Rachel's Precaution Reporter #9, October 26, 2005

LETTER TO THE EDITOR: ELIZABETH WHELAN DESERVES A RESPONSE

[Rachel's introduction: "Let's keep our focus on establishing the precautionary principle at the 'new product development stage' so it can redirect the path of innovation towards safer technologies, as it has with food additives and drugs." -- Professor Clark Bullard]

By Clark Bullard

Elizabeth Whelan's essay "Can Too Much Safety be Hazardous? in RPR #3 deserves a response. What she advocates is backsliding into the same "risk assessment" morass that has failed us in the past.

She frames her critique around a hypothetical ban on chlorine, asserting that evidence to date indicates that the benefits of chlorine exceed its risk, and therefore a "precautionary" ban would be unwise. And she makes the more general claim that "the precautionary principle assumes that no detriment to health or the environment will result from the proposed new banning or chemical regulation."

In fact the precautionary principle substitutes precaution for recklessness, not for evidence. The idea is to apply the principle at the outset, when a new chemical (or other risk) is first proposed and ignorance reigns. Just as we do in the case of food additives and drugs, we hold a new product off the market until evidence of its safety is produced. Often those scientific experiments identify a safer pathway to progress.

With 20-20 hindsight, Whelan claims that chlorine turned out to be worth the environmental costs. We can never know whether a precautionary approach would have led to the invention of ozone-based bleaches and related technologies decades earlier. What we do know is that other large-scale experiments on non-consenting human subjects have turned out to be disastrous: DDT, lead-based paint, and CFC's, for example. Now a billion people in the developed world are trying another such [poorly designed, poorly controlled] experiment with greenhouse gases, while billions of nonconsenting humans in the developing world have the most to lose.

Would we perform such experiments in our laboratories? No, it would be unethical. Has that moral taboo retarded scientific progress and prevented discovery of some miracle drugs? Maybe. But I would not recommend that we start conducting scientific experiments on nonconsenting human subjects, just so we can look back a half-century from now and see how many succeeded and how many failed.

Let's keep our focus on establishing the precautionary principle at the "new product development stage" so it can redirect the path of innovation towards safer technologies, as it has with food additives and drugs.

Clark Bullard Professor of Mechanical Engineering University of Illinois at Urbana-Champaign 1206 W Green St Urbana IL 61801 217 333 7734 (voice) 217 333 1942 (fax) http://acrc.mie.uiuc.edu/