Multinational Monitor  [Printer-friendly version]
September 15, 2004


[Rachel's introduction: Opponents trot out a series of misleading
claims to contest the precautionary principle. A careful look shows
how these claims misrepresent basic Precautionary Principle precepts.]

By Nancy Myers

Opponents trot out a series of misleading claims to contest the
precautionary principle. A careful look shows how these claims
misrepresent basic Precautionary Principle precepts:

Claim: "If precaution applies to everything, it would stop all
technology in its tracks."

Response: Precautionary action usually means adopting safer
alternatives. A broad precautionary approach will encourage the
development of better technologies. Using this approach, society will
say "yes" to some technologies while it says "no" to others. Making
uncertainty explicit, considering alternatives, and increasing
transparency and the responsibility of proponents and manufacturers to
demonstrate safety should lead to cleaner products and production
methods. It can also mean imposing a moratorium while further research
is conducted, calling for monitoring of technologies and products
already in use, and so forth.

Claim: "Precaution calls for zero risk, which is impossible to

Response: Any debate over the possibility of "zero risk" is pointless.
Our real goal must be to impose far less risk and harm on the
environment and on human health than we have in the past. We must
harness human ingenuity to reduce the harmful effects of our

The real question is who or what gets the benefit of the doubt. 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. Increasingly, manufacturers are choosing to reduce risk
themselves by substituting safer alternatives in response to consumer
uneasiness, the threat of liability and market pressures.

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.

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.

Claim: "We don't need the Precautionary Principle; we have risk

Response: Risk assessment is the prevalent tool used to justify
decisions about technologies and products. Its proponents argue that
because conservative assumptions are built into these assessments,
they are sufficiently precautionary.

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, technology
or activity 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 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 or
level of safety, 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.

Claim: "Precaution itself is risky: it will prevent us from
adopting technologies that are actually safer."

Response: This is not true. Precaution suggests two approaches to new

Greater vigilance about possible harmful side effects of all
innovations. Alternatives to harmful technologies (such as genetic
modification to reduce pesticide use) must be scrutinized as carefully
as the technologies they replace. It does not make sense to replace
one set of harms with another. Brand-new technologies must receive
much greater scrutiny than they have in the past. Redirection of
research and ingenuity toward inherently safer, more harmonious, more
sustainable technologies, products, and processes.

Claim: "Implementing the Precautionary Principle will be too
expensive. We can't afford it."

Response: If a cost-benefit analysis indicates that a precautionary
approach is too expensive, that analysis is probably incomplete. Does
it consider long-term costs? The costs to society? The costs of
harmful side effects -- monetary and nonmonetary? The costs spread
over a product's entire lifecycle -- including disposal? The pricetags
of most products and developments do not reflect their real costs.
Like precautionary science, precautionary economics operates in the
real world, in which connections, costs and benefits are complex and
surrounded by uncertainty -- but they cannot be ignored. Tallying the
"cost" of precaution requires making true value judgments, which can
only partially be expressed by money. But in the 21st Century,
precaution is essential to a healthy, sustainable economy.

Claim: "The Precautionary Principle is anti-science."

Response: On the contrary, the Precautionary Principle calls for more
and better science, especially investigations of complex interactions
over longer periods of time and development of more harmonious
technologies. It calls for scientific monitoring after the approval of
products. The assertion that the principle is "anti-science" is based
on any or all of the following faulty assumptions:

1) Those who advocate precaution urge action on the basis of vague
fears, regardless of whether there is scientific evidence to support
their fears.

Most statements of the Precautionary Principle say it applies when
there is reason to believe serious or irreversible harm may occur.
Those reasons are based on scientific evidence of various kinds:
studies, observations, precedents, experience, professional judgment.
They are based on what we know about how processes work and might be
affected by a technology.

However, precautionary decisions also take into account what we know
we do not know. The more we know, scientifically, the greater will be
our ability to prevent disasters based on ignorance. But we must be
much more cautious than we have been in the past about moving forward
in ignorance.

2) Taking action in advance of scientific certainty undermines

Scientific standards of certainty are high in experimental science or
for accepting or refuting a hypothesis, and well they should be.
Waiting to take action before a substance or technology is proven
harmful, or even until plausible cause-and-effect relationships can be
established, may mean allowing irreversible harm to occur -- deaths,
extinctions, poisoning, and the like. Humans and the environment
become the unwitting testing grounds for these technologies. This is
no longer acceptable. Moreover, science should serve society, not vice
versa. Any decision to take action -- before or after scientific proof
-- is a decision of society, not science.

3) Quantitative risk assessment is more scientific than other kinds of

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 -- nor does it raise our
sights to better alternatives.

Claim: "The Precautionary Principle is a cover for trade

Response: The Precautionary Principle was created to protect public
health and the environment, not to restrict valid trade. North
American, Argentinean and other representatives in trade talks have
leveled this accusation against the European Union in response to EU
action on beef containing growth hormones and on genetically modified
foods and crops. Recent EU statements on the Precautionary Principle
have emphasized that the principle should be applied fairly and
without discrimination.

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 2000 European Commission statement on the
Precautionary Principle and Cartagena Biosafety Protocol both
assert that right.

Nancy Myers is communications director for the Science and
Environmental Health Network.