Rachel's Precaution Reporter #11
"Foresight and Precaution, in the News and in the World"
Wednesday, November 9, 2005..........Printer-friendly version
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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."" :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: From: The Athens (Georgia) Banner-Herald, Nov. 3, 2005 [Printer-friendly version] 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. Return to Table of Contents :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: From: Bioneers, Oct. 15, 2005 [Printer-friendly version] 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. Return to Table of Contents :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: From: Institute of Science in Society (I-SIS), Jul. 13, 2000 [Printer-friendly version] 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: firstname.lastname@example.org -- Website/Mailing List press- email@example.com -- ISIS Director firstname.lastname@example.org Return to Table of Contents :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: 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 Return to Table of Contents ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: Rachel's Precaution Reporter offers news, views and practical examples of the Precautionary Principle, or Foresight Principle, in action. The Precautionary Principle is a modern way of making decisions, to minimize harm. Rachel's Precaution Reporter tries to answer such questions as, Why do we need the precautionary principle? Who is using precaution? Who is opposing precaution? We often include attacks on the precautionary principle because we believe it is essential for advocates of precaution to know what their adversaries are saying, just as abolitionists in 1830 needed to know the arguments used by slaveholders. Rachel's Precaution Reporter is published as often as necessary to provide readers with up-to-date coverage of the subject. As you come across stories that illustrate the precautionary principle -- or the need for the precautionary principle -- please Email them to us at email@example.com. Editors: Peter Montague - firstname.lastname@example.org Tim Montague - email@example.com ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: To start your own free Email subscription to Rachel's Precaution Reporter send a blank Email to one of these addresses: Full HTML edition: firstname.lastname@example.org Table of Contents edition: email@example.com In response, you will receive an Email asking you to confirm that you want to subscribe. :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::
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