researchers to make the case that the food industry is intentionally making people addicted to ultra-processed food? They even found some former tobacco scientists in their labs. That story writes itself – especially all of those big fast-food corporations who would settle out of court in a heartbeat. Ten billion is absolute peanuts for them.

Robbie: Two problems there. One, they print all of the food information on the back on the tray linings so the customers only have themselves to blame for their poor food choices. Two, we haven’t even got a definition of ultra-processed food and most research is based on really weak correlation studies. We’ll lose all cases in appeal when we aren’t able to choose the Judicial Hellhole jurisdictions and judges.

Don: What’s the point of paying campaign contributions to all of those judges and attorney generals if they can’t deliver anything for us?

John: I was thinking that the plastics industry is ripe for some settlement harvesting. There are a few cases in California against industry’s claims of being able to recycle plastics. These were funded by that Australian metals industry billionaire, so maybe we could amplify them with claims for environmental clean-up costs and force a settlement.

Susan: Sorry, but nobody in any courtroom cares about the environment. We need to march in the walking wounded, preferably hooked up to IVs, to show how plastics poisoned them and made them sick.

John: Our firm has been funding studies into microplastics causing all sorts of diseases and endocrine disruption. Can’t we start advertising for victims? I’m sure Andrew at Minderoo will underwrite our bellwether cases.

Robbie: Negative. The studies have all been making claims that are embarrassingly unsubstantiated … sorry. It doesn’t matter how many times our NGOs push that fear campaign, it is not sticking. PFAS??? Only regulators gave a damn and many are walking those decisions back. And besides, most of the companies processing the plastics that we are detecting in humans are small, downstream operators. They will just go bankrupt and that is a rabbit hole I am not going down again.

Susan: We can always hit Tylenol for autism. Bobby Jr practically handed that to us on a platter.

Don: Yeah, but Kenvue is on its knees already. Do you really want to spend the next decade in bankruptcy arbitration?
… Guys, this is going nowhere. We need new blood and we need it soon, otherwise it is back to the strip malls for a good number of us.

Joanna: You make us sound like vampires. (Heavy, nervous laughter from Don and Robbie)

Sam: We investigated the books of most Big Tech companies, and their cashflow will easily cover the billions to settle out of court. Given our financial distress, we need to go after the motherload.

Robbie: Yeah, but what cases can we use to extort them?

Sam: I’m sure we can find something. We might be able to go after Apple and Samsung on cell phone radiation. We can find some scientists to link 5G to cancers. Or maybe file more cases against social media companies for getting our kids addicted and depressed. The GenZs are ready and willing to take a microphone to claim their victimization. I mean, … they’re already doing it on TikTok. Then there is data protection, AI and misinformation. The public hates these tech billionaires so the juries are well-primed to deliver a few landmark decisions. We can easily pay some experts to come up with some evidence and publish some papers in the usual journals.

Joanna: But we are risking getting more and more exposed as the power controlling these issues from the shadows. Isn’t there a threat of reputational damage to our industry if a couple Elon posts stick to us?

John: No issue. Big Tech is falling more and more into the Evil Industry category. Did you see what the media did to that nice Sam Altman guy? Now the public are attacking his house. No, the public will be too outraged by industry malfeasance to notice the billions we are harvesting from them. They lie and we lie low. Our networks and industry groups will do all of the work for us. Those New York and DC-based NGOs we have been using work for peanuts.

Susan: It’s time to tobacconize them! Maybe our friends in IARC can do another monograph on cell phone radiation and cancers. I’ll reach out to Chris and Bernard to make some calls. Our journalists and foundations won’t need much convincing to use our reports to go after them.

Don: OK, it looks like a plan. Their pockets are deep and the billionaires don’t want to be vilified more than they already are. Let’s get a group together to see what Big Tech companies are doing that we can sue them for, then we can target one company and start planning our campaign. We’ll need to decide whose litigation finance company is going to underwrite and package this one.

Sam: We should set up a separate shell foundation to coordinate the attacks. Which NGOs and universities can we sign on? Let’s start with a short list of academics for our fiscal sponsor group.

John: And Davos has been picking up the AI and security points at the last two meetings. With all the scandals going on, I guess Larry is the one we should tap into at the World Economic Forum? I know Blackrock is rolling big time in data center investment funds, but this wouldn’t be the first time we got him to speak out of both sides of his mouth.

Don: Good points. But we’ll need to generate some credible-sounding evidence first. Remember the chemtrail fiasco? Shall we meet up at the Rockefeller Foundation’s New York offices in a month to start developing a strategy and dividing up who gets to sit on the Plaintiff’s Bar?

Meeting closed at 11:45, followed by a nice lunch.

These minutes are not 100% accurate. Given the nature of the business, it is likely the vocabulary and attitudes were less humane.

The main profits from any energy revolution are made by the first movers. With the present transition to green, renewable energy, the profits are obscene.

In 2017, I installed a number of solar panels on my roof. I wrote about how I realized what a hypocrite I was, erecting environmentally destructive green vanity symbols while financially impairing my neighbors. For the last decade, I enjoyed subsidies and free energy while they had to pay for them with higher electricity tariffs. To this day, solar panels are still playthings for the privileged, but it has gotten worse. As the green activists continue to push for a renewable-only grid, I am finding new ways to profit from my neighbors. As in 2017, I still hate myself … but I’m not an idiot. I’ll bank the profits and the government incentives.

Greens and socialists (more and more the same thing today – Marxists without the proletariat), have this anti-industry, post-capitalist agenda where they see renewables as the means to return energy to the people, the prosumers, flattening the inequities and social injustices of capitalist exploitation. These people are so cute, and while on paper, it might sound virtuous, in practice, the consequences, especially to their electorate, are devastating. How many apartment complexes or working class neighborhoods have solar panels or wind farms on their properties? Certainly not the apartment building across the street from me. The only thing they are getting is unaffordable energy bills, unstable electricity supply and a grim outlook as the energy mix continues to decarbonize.

Capitalism is merely entrepreneurial opportunism. It is not a disease that some self-appointed socialists need to eradicate; it is human nature. Even in the strictest peasant Communist state, people will still try to take advantage of an opportunity and do better for themselves and their families. Striving for success is normal behavior. The socialists find their progress or success offensive; the greens detest their increased consumption and wealth.

To them, the fossil fuel industry symbolizes this expansion of wealth, environmental harm and naked exploitation. So they have been running a campaign to transition from these capitalist weapons of mass destruction, and despite the temporary Trump bump, have been fairly successful in shifting from an efficient energy grid mix to a green grid. Meanwhile the dash for Middle East oil and the war economy market panic are masking the movement towards a renewables-based market trading environment. But behind to political gyrations, the transition continues unabated. If anything, their argument goes, the fossil fuel supply cuts have made a transition to renewables even more urgent. With that newfound urgency, we seem to be entering a new age of “green capitalism” on the renewables market.

What has changed in those nine years since I decided to put those horrible green goblins on my roof?

Grid Evolutions

People with means are able to capitalize on the opportunities in the energy sector. Wealthy neighborhoods have solar panels, EV chargers and well-insulated homes, all subsidized by the governments pretending they were meeting UN climate targets (by incentivizing the affluent). Farmers are now planting solar farms instead of food, leasing space for wind turbines and generating methane instead of fertilizer. I fear for the long-term effects of this incentivized stupidity, but at least these farmers are finally earning a decent income and having some time off in the summer.

In the decade since my solar panels have been paying me dividends, we have seen several energy shocks (from the post-COVID supply crisis to the Russian invasion of Ukraine to the present tragedy in Iran). While my socialist-green neighbors have had to pay premiums to keep the lights on, I continued to enjoy free electricity and heating.

Faced with the climate-imposed demands for an energy transition, and the green NGO rejection of nuclear, cold fusion, hydroelectric and geothermal solutions, utilities have had to find means to control the unpredictability of renewable energy supply. To be more efficient, they are letting the market take over. The main threat is to have mass outages caused by renewable energy instability (remember the Spanish-Portuguese grid failure last year). Amid stupid, irrational preconditions, the grid had to get smart.

Most energy companies are demanding their customers install digital electricity meters so they can more easily inflict variable pricing to control and reduce energy consumption during peak periods. Seeing how this change would mean my old analog meter would no longer spin backwards to provide me with free energy and heating through the dark winters, I did what most other affluent Belgians did – I went out and bought a home battery so I could avoid having to pay for electricity at night. With government incentives, I didn’t even realize I was no longer going to be sharing my energy with my neighbors.

As I watched them install this non-recyclable, heavy-metaled monster in my garage, I tried not to think of all the children in the Congo that were being exploited for my privilege. And of course, all of my options are “Made in China”. There is no way this green solution of home batteries could ever be considered as ecologically friendly, let alone socially just. But the Green-Socialists have willed it so and the UN has sanctioned it as a necessary step for Net Zero. I made the investment.

Buy Low, Sell High

But I didn’t just buy a home battery. I bought a smart battery. As the salesman was trying to convince me of my advantages, even I was floored by the obscenity of this next level of green capitalist opportunism.

With my smart battery on a dynamic pricing electricity contract, I could turn my solar panels into a money spinner, and more. There are times when energy on the grid is at a surplus (ie, on very sunny or windy days) causing electricity to be negatively priced. At this time I could top up my smart battery and wait until the grid price is high to sell my power back at a profit. This is not energy I produced to share on the grid, this is pure, no-risk market manipulation automated to ensure maximum profit. My salesman was from a new energy provider that only serves such clients and then trades their surplus on the open market, furthering my opportunities.

Rather than being illegal, my robber baron capitalism is subsidized since I am helping stabilize the grid. The European Union even mandates that I have the right to exploit. My neighbors in the apartment complex, without solar panels or home batteries, had to pay the full price of their fixed tariff energy accounts. Meanwhile, I was not only getting free energy, I was able to profit from their misfortune by selling them those high-tariff kilowatts during peak hours that I was actually paid to load up.

While the salesman was appealing to my self-interest to be able to sell me a far larger battery than my wife and I would ever need, I kept looking out the window at my neighbors, the ones who voted for the Green and Socialist parties in the last election. As if I didn’t feel the obscenity of it all, I was then informed that if I had an electric car, I could store and trade even more energy through the car battery. So it is no longer a car. That was a feature too far – even I know that an EV is the most unsustainable thing I could possibly own. My neighbors can no longer afford cars because the government-demanded transition to EVs has pushed the price of mobility out of their reach.

I would tell them to take the bus but public transport support is being slashed as governments have to spend more to fund the energy transition subsidies. What a wonderful age for fat-cat capitalist exploitation!

Green Capitalism

The ideal world the Greens and Socialists have been dreaming of has led to a new generation of opportunists – green capitalists – who have spotted the gap in the market. My smart battery salesman has 40 solar panels in his garden (he realistically only needs seven or eight) and he proudly shared with me a spreadsheet with his return on investment and monthly income. Like any new form of capitalism, it will take a while for regulators to catch up and humanize the injustices. In the meantime, there will be even more winners as the green capitalists take advantage of the inequities and opportunities from the next wave of energy expansion required to meet the new data centers coming online.

I was told I could easily stack more batteries in my garage. The opportunities to profit here are endless.

My neighbors in the apartment complex, renters, don’t have the means to enter this lucrative energy market. They have candles. I try not to imagine how vulnerable they will become during this upcoming energy crises. What is even more obscene is that the Belgian government will likely, once again, give grants to all citizens (voters) to help ease the high energy costs from the US-Iran war. Once again, I will bank that money.

I am a robber baron of the new green capitalism and I should not be allowed to profit from the misfortune of others. But as my government has committed to meeting the UN climate goals, move to some mythical net-zero and complete the unnecessary transition to renewables, I am considered a hero of the green economy. I try not to think of what I am doing to the environment with my unsustainable solar panels and monster smart battery, or how I am profiting while my neighbors’ struggle.

I just consider myself a Ukrainian peasant at heart, with some good fortune, trying as always to save some money. It’s in my blood.

The rather tiresome Activist Playbook is being applied again, this time not to pesticides, plastics, fossil fuels or chemicals like PFAS, but now to so-called ultra-processed foods. A recent study published in the British Medical Journal (BMJ) by a group of French activist scientists and their doctoral students has been making headlines in the food-fear world. They are suggesting that exposure to chemicals used in six food additive preservatives (like vinegar) increases the risk of cancer. Which types of cancer? All of them, it seems.

The Activist Playbook is a well-oiled machine:

• Fund some scientists to produce a study suggesting a health risk or correlation to a cancer (in mice) from lab exposure to a chemical found in consumer products.

• Use a communications consultancy to create a significant amount of media coverage and public outrage.

• Use your network within the Ramazzini/IARC activist community to push forward a hazard-based monograph on these chemicals to further legitimize your alarmist claims.

• Get NGOs to use these fears to push the anti-industry, post-capitalist narrative.

• Once the International Agency for Research on Cancer (IARC) pronounces their cancer classification, let the media and NGOs amplify the campaign as the US litigation industry begins to file lawsuits at a targeted company.

• Bring regulators into the game to invoke the precautionary principle, enhancing the perception of cancer causation to help influence the lawsuit outcomes.

• With hundreds of thousands of walking-wounded victims filing lawsuits and a select group of media-darling scientists force-feeding the public on a diet of fear and confusion, extort the targeted company into a multi-billion dollar settlement that hopefully bankrupts them.

• Take the cash and move onto the next chemical substance.

Ultra-processed foods are the next Holy Grail as the litigation industry’s climate lawfare and herbicide and talc honeypots run out of momentum. The first attempt, to identify the artificial sweetener, aspartame, as a carcinogen failed. But there are many chemicals used in the so-called ultra-processed food industry, so the activist scientists just moved on to a selection of preservatives used in food additives. Like aspartame though, the scientific community, fed up with the junk science designed for the media, is wasting no time to speak up and voice their criticisms.

The Relentless Madame UPF

The BMJ study was led by Mathilde Touvier, a French researcher and media darling who has always been ready for a microphone or a spot on a daytime talk show. I came to discover Madame Touvier’s tactics in the failed campaign to use the Activist Playbook to bring aspartame into the litigation industry’s arsenal of extortion. Then she was using any tactic she could to get the public outraged by the artificial sweetener, breaking rules of scientific integrity (like releasing possible findings of her study to the media prior to peer review). Her most recent attack on the chemicals in food preservatives reflected similar tactics and ethical issues.

In the BMJ paper, Touvier threw shade on the source of the study’s funding (perhaps trying to hide how much of it was a one-woman-show). She was a European Research Council (ERC) grantee (receiving €2 million in funding for this project) and she was awarded a funding prize from the Fondation Bettencourt Schueller. But rather than simply acknowledging that she had personally received direct EU and foundation funding, Touvier opted for the more deceptive line of saying: “This project received funding from the European Research Council (ERC) ... and a Bettencourt-Schueller Foundation research prize 2021”. This is typical of Touvier’s tactics, consciously trying to hide the fact that she received direct funding. Why didn’t she just acknowledge that she herself received the funding?

There was some interesting wording in the Bettencourt-Schueller Foundation funding award (“to identify correlations between ultra-processed foods and health”). The funding was not for a researcher to study a causal link between food and health issues, but rather was specified to identify correlations between certain foods and diseases. It is widely accepted in the scientific world that correlation does not imply causation. Touvier’s study seems to be another case of an activist foundation funding an activist scientist to develop activist-modeled assumptions for an activist fear campaign.

The Relentless Communicator

Once the study was published, the ultra-processed food campaigners took over amplifying the news in the mainstream media, including getting Touvier’s name all over articles in CNN, the Guardian and LeMonde. None of these articles covered dissenting views or discussed weaknesses and issues with the research. The BfR was motivated to issue the statement on this study (see below) because it had “garnered significant media attention”.

Getting the mainstream media to pick up an scientific journal article within 24 hours, and parrot the press release, does not happen normally with scientific publications unless a communications consultancy is employed to amplify the impact.

It should be noted that the same group of authors published a second article from the same research (on the very same day as the BMJ cancer correlation article) in Nature Communications claiming a link between these chemical preservatives in food additives with an increased risk of Type 2 diabetes. Given that the articles were submitted for peer review in popular journals four to five months in advance, it is extraordinary that the authors would demand to coordinate publication on the very same day, January 7. The purpose, of course, was to make a bigger impact in the mainstream media on January 8, 2026 so I suppose everyone wins (except the truth).

The two journals, BMJ and Nature, also behaved shabbily here in agreeing to Touvier’s media stunt, opting to publish activism to garner clicks rather than advance serious scientific research.

Next Step: Get an IARC Monograph Cancer Classification for the US Litigation Industry

Touvier has recently been elected to represent France on IARC’s Scientific Council. The study also includes another IARC author, Inge Huybrechts, so we can expect an IARC monograph on ultra-processed foods in the coming years based on the correlation findings of this study. Like the late addition of glyphosate to an IARC monograph on insecticides, the US litigation industry will do what it can to accelerate this process in order to then start amassing plaintiffs to sue a targeted food corporation.

Some would argue that this is a very cynical criticism. Not every scientist accepts and compulsively uses adversarial regulation tactics to attack industry. Some do this research because they believe they are advancing scientific discovery and keeping people safe. If Mathilde Touvier were to fit this mold, then she would have used a proper methodology rather than relying on correlations, she would have adjusted findings to consider confounding factors and false positives and she would have done deeper research into the level of exposures that could create a causal relationship between a chemical and a cancer (see BfR critique below). But as she did not, we can only assume that Touvier’s motives for producing this study were to create a strong media reaction and public outrage, advance her personal campaign against ultra-processed foods and create a benchmark for (regulatory, activist and litigious) pressure against the food industry.

• The litigation industry does not need quality evidence to create a case to persuade a jury.

• The activist NGOs do not need quality evidence to run a campaign and create public fear.

• The foundations do not need quality evidence to set up a funding program.

The Activist Playbook is built to thrive even if the scientific evidence falls flat. But in any case, we still need to ask: What did the scientific community think about the quality of Touvier’s research, her methodology and her conclusions?

The Scientific Community Reacts

After the last decade of campaigns built on junk science, the scientific community is no longer as patient with the tactics of these fear-mongering activist scientists. Last month, the German Federal Institute for Risk Assessment (BfR) examined the Touvier cancer correlation paper and concluded that the publication did not provide any data that would make the agency consider reevaluating its position on the safety of the six preservatives used in food additives (ie, that Touvier failed to provide sufficient data or information to suggest these preservatives were carcinogenic).

As the BfR published their critique in German, the Firebreak provided an English translation below. The German risk assessment agency summed up the quality of the study as follows:

From the perspective of the German Federal Institute for Risk Assessment (BfR), the study is subject to a number of significant limitations and uncertainties. Therefore, the BfR currently sees no reason to reassess the health risks of the preservatives in question based on this study.

In other words, while it may not affect the Activist Playbook and the intentions of the tort lawyers, NGO activists, foundation funders and media scaremongers, from the scientific position, Mathilde Touvier’s latest anti-UPF campaign stunt can be summed up in two words: “Junk science”.

Study on preservatives and cancer has weaknesses

The Federal Institute for Risk Assessment arrives at a critical assessment.

This is what it’s about:

A study conducted in France has identified six preservatives as being linked to an increased risk of cancer. The recently published research has garnered significant media attention. It is based on an analysis of questionnaires completed online by more than 100,000 participants in the NutriNet-Santé cohort study over an average period of 7.6 years.

From the perspective of the German Federal Institute for Risk Assessment (BfR), the study is subject to a number of significant limitations and uncertainties. Therefore, the BfR currently sees no reason to reassess the health risks of the preservatives in question based on this study.

Link to the study: https://www.bmj.com/content/392/bmj-2025-084917

The study used participants’ dietary information to infer the preservatives contained in their food. At the start of the study, the 105,260 participants were free of malignant tumors. During the study period, 4,226 of them developed cancer.

Eleven of the 17 preservatives examined were not associated with the occurrence of cancer. For the remaining six substances, a statistically significant association with an increased incidence of tumors was found. If the results for these preservatives are confirmed, the study authors believe it would be a reason to reconsider their current regulation.

The BfR has assessed the publication and points out a number of weaknesses in the study:

• Questionable causality: The NutriNet-Santé study is an observational study that investigated statistical associations (correlations) between preservatives and the occurrence of cancer. However, statistically significant associations cannot automatically be interpreted as causal relationships.

• Multiple testing: This study examines associations between a variety of preservatives and the occurrence of cancer. Therefore, it is susceptible to the phenomenon of multiple testing: When several statistical tests are performed, it is to be expected that some will randomly produce a false positive result. Since many preservatives were investigated in this publication, positive associations could be due to chance.

• Confounding factors: A significant problem in observational studies is the occurrence of confounding factors. These must be taken into account during data analysis. This is done, among other things, using statistical methods (adjustment). Despite extensive adjustment, residual confounding may remain. For example, it is difficult to separate the effect of certain preservatives from that of the foods in which they occur. Thus, the intake of sulfites (a preservative in wine) is associated with wine consumption. The observed cancer risk associated with sulfites may therefore be more likely attributable to alcohol consumption than to the preservative itself. Regular alcohol consumption is an established risk factor for certain cancers.

• Unclear recording: The data basis for the estimate of the intake of preservatives (exposure) in this study was based on the self-reported data of the participants. Inaccurate or incorrect answers lead to uncertain estimates of the preservatives ingested with the food.

• Questionable plausibility: The study reports an increased cancer risk of 12 percent (acetic acid) and 15 percent (acetates) for acetic acid and acetates, respectively (hazard ratio of 1.12 and 1.15, respectively). This is of the same order of magnitude as the increased cancer risk identified in the study for sorbates (14 percent), sulfites (12 percent), sodium erythorbate (12 percent), and potassium nitrate (13 percent). Acetic acid and acetates are natural components of many foods and are also produced in significant quantities during human metabolism. This calls into question the plausibility of the associations found for these preservatives and suggests that they should be considered of limited relevance.

• Reassessed: The preservatives discussed in the study were reassessed by the European Food Safety Authority ( EFSA ) as part of its program for the reassessment of approved food additives. With regard to potentially genotoxic and carcinogenic properties, EFSA had no health concerns for the additives in question.

Conclusion: For the majority of the preservatives considered in the study, no association with the occurrence of cancer was found. The observed associations are subject to uncertainties and should be interpreted with caution. It is unclear whether the observed associations are the result of multiple testing. If the observed associations do indeed describe existing effects, it remains unclear whether these are truly attributable to the additives. As the authors of the publication also emphasize, the results would need to be confirmed by an independent body. From the BfR ‘s perspective, this publication does not justify changing the risk assessments of the preservatives in question carried out by the EFSA .

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