The Defra Code of Practice on the Spread of Ragwort has numerous problems especially from a scientific point of view. The first point to make is that it isn't the law just guidance. The somewhat oddly named Ragwort Control Act neither makes ragwort control mandatory nor makes it compulsory to make a code. It came about because of pressure from equine organisations who were, in effect, making things up about the plant. In fact even the name of the Code of Practice is wrong. It talks about the spread of a plant, implying it is increasing, when in fact it was decreasing. The Government's own Countryside Survey showed that ragwort declining in Defra's area of remit, during the time the name was created. This is actually what you would expect since wildflowers in general are in decline.
Ragwort can be poisonous. That is known, but in order to produce proper guidance this isn't enough. They need to do this properly. There are many questions and the most important factor is determining actually what the danger and the risk actually is in order to advise people properly.
The most important factor in evaluating the risk is actually determining the level of the risk. In this respect the Code of Practice is very obviously wrong. It uses statistics in an invalid, and indeed innumerate fashion. This is the key important factor. The whole matter is about risk. If the risk is wrong then the whole purpose and nature of the document is undermined.
The Code of Practice gets the risk of ragwort completely wrong. It uses data which probably doesn't even exist. Draws conclusions that are wrong and then gets the maths wrong when processing those conclusions.
The central determination of risk is done as follows.
A figure of 500 horse deaths from ragwort poisoning in 2000. This figure is based on the number of confirmed horse deaths from ragwort poisoning seen by the Philip Leverhulme Large Animal Hospital Teaching Hospital at Liverpool University as a percentage of all the horse cases treated during the year, and grossed up to be representative of the total horse population.
This is very clearly a nonsensical use of statistics. First of all there cannot be any confirmed horse deaths from ragwort poisoning. The scientific literature is absolutely clear See: There is no test that can confirm ragwort poisoning
Secondly, Freedom of Information requests to the animal hospital concerned show that they almost never record any cases that might fit ragwort poisoning, having recorded only 1 possible case over an eight year period!
Thirdly, you cannot use statistics in this manner so Defra's mathematics is wrong! Examples at a hospital are not representative of the country as a whole, especially as this is the hospital of Professor Derek Knottenbelt who is well known for his work as an anti-ragwort campaigner, and who therefore would attract more cases.
Well-known medical expert Dr Ben Goldacre wrote an article in the Guardian Newspaper. [1] It was about human medicine, but he made a criticism of an identical idea of surveying at a medical institution and is scathing about it.
We can't do a full census of the whole population every time we want some data, because they're too expensive and time-consuming. Instead, we take what we hope is a representative sample. This can fail in two interesting ways. Firstly, a sample can be systematically unrepresentative: if you want to know about the health of the population as a whole, but you survey people in a GP's waiting room, then you're an idiot.There are also questions to be asked as to whether they should have been relaying on Professor Knottenbelt. He is often claimed to be an international expert on ragwort, but the evidence says otherwise. He is noted for his false claims such as that it was increasing when it was decreasing, that an animal which relied on it for its almost sole source of food was being poisoned by it, and that animals could survive having their habitat destroyed, as well as a whole load of other nonsensical claims. See Professor Derek Knottenbelt Country Illustrated magazine
It is perhaps the case that Defra realised their errors because on the 24th May 2016 the webmaster of gov.uk Paul Bowsher (@boffbowsh) tweeted
My task this morning: withdrawing guidance on dealing with the spread of ragwort #justGOVUKthings[2]
And the website carrying the Code then said:-
This publication was withdrawn on 12 April 2016The page linking to the document made it even clearer declaring it, "out of date". [3]This statutory Code of Practice remains an active and relevant document, used by both government and stakeholders. It has been retained for reference purposes as it provides detailed information on how to prevent the spread of ragwort.
Defra officials obviously misunderstood the political ramifications and have since tried to claim that this never happened, when the evidence shows it obviously did, In any case the Ragwort Control Act requires that the new code they have reinstated after withdrawing has to go before parliament and it hasn't.
Other serious errors since this time have included telling people that our native ragwort plant is on a list of invasive alien species.
At the time of writing Defra's website says that following Defra's bad advice will help you avoid fines under the Weeds Act. This is lying by omission. The omission being that you cannot just be fined under the Weeds Act as the act does not make the control of ragwort compulsory and only provides for rarely used control orders which have to be defied before any fine could be issued. See ragwort law
The Code of Practice is very clearly out of date. A 2022 paper [4] states:
Outbreaks of hepatic disease are common and once often were suspected to be caused by pyrrolizidine alkaloid (PA) toxicosis, [Ragwort poisoning] although more recent evidence suggests that PA toxicity is far less common than generally suspected.
The real thing to remember is of course that Defra's Code of Practice obviously doesn't use evidence properly. The only rational conclusion to draw seems to be that it cannot be relied upon by sensible people.
References:
1. https://www.theguardian.com/commentisfree/2011/aug/19/bad-science-unemployment-statistical-noise
2. http://web.archive.org/web/20160524092933/https:/twitter.com/boffbowsh/status/735032168926302208
3. https://web.archive.org/web/20160510161452/https://www.gov.uk/government/publications/code-of-practice-on-how-to-prevent-the-spread-of-ragwort?s=09
4. Association between forage mycotoxins and liver disease in horses Durham A.E J Vet Intern Med. 2022 Jul; 36(4): 1502-1507.