|Science & Environmental Health Network|
Science, Ethics and Action in the Public Interest
Debating the Precautionary Principle
The precautionary principle has taken center stage in a number of recent international discussions on trade, the environment, and human health. As a result, it has stirred criticism as well as interest. In these discussions and in a growing number of media reports on the principle, certain criticisms and qualifications, enumerated below, have been repeated with some frequency.
The Science and Environmental Health Network offers the following responses to stimulate the thinking of others on these statements and on the precautionary principle. Many of these ideas were articulated in a January 2000 meeting of precautionary principle advocates and in discussions following the meeting.
"The precautionary principle is vague and has conflicting definitions."
For example, the 1998 Wingspread Statement on the Precautionary Principle summarizes the principle this way: "When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically." (The Wingspread Conference on the Precautionary Principle was convened by the Science and Environmental Health Network.)
The February 2, 2000 European Commission Communication on the Precautionary Principle notes: "The precautionary principle applies where scientific evidence is insufficient, inconclusive or uncertain and preliminary scientific evaluation indicates that that there are reasonable grounds for concern that the potentially dangerous effects on the environment, human, animal or plant health may be inconsistent with the high level of protection chosen by the EU."
The January 29, 2000 Cartagena Protocol on Biosafety says: "Lack of scientific certainty due to insufficient relevant scientific information . . . shall not prevent the Party of import, in order to avoid or minimize such potential adverse effects, from taking a decision, as appropriate, with regard to the import of the living modified organism in question."
(The negatives in this last statement echo the 1992 Rio Declaration on Environment and Development: "Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.")
As the principle has been elaborated recently, it nearly always implies three additional ideas, beyond "harm" and "scientific uncertainty":
Taken together, these concepts provide what we believe is a sound overarching approach to assessing and making decisions on products and technologies and other human activities that may impact health or the environment. That is how "precaution" operates at the broadest level. On this level it is something like the common-sense attitude we take in conducting our own lives and making decisions: We consider whether we need or want something, try to learn as much as we can about risks and benefits, consider alternatives, choose the best and (most likely) safest route, and hold responsible those who provide the services we choose. And when something we value is threatened, we tend to err on the side of caution.
But the precautionary principle, especially as articulated in international treaties and agreements, is also a specific justification for action in cases of likely harm and scientific uncertainty.
"If precaution applies to everything, precaution would stop all technology in its tracks."
"Precaution calls for zero risk, which is impossible to achieve."
The precautionary principle is based on the assumption that people have the right to know as much as possible about risks they are taking on, in exchange for what benefits, and to make choices accordingly. With food and other products, such choices are often played out in the marketplace. A major factor in the controversy over genetically engineered food is the consumer understanding that benefits of these products (which accrue more to producers than to consumers) do not outweigh the risk of harm to themselves or the environment.
Increasingly, manufacturers are choosing to reduce risk themselves by substituting safer alternatives in response to consumer uneasiness, the threat of liability, and market pressures. For example, a number of toy manufacturers have voluntarily stopped using phthalates in soft plastics. Such actions are in the spirit of the precautionary principle.
A key to making those choices is transparency - about what products contain, and about the testing and monitoring of those ingredients. Another is support, by government and industry, for the exploration of - and rigorous research on - alternatives.
Sometimes it makes sense to eliminate even questionable risks if it is easy to do so. For example, most airlines forbid passengers to use electronic devices during takeoff and landing, even though studies have not confirmed that they pose a danger.
In other cases the risk will be small but the consequences severe. An example of this kind of precautionary action is the U.S. "zero-tolerance" standard for Listeria monocytogenes in ready-to-eat foods. Listeria infections are rare, but they are extremely dangerous. (See Edward Groth III, "Science, Precaution, and Food Safety: How Can We Do Better?" Consumers Union of the U.S., Inc., February 2000.)
Market and voluntary action is not enough, especially on issues that go beyond individual and corporate choice. It is the responsibility of communities, governments, and international bodies to make far-reaching decisions that greatly reduce the risks we now impose on the Earth and all its inhabitants.
"We don't need the precautionary principle: we have risk assessment."
Too often, however, risk assessment has been used to delay precautionary action: decision-makers wait to get enough information and then attempt to "manage" rather than prevent risks. Risk assessment is not necessarily inconsistent with the precautionary principle, but because it omits certain basic requirements of the decision-making process, the current type of risk assessment is only helpful at a narrow stage of the process, when the product or technology and alternatives have been well developed and tested and a great deal of information has already been gathered about them. Standard risk assessment, in other words, is only useful in conditions of relatively high certainty, and generally only to help evaluate alternatives to damaging technologies.
Under the precautionary principle, uncertainty is also given due weight. The nature of the uncertainties about a technology can suggest such things as whether short-term testing can provide adequate answers; and if not, whether longer-term testing and monitoring can do so; and whether the benefits of the technology warrant that investment. The precautionary principle calls for the examination of a wider range of harms - including social and economic ones - than traditional risk analysis provides. It points to the need to examine not only single, linear risks but also complex interactions among multiple factors, and the broadest possible range of harmful effects.
This broad, probing consideration of harm - including the identification of uncertainty - should begin as early as possible in the conception of a technology and should continue through its release and use. That is, a precautionary approach should begin before the regulatory phase of decision-making and should be built into the research agenda.
What is not consistent with the precautionary principle is the misleading certainty often implied by quantitative risk assessments - that precise numbers can be assigned to the possibility of harm, that these numbers are usually a sufficient basis for deciding whether the substance or technology is "safe," and that lack of numbers means there is no reason to take action. The assumptions behind risk assessments - what "risks" are evaluated and how comparisons are made - are easily manipulated by those with a stake in their outcome.
"The precautionary principle is a tool of risk assessment."
"Precaution itself is risky: it will prevent us from adopting technologies that are actually safer."
"The precautionary principle is anti-science."
Risk assessment is only one evaluation method and provides only partial answers. It does not take into account many unknowns and seldom accounts for complex interactions.
"The precautionary principle is a cover for trade protectionism."
However, the real issue is not protectionism but whether a nation has the sovereign right to impose standards that exceed the standards of international regimes. The recent European Commission statement on the precautionary principle and Cartagena Biosafety Protocol both assert that right.
"Precautionary actions must be proportionate, cost-effective, and temporary (subjected to further research)."
Action should indeed be generally proportionate to the severity of a threat and standards of protection. But (as noted above) sometimes the availability of alternatives or the ease of taking action makes decisive action appropriate even if the threat is not severe or imminent.
"Cost-effectiveness" and "cost-benefit analysis" have been used in the past to stop regulatory action. Cost considerations, like risk assessments, are easily manipulated: whose costs and whose benefits are considered? The European Commission precautionary principle statement makes the useful assertion that "protection of health takes precedence over economic considerations." If "cost-effectiveness" is defined in this way, then of course precautionary decisions are cost-effective, directing us to the least costly choices.
All decisions about technology, positive and negative, should be temporary - that is, open to review and revision based on new knowledge and experience. A precautionary approach has many feedback loops. As uncertainty is reduced, we may say "yes" to some things to which we previously said "no, " and vice versa. This implies that all stakeholders should have access to relevant information. But sometimes the judicious decision will be to turn away from technologies that pose too many uncertainties and offer too few benefits. It will not always make sense to invest limited government resources into continuing research into those technologies.
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