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The perils of precaution


The precautionary principle is now part of the DNA of the European Union, it seems. Proponents argue that it is a tool which brings great benefit to citizens, by protecting them from harm. Critics, on the other hand, say that it is a blunt instrument with which to bludgeon new technologies to death. As a contribution to this debate, the European Environment Agency has published a report  on ‘Late lessons from early warnings: science, precaution, innovation’, following an earlier volume in the series published in 2001 (Late lessons from early warnings: the precautionary principle 1896-2000).

The first report covered a number of cases where concerns about potential health problems were not initially taken seriously enough but which later were shown to justify action. These included the widespread use of asbestos and halocarbons (phased out because of their inhalation dangers and impact on the ozone layer respectively), sulphur dioxide emissions (contributing to smog and acid rain) and the failure to recognise the possible impact of BSE.

These were used by the editorial team as evidence for greater reliance on the precautionary principle to guide policy, in particular to be readier to take action when the situation is uncertain or there is real ignorance about the impact of specific practices. In the case of asbestos and BSE, failure to recognise direct links to human disease resulted in deaths. These were relatively few in the case of BSE and what came to be called new variant CJD, but were still, with the benefit of hindsight, avoidable. More to the point, there were credible projections made at the time of far greater impacts on human health.

But none of these cases is completely black and white, and it can be argued that some of the policy responses were too extreme. A blanket ban on all asbestos use causes problems for householders, for example, because some older ceiling coatings contained very low levels of the material and so any replacement of old ceiling boards means they have to be removed and disposed of in the same way as truly hazardous fibrous asbestos. Similarly, removing waste food from the animal feed chain eliminated a safe and environmentally-friendly part of the diet of pigs.

The second volume – all 750 pages of it – covers additional case studies but also goes further, by reviewing what are considered to be false positives, cases where regulatory action was taken but this was deemed to be excessive or unnecessary. The overall conclusions are that most of these – by their definition – were not actually false positives and that in any case the impact of false negatives (issues where action was delayed) has been much more significant.

The first thing which strikes me about the report is that it is highly political. This is not just about using science to protect human health and the environment, but a strong statement of a political philosophy of egalitarianism. Take, for example, the first paragraph of the preface by Prof Jacqueline McGlade, the IEA’s executive director:

“There is something profoundly wrong with the way we are living today. There are corrosive pathologies of inequality all around us — be they access to a safe environment, healthcare, education or clean water. These are reinforced by short-term political actions and a socially divisive language based on the adulation of wealth. A progressive response will require not only greater knowledge about the state of the planet and its resources, but also an awareness that many aspects will remain unknown. We will need a more ethical form of public decision-making based on a language in which our moral instincts and concerns can be better expressed. These are the overall aims of Volume 2 of Late lessons from early warnings.”

This is not the language of science, and is surprising coming from someone who has held senior academic positions before her current post. But given that the EEA provided offices for the Worldwatch Institute and that McGlade was a director of Earthwatch until forced to step down, this is clearly an organisation with a mission.

The definition of ‘false positive’ used means that nothing can be categorised as such unless preventative regulatory action has been taken and there is high confidence in the scientific evidence that risks are low. ‘High confidence’ is based on the scale used by the IPCC, and means 67-95% confidence in the knowledge and understanding: a subjective judgement made by the authors. By this definition, issues which are being campaigned on by environmentalist groups are not false positives unless regulatory action has been taken.

Using this approach, the authors found only four false positives among 88 cases where over-regulation had been alleged:

·         Southern corn leaf blight – a case where excess corn was planted in 1971 in anticipation of high crop losses.

·         Saccharin – mistakenly believed to be a human carcinogen (1977).

·         Swine flu – mass immunisation in the USA in 1976 against swine flu which did not recur.

·         Food irradiation – reluctance by US authorities to allow this despite its proven role in reducing food pathogens.

Those cases not deemed to be false positives were then categorised in various ways, most notably as ‘the jury is still out’ or an ‘unregulated alarm’. Some interesting categorisation is apparent in the list. In particular, issues for which the authors believe the jury is still out include mobile phones (tumour risk), electromagnetic fields (the risk from power lines), GMOs in general, the Monarch butterfly and Bt corn, Teflon and the MMR vaccine.

The balance between risk and benefit is often a difficult one to find. Protecting people and the environment is clearly important, but there is a very real danger that the culture of precaution is being taken too far. For example, it is widely recognised that the MMR vaccine scare was based on very poor science and that the benefits of vaccination vastly outweigh risks. Despite this, a significant number of children have succumbed to potentially dangerous diseases because parents were unnecessarily alarmed. Similarly, there is no evidence at all of real harm being caused to Monarch butterflies feeding near North American fields. And as for GM crops, this categorisation seems more like the knee-jerk reaction of environmental activists than a defensible view.

It is wrong that an official EU agency – funded by taxpayers’ money – should be allowed to behave in such a way when EFSA comes in for strong criticism for supposed pro-industry bias. The power and pervasiveness of the environmentalist lobby in the EU has been demonstrated once again.