Rachel's Precaution Reporter #4
Wednesday, September 21, 2005

From: Mendocino County Public Health Advisory Board ......[This story printer-friendly]
June 13, 2005


[Rachel's introduction: A broad coalition of local officials and interested citizens have asked their county board of supervisors to consider adopting the precautionary principle as county policy.]

In June, 2005, the 19-member Mendocino County [California] Public Health Advisory Board (MCPHAB) unanimously agreed to request that the County Board of Supervisors study the implementation of the recautionary Principle and its effect on County decision-making.

The decision by the Public Health Advisory Board is the first step towards the County's adoption of the recautionary Principle. The Principle represents a new way of approaching decisions that affect the environment and human health.

MCPHAB was encouraged to draft the letter to the County Board of Supervisors after hearing an educational talk on the Precautionary Principle given by Debbie Raphael of the San Francisco Department of the Environment. Ms. Raphael was a key figure in San Francisco's passage of the Precautionary Principle ordinance in 2003. A newly formed committee made up of individuals throughout the county and spearheaded by Environmental Commons' Britt Bailey hosted and supported Raphael's presentation. The committee includes Doug Hammerstrom (Ft. Bragg City Council), Greg Krouse (Sustainable Landscaper), Dr. Marvin Trotter (Public Health Officer), David Colfax (5th District Supervisor), Dr. Melissa Gosland (Redwood Coast Medical Services), Dr. Alice Diefenbach (Centers for Disease Control), Doug Mosel (Californians for GE-Free Agriculture), and Sara O'Donnell (Cancer Resource Center of Mendocino).

"This is a truly momentous day for Mendocino County. We are on the forefront of a new way of making decisions -- decisions that will be better for our environment and subsequently our health," said Britt Bailey of Environmental Commons.

According to Sara O'Donnell, MCPHAB member and Director of the Cancer Resource Center, "We believe the time is right for our County and its citizens to be democratically involved in choosing the best alternative with the least potential impact on human health and the environment. For years we have made decisions based on a traditional type of risk assessment that tries to justify harm," and the Precautionary Principle reverses that trend."

Greg Krouse, a sustainable landscaper and host of a toxics-related radio program, stated, "The notion that the county could adopt the Precautionary Principle is very exciting. I think that the greater democracy this process affords will eliminate the loggerheads that often accompany controversial issues."

The County will examine the possibility of implementing the Precautionary Principle while the County's citizens will be offered opportunities to learn more about the Principle. A key element of the Precautionary Principle includes participatory decisions that are transparent and democratically derived.

Get more details about the Precautionary Principle here.

Britt Bailey, Director Environmental Commons (707) 884 -5002

Carol Mordhorst, Director of Public Health Mendocino County Public Health Department (707) 472 -2777

Sara O'Donnell, Executive Director Cancer Resource Center of Mendocino County (707) 467 -3828


From: www.EurActiv.com ....................................[This story printer-friendly]
September 14, 2005


[Rachel's introduction: Uncertainty over the health risks of low- level chemical contamination may compel European lawmakers to strengthen their precautionary REACH proposal for chemicals policy.]


Biomonitoring involves taking samples of blood, tissue, urine or hair to detect the presence of certain substances in the human body. The process is currently used by environmental campaigners, lobbyists and the EU Commission as a tool to assess human exposure to pollution and to define health and environmental policies.

However, the lack of scientific knowledge on the paths taken by the pollutants and their actual risk for human health is making biomonitoring a controversial issue (for more, see EurActiv LinksDossier).


Analysis of blood taken from 42 mothers and the umbilical cord of 27 newborn babies has revealed the presence of man-made hazardous chemicals in every sample.

The results were published on 8 September by Greenpeace and the WWF as part of a campaign to strengthen the REACH proposal to regulate chemicals in the EU [European Union]. The bill is now entering a decisive voting phase in the European Parliament.

The umbilical cords and blood were tested for eight chemicals, including musks used in perfumes, brominated anti-flammable agents used in textiles, a pesticide which has already been banned worldwide, and phtalates used to soften plastic objects such as toys. The samples were also tested for perfluorinated compounds which are used to make non-stick frying pans and water-repelling coatings.

"The major problem [with these chemicals] is that we know virtually nothing about their potentially adverse effects because of the way production, marketing and use of chemicals is regulated in Europe," comment the WWF and Greenpeace in the study.

But they argue this is precisely why chemicals should be better controlled and the proposed REACH regulation strengthened.

"It is shocking that such chemicals are in the human body at any stage of our life, let alone at the very start, when the child is most vulnerable. Governments need to act and require industries to substitute these contaminating chemicals with safer alternatives," said Helen Perivier, Toxics Campaigner for Greenpeace International. Positions:

The European chemical industry council (CEFIC) says it is aware of the societal concerns caused by chemicals and "takes its responsibility to address it seriously".

Still, it guards against all undue alarm. "The presence of trace amounts of a chemical substance does not necessarily constitute a health risk and should not cause alarm," wrote CEFIC at the conclusion of a conference on environment and health in December last year.

"We are in full compliance with environmental health and safety rules," said CEFIC's Caroline de Bie. "When you look at the quantities, it is really tiny," she added saying it is "very alarmist" to communicate such test results to the greater public.

CEFIC points out to independent experts and paediatricians who agree that "whilst trace amounts of chemicals can be detected in the blood, there is no evidence of harm at these levels". According to CEFIC, biomonitoring provides "a one-off measurement of the trace levels typically found, but does not provide any information of whether the levels vary over time or what was the source of exposure".

Dr Gavin ten Tusscher, a paediatrician quoted in the WWF/Greenpeace study and a member of an advisory group on biomonitoring to the European Commission agrees that there should be no immediate cause for alarm. "I would not advise people to worry, but I would recommend that they put pressure on policymakers to change legislation".

"The negative health effects for the average individual are so slight that they are barely noticeable", he agrees. "But if you view them on a population level they are frightening," he then adds.

The argument that the potentially negative health effects of trace levels of chemicals in people's blood are still to be proved is brushed aside by Dr. Vyvyan Howard, a toxico-pathologist at Liverpool University, who is also quoted in the study.

Howard points to the "enormous complexity" of chemicals, saying a given product such as a pesticide can exist in 62,000 different forms.

In this context Howard argues that pretending every compound can be tested for safety is illusory. "We simply don't have the tools to analyse all of them," he says. Given the high level of complexity of exposure, he argues "we have little else to resort to other than the precautionary principle. These pollutants should not be in the foetus".



** Biomonitoring in health & environment policy-making ** Chemicals Policy review (REACH)

Official Documents

Commission: press release -- Presence of persistent chemicals in the human body results of Commissioner Wallstrom's blood test (6 Nov. 2003)

DG Environment: Conference Proceedings Human Biomonitoring - Conclusions [zip file]

EU Actors' positions

WWF: Unwanted gift for life: children exposed to hazardous chemicals before birth (8 Sept. 2005)

WWF/Greenpeace: Report -- A present for life -- Hazardous chemicals in umbilical cord blood (8 Sept. 2005)

CEFIC: Biomonitoring and human health (Dec. 2004)

Related Documents

UK hopes to hammer out deal on chemicals in November (16 September 2005)

Two EP committees streamline EU chemicals law (15 September 2005)

MEP: Do not expect a major swing on REACH (14 September 2005)

Key lawmaker ready for compromise on REACH (13 September 2005)

Chemicals debate coming to the boil in the autumn (05 August 2005)

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Copyright EurActiv 2000-2005


From: New Scientist .......................................[This story printer-friendly]
January 11, 2005


[Rachel's introduction: A report issued by the UK's National Radiological Protection Board (NRPB), a government advisory body, calls for a "precautionary approach" to cellphone use.]

By Will Knight

Recent studies suggesting cellphone radiation may pose a health hazard have prompted UK experts to warn parents against giving mobile phones to young children.

A report issued on Tuesday [Jan. 4, 2005] by the UK's National Radiological Protection Board (NRPB), a government advisory body, calls for a "precautionary approach" to cellphone use. The study acknowledges that there is no firm evidence that cellphone radiation is harmful but warns that the possibility also cannot be ruled out.

"I don't think we can put our hands on our hearts and say mobile phones are safe," said Sir William Stewart, chairman of the NRPB, at a press conference in London on Tuesday.

The NRPB report repeats concerns first raised in an influential study into cellphone health affects published in 2000 by the Independent Expert Group on Mobile Phones, also set up by the UK government and led by William Stewart. However, the new report adds that scientific research published since 2000 provides fresh evidence that cellphone radiation may be harmful to users. DNA damage

This research includes a European study published in December 2004 indicating that radiation from cellphones may damage DNA, a Swedish study from April 2004 showing a correlation between mobile phone use and auditory nerve tumours and Dutch research from October 2003, linking cellphones to impaired brain function.

But the NPRB report says these studies must be replicated by other research laboratories before any conclusion can be reached.

Zenon Sienkiewicz, principle scientist at NRPB, notes that complicating factors will also have to be investigated, such as whether some people are more susceptible to cellphone radiation than others. "All we're saying in the report is let's not close our minds," he told New Scientist.

Stewart says parents should not give cellphones to children under nine years old because they may be particularly susceptible to any ill effects of cellphone radiation. This is because they have smaller heads, meaning the radiation can affect a greater part of their brain, and less fully developed nervous systems.

Service suspended

"If there are risks -- and we think that maybe there are -- then the people who are going to be most affected are children, and the younger the children, the greater the danger," Stewart said.

Shortly after the report was published, UK company Commun8, which launched a mobile phone service aimed at children, announced that it would suspend operations.

But other representatives of the industry took a positive view of the report. "The key point of the NRPB advice is that there is no hard information linking the use of mobile telephony with adverse health effects," said Mike Dolan executive director of the UK Mobile Operators Association.

The NPRB report also recommends that older children and adults consider limiting their phone use and sending text messages instead of making voice calls whenever possible.

The rate of cellphone development is another cause for worry, according to the report. Third generation (3G) phones typically produce more radiation than older handsets, but there have been few studies of the health effects of these devices specifically. The board also said further research should be carried out into the effects of wireless networking technology such as Bluetooth and Wi-Fi.

Related articles:

Cellphones May Boost Forces on Biological Tissue

3G Base Stations May Cause Headaches

Cancer cell study revives cellphone safety fears

Copyright 2005 Reed Business Information Limited


From: The Heritage Foundation .............................[This story printer-friendly]
January 15, 2004


[Rachel's introduction: "A subjective concept such as 'the precautionary principle' is itself dangerous because it permits what conservative scholars have called 'precaution without principle.""]

By John D. Graham, Ph.D.

The concept of a universal precautionary principle apparently has its origins in early German and Swedish thinking about environmental policy, particularly the need for policymakers to practice foresight in order to prevent long-range environmental problems. The concept was included in the Amsterdam Treaty--an important step toward establishment of the European Union--but the concept was left undefined and was applied only to environmental policy. In the past 20 years, there have been numerous references to precaution in various international treaties, statements of advocacy groups, and academic writings, but the significance of the principle in international law remains uncertain.

In recent years there has been growing international interest in the subject of precaution. Reacting to criticism that the principle was too ambiguous, the European Commission in 2000 issued a formal "Communication" about the precautionary principle. This Communication extended the applicability of the principle to public health and consumer protection as well as environmental policy. For several years, the German Marshall Fund has been working with Duke University to sponsor several informal dialogue sessions involving governmental officials and academics from Europe and the USA. Several months ago, the Canadian government released a "Framework" document for the application of precaution in science-based decisions about risk.

The United States government believes it is important to understand that, notwithstanding the rhetoric of our European colleagues, there is no such thing as the precautionary principle. Indeed, the Swedish philosopher Sandin has documented 19 versions of the precautionary principle in various treaties, laws, and academic writings. Although these versions are similar in some respects, they have major differences in terms of how uncertain science is evaluated, how the severity of consequences is considered, and how the costs and risks of precautionary measures are considered. The United States government believes that precaution is a sensible idea, but there are multiple approaches to implementing precaution in risk management. Defining the Principle

Given the ambiguity about the precautionary principle, it may be useful to start with a dictionary definition. Webster's 2nd Edition of the New World Dictionary defines precaution as "care taken beforehand" or "a measure taken beforehand against possible danger." Understood in this way, precaution is a well-respected notion that is practiced daily in the stock market, in medicine, on the highway, and in the workplace. In both business and politics, decision makers seek the right balance between taking risks and behaving in a precautionary manner.

Before joining the Office of Management and Budget, I served for 17 years on the faculty of the Harvard School of Public Health. In that capacity I learned that public health historians have documented the preventable pain and suffering that can occur from insufficient consideration of the need for precaution. In the United States we felt that pain as a result of how we handled emerging science about tobacco, lead, and asbestos. Historians teach us that the major health problems from these substances could have been reduced or prevented altogether if decision makers had reacted to early scientific indications of harm in a precautionary manner.

We should not belittle the scientific complexities in each of these examples. Take the link between smoking and lung cancer. Although this link now seems obvious, in the middle of the previous century the link was not obvious to many competent and thoughtful physicians. They knew that many lifetime smokers never developed lung cancer; they also knew that some lung cancer patients had never been smokers. Compounding the problem was the inability of laboratory scientists to produce lung tumors in laboratory animals exposed by inhalation. In the final analysis, it took large-scale statistical studies of smokers to resolve the issue. In fact, there was a large scale study of the health of British physicians that played an important role in building the medical consensus against smoking.

In each of these examples (tobacco, lead, and asbestos), it was epidemiology rather than the experimental sciences that played the most pivotal role in identifying health risks. Ironically, it is epidemiology that is now one of the more controversial contributors to public health science. Exaggerated Claims of Hazard

There is no question that postulated hazards sometimes prove more serious and/or widespread than originally anticipated. Ralph Nader has previously argued that this is the norm in regulatory science, while the European Commission recently issued a report of case studies where hazards appear to have been underestimated. However, the dynamics of science are not so easily predicted. Sometimes claims of hazard prove to be exaggerated, and in fact there are cases of predictions of doom that have simply not materialized.

Consider the "dismal theorem" of the Reverend Thomas Malthus (1798). He hypothesized that population would grow exponentially while sources of sustenance would only grow arithmetically. The result, he predicted, would be that living standards would fail to rise beyond subsistence levels. However, history has shown this theorem to be incorrect. Malthus did not foresee the technological advances that have allowed both population and standard of living to rise steadily and substantially.

A more recent example in the USA concerns the popular artificial sweetener saccharine. The Food and Drug Administration declared the regulatory equivalent of war against this product on the basis of experimental laboratory test results. The finding was that huge doses of saccharine cause bladder cancer in rodents. While the FDA attempted to ban saccharine based on this evidence, the U.S. Congress overturned the FDA's action. With the benefit of hindsight, it now appears that the FDA's attempted ban may have been poorly grounded in science. Just recently, the federal government in the USA removed saccharine from the official list of "carcinogens" for two reasons: experimental biologists have found that saccharin causes bladder tumors in rodents through a mechanism (cell proliferation) that is unlikely to be relevant to low-dose human exposures; and large-scale epidemiological studies of saccharine users have found no evidence that the product is linked to excess rates of bladder cancer in people.

Students of risk science are aware that the number of alleged hazards far exceeds the number that are ever proven based on sound science. Consider the following scares: electric power lines and childhood leukemia, silicone breast implants and auto-immune disorders, cell phones and brain cancer, and disruption of the endocrine system of the body from multiple, low-dose exposures to industrial chemicals. In each of these cases, early studies that suggested danger were not replicated in subsequent studies performed by qualified scientists. Efforts at replication or verification were simply not successful. At the same time, when early studies are replicated by independent work, such as occurred with the acute mortality events following exposure to fine particles in the air, it is important for public health regulators to take this information seriously in their regulatory deliberations.

Given that the dynamics of science are not predictable, it is important to consider the dangers of excessive precaution. One of those is the threat to technological innovation. Imagine it is 1850 and the following version of the precautionary principle is adopted: No innovation shall be approved for use until it is proven safe, with the burden of proving safety placed on the technologist. Under this system, what would have happened to electricity, the internal combustion engine, plastics, pharmaceuticals, the Internet, the cell phone and so forth? By its very nature, technological innovation occurs through a process of trial-and-error and refinement, and this process could be disrupted by an inflexible version of the precautionary principle.

Many risk specialists in the USA regret some of the prior policy steps we have taken on the basis of precaution. In U.S. energy policy, for example, the Three Mile Island incident had a large policy impact, though even today there is no evidence of significant public health harm caused by the accident at Three Mile Island. In fact, there has been a de facto moratorium on the construction of new nuclear power plants in the USA. We have become more deeply dependent on fossil fuels for energy, and now precaution is being invoked as a reason to enact stricter rules on use of fossil fuels. Part of the answer may rest with clean coal technologies and renewable energy, but we should not foreclose the advanced nuclear option. Recent Progress in Europe

In comparing the actions of different countries and regions, it is important to avoid the fallacy that Europe is precautionary while the USA is not. The late Aaron Wildavsky, in his studies of risk regulation, observed that cultures engage in risk selection. Some have argued that the USA is more tolerant than Europe of the possible risks of bioengineered foods, global climate change, and industrial chemical exposures. However, a fair analysis would also show that Europe has been less precautionary than the USA on diesel engine exhaust, environmental tobacco smoke, and lead in gasoline. In fact, the recent comparative research by Professor Jonathan Wiener of Duke University has found no evidence to support the popular myth that Europe is generally more precautionary than the USA.

A subjective concept such as "the precautionary principle" is itself dangerous because it permits what conservative scholars have called "precaution without principle." In particular, the principle may be easily manipulated by commercial interests for rent-seeking purposes. According to Conko and Miller, students of biotech policy, the EU policy on genetically modified organisms "creates a bizarre bureaucratic distinction that favors certain classes of products widely made in Europe." This practice is hardly new. That is precisely what the World Trade Organization found in its earlier decision against the EU ban on hormone-treated beef, a ban that had no grounding in public health science.

Although there are many reasons to be skeptical about Europe's stance on precaution, there are recent signs of progress from Europe. Take the response of Brussels to "mad cow's disease." Once the British government and industry had taken all reasonable steps to address this problem, Brussels instructed member states of the EU to lift their bans on beef imports from the UK. All member states complied except France, which argued that French beef might still be safer than British beef and that France has the right to invoke the precautionary principle. Brussels took France to the European Court of Justice, where the Court ruled against France, indicating that speculative appeals to the precautionary principle must have some grounding in science.

Much more recently, the European Commission has rejected an unauthorized use of the precautionary principle by the provincial government of Upper Austria. In March of this year Austria notified Brussels of its proposed ban of genetically modified seeds that the EC had approved for cultivation under the EC Directive 90/220. Upper Austria appealed to the precautionary principle but Brussels overruled them: "Recourse to the precautionary principle presupposes that potentially dangerous effects... have been identified, and that scientific evaluation does not allow the risk to be determined with sufficient certainty." The EC noted that Upper Austria had not made this case and there was certainly nothing unique about the safety of genetically modified seeds in Upper Austria.

While it is fashionable to criticize Europe on the subject of precaution, and much of that criticism is deserved, it should also be noted that the EC's official views on precaution are becoming more nuanced. In the February 2000 Communication, for example, we found the following views that are similar to the perspective of the U.S. government:

1. Precaution is a necessary and useful concept but it is subjective and susceptible to abuse by policymakers for trade purposes. 2. Scientific and procedural safeguards need to be applied to risk management decisions based on precaution. 3. Adoption of precautionary measures should be preceded by objective scientific evaluations, including risk assessment and benefit-cost analysis of alternative measures. 4. There are a broad range of precautionary measures, including bans, product restrictions, education, warning labels, and market-based approaches. Even targeted research programs to better understand a hazard are a precautionary measure. 5. Opportunities for public participation--to discuss efficiency, fairness and other public values--are critical to sound risk management.

In OMB's 2003 Report to Congress on the Costs and Benefits of Regulation, we also emphasize the important role that analytic tools have in informing regulatory judgments about precaution. There are offshoots of cost-benefit analysis called value-of-information analysis and decision analysis that were designed precisely for the purpose of analyzing problems with large degrees of scientific uncertainty. These tools are already widely used in engineering and business and are increasingly applied to environmental issues. We urge readers to consult OMB's report for references to this growing analytic literature on precautionary regulation. Conclusion

In summary, there are two major perils associated with an extreme approach to precaution. One is that technological innovation will be stifled, and we all recognize that innovation has played a major role in economic progress throughout the world. A second peril, more subtle, is that public health and the environment would be harmed as the energies of regulators and the regulated community would be diverted from known or plausible hazards to speculative and ill- founded ones. For these reasons, please do not be surprised if the U.S. government continues to take a precautionary approach to calls for adoption of a universal precautionary principle in regulatory policy.

John D. Graham, Ph.D., is Administrator of the Office of Information and Regulatory Affairs at the U.S. Office of Management and Budget.

The Heritage Foundation 214 Massachusetts Ave NE Washington, DC 20002-4999 phone -- 202.546.4400 fax -- 202.546.8328 e-mail -- staff@heritage.org

Copyright 1995 -- 2005 The Heritage Foundation


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 rpr@rachel.org.

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