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Rachel's Precaution Reporter #11

"Foresight and Precaution, in the News and in the World"

Wednesday, November 9, 2005..........Printer-friendly version
www.rachel.org -- To make a secure donation, click here.
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Table of Contents...

Advancing the Precautionary Principle in Georgia
  In Georgia, the precautionary principle is advancing in several
  locales simultaneously as environmental justice activists, church
  groups, and government officials join forces to explore the power of
  foresight and forecaring to protect public health in communities.
Bold Precaution: The Precautionary Principle Gains Traction
  So, what is this precautionary principle? The word itself was
  translated from a German word, which literally means fore-caring. It's
  the foresight principle. It's the fore-action principle. It's the
  grandmother principle. It's the principle that says, "We are going to
  look out for future generations and to future
  generations for
  their well-being and their sanity."
Use and Abuse of the Precautionary Principle in Biotech Food
  "The precautionary principle is actually part and parcel of sound
  science.... Scientific evidence is always incomplete and uncertain.
  The responsible use of scientific evidence, therefore, is to set
  precaution. This is all the more important for technologies, such as
  genetic engineering, which can neither be controlled nor recalled."
Let Them Eat Precaution
  "Undercut by the mounting genetic evidence, anti-G.M. forces have
  cooked up a new tactic, invoking the lowest common denominator in
  fabricated scientific disputes: the 'precautionary principle.""

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From: The Athens (Georgia) Banner-Herald, Nov. 3, 2005
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HEALTH BOARD MAY ASK PLANT TO STOP USING TOXIC CHEMICAL

By Lee Shearer

[RPR introduction: The precautionary principle is moving forward
steadily in Georgia. In April, ECO-Action in Atlanta sponsored a
precaution workshop for local, state and federal government officials.
(We last heard about ECO-Action in RPR #7.) Subsequently, ECO-Action
was invited to put on a precaution workshop for the Northeast Georgia
Children's Environmental Health Coalition which is made up of
community-based groups, plus representatives from the University of
Georgia and the Northeast [Georgia] Health District a wing of the
Georgia Division of Public Health, in Athens, Ga.

Now a citizens' group in Athens -- Clean Air Athens -- has set a
long-term goal of getting the precautionary principle adopted in
Athens (Clarke County). The group's short-term goal is to reduce toxic
air emissions from two local manufacturing firms, Certainteed and
Nakanishi (a manufacturer of bearings). Bill Sheehan of the Product
Policy Institute in Athens, who attended the April workshop in
Atlanta, is promoting the precautionary principle and related
innovative policies and has joined fellow residents working with
Clean Air Athens.

As we learn in the news story below, the Northeast [Georgia] Health
District has now asked the Clarke County Board of Health to ask
Nakanishi in Athens to find a less-dangerous substitute for their main
toxic emission; presently the firm emits 300 pounds of cancer-causing
TCE each day into the air in Athens, near a middle school.

Interestingly, the Clarke County Board of Health has no legal
authority to demand reduction in toxic releases -- in Georgia,
environmental regulators are the ones charged with protecting public
health from toxics, and it is simply the case that corporations own
the legislature in Georgia, as in so many other states. All the county
health department can legally do is politely request that a
corporation stop poisoning the community.

An important motivating force in this story is Jill McElheney, a
citizen in Athens-Clarke County who founded Micah's Mission. It was
she who got the Northeast Health District to join local citizens in
forming the Northeast Georgia Children's Environmental Health
Coalition. A child of Ms. McElheney's was diagnosed with leukemia at
age 4 (he's now doing well). Ms. McElheney's water supply was later
found to be chemically contaminated. Powerful (and powerfully
motivated) women, like Jill McElheney, and Carol Williams of
ECO-Action, have been leading the toxics/EJ movements for many years.
It seems only natural that they should now lead the precautionary
principle citizens' movement that has arisen out of grass-roots
efforts to end toxic injustice.

This is a story of successful multi-racial coalitions, working with
both conservative and liberal churches, that have reached out to bring
university personnel, plus local and state government agencies, into
this work. They have found a way to move precaution forward to protect
children in a state not generally known for being on the forefront of
innovative public policies. It doesn't get much better than this. --
RPR Editors]

HEALTH BOARD MAY ASK PLANT TO STOP USING TOXIC CHEMICAL

By Lee Shearer

The Clarke County Board of Health will schedule a meeting to decide
whether to ask an Athens factory to stop emitting trichloroethylene,
or TCE, a hazardous chemical that may cause cancer.

An official with the Northeast Health District presented information
on TCE at the board's bi-monthly regular meeting Wednesday and asked
the board to draft a letter making the request. The factory in
question, bearing maker Nakanishi Manufacturing Corporation, uses the
chemical as a degreaser at its factory at the intersection of Voyles
Road and Spring Valley Road near Coile Middle School and New Grove
Baptist Church.

But the board, meeting with only four of its seven members, should
wait until it can get all or most of the members at a meeting, said
Athens-Clarke County Commissioner States McCarter, a member of the
health board.

The board of health cannot force the company to stop using TCE. The
letter would merely request that the company find a different chemical
to use.

The company releases about 300 pounds of TCE per day into the
atmosphere, Louis Kudon, director of the Northeast Health District's
Community Health Assessment, Surveillance and Epidemiology Unit, told
the board.

Long-term exposure to the chemical can damage the human liver, kidneys
and central nervous system, and health agencies consider it "probably
carcinogenic" to humans, he said.

Health district workers have sampled air at the nearby middle school
and other locations close to the plant, but did not detect the
chemical. However, the equipment they used could only detect TCE at
concentrations above one part per million, he said.

Researchers at the University of Georgia plan to go back and sample
air in the area again, however, this time using equipment that can
measure the chemical in parts per billion, he said.

Kudon said the health district has not heard of any increase in
cancers or other health problems at Coile Middle School.

The federal Occupational Safety and Health Administration limits
workers' TCE exposure to no more than 100 parts per million over an
eight-hour period, but there is no standard for outdoor air, he said.

The chemical once was commonly used in household products, but now it
is rarely used, he said.

Most companies have replaced TCE with other products, Kudon said as he
asked the board to send the company a letter requesting it stop using
the chemical.

"We would like the Board of Health to write a letter stating that
releasing TCE into the environment is not a good idea and we would
like them to replace it," he said.

Georgia produces more TCE air pollution than all but seven other
states, at about 231,000 pounds a year, and the Nakanishi plant
produces nearly half of Georgia's total with about 111,000 pounds, he
said.

McCarter said he was "not comfortable" with voting on the letter with
only four board members present, nor with the fact that health workers
had not actually detected TCE in air near the factory.

Board of Health Chairman Charles Braucher Sr. suggested calling a
meeting in December to take up the issue, but other board members
suggested a meeting even earlier, later this month.

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From: Bioneers, Oct. 15, 2005
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BOLD PRECAUTION: THE PRECAUTIONARY PRINCIPLE GAINS TRACTION

By Carolyn Raffensperger

2005 Bioneers Plenary Speech

I got into the environmental movement because I wanted to say no to
putting radioactive waste in the Four Corners area of the Southwestern
desert. I was in my 20's, and the question was, "What part of 'no' did
I understand?" Not a whole lot. The first person I had as a hero was
Lois Gibbs -- the housewife who was at Love Canal, who broke that news
and articulated the key element of the precautionary principle, which
is: "We don't want to keep making these messes." It was out of Love
Canal that so much of our work was born.

You've probably heard about two of the most terrible disasters of the
environmental movement: Love Canal and Bhopal. I mention Lois Gibbs
and Love Canal because we really are a movement, and we are going to
have the first national conference on the precautionary principle in
June, 2006. Lois Gibbs is the lead person helping to organize that
conference along with our organization, the Science and Environmental
Health Network. We are bringing together everyone, you included. We
want you there. The precautionary principle is no longer a little idea
out there. It is now moving hearts and minds. It is now being
incorporated into government. It is now being used to prevent the kind
of damage that we saw at Bhopal and Love Canal. No more.

Any idea is really an ecology of ideas. It's not as if the
precautionary principle sprung out of my brain, or anybody else's
brain for that matter, fully formed. It really was the experience of
Love Canal and Bhopal, and all of those other disasters and the search
for solutions. The search for ways of no longer saying no. And then,
oh no. That's what we have been saying, isn't it? In my case, I've
been saying no to the terrible loss of the white pelicans in North
Dakota for two summers now. Last summer 27,000 white pelicans
vanished. They just disappeared. But this year 9,000 of them came
back. We didn't know if they would. Nine thousand came back to North
Dakota to the Chase Lake Refuge. Do you know what happened this year?
Another, "Oh, no." Eight thousand babies died. Last year the adults
vanished, and this year the babies. Oh no.

What do we say yes to? There is a fantastic quote about this ecology
of ideas. The quote is by Barry Lopez, who says, "Pay attention to the
mystery. Apprentice to the best apprentices. Rediscover in nature your
own biology. Write and speak with appreciation for all you have been
gifted. Recognize that a politics with no biology, or a politics
without field biology, or a political platform in which human
biological requirements form but one plank, is a vision of the gates
of hell."

We are at the gates of hell, and if we want to go on through the gates
of hell we can continue business as usual. We can continue doing the
kind of slash-and-burn chemistry that we have been doing, or we can
adopt green chemistry. We can change the way that we do health policy,
become ecologically sound and use ecological medicine. We can use
adaptive management for relating to our large ecosystems. We can begin
to use all of these things, and those ideas are at the heart of the
precautionary principle.

So, what is this precautionary principle? The word itself was
translated from a German word, which literally means fore-caring. It's
the foresight principle. It's the fore-action principle. It's the
grandmother principle. It's the principle that says, "We are going to
look out for future generations and to future generations for their
well-being and their sanity." So that they will not be lonely. So that
they will not live in a world without jaguars. So that they will not
live in a world without white pelicans. So that they will not live in
a world without all of our fellow travelers and our fellow beings.

The idea of the precautionary principle was summed up in the
Wingspread statement, which says, "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 have not been
fully established scientifically." How is that for a mouthful? Do you
know what it means? Do you know what you can do now to just walk out
and take care of the precautionary principle, and enact it and carry
it out in your communities? Well, we didn't either. So, we take that
idea and the central core of it -- like the seeds in an apple. They
are very clear, and they are in every single definition of the
precautionary principle. What are those seed ideas?

It's the threat of harm. What are we worried about? What do we care
about? What threatens what we love? It is scientific uncertainty. What
don't we know? How do we know? Do we know? And there are all of the
things that go into scientific uncertainty. Are we just ignorant and
nobody knows? Can we find out through more data? What is it that we
need to use science for, and what can't science help us with? And it
is taking action. We need to take action to prevent more global
climate change and global warming. We need to take action to prevent
the destruction of our children's brains through toxic chemicals. We
want our breast milk pure. So we have to act. We have to act to
prevent harm.

So, what's the harm? What do we know and what don't we know? And can
we take action? Those three elements: action, uncertainty and harm.
That's all it is. People will tell you, "Oh, we don't know what the
precautionary principle means. There are just so many definitions,"
Well, we do know what it means. It means those three things every
time.

But that's still not going to help you a lot when you want to take
action, say in San Francisco or Denton, Texas. So what do you do then?
There are five steps that you can take that will get you through
almost any situation They will help you apply this precautionary
principle, and help you take precautionary and preventive action to
prevent harm.

What are the five steps? First, you set goals. What kind of world do
we want to live in? There are health problems all over the country,
and everywhere I go I learn the statistics of wherever I am. What do
you care about in Marin County? What do you care about in Anchorage,
Alaska? What do you care about in all of the places where the Beaming
Bioneers satellite conferences are being held? Atlanta, Georgia, what
kind of world do you want to live in? Do we want to continue to have a
rising rate of asthma? Of breast cancer? When my mother got married,
the statistic was one woman in 25. Just a few years ago it was one
woman in eight. Now not a lot has changed between my mother and me
genetically, so it's not that. Do you know what the statistic is
today? One woman in seven. When my ten-year-old niece gets married,
what's the statistic expected to be? One woman in three. Is that the
kind of world we want to live in? I don't. So, what kind of world? Is
that preventable? Let's prevent those breast cancers if we can.

Let's establish the goal for the kind of world we want to live in. Do
it in your own communities, and then you can start to look for the
safest, and most beautiful, most respectful alternative. What are the
ways that will help us meet our goal? How do we have healthy babies?
How do we ensure that there will be jaguars in the world?

Second, we begin to look at our alternatives. We begin to look at the
ways that we are doing business and that are not helping us meet our
goals. We choose the alternatives to get us to where we want to be.
There are some wonderful examples of doing this. In North Dakota they
have developed a seed-breeding project, where the farmers and the
scientists in the whole Great Plains region are developing seeds that
are suitable for that environment, and they're doing it together. Then
they're trying to figure out how to protect and keep the seeds for
generations, like a library. That's an alternative to genetically
modified organisms, and it's better suited to have breeding projects
and programs in our community. It's a wonderful alternative.

Debbie Raphael works for the city of San Francisco, and she has
figured out how to think about these alternatives. San Francisco
looked at all of the money that the city and county were spending on
things that actually got in their way, that are not helping them meet
their goals and live in the kind of world that San Francisco wants to
live in. They developed an overarching precautionary ordinance that
said, "San Franciscans have a right to a healthy and safe
environment." I don't know about you and other places in the country -
if you're in Iowa, Arkansas, or Colorado -- do you have a right to a
healthy environment? Or is it only San Franciscans? I think we all do.
Many of your constitutions around the country say that you have that
right.

Then San Francisco wanted to look for those safer alternatives, and so
they took the second step and developed an environmentally preferable
purchasing policy to carry out the very first step of implementing the
precautionary principle. What are the alternative products that we can
purchase and use in our daily activities that will help us reach the
goal that we're trying to meet? It's a wonderful ordinance. You can
look at the ordinance on our Web site (www.sehn.org).

So, set your goal, look for the alternative ways to meet those goals,
and then, third, start to heed early warnings. How do we start paying
attention to the signals and the clues that are going on in the
environment? The motto of Bioneers is: It's all alive. It's all
connected. It's all intelligent. It's all relatives. Well, I don't
know about the intelligent part. If we can't figure out the patterns
and the early warnings, our intelligence is a little bit questionable.
Are we educable as a species?

If we begin to look at these patterns -- for instance, the patterns of
the rising rate of breast cancer -- and we begin to say, "This is not
the way we want to live," then we can take action in the face of those
early warnings. How many things can you think of where we didn't take
heed of some bad pattern? How long did it take before the tobacco
executives said, "Oh, tobacco causes cancer." How long did it take? It
took from the first studies in 1945 until we finally had proof in the
mid-1990's. How much evidence do we need? How much evidence do we need
when a baby is born with a pesticide in its meconium -- so that it has
crossed the mother's body into the placenta and into that baby, and
now that baby is excreting it? We already know a little bit about some
of these pesticides and what they do to rats and mice. I am hoping
that we can be smarter, that we can say, "this is not a good idea." Do
we want to do this to our children? No. We know what we did by
ignoring lead. We knew what would happen when we ignored asbestos. I
could go on down the line. Heed early warnings and you'll help meet
the goals.

Then fourth, let's reverse the burden of proof. Do you know what
happened to places like Love Canal? Business and government would say,
"Oh, you're fine. There's no problem. It's not making you sick." The
residents said, "We've got a problem. This is not good for us. This is
not good for our health." Business and government said, "Prove it. You
prove that this is toxic. You prove that it's doing harm." They didn't
even test their chemicals. Then they said, "There's no evidence that
it causes problems." So we need to reverse the burden of proof. I
should not have the responsibility of proving that your chemical or
genetically modified organism is causing me harm if you haven't even
tested it. If you don't know, how come I have to know? Your ignorance
is not my problem. But in many cases, it has turned out to be my
problem.

So we reverse the burden of proof from society to the promoters of
these technologies or practices. What it means is giving the benefit
of the doubt to human health and the environment. It means giving the
benefit of the doubt to that child's brain that is in that mother's
womb. It means giving the benefit of the doubt to your daughter's
breasts so that you don't have to start planning for her mastectomy.
It means giving the benefit of the doubt to the whales. It means
giving the benefit of the doubt to our rainforests. It means giving
the benefit of the doubt to Prince William Sound and to the Copper
River and to the Arctic National Wildlife Refuge rather than to
profit. Why do we give the benefit of the doubt to money? Why do we do
that? This is nuts.

Are we educable as a species? Well that's what the precautionary
principle is hoping. We're asserting that we're educable and that we
can act on early warnings and that we can reverse the burden of proof
and actually give the benefit of the doubt to the things we love. What
a good idea.

That brings me to another point: The precautionary principle is not
just dependent on science. We can't leave these decisions to science
alone. It actually doesn't require just the head. It requires the
heart. It requires ethics and values, the things we care about. When
you bring those two together, you have a pretty good way of deciding
about the kinds of actions we take. If a scientist can't make the
decision, who is going to? We are. We, the people, need to be at the
table, because all of these decisions affect our lives. They affect
your grandchild's life, and your grandchild's grandchild's life. We
have to be at the table. That's democracy.

So those are the five elements of how you carry out the precautionary
principle. You start by setting a goal and envisioning the world that
your community wants to live in. You choose the alternative that helps
you meet your goal, the safest alternative, the most beautiful
alternative, the one that also helps provide jobs. There are no silver
bullets with the precautionary principle. We want a buffet of options.
We want to encourage green chemistry. That's at the heart of things
like a good precautionary principle. We want sustainable agriculture.
So set the goals, find the safest alternative, heed early warnings,
and then reverse the burden of proof and give the benefit of the doubt
to public health and the environment. Then use democracy. We get to
decide.

Is anybody doing this? There are wonderful stories in so many places.
The Los Angeles Unified School District asked, "Why are we using all
of these pesticides in the schools when we could do something
different? We could apply the precautionary principle and use
integrated pest management and not do this." They did it because they
had read about the Wingspread statement, and those wonderful activists
successfully applied it to the school and removed about one hundred
toxic chemicals from use.

Denton, Texas did something very similar. These activists realized,
"Hmmm. They're using pesticides in the parks." They went to the park
district and said, "This is not a good idea. These are hazardous to
human health and they're hazardous to our pets. Gosh, can't we do
something different?" So they went to the chamber of commerce and
said, "We need to do something about this." The chamber of commerce
replied, "Oh no, we can't have an ugly dandelion." They weren't so
worried about the cancer or the other harm. It was the dandelions that
were a problem. So, in Denton, Texas, they researched and discovered
that Iowa State University had actually developed a natural herbicide
out of the waste part of corn. Denton, Texas had a white corn
processing plant, and that waste was becoming a community problem.
They took that waste and made it into a natural herbicide for the
parks. They found an alternative and they were able to carry it out.
So they adopted the precautionary principle.

I want to celebrate Indiana because that red state is actually the
home, the birthplace, of the precautionary principle in the United
States. Dan Quayle's campaign chairman -- the vice-president under the
first George Bush -- appointed a country lawyer in Indiana named
Gordon Durnil, to head the International Joint Commission. He didn't
like what was going on in the Great Lakes. He didn't like the toxic
chemicals and he didn't like seeing birds with their deformed beaks.
So he said, "We're going to use the precautionary principle." That
happened in Indiana. Do you know what that means? No more red states.
No more blue states. All green. We want the next election to all be
green states.

I want to leave you with that wonderful line in Wendell Berry's poem,
Manifesto: The Mad Farmer Liberation Front, in which he asks two
questions:

Ask yourself: Will this satisfy
a woman satisfied to bear a child?
Will this disturb the sleep
of a woman near to giving birth?

If we always ask those questions, we'll be okay. If our pregnant women
can sleep, if our pregnant polar bear mothers can sleep, we'll be
okay. If they are satisfied to bear a child, they'll be okay and we'll
be okay with the decisions we make.

I love the very last line in that Wendell Berry poem, especially when
we're faced with so much destruction and when it doesn't feel as if
there are a lot of options.

He says, "Practice resurrection."

Thank you to every one of you who is making a difference in this
world. Your work matters. Practice resurrection.

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From: Institute of Science in Society (I-SIS), Jul. 13, 2000
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USE AND ABUSE OF THE PRECAUTIONARY PRINCIPLE

I-SIS submission to US Advisory Committee on International Economic
Policy (ACIEP) Biotech Working Group, July 13, 2000

By Peter T. Saunders

Introduction

The precautionary principle is accepted as the basis of the Cartegena
Biosafety Protocol agreed in Montreal in January 2000, already signed
by 68 nations who attended the Convention on Biological Diversity
Conference in Nairobi in May, 2000. The principle is to be applied to
all GMOs whether used as food or as seeds for environmental release.

The precautionary principle states that when there is reasonable
suspicion of harm, lack of scientific certainty or consensus must not
be used to postpone preventative action. There is indeed sufficient
direct and indirect scientific evidence to suggest that GMOs are
unsafe for use as food or for release into the environment. And that
is why more than 300 scientists from 38 countries are demanding a
moratorium on all releases of GMOs (World Scientists Statement and
Open Letter to All Governments).

The precautionary principle is actually part and parcel of sound
science. Science is an active knowledge system in which new
discoveries are made almost every day. Scientific evidence is always
incomplete and uncertain. The responsible use of scientific evidence,
therefore, is to set precaution. This is all the more important for
technologies, such as genetic engineering, which can neither be
controlled nor be recalled.

Use and Abuse of the Precautionary Principle

There has been a lot written and said about the precautionary
principle recently, much of it misleading. Some have stated that if
the principle were applied it would put an end to technological
advance. Others claim to be applying the principle when they are not.
From all the confusion, it is easy to mistake it for some deep
philosophical idea that is inordinately difficult to grasp (1).

In fact, the precautionary principle is very simple. All it actually
amounts to is this: if one is embarking on something new, one should
think very carefully about whether it is safe or not, and should not
go ahead until reasonably convinced it is. It is just common sense.

Too many of those who fail to understand or to accept the
precautionary principle are pushing forward with untested,
inadequately researched technologies, and insisting that it is up to
the rest of us to prove them dangerous before they can be stopped. The
perpetrators also refuse to accept liability; so if the technologies
turn out to be hazardous, as in many cases they have, someone else
will have to pay the penalty

The precautionary principle hinges on concept of the burden of proof,
which ordinary people have been expected to understand and accept in
the law for many years. It is also the same reasoning that is used in
most statistical testing. Indeed, as a lot of work in biology depends
on statistics, misuse of the precautionary principle often rests on
misunderstanding and abuse of statistics. Both the accepted practice
in law and the proper use of statistics are in accord with the common-
sensible idea that it is incumbent on those introducing a new
technology to prove it safe, and not for the rest of us to prove it
harmful.

The Burden of Proof

The precautionary principle states that if there are reasonable
scientific grounds for believing that a new process or product may not
be safe, it should not be introduced until we have convincing evidence
that the risks are small and are outweighed by the benefits.

It can also be applied to existing technologies when new evidence
appears suggesting that they are more dangerous than we had thought
(as in the case of cigarettes, CFCs, greenhouse gasses and now GMOs).
Then, it requires that we undertake research to better assess the risk
and that in the meantime, we should not expand our use of the
technology and should put in train measures to reduce our dependence
on it. If the dangers are considered serious enough, then the
principle may require us to withdraw the products or impose a ban or a
moratorium on further use.

The principle does not, as some critics claim, require industry to
provide absolute proof that something new is safe. That would be an
impossible demand and would indeed stop technology dead in its tracks,
but I do not know of anyone who is actually demanding it. The
precautionary principle does not deal with absolute certainty. On the
contrary, it is specifically intended for circumstances where there is
no absolute certainty.

What the precautionary principle does is to put the burden of proof
onto the innovator or perpetrator, but not in an unreasonable or
impossible way. It is up to the perpetrator to demonstrate beyond
reasonable doubt that it is safe, and not for the rest of society to
prove that it is not.

No one should have any difficulty understanding that because precisely
the same sort of argument is used in the criminal law. The prosecution
and the defence are not equal in the courtroom. The members of the
jury are not asked to decide whether they think it is more or less
likely that the defendant has committed the crime he or she is charged
with. Instead, the prosecution is supposed to prove beyond reasonable
doubt that the defendant is guilty. Members of the jury do not have to
be absolutely certain that the defendant is guilty before they
convict, but they do have to be confident they are right.

There is a good reason for adopting a burden of proof that assumes
innocence until proven guilty. The defendant may be guilty or not, and
may be found guilty or not. If the defendant is guilty and convicted,
justice has been done, as is the case if innocent and found not
guilty. But suppose the jury reaches the wrong verdict, what then?

That depends on which of the two possible errors was made. If the
defendant actually committed the crime, but found not guilty, then a
crime goes unpunished. The other possibility is that the defendant is
wrongly convicted of a crime, in which case an innocent life is
ruined. Neither of these outcomes is satisfactory, but society has
decided that the second is so much worse than the first that we should
do as much as we reasonably can to avoid it. It is better, so the
saying goes, that "a hundred guilty men should go free than that one
innocent man be convicted". In any situation in which there is
uncertainty, mistakes will be made. Our aim is to minimise the damage
that results when mistakes are made.

Just as society does not require the defendant to prove innocence, so
it should not require objectors to prove that a technology is harmful.
It is for those who want to introduce something new to prove, not with
certainty, but beyond reasonable doubt, that it is safe. Society
balances the trial in favour of the defendant because we believe that
convicting an innocent person is far worse than failing to convict
someone who is guilty. In the same way, we should balance the decision
on hazards and risks in favour of safety, especially in those cases
where the damage, should it occur, is serious and irredeemable.

The objectors must bring forward evidence that stands up to scrutiny,
but they do not have to prove that there are serious dangers. It is
for the innovators to establish beyond reasonable doubt that what they
are proposing is safe. The burden of proof is on them.

The Misuse of Statistics

You have an antique coin that you want to use for deciding who will go
first at a game, but you are worried it might be biased in favour of
heads. You toss it three times, and it comes down heads all three
times. Naturally, that does not do anything to reassure you, until
someone who claims to know something about statistics comes along, and
informs you that as the "p-value" is 0.125, you have nothing to worry
about. The coin is not biased.

Does that not sound like arrant nonsense? Surely if a coin comes down
heads three times in a row, that cannot prove it is unbiased. No, of
course it cannot. But this sort of reasoning is too often being used
to prove that GM technology is safe.

The fallacy, and it is a fallacy, comes about either through a
misunderstanding of statistics or a total neglect of the precautionary
principle -- or, more likely, both. In brief, people are claiming that
they have proven that something is safe, when what they have actually
done is to fail to prove that it is unsafe. It's the mathematical way
of claiming that absence of evidence is the same as evidence of
absence.

To see how this comes about, we have to appreciate the difference
between biological and other kinds of scientific evidence. Most
experiments in physics and chemistry are relatively clear cut. If you
want to know what will happen if you mix, say, copper and sulphuric
acid, you really only have to try it once. If you want to be sure, you
will repeat the experiment, but you expect to get the same result,
even to the amount of hydrogen that is produced from a given amount of
copper and acid.

In biology, however, we are dealing with organisms which vary a lot
and never behave in predictable, mechanical ways. If we spread
fertiliser on a field, not every plant will increase in size by the
same amount, and if you cross two lines of corn not all the resulting
seeds will be the same. So we almost always have to use some
statistical argument to tell us whether what we observe is merely due
to chance or reflects some real effect.

The details of the argument will vary depending upon exactly what it
is we want to establish, but the standard ones follow a similar
pattern. Suppose, that plant breeders have come up with a new strain
of maize, and we want to know if it gives a better yield than the old
one. We plant each of them in a field, and in August, we harvest more
from the new than from the old. That is encouraging, but it might
simply be a chance fluctuation. After all, even if we had planted both
fields with the old strain, we would not expect to have obtained
exactly the same yield in both fields.

So what we do is the following. We suppose that the new strain is the
same as the old one. (This is called the "null hypothesis", because we
assume that nothing has changed.) We then work out the probability
that the new strain would yield as well as it did simply on account of
chance. We call this probability the "p-value". Clearly the smaller
the p-value, the more likely it is that the new strain really is
better -- though we can never be absolutely certain. What counts as
'small' is arbitrary, but over the years, statisticians have adopted
the convention that if the p-value is less than 5% we should reject
the null hypothesis, i.e. we can infer that the new strain really is
better. Another way of saying the same thing is that the difference in
yields is 'significant'.

Note that the p-value is neither the probability that the new strain
is better nor the probability that it is not. When we say that the
increase is significant, what we are saying is that if the new strain
were no better than the old, the probability of such a large increase
happening by chance would be less than 5%. Consequently, we are
willing to accept that the new strain is better.

Why have statisticians fastened on such a small value? Wouldn't it
seem reasonable that if there is less than a 50-50 chance of such a
large increase we should infer that the new strain is better, whereas
if the chance is greater than 50-50 -- in racing terms if it is "odds
on" -- then we should infer that it is not.

No, and the reason why not is simple: it's a question of the burden of
proof. Remember that statistics is about taking decisions in the face
of uncertainty. It is serious business recommending that a company
changes the variety of seed it produces and that farmers should switch
to planting the new one. There could be a lot of money to be lost if
we are wrong. We want to be sure beyond reasonable doubt, and that's
usually taken to mean a p-value of .05 or less.

Suppose that we obtain a p-value greater than .05, what then? We have
failed to prove that the new strain is better. We have not, however,
proved that it is no better, any more than by finding a defendant not
guilty we have proved him innocent.

In the example of the antique coin coming up three heads in a row, the
null hypothesis was that the coin was fair. If so, then the
probability of a head on any one toss would be 1/2, so the probability
of three in a row would be (1/2)3=0.125. This is greater than .05, so
we cannot reject the null hypothesis, i.e. we cannot claim that our
experiment has shown the coin to be biased. Up to that point, the
reasoning was correct. Where it went wrong was in claiming that the
experiment has shown the coin to be fair.

Yet that is precisely the sort of argument we see in scientific papers
defending genetic engineering. A recent report, "Absence of toxicity
of Bacillus thuringiensis pollen to black swallowtails under field
conditions" (2) is claiming by its title to have shown that there is
no harmful effect. Only in the discussion, however, do they state
correctly that there is "no significant weight differences among
larvae as a function of distance from the corn field or pollen level".

A second paper claims to show that transgenes in wheat are stably
inherited. The evidence for that is the "transmission ratios were
shown to be Mendelian in 8 out of 12 lines". In the accompanying
table, however, six of the p-values are less that 0.5 and one of them
is 0.1. That is not sufficient to prove that the genes are unstable,
or inherited in a non-Mendelian way. But it certainly does not prove
that they are, which is what is claimed.

The way to decide if the antique coin is biased is to toss it more
times and record the outcome; and in the case of the safety and
stability of GM crops, more and better experiments should be done.

The Anti-Precautionary Principle

The precautionary principle is such good common sense that one would
expect it to be universally adopted. Naturally, there can be
disagreement on how big a risk we are prepared to tolerate and on how
great the benefits are likely to be, especially when those who stand
to gain and those who will bear the costs if things go wrong are not
the same. It is significant that the corporations are rejecting
proposals that they should be held liable for any damage caused by the
products of GM technology. They are demanding a one-way bet: they
pocket any gains and someone else pays for any losses. It's also an
indication of exactly how confident they are that the technology is
really safe.

What is baffling is why our regulators have failed and continue to
fail to act on the precautionary principle. They tend to rely instead
on what we might call the anti-precautionary principle. When a new
technology is being proposed, it must be permitted unless it can be
shown beyond reasonable doubt that it is dangerous. The burden of
proof is not on the innovator; it is on the rest of us.

The most enthusiastic supporter of the anti-precautionary principle is
the World Trade Organisation (WTO), the international body whose task
it is to prevent countries from setting up artificial barriers to
trade. A country that wants to restrict or prohibit imports on grounds
of safety has to provide definitive proof of hazard, or else be
accused of erecting false barriers to free trade. A recent example is
WTO's judgement that the EU ban on US growth-hormone injected beef is
illegal.

Politicians should constantly be reminded of the effects of applying
the anti-precautionary principle over the past fifty years, and
consider their responsibility for allowing corporations to damage our
health and the environment, which could have been prevented. I mention
just a few: mad cow disease and new variant CJD, the tens of millions
dead from cigarette smoking, intolerable levels of toxic and
radioactive wastes in the environment that include hormone disrupters,
carcinogens and mutagens.

Conclusion

There is nothing difficult or arcane about the precautionary
principle. It is the same sort of reasoning that is used in the courts
and in statistics. More than that, it is just common sense. If we have
genuine doubts about whether something is safe, then we should not use
it until we are convinced it is all right. And how convinced we have
to be depends on how much we need it.

As far as GM crops are concerned, the situation is straightforward.
The world is not short of food; where people are going hungry, it is
because of poverty. There is both direct and indirect evidence to
indicate that the technology may not be safe for health and
biodiversity, while the benefits of GM agriculture remain illusory and
hypothetical. We can easily afford a five-year moratorium to support
further research on how to improve the safety of the technology, and
into better methods of sustainable, organic farming, which do not have
the same unknown and possibly serious risks.

Notes and references

See, for example Holm & Harris (Nature 29 July, 1999).

Wraight, A.R. et al, (2000). Proceedings of the National Academy of
Sciences (early edition). Quite apart from the use of statistics, it
generally requires considerable skill and experience to design and
carry out an experiment that will be sufficiently informative. It is
all too easy to fail to find something even when it is there. Our
failure to observe it may simply reflect a poor experiment or
insufficient data or both.

Cannell, M.E. et al (1999). Theoretical and Applied Genetics 99 (1999)
772-784.

* Dr. Peter Saunders, Professor of Applied Mathematics at King's
College London, co-Founder of I-SIS.

I-SIS is a not-for-profit organisation, depending on donations,
membership fees, subscriptions, and merchandise sales to continue its
work. Find out more about membership here

The Institute of Science in Society, PO Box 32097, London NW1 OXR
telephone: [44 1994 231623] [44 20 8452 2729] [44 20 7272 5636]

General Enquiries: sam@i-sis.org.uk -- Website/Mailing List press-
release@i-sis.org.uk -- ISIS Director m.w.ho@i-sis.org.uk

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From: Truth About Trade & Technology, Feb. 4, 2004
[Printer-friendly version]

LET THEM EAT PRECAUTION

By Jon Entine

[RPR Introduction: We have added links to provide clarification, and
in some cases a different perspective, to this diatribe against
foresight and forecaring. --Editors]

On cue, at last fall's World Trade Organization meeting in Cancun,
self anointed "Green" activists showed up to protest the use of gene
modification (G.M.) technology in agriculture. A bevy of teenagers
outfitted as monarch butterflies flitted through what resembled a
Halloween riot. Dotted amongst the chanting demonstrators was an
assortment of human side dishes including walking "killer" tomatoes, a
man dressed as a cluster of drippy purple grapes, and a woman in a
strawberry costume topped with a fish head peddling T-shirts that
warned of the weird and horrid mutants that will be created if
"Corporate America" and the "multinationals" get their way.

It would all be so very entertaining -- if there weren't so much at
stake, largely for the very people in Africa and Asia for whom these
protestors purport to speak. As Patrick Moore, co-founder of
Greenpeace, who split with environmental fundamentalists over their
didactic rejection of genetic modification, writes in his piece
beginning on page 24, "I cannot comprehend that anyone, let alone
someone who fancies himself as progressive, would argue against
pursuing research on putting a daffodil gene in rice that could boost
its Vitamin A content and prevent a half million children from going
blind each year. Yet, that's just what they're doing. They even oppose
basic research."

What a disheartening turn in the genetics revolution. Fifty-one years
ago this February, James Watson and Francis Crick hoisted pints of ale
into the air at the Eagle Pub near Cambridge University and declared:
"We have found the secret of life!" The two young scientists had
finally identified the elegant, double-helix structure of the DNA
molecule, which contains the chemical codes for all living things,
animal and plant. The era of genetic science had begun. In 2004 we are
just beginning to exploit its potential .We see the future in the
promising screening procedures and therapies developed to treat
hundreds of genetic disorders from breast cancer to sickle cell to
cystic fibrosis. It enables crime scene investigators to clear the
innocent and convict the real criminals.

But of most immediate importance, it is spreading the Green
Revolution to the poorest corners of the globe. G.M. technology has
led to the development of soybeans, wheat, and cotton that generate
natural insecticides, making them more drought resistant, reducing the
need for costly and environmentally harmful chemicals, and increasing
yields. Researchers are perfecting ways to increase the vitamin
content of staples like rice and bananas, which could dramatically
cut malnutrition and lengthen life spans. Yet, for all its vast
demonstrated value, this still-nascent technology, which promises
further breakthroughs in fields such as plant-based pharmaceuticals,
remains drastically underused, mired in controversy.

Some concerns are serious. There needs to be a vigorous discussion
about the degree to which corporations should be allowed to patent and
therefore control beneficial biotech products they develop. Monsanto,
Novartis, and other firms maintain they need to recoup their research
costs. There is an eminently reasonable concern over corporate
control, but it has taken a backseat to sensational and often
misleading allegations.

Consider the hyperbolic campaign against treating cows to increase
milk yields. Organic activists allege that 90 percent of our milk
supply is "contaminated" by being mixed with milk from cows treated
with a protein supplement, recombinant bovine somatotropin (rbST). A
decade ago, farmers discovered that cows given supplements produce
more milk for a longer time. That means less feed and fuel are needed
than for other herds, which results in a host of environmental
benefits. But the bio-fermentation process, which is similar to making
beer and wine and doesn't change the milk, involves biotechnology, and
has sparked an outrageous scare campaign.

There is simply no evidence that biotechnology poses greater risks
than crossbreeding or gene-splicing, which have given us seedless
grapes and the tangelo. Virtually every plant grown commercially for
food or fiber is a product of crossbreeding, hybridization, or both.
Using traditional breeding methods, about which there is absolutely no
controversy, thousands of genes of often unknown function are moved
into crops and animals. The new biotech tools allow breeders to select
specific genes that produce desired traits and move them from one
plant or animal to another.

Time and again, dire warnings have been unmasked as little more than
hysteria-grams. Years of hammering away with misinformation have taken
an enormous toll -- polluting public opinion, profoundly altering the
trajectory of biotechnology applications, and damaging the financial
wherewithal of companies and university research projects.

Undercut by the mounting genetic evidence, anti-G.M. forces have
cooked up a new tactic, invoking the lowest common denominator in
fabricated scientific disputes: the "precautionary principle." They
assert that "Trojan Horse" genes not subject to built-in checks and
balances in nature could cause environmental havoc. They argue for a
halt to all commercial uses of biotechnology. They politicize the
issue by introducing into common usage the pejorative appellations
"pollution" and "contamination" to describe the mixing of genetically
modified seed or crops with conventional supplies. They claim to be
acting on behalf of innocent but unaware consumers and the natural
environment.

"Better safe than sorry" has nice a ring of moderation, but it's
deceptive in this context. Recall the dozens of serious injuries and
the death of a Seattle girl in 1997 from drinking unpasteurized, E.
coli-laced juice made by Odwalla from apples that had fallen in
"natural" fertilizer: dung. While there have been no documented health
problems and no deaths or injuries linked to bioengineering, people
die every year from eating "naturally" contaminated foods. If the
precautionary principle were applied to "natural" foods, they would be
stripped from the grocery shelves overnight.

Let's underscore what's going on here: Activists demonize
biotechnology by exploiting a general wariness about science. This is
not a scientific dispute, but an ideological and religious one: Don't
tamper with nature. It's a romantic and superficially seductive
message, but a blanket insinuation that nature is always benign or
better is obviously hokum. The anti-biotech industry is stocked with
scientific illiterates who worship the primitive over progress and
confrontation over reform even if it means freezing the developing
world out of the benefits that we take for granted.

Some mainstream environmental groups, such as the Sierra Club, and
"ethical" investors, which could have taken the high road on a complex
issue, instead stand with anti-science hardliners in arguing for
mandatory labeling of products made with G.M. technology. More
disclosure seems reasonable, but mandatory labeling is a disingenuous
ploy designed to stigmatize biotech products with what amounts to a
skull and crossbones. Michael Passoff, of anti-biotech group As You
Sow, bragged about what would happen if the campaign succeeds. "We
expect that [the food industry] won't want to risk alienating their
customers with labeling, so they'll eventually decide not to use any
bio-stuff at all," he chortled. In other words, G.M. products with
proven health and environmental benefits would vaporize from the
marketplace.

The call for labeling, even absent evidence of problems, has
nonetheless resonated strongly in Europe, where scares involving mad
cow disease and dioxin-contaminated feed have rattled the public.
Supermarket chains have yanked G.M. products. The European Union has
had an unofficial moratorium on new bioengineered seeds and food for
five years, and will not lift the embargo until it is assured that the
U.S. won't resist its labeling rules. Japan, Korea, Australia, New
Zealand, and other countries support mandatory labeling of G.M.-
derived foods.

The ideological crosswinds have spawned regulatory bodies, global
protests, litigation, Internet campaigns, and an international
humanitarian crisis over whether people in famine stricken countries
should starve rather than eat crops grown using biotechnology. The
"earth firsters" are directly responsible for spooking Zambia into
rejecting donations of G.M. grain that would have helped feed its
desperately starving population.

There are certainly valid concerns that need to be addressed if
genetic modification is to get a fair shot in the marketplace.
However, in the current atmosphere, rational policy initiatives and
coordinated international trade policies are extremely difficult. What
is lacking in Europe, and increasingly in the U.S., is a public
discussion about the existing and potential benefits of biotechnology.
Let's hope this issue of TAE [The American Enterprise] furthers that
discussion.

Guest author Jon Entine is an adjunct fellow at the American
Enterprise Institute and scholar in residence at Miami University of
Ohio. His book on the genetics of Biblical ancestry will come out this
year.

Reprinted from The American Enterprise

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