Multinational Monitor [Printer-friendly version] September 15, 2004 THE PRECAUTIONARY PRINCIPLE: ANSWERING THE CRITICS [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 achieve." 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 activities. 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 assessment." 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 technology: 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 science. 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 evaluation. 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 protectionism." 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.