Manure fraud threat turns mosquito into elephant

The report Threat Assessment Environmental Crime 2021 was published last month on behalf of the Public Prosecution Service. The picture that is sketched about the fertilizer sector is by no means positive. Manure fraud – if it is at all – is portrayed as a very extensive problem.

The program report was drawn up by 'all participants involved in the criminal law approach to environmental crime', including the NVWA and the police. Just to be clear: fraud cannot be excused in any way. Not even if it's small. It is not only reserved for the fertilizer industry, also the state lawyer cheats. That said, perspective is in order.

Generate a lot of publicity
But how big is the problem really? The NVWA cannot make that estimate because it is not part of the investigation. Drawing conclusions and labeling it as a major problem is by no means careful. What strikes me is that the makers try to generate a lot of publicity, including on social media, using expletives that are out of place. Is it negatively exposed to push politics in a certain direction?

The NVWA uses various weight indications throughout the report. Sometimes it is about tons and when it comes to the interpretation of the problem, kilograms are used. Not in the least objective and consistent and with a preconceived goal. Obtaining more money and capacity. A good methodological study should at least meet minimum criteria, one of which is due care.

How big is the problem really?
In the Netherlands, 75 million tons of manure is produced annually. I'm not going to burn my fingers selectively using different weight units and using the unit tons. Putting everything into perspective, the magnitude can be interpreted as follows.

In the period 2003 to 2018 – yes, you read that correctly, it concerns 15 years – the NVWA discovered approximately 1.235 tons of manure where the manure has not been accounted for or has been accounted for incorrectly. That is converted 82 tons per year. That is 0,000001% as a percentage of all manure produced.

Probably in the picture
In this period from 2003 to 2016 it concerns 'presumably' not or incorrectly responsible manure. In a period of 16 years, the criminal justice specialists talk about 185.000 tons of manure, which is probably considered fraud. A suspicion means that the least has been proven.

After all, the judge rules and not the NVWA. This 185.000 tons, if proven at all, over a period of 16 years ultimately amounts to 11.562 tons per year. That is a percentage of all manure produced 0,00015%.  Even if the problem were 100 times bigger and everything is declared proven, it is still a mosquito in percentage (0,015%).

Breathing Bias
The conclusions of the manure fraud investigation are by no means careful, tendentious and with a possible purpose. To put the sectors – including livestock farming – in a bad light. It exudes bias. Personally, I think this is a bad thing. Objectivity and thorough methodological research are thus wronged. There are other and more effective ways to draw attention to the problem.

A question that comes to my mind: is it fraud or is it just human error? Human errors that are labeled as manure fraud, to violate the law. So be it said.

Wilfried Neelen

Tried and tested in business advice. Fulfilled multiple executive and managerial positions. In the last 20 years mainly active in the fertilizer distribution and contracting sector. Motto: we do the right things and do things right.

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