Regulatory Toxicology and Pharmacology
October 4, 2005


Assessing and managing risks of chemical substances and genetically
modified organisms in the European Union

By Mikael Karlsson*

Received 12 October 2004. Available online 4 October 2005.


Use of chemical substances and genetically modified organisms cause
complex problems characterised by scientific uncertainty and
controversies. Aiming at sustainable development, policies for
assessment, and management of risks in the two areas are under
development in the European Union. The article points out that both
science and norms play a central role in risk assessment as well as
risk management and suggests that the precautionary principle, the
principle of public participation, and the polluter pays principle,
all adopted in the European Union, offer a way to operationalise the
concept of sustainable development. It is shown, however, that a
number of steps ought to be taken to better implement the principles
through different policy measures. In doing so, and by recognising the
role of both science and norms, the decision-making on risks related
to the use of chemicals or genetically modified organisms can be
improved to better promote sustainable development.

1. Introduction

Science describes the world; politics govern it. Scientific knowledge
is just one of two fundamental components of policy making. What is
right and wrong, desired or undesired, cannot be judged on the basis
of science alone. In politics, norms based on values are also central.
When scientific facts are clear and norms are homogenous, political
decision-making is a rather easy task. With plural values, decisions
are harder to make, but still manageable through ordinary processes in
democratic political systems. However, when diverging values cause
controversy or conflict, and when key facts simultaneously are under
dispute, or even completely missing, the complicated situation arisen
requires special attention and management.

Such complex situations are not seldom a starting point in
contemporary environmental policy-making. As will be shown, this is
true for the management, aiming at sustainable development, of
chemical substances and genetically modified organisms (GMOs) in the
European Union, where a number of complex problems, related to
scientific uncertainty and diverging values, can be identified.

In the following, the two problem domains of chemical substances and
GMOs will be described and characterised. The meaning of the objective
of sustainable development will be analysed, framing a background
against which present, and emerging EU policies for risk assessment
and risk management of chemical substances and GMOs will be analysed.
The paper ends with a comparison of the two areas, and a discussion on
norms and science in policies for sustainable development.

2. Chemical substances, genetically modified organisms, and complex

The experiences following more than half a century of use of man-made
chemicals are divided. On the one hand, the benefits for society at
large have been enormous. Production and use of chemicals play an
indispensable role in, e.g., agriculture, medicine, industry, and for
the daily welfare of citizens. On the other hand, the use of many
chemicals has caused severe problems due to their toxic or otherwise
'hazardous' properties, such as persistence and liability to

Adverse effects of already regulated hazardous substances prevail. For
example, the levels of chlorinated hydrocarbons in oceans and marine
biota are still high enough for authorities in the European Union to
recommend or issue food restrictions for pregnant women (SNFA, 2004)
and for the population at large (EC, 2001a). In the USA, PCB-levels in
fishes in the Great Lakes are high enough to cause adverse health
effects, such as impaired memory, among consumers with high fish
consumption (Schantz et al., 2001). Remediation costs for hazardous
substances are often high. The total remediation and waste management
costs for PCB in Sweden during the period 1971-2018 has been estimated
to 380-480 million euro, health and environmental costs uncounted; the
corresponding figure for the whole EU is 15-75 billion euro (NCM,

In addition to this, new problems are recognised. This is partly due
to re-evaluations of earlier risk assessments, such as when the US
National Research Council in 2001 considered arsenic in water five to
ten times as carcinogenic as earlier thought (NRC, 2001), but also
follows from completely new assessments of existing and new chemicals.
In the European Union, for example, the use and the effects of single
phthalates (such as DEHP) and brominated flame retardants (such as
deca-BDE) are under scrutiny, and new regulations are being developed
or imposed (ECB, 2004). Nevertheless, most substances in the European
Union have not been assessed at all for their health and environmental
risks (Allanou et al., 1999). As a result, a proposal for a new
regulatory framework for registration, evaluation, authorisation an
restrictions of chemicals (REACH) has been presented in the European
Union (European Commission, 2003). This proposal is at present the
most disputed element of EU chemicals policy and has given rise to an
infected debate in more or less all relevant political fora (European
Commission, 2001a, European Commission, 2002, European Commission,
2003, Scott and Franz, 2002 and US House of Representatives, 2004).

Compared with the use of man-made chemicals, releases of GMOs is a
relatively recent activity, even though the global area planted with
genetically modified (GM) plants is increasing fast (James, 2003).
Just as for chemicals, the risks are difficult to assess, and the
debate on how to manage them is contested. On the one hand, proponents
claim limited risks and large benefits for, e.g., agriculture,
environmental protection, and global food security (Heap, 2003 and
Persley, 2000). On the other hand, and in contrast to the debate on
chemicals, critics point not only at risks, but also question the
benefits (Murray, 2003 and Nestle, 2003). EU consumers in general
seldom claim any benefits and feel on the contrary exposed to
different risks (Bucchi and Neresini, 2004 and Gaskell et al., 2003).
The health and environmental risks of GMOs can be structured in three

First, adverse effects can be caused by toxic or otherwise hazardous
properties of a GMO, if humans or other organisms eat or in other ways
are exposed to the GMO, or products released or derived from it. For
instance, GM food may cause human allergies (Nestle, 2003), and insect
resistant plants may affect non-target organisms and thereby decrease
biodiversity (Groot and Dicke, 2002). Second, GMOs with a relatively
high fitness can spread in the environment, or their genes can be
transferred to other organisms, which may cause unwanted environmental
changes. An escaping GM fish with strengthened growth capacity could
illustrate this potential problem (Howard et al., 2004). Third, the
use of GMOs can cause adverse environmental effects through altered
practises in agriculture. One example is that cultivation of herbicide
tolerant GM crops, through altered use of herbicides, has been shown
to decrease weed to such an extent that, e.g., non-target organisms,
such as birds dependent on weed seeds, may be negatively affected
(Firbank et al., 2003).

In addition to effects on health and the environment, wider socio-
economic harm may follow use of GMOs. One obvious example is the
millions of US dollars in liabilities that a company had to pay when
its so called 'Starlink corn," permitted by US EPA for feed but not
for food, unintentionally was spread in the food chain in the USA and
other countries (Nestle, 2003).

The debate whether GMOs cause benefits or costs (or both) is
contested. Against this background, and due to health and environment
concerns, EU decision-makers upheld a moratorium for commercial
releases of GMOs for some years and still block some decisions. As a
result, the legislation on GMOs has been reformed (Karlsson, 2003a).
Comprehensive risk assessments are nowadays required by law but still
their validity is subject to debate (Smith, 2004), not least
concerning how to interpret uncertainties, which is a partly
normative, partly scientific question. Science and values are
integrated in the argumentation regarding uncertainties.

As shown, use of both chemicals and GMOs cause highly complex risks,
characterised by scientific uncertainty and controversies. Policy
regimes for assessing and managing risks in the two areas are in place
or under development in the European Union. The new legislation aims
at promoting sustainable development. In the following, the meaning of
this objective will be analysed and operationalised.

3. Operational principles for sustainable development

The concept of sustainable development is a cornerstone in
international politics, something that was manifested at the United
Nations World Summit for Sustainable Development in Johannesburg 2002
(United Nations, 2002). In the European Union, sustainable development
is stated in primary law as an objective for the union (EU, 1997), and
a strategy for achieving the objective has been elaborated (European
Commission, 2001b). In EU and elsewhere, the concept is often
interpreted with reference to the World Commission on Environment and
Development, meaning that 'the needs of the present' should be met
'without compromising the ability of future generations to meet their
own needs' from environmental, economic, and social perspectives
(WCED, 1987). This implies a moral duty to develop the society with a
much stronger emphasis on improving the state of the environment, as
well as socio-economic and environmental living conditions for present
and future generations. For the sake of clarity, scientific findings
are naturally of highest importance when elaborating and implementing
policies for sustainable development, but nevertheless sustainable
development is a wide-reaching normative concept, not a scientific

Many attempts to operationalise the concept take a restricted view and
focus on 'nature as such' or 'relationships between man and nature,"
such as preservation of certain environmental components (e.g.,
biodiversity), a specified state of the environment (e.g., limit
values for pollutants), or preferable use of resources (e.g., maximum
sustainable yield) (Karlsson and Ljung, 2001). Science is a given
cornerstone in such estimations, but when finally deciding on what is
to consider desirable or acceptable, norms always play the central
role. To some extent of course, values influence the scientific work,
and vice versa, but still, science has no decisive role in policy

Compared with the full meaning of sustainable development, the just
mentioned interpretations ignore important aspects. In cases of high
scientific uncertainty, estimating, and deciding, for instance, which
limit values that are suitable for humans and other species is
difficult and in many cases even impossible. The number of
miscalculations during the last century, resulting in severe
environmental risks and problems, has been quite high, for example,
when it comes to hazardous chemicals (Harremoës et al., 2001).
Further, such interpretations of sustainable development tend to
overlook the fact that management of environmental risks often is very
controversial, as is the case for, e.g., genetically modified

Recognising uncertainty and controversy, which follow use of chemicals
or GMOs, sustainable development might better be operationalised in
terms of relationships within social systems, rather than as relations
between humans and nature. Without neglecting the high value of
science, such a perspective emphasises the normative character of the
objective of sustainable development, and underlines that it has high
relevance for structures and processes in social systems. When
managing risks under uncertainty and controversy, aiming at
sustainable development, three important questions arise: how should
the uncertainty be interpreted and managed? Who should do the
interpretation and decide on management strategies? How should the
responsibility for the management be distributed?

Answers are offered by three commonly accepted principles in
environmental policy, namely the precautionary principle, the
principle of public participation, and the polluter pays principle,
all adopted by the international community as well as in the European
Union (EC, 1997 and UNCED, 1993). These normative principles offer a
way to further operationalise the significance of the environmental,
social and economic dimensions of sustainable development, and will be
further elaborated in the following.

First, precautionary decisions have been taken in environmental policy
since long (Karlsson, in press). An often-referred formulation of the
precautionary principle is found in principle 15 of the Rio
Declaration (UNCED, 1993). This version is relatively weak though,
since it merely discredits lack of scientific proof as an argument for
staling prevention. Most binding environmental agreements stipulate a
more strict interpretation, namely that 'if there is a threat, which
is uncertain, then some kind of action is mandatory' (Sandin, 1999).
Even though several detailed questions follow from this formulation,
it is evident from the background above, that use of GMOs as well as
chemical substances invokes.

A number of aspects regarding the interpretation of uncertainty in
risk assessment and management follow from the principle (Karlsson, in
press). To decrease uncertainty, strengthened research is important
regarding direct as well as indirect and long-term effects. Under
uncertainty, one question concerns what degree of "proof" that is
required for decision-making. In science, an adequate bias often says
that it is better to miss one true cause-effect relationship, than to
interpret a false phenomenon as true. In precautionary decision-
making, however, the probability of failing to conclude a true
phenomenon should be minimised. In doing so, the burden of proof ought
to rest with the operator concerned, and not with the regulator.
Further, the principle triggers substitution when less uncertain and
less hazardous ways of reaching an objective are at hand. Other
measures, such as prohibitions, may also come in question. When
deciding on a specific management measure, the principle challenges
the ambition to maximise expected utility, and gives preference to
rather choose alternatives that, based on estimations and not only
quantified probabilities, causes least possible loss if realised (the
so-called 'maximin-rule'), an idea advocated by, e.g., Rawls (1971),
and elaborated by, e.g., Hansson (1997).

The second principle, regarding public participation, implies that
citizens and the civil society have a right to take part in both risk
and uncertainty assessment processes as well as decision-making on
risk management. The principle is underlined in the Rio Declaration
and Agenda 21 (UNCED, 1993), and is a central pillar in the so-called
Aarhus Convention (UN ECE, 1998), the latter presently step by step
being incorporated in EU law (see e.g., EC, 2003a).

Public participation provides a mean for risk assessment and risk
management processes to better encapsulate all three dimensions of
sustainable development. It also enables decision-makers to better
understand both diverging interpretations of uncertainty and the
underlying values held by different stakeholders, thereby providing
them with means to make better informed decisions (Karlsson, 2003b).
Further, a participatory process empowers citizens to influence the
development, gives legitimacy to the values they hold, and stimulates
activity and involvement. It may thereby reduce controversies and
contribute to restore trust in science among the public. Several
methods for public participation have been developed and applied, such
as public hearings and laymen participation in different forum (SBC,
2002 and UN ECE, 2000).

The third principle for sustainable development, the polluter pays
principle, concerns the distribution of costs and the ultimate
polluter's responsibility to 'pay' for, e.g., environmental costs. The
principle has for decades been a cornerstone in OECD policy (OECD,
1972) and can be found in the Rio Declaration (UNCED, 1993). In the EC
treaty, the principle is laid down as an obligation for the polluter
to cover costs for mitigating measures, as well as costs encountered
by people facing remaining pollution, once mitigation has taken place
(EC, 1997). According to neo-classic economic theory, the
implementation of the principle internalises external costs and
directs development towards increased socio-economic efficiency
(Pigou, 1920).

The polluter pays principle can be operationalised by setting
technical standards, such as requiring best available technology,
through charging environmental taxes and fees for pollution or
preventive work (such a supervision and risk-related research), or by
implementing liability and insurance systems.

Since use of chemicals as well as GMOs causes complex risks, the
principles, and operational tools just described might give guidance
for policies in the area. In the following, the present regulatory
regimes for each problem domain will be described and analysed in
relation to the three principles of sustainable development.

4. Present and emerging risk policies for chemical substances in the
European Union

When it comes to assessing the effects on man and nature of chemical
substances, uncertainty is a key obstacle, and unexpected effects
have, therefore, been rather common during the last decades (Harremoës
et al., 2001). In the European Union, the so-called existing
substances, i.e., those reported to be on the market before September
18 in 1981, which largely have unknown inherent properties (Allanou et
al., 1999), have been target for a risk assessment process for some
years (EEC, 1993). Out of more than 100,000 existing substances,
however, less than 100 have been completely assessed (ECB, 2004).
Evidently, the process is very slow. Regarding risk assessment of so-
called new substances, the regulation in place functions better, even
though critique has been raised about, e.g., lack of flexibility
regarding assessment of exposure differences (European Commission,

With some exceptions, such as accidents with chemicals, risk
assessments are limited to cases where chemicals are handled under
normal use. The assessment of new and existing chemical substances
consists of several steps, mainly (a) hazard identification, (b)
dose-response assessment, (c) exposure assessment, and (d) risk
characterisation. Risk is characterised as the ratio of estimated
ordinary (or worst-case) exposure levels, and levels estimated to be
harmful. An assessment thus compares "predicted environmental
concentrations" with the "predicted no effect concentration," as well
as the "no observed effect level" or the "lowest observed effect
level" with ordinary exposure levels (European Commission, 1993 and
European Commission, 1994).

The assessments are carried out by experts in authorities through
relatively standardised methods without always considering specific
environmental circumstances. In the process, science delivers
fundamental knowledge, but questions regarding, e.g., what endpoints
to study, and what degree of evidence to consider conclusive are
ultimately given normative (but scientifically based) answers. It has
been shown that the so-called objective risk assessments are all but
objective (Ruden, 2002), but the factual subjectivity of experts is
seldom officially admitted.

In the presently applicable directives and regulations that govern the
risk assessment, the precautionary principle is not acknowledged at
all, and the public is not generally able to participate, even though
some Competent Authorities have formal or informal reference groups
for risk assessments, in which different stakeholders occasionally may
participate. Neither is the polluter pays principle implemented, since
authorities (i.e., the taxpayers and not the polluters) in general
must cover large costs for assessing substances.

Turning to the management of chemical substances, the general
stipulation to show unacceptable risks in formalised assessments based
on comprehensive scientific findings before regulatory decisions on,
e.g., restrictions of a chemical may be taken (European Commission,
2001c), hampers precautionary risk management. Substances not
scientifically proven to have toxic properties, i.e., are causing
cancer, mutations or reproductive effects in, e.g., animal
experiments, are normally not considered a case for restrictions, not
even when there is scientifically based suspicion of problems (such as
when substances are persistent and bioaccumulative). This is
particularly problematic since risk assessments hardly consider, e.g.,
interactions between different stress factors, such as synergetic
effects. Persistent and bioaccumulative substances are generally not
considered a problem under present chemicals law, in spite of strong
scientific support that chemicals having those properties often cause
severe problems (CNC, 2000). By in this way ignoring that uncertainty
about inherent properties and exposure routes is rather a rule than an
exception, risk management is attributed with inefficiencies and
ineffectiveness. Thus, the legislative norms set by politicians may
actually hinder them to protect public health and the environment,
except in rare cases of high scientific certainty.

In addition, the public is not able to participate in decision-making
on management regimes, and has a low trust, when it comes to
environmental problems, for business and political institutions (EORG,
2002). The polluter pays principle is not implemented, since most
environmental costs are not at all internalised.

These and other problems are the underlying rational for the present
and contested attempts in the EU to develop a new chemicals policy. In
what follows, these new approaches will be analysed through the lens
of the three principles of sustainable development.

The emerging REACH policy explicitly states that the precautionary
principle should be applied and places the burden of proof with
operators. However, stringent requirements will continue to apply for
restricting the use of a chemical, thus contradicting the
precautionary principle. In the REACH proposal (European Commission,
2003), besides carcinogenic, mutagenic, and reproduction-toxic
substances, 'very' persistent and 'very' bioaccumulating substances
will be targets for authorisation. On the one hand, this increases the
number of hazardous substances that are considered a target for
further management. On the other hand though, these substances are
supposed to be granted a permit through an authorisation process if a
producer can show that each substance in question is "adequately
controlled" or beneficial from a socio-economic point of view
(European Commission, 2003). However, any socio-economic analysis on
chemicals meets the problem on how to weigh regulatory costs in the
short run against health and environmental benefits in the long run
something being impossible in cases of high uncertainty and not in
line with the 'maximin-rule." The authorisation concept in REACH is,
therefore, hardly compatible with the precautionary principle.
Further, substitution is not a mandatory element of the proposal (even
though the idea is vaguely acknowledged), which means that a hazardous
substance might be permitted, even though there are better
alternatives at hand.

To better cope with the complexity, a number of legislative amendments
could be made to implement the precautionary principle (Karlsson, in
press). Regulators should be free to base decisions on findings less
conclusive than full scientific evidence. Unknown substances in a
specific group of chemicals could be classified in the same manner as
the most hazardous chemical in that group. Inherent properties should
be given a stronger weight in such classifications. Once a classified
substance has been considered hazardous and subject to further
management, the question arises how and to what extent to manage it.
Here, potentially toxic, or persistent and bioaccumulative substances
should be considered a target for substitution or phase-out.
Legislative proposals along these lines have been presented elsewhere
(CNC, 2000).

Looking at participatory management, the on-going (October, 2004) so-
called Extended Impact Assessment of REACH has been set up by the
European Commission, with a strong role for of the chemicals industry,
but without enabling the civil society organisations to really
participate in the process (WWF and EEB, 2004). This is just one
example showing that the principle of public participation hardly can
be said to have been satisfactory implemented.

Concerning the polluter pays principle, environmental taxes, and
liability regimes are neither in place at present nor proposed for the
near future. The new EU directive on environmental liability (EC,
2004) gives exceptions for authorised activities. In the same manner,
as soon as a producer has fulfilled his obligations under REACH, e.g.,
once a substance has been authorised, the so-called duty of care is
considered fulfilled and liability claims can never be raised,
regardless of the magnitude of any negative consequences in case of
unexpected harm. The proposed system does thereby not implement the
polluter pays principle.

5. Risk policies for genetically modified organisms in the European

The EU policy on genetically modified organisms has undergone a reform
during the last years. A new directive on deliberate release of GMOs
has entered into force (EC, 2001b), and regulations on, e.g.,
labelling and traceability have been developed and implemented (EC,
2003b and EC, 2003c). In what follows, the new GMO regime will be
analysed in relation to the three principles of sustainable

As for chemicals, risks of GMOs are often difficult to assess. While a
GM potato for industrial use, grown in an area with few wild or
cultivated relatives, would be relatively easy to assess, such
circumstances are exceptional. Often, genes are spread by pollen or in
other ways, and quite many of the modified properties are potentially
problematic. Uncertainty is high. When it comes to formal risk
assessments of GMOs, an operator is required to establish the
assessments on a case by case basis. Of particular importance are (1)
the characteristics of a GMO that may cause a number of different
adverse effects, (2) the magnitude of each such effect if realised,
and (3) the likelihood of the realisation of each effect. A key
question is the probability itself of an adverse effect. Nowadays, the
required scope of the risk assessment is rather wide, where direct and
indirect effects on health and environment that might follow, e.g., of
deliberate release should be considered. Unlike the situation when
assessing chemical substances, risk is here understood as the product
of the magnitude of adverse effects, and the probability of those
effects happening at all (Steinhäuser, 2001).

The deliberate release directive (EC, 2001b) states explicitly that
the precautionary principle must be taken into account, but does not
specify any clear implication of the principle (Karlsson, 2003a). The
burden of proof rests with an operator when applying for the required
permit for a release and the operator must always submit a
notification including a risk assessment. However, if a Member State
demands a stricter management of an already authorised GMO, it must
scientifically prove that unacceptable risks are at hand, a
stipulation not compatible with the precautionary principle. Further,
no reference is made to substitution at all. Concerning hazardous
inherent properties though, the directive sets final dates when genes
coding for resistance to antibiotics should be phased-out from market
and other kinds of release, but only as long as they may have adverse
effects. Scientifically based guidelines with a much wider focus on
inherent properties of GM crops have been presented (ACRE, 2000) and
could serve as a guide for further development of the EU legislation
in line with the precautionary principle.

Concerning public participation, the understanding of environmental
and socio-economic consequences following use of GMOs is of course
subject to not only laymen's, but also experts' values. By acting as
if assessments were completely objective, the values of experts will
often be given too much weight, and the values held by the public
might be neglected. A complementary approach to traditional risk
assessments dressed in scientific and quantifiable terms would be for
authorities to actively invite people to express their value-laden
views on GMOs and risk policies. Such an effort could reduce the
tendency to overlook wider ethical issues related to the three
dimensions of sustainable development, and could also help to restore
trust in science and scientific expertise. The new directive opens for
consultation of the public to some extent, but the implementation is
up to each Member State to manage. Nothing of course restricts Member
States from applying extensive participatory decision-making on
releases of GMOs, but so far the record is not very impressive, even
though some improvements can be seen, such as the Farm-Scale
Evaluations in the UK (SBC, 2002). Nevertheless, public participation
seems, in general, to stop at information on websites and labelling of
GMOs, which is hardly to consider adequate.

Finally, when it comes to the polluter pays principle, the directive
on environmental liability (EC, 2004) will not have any meaning when
it comes to ordinary use of GMOs, since it gives exceptions for
authorised activities, among them permits for deliberate releases of
GM crops. No other tools have been applied to implement the polluter
pays principle in general.

6. Concluding remarks

Use of chemical substances as well as genetically modified organisms
gives rise to similar kinds of complex problems characterised by
uncertainty and controversies. That said, however, a number of
differences can be pointed out. While the debate on GMOs is partly
focused on whether or not there are any benefits or costs at all, the
dispute over the REACH proposal seems to be concentrated on how large
costs and benefits are. In all these deliberations, both scientific
knowledge and values held by different stakeholder play a role.

Concerning risk assessment, the key principles underlying the
processes set up for chemicals and GMOs, respectively, differ. This
might be explained by unjustified traditional, as well as substantial
technical reasons; an example of the latter is that the number of
chemicals on the market is about a thousand times higher than the
number of marketed GMOs. Notice though in both cases, that even though
risk assessments build on scientific methods, the endpoints considered
relevant to study, and the way to interpret findings and uncertainty,
follow from normative decisions, i.e., from a specific policy regime.
As shown above, however, neither assessment regime is designed to
fully implement the three principles of sustainable development.

As regards the management of risks, there are also similarities and
differences. In chemicals policy, the idea to increasingly base
management on inherent properties (such as persistence and capacity to
bioaccumulate) and less on proven risk is gradually receiving
increased attention, something that can be seen in the REACH proposal.
For GMOs, however, inherent properties are in general not targets as
such in the present regulations. Here, a lesson might be learned from
decades of problematic use of chemicals: inherent properties matter
and may well form a basis for amendments of the directive on
deliberate release of GMOs. On the other hand, the management of GMOs
seems to offer better possibilities for the public to participate.
When it comes to the idea that the polluter should pay, neither
management regime implements the principle. As for risk assessment, it
can be concluded that the three principles are far from fully
implemented in the risk management systems.

To conclude, there are substantial shortcomings in both policy areas
in relation to the objective of sustainable development. In coping
with the complexities in each problem domain, implementation of the
proposed principles of sustainable development could increase the
chances that use of chemicals and GMOs increase environmental and
socio-economic gains, and simultaneously decrease risks for health and
the environment.

These proposals are of course normative. But so are all ideas on
policy. There is no such thing as scientific policies or scientific
legislation. Science (not sound science, which is tautological) is
good, and getting better and better, in describing the world,
including the risks and problems of GMOs and chemicals. Nevertheless,
decisions in society are made in democratic processes, in which
stakeholders interpret uncertainty and scientific information in
relation to norms that reflect values, altogether hopefully for the
benefit of man and nature.

Policies that recognise complexity and the importance of both norms
and science, by implementing risk assessment and risk management
regimes that are based on the principles discussed, will more likely
than present risk policies promote sustainable development.


The author thank Hanna Karlsson for valuable comments on earlier
drafts of this article.


ACRE, 2000 ACRE, 2000. Best Practice in GM Crops Design. Advisory
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Allanou et al., 1999 R. Allanou, B.G. Hanse and Y. van der Bilt,
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European Chemicals Bureau, Institute of Health and Consumer
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Bucchi and Neresini, 2004 M. Bucchi and F. Neresini, Why are people
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