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To: "Science and Environmental Health Network" <email@example.com>
cc: (bcc: Lois Epstein)
Subject: Special Bulletin: Precautionary Principle
Debating the Precautionary Principle
Science and Environmental Health Network
The precautionary principle has taken center stage in a number of recent
international discussions on trade, the environment, and human health. As a
result, it has stirred criticism as well as interest. In these discussions
and in a growing number of media reports on the principle, certain
criticisms and qualifications, enumerated below, have been repeated with
The Science and Environmental Health Network offers the following responses
to stimulate the thinking of others on these statements and on the
precautionary principle. Many of these ideas were articulated in a January
2000 meeting of precautionary principle advocates and in discussions
following the meeting.
1. "The precautionary principle is vague and has conflicting definitions."
The precautionary principle is worded differently each time it is
articulated. This is not uncommon in international customary law. Although
some statements of the principle are more detailed than others, there are
no major conflicts among them. At the core of each statement is the idea
that action should be taken to prevent harm to the environment and human
health, even if scientific evidence is inconclusive.
For example, the 1998 Wingspread Statement on the Precautionary Principle
summarizes the principle this way: "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 are not fully established
scientifically." (The Wingspread Conference on the Precautionary Principle
was convened by the Science and Environmental Health Network.)
The February 2, 2000 European Commission Communication on the Precautionary
Principle notes: "The precautionary principle applies where scientific
evidence is insufficient, inconclusive or uncertain and preliminary
scientific evaluation indicates that that there are reasonable grounds for
concern that the potentially dangerous effects on the environment, human,
animal or plant health may be inconsistent with the high level of
protection chosen by the EU."
The January 29, 2000 Cartagena Protocol on Biosafety says: "Lack of
scientific certainty due to insufficient relevant scientific information .
. . shall not prevent the Party of import, in order to avoid or minimize
such potential adverse effects, from taking a decision, as appropriate,
with regard to the import of the living modified organism in question."
(The negatives in this last statement echo the 1992 Rio Declaration on
Environment and Development: "Where there are threats of serious or
irreversible damage, lack of full scientific certainty shall not be used as
a reason for postponing cost-effective measures to prevent environmental
As the principle has been elaborated recently, it nearly always implies
three additional ideas, beyond "harm" and "scientific uncertainty":
1) the notion of seeking alternatives to harmful technologies;
2) the idea of shifting to proponents of a technology the responsibility
for demonstrating its safety; and
3) the goal of transparency and democracy in making decisions about
Taken together, these concepts provide what we believe is a sound
overarching approach to assessing and making decisions on products and
technologies and other human activities that may impact healthor the
environment. That is how "precaution" operates at the broadest level. On
this level it is something like the common-sense attitude we take in
conducting our own lives and making decisions: We consider whether we need
or want something, try to learn as much as we can about risks and benefits,
consider alternatives, choose the best and (most likely) safest route, and
hold responsible those who provide the services we choose. And when
something we value is threatened, we tend to err on the side of caution.
But the precautionary principle, especially as articulated in international
treaties and agreements, is also a specific justification for action in
cases of likely harm and scientific uncertainty.
2. "If precaution applies to everything, precaution would stop all
technology in its tracks."
This criticism confuses the broad, common-sense precautionary approach to
decision-making with specific precautionary action. It is wrong on two
In the first place, precautionary action does not always mean calling a
halt or implementing a ban. It can also mean imposing a moratorium while
further research is conducted, calling for monitoring of technologies and
products already in use, adopting safer alternatives, and so forth.
In the second place, a broad precautionary approach will encourage the
development of better technologies. Using this approach, society will say
"yes" so some technologies while it says "no" to others. Making uncertainty
explicit, considering alternatives, and increasing transparency and the
responsibility of proponents and manufacturers to demonstrate safety should
lead to cleaner products and production methods.
3. "Precaution calls for zero risk, which is impossible to achieve."
Any debate over the possibility of "zero risk" is pointless. Our real goal
must be to impose far less risk and harm on the environment and on human
health than we have in the past. We must harness human ingenuity to reduce
the harmful effects of our activities.
The precautionary principle is based on the assumption that people have the
right to know as much as possible about risks they are taking on, in
exchange for what benefits, and to make choices accordingly. With food and
other products, such choices are often played out in the marketplace. A
major factor in the controversy over genetically engineered food is the
consumer understanding that benefits of these products (which accrue more
to producers than to consumers) do not outweigh the risk of harm to
themselves or the environment.
Increasingly, manufacturers are choosing to reduce risk themselves by
substituting safer alternatives in response to consumer uneasiness, the
threat of liability, and market pressures. For example, a number of toy
manufacturers have voluntarily stopped using phthalates in soft plastics.
Such actions are in the spirit of the precautionary principle.
A key to making those choices is transparency--about what products contain,
and about the testing and monitoring of those ingredients. Another is
support, by government and industry, for the exploration of--and rigorous
Sometimes it makes sense to eliminate even questionable risks if it is easy
to do so. For example, most airlines forbid passengers to use electronic
devices during takeoff and landing, even though studies have not confirmed
that they pose a danger.
In other cases the risk will be small but the consequences severe. An
example of this kind of precautionary action is the U.S. "zero-tolerance"
standard for Listeria monocytogenes in ready-to-eat foods. Listeria
infections are rare, but they are extremely dangerous. (See Edward Groth
III, "Science, Precaution, and Food Safety: How Can We Do Better?"
Consumers Union of the U.S., Inc., February 2000.)
Market and voluntary action is not enough, especially on issues that go
beyond individual and corporate choice. It is the responsibility of
communities, governments, and international bodies to make far-reaching
decisions that greatly reduce the risks we now impose on the Earth and all
4. "We don't need the precautionary principle: we have risk assessment."
Risk assessment is the prevalent tool used to make decisions about
technologies and products. Its proponents argue that because conservative
assumptions are built into these assessments, they are sufficiently
Too often, however, risk assessment has been used to delay precautionary
action: decision-makers wait to get enough information and then attempt to
"manage" rather than prevent risks. Risk assessment is not necessarily
inconsistent with the precautionary principle, but because it omits certain
basic requirements of the decision-making process, the current type of
risk assessment is only helpful at a narrow stage of the process, when the
product or technology and alternatives have been well developed and tested
and a great deal of information has already been gathered about them.
Standard risk assessment, in other words, is only useful in conditions of
relatively high certainty, and generally only to help evaluate alternatives
to damaging technologies.
Under the precautionary principle, uncertainty is also given due weight.
The nature of the uncertainties about a technology can suggest such things
as whether short-term testing can provide adequate answers; and if not,
whether longer-term testing and monitoring can do so; and whether the
benefits of the technology warrant that investment. The precautionary
principle calls for the examination of a wider range of harms--including
social and economic ones--than traditional risk analysis provides. It
points to the need to examine not only single, linear risks but also
complex interactions among multiple factors, and the broadest possible
range of harmful effects.
This broad, probing consideration of harm--including the identification of
uncertainty--should begin as early as possible in the conception of a
technology and should continue through its release and use. That is, a
precautionary approach should begin before the regulatory phase of
decision-making and should be built into the research agenda.
What is not consistent with the precautionary principle is the misleading
certainty often implied by quantitative risk assessments--that precise
numbers can be assigned to the possibility of harm, that these numbers are
usually a sufficient basis for deciding whether the substance or technology
is "safe," and that lack of numbers means there is no reason to take
action. The assumptions behind risk assessments--what "risks" are evaluated
and how comparisons are made--are easily manipulated by those with a stake
in their outcome.
5. "The precautionary principle is a tool of risk assessment."
This statement implies that the precautionary principle only applies to
risk management, rather than a comprehensive approach to preventing harm.
It implies that uncertainty will eventually be resolved through more
research or trial and error. Related to the above arguments, this one
assumes a narrow definition (and use) of the precautionary principle--a
stop or holding action when scientific evidence is uncertain. We argue that
this is only one aspect of the precautionary principle, and that, on the
contrary, risk assessment as it is currently practiced may be a
useful--but narrow--tool of a broader approach to precautionary
6. "Precaution itself is risky: it will prevent us from adopting
technologies that are actually safer."
This consideration is built into the precautionary principle. Current and
prospective alternatives to harmful technologies (such as genetic
modification to reduce pesticide use) must be scrutinized as carefully as
the technologies they replace. It does not make sense to replace one set of
harms with another.
7. "The precautionary principle is anti-science."
On the contrary, the precautionary principle calls for more and better
science, especially investigations of complex interactions over longer
periods of time. The assertion that the principle is "anti-science" is
based on any or all of the following faulty assumptions:
1) Those who advocate precaution urge action on the basis of vague fears,
regardless of whether there is scientific evidence to support their fears.
Most statements of the precautionary principle say it applies when there is
reason to believe serious or irreversible harm may occur. Those reasons are
based on scientific evidence of various kinds: studies, observations,
precedents, experience, professional judgment, and so forth. They are based
on what we know about how processes work and might be affected by a
However, precautionary decisions also take into account what we know we do
not know. The more we know, scientifically, the greater will be our ability
to prevent disasters based on ignorance. But we must be much more cautious
than we have been in the past about moving forward in ignorance.
2) Taking action in advance of full scientific proof undermines science.
Scientific standards of proof are high in experimental science or for
accepting or refuting a hypothesis, and well they should be. Waiting to
take action before a substance or technology is proven harmful, or even
until plausible cause-and-effect relationships can be established, may mean
allowing irreversible harm to occur--deaths, extinctions, poisoning, and
the like. Humans and the environment become the unwitting testing grounds
for these technologies. Precaution advocates say this is no longer
acceptable. Moreover, science should serve society, not vise versa. Any
decision to take action--before or after scientific proof--is a decision of
society, not science.
3) Quantitative risk assessment is more scientific than other kinds of
Risk assessment is only one evaluation method and provides only partial
answers. It does not take into account many unknowns and seldom accounts
for complex interactions.
8. "The precautionary principle is a cover for trade protectionism."
The precautionary principle was created to protect public health and the
environment, not to restrict valid trade. North American, Argentinian, and
other representatives in trade talks have leveled this accusation against
the European Union in response to EU action on beef containing growth
hormones and on genetically modified foods and crops. Recent EU statements
on the precautionary principle have emphasized that the principle should be
applied fairly and without discrimination.
However, the real issue is not protectionism but whether a nation has the
sovereign right to impose standards that exceed the standards of
international regimes. The recent European Commission statement on the
precautionary principle and Cartagena Biosafety Protocol both assert that
9. "Precautionary actions must be proportionate, cost-effective, and
temporary (subjected to further research)."
These qualifications (along with "fairness") have been included in recent
statements, no doubt partly to make the precautionary principle more
palatable to U.S. officials. While it is difficult to argue against any of
them, they could dilute the effectiveness of the principle. For example:
Action should indeed be generally proportionate to the severity of a threat
and standards of protection. But (as noted above) sometimes the
availability of alternatives or the ease of taking action makes decisive
action appropriate even if the threat is not severe or imminent.
"Cost-effectiveness" and "cost-benefit analysis" have been used in the past
to stop regulatory action. Cost considerations, like risk assessments, are
easily manipulated: whose costs and whose benefits are considered? The
European Commission precautionary principle statement makes the useful
assertion that "protection of health takes precedence over economic
considerations." If "cost-effectiveness" is defined in this way, then of
course precautionary decisions are cost-effective, directing us to the
least costly choices.
All decisions about technology, positive and negative, should be
temporary--that is, open to review and revision based on new knowledge and
experience. A precautionary approach has many feedback loops. As
uncertainty is reduced, we may say "yes" to some things to which we
previously said "no, " and vice versa. This implies that all stakeholders
should have access to relevant information. But sometimes the judicious
decision will be to turn away from technologies that pose too many
uncertainties and offer too few benefits. It will not always make sense to
invest limited government resources into continuing research into those
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