ISIS Press Release 09/01/06
Lectures in The Philippines
By Dr. Mae-Wan Ho and Prof. Peter Saunders in universities and open forums
in Luzon and Mindanao 11-16 December 2005
The Precautionary Principle
Prof. Peter Saunders
Institute of Science in Society and King’s College London
Abstract
The precautionary principle is really just a statement that we shouldn’t introduce
a new technology or continue with an old one unless we’re convinced it’s safe
both for us and for the environment. If we’re not sure, we wait until we are.
We don’t just charge ahead and hope for the best.
This is obvious common sense,
but many powerful people oppose it, often because they or their friends want
to make money out of products that appear likely to be - or even are known
to be - hazardous. I list and refute the arguments most often used against
the precautionary principle. I describe one example - asbestos - where failure
to apply the principle resulted in a massive cost in lives and money,
and show how the principle could and should be applied in the cases of Bovine
Somatotropin (currently before the WTO) and GMOs.
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. In this context
the proponent of an activity, rather than the public, should bear the
burden of proof.
The Wingspread Declaration
[1]
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The Precautionary Principle applies “where preliminary objective scientific
evaluation indicates that there are reasonable grounds for concern …”
The European Commission
[2]
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It’s just common sense
The precautionary principle is really just a statement that we shouldn’t
introduce a new technology or continue with an old one unless we’re convinced
it’s safe both for us and for the environment. If we’re not sure, we wait
until we are. We don’t just charge ahead and hope for the best.
Now you might think that
this was such an obviously sensible idea that no one could possibly disagree.
Unfortunately, there are many who do. That’s usually because they or the people
who support them want to make profits out of things that might be very dangerous:
for instance, asbestos, tobacco and GMOs.
They insist on what we might
call the anti-precautionary principle: what they are producing must be permitted
unless and until it can be proven to be dangerous. What is more, they set
a very high standard of proof: the tobacco companies are still advertising
and selling cigarettes despite the overwhelming evidence that smoking, even
passive smoking, contributes to many serious diseases, not only lung cancer,
and significantly shortens life expectancy.
Because these people represent
big corporations, well-financed think tanks, and university departments, they
have a lot of influence. So we can’t assume that just because the precautionary
principle is common sense our governments are going to adopt it. We’re going
to have to convince them, and to do that we have to be clear in our own minds
about what it is and how it works.
The burden of proof
The precautionary principle is like the legal principle of the burden
of proof. In a criminal court, the two sides are not on equal terms. The defendant
doesn’t have to prove he is innocent. He doesn’t have to prove anything. The
prosecution must prove he is guilty “beyond reasonable doubt.” If they cannot,
he goes free.
The reason for this deliberate
bias is that while we hope that our courts will convict the guilty and acquit
the innocent, they won’t always get it right, and we have to think about what
will happen then. Most people would agree that while it is bad that a crime
should go unpunished, it is much worse that an innocent person should be convicted.
So just thinking that someone is probably guilty isn’t good enough. The jury
may only convict if they are really convinced he is, beyond reasonable doubt.
In exactly the same way,
the precautionary principle says that if we have good scientific grounds for
being concerned that something presents a serious danger to health or the
environment, then we do not have to prove that it is dangerous before we can
justify banning it. It is the people who want to use and profit from the technology
that have to prove it is safe. Of course they don’t have to provide absolute
proof – there are no absolutes in science any more than in the courtroom
– but they have to demonstrate safety beyond reasonable doubt. And we bias
the decision in that direction because the damage that can be done if a technology
turns out to be unsafe can be so much greater than what we stand to lose by
waiting until we are sure it is safe, or can be made so.
Common criticisms refuted
Opponents of the precautionary principle
have a number of standard objections that they generally raise
when attacking it. They are all easily refuted, and I’m not even sure if the
people that put them forward really believe them, but it’s as well to go through
the ones that are most often used.
1. “The precautionary principle is useless because it does
not lead to decisions.” The principle is not a formula for making
decisions. Decisions are made by people exercising their judgement, and the
precautionary principle is just one of the things they should take into account.
A judge will explain the concept of the burden of proof to the jury, but they
still have to decide whether the defendant is guilty beyond reasonable doubt,
and even what level of doubt they are prepared to accept as reasonable. In
the same way, even if we accept the precautionary principle, we must still
weigh up the evidence as best we can and decide for ourselves.
2. “The precautionary principle does nothing that is not
already covered by risk assessment.” Risk assessment involves
multiplying the probability that something happens by the cost if it does.
The precautionary principle comes into play when we are not able to estimate
one or both of these factors at all, or with any degree of accuracy.
3. “The precautionary principle is too weak. It would make
no difference at all to policy.” I shall show later how using
the precautionary principle would have made a major difference to policy on
asbestos (as it would have on many other issues) and would make a difference
now if applied to BST and GMOs.
4. “The
precautionary principle is too strong. It would stop all progress”. In
practice, the Precautionary Principle would not affect most innovations at
all. In most other cases, it would mean only a short delay while the technology
was properly tested. (Even with the burden of proof on the prosecution, many
people do get convicted!)
5. “The precautionary principle is anti-scientific.”
Nothing could be further from the truth. The precautionary principle applies
only when there are good scientific grounds for concern. It then requires
that more good science be done to address those concerns. What is anti-scientific
is to assure the public that something is safe when you have no evidence to
back up your claim.
6. “The precautionary principle is merely a cover for protectionism.”
Anything that involves regulation can be used to block imports. Here, however,
the innovator has the opportunity to have the ban lifted by providing convincing
scientific evidence that what he wants to export is safe.
7. “These issues should be decided in the courts.” The
precautionary principle is not an alternative to the courts; like the burden
of proof it is a principle that the courts can and should use.
Examples
I’ll now discuss three examples. The first illustrates clearly what can
happen when the precautionary
principle is not used; the other two are current issues where using the
principle would make a real difference.
Asbestos
Everyone knows that asbestos is very dangerous and that it is still being
removed from buildings some of which are no more than 30 years old. Most people
probably believe that the danger was only recently discovered and that action
was taken as soon as it was. Actually it wasn’t quite like that [3].
Asbestos was first mined
in Canada in 1879. It was soon noticed that people who worked
with asbestos tended to suffer from respiratory diseases, and in 1898 an English
factory inspector, Lucy Deane, observed that these were more serious than
what she saw in other workers who worked in dusty conditions. She was also
able to discover why: asbestos fibres are sharp and so likely to damage the
lungs.
Nothing was done about her
report, and even in 1917, when more evidence had accumulated, the UK Factory
Department decided that there was no need to take any action. In the very
next year, however, insurance companies in the USA and Canada
started to refuse cover to asbestos workers, “due to the assumed injurious conditions in the industry”.
Note the parallel
with GMOs today. We are being assured by the biotech industry and by our governments
that GMOs are safe, yet at the same time the industry is refusing to accept
any liability if they are not, and insurance companies are refusing to provide
cover. A clear example of what happens when, as the Americans say, you ask
someone to put his money where his mouth is.
For most of the rest of the twentieth century, the evidence
against asbestos steadily built up. It became clear that not only people who
worked with asbestos but also their families and others who came in contact
with it were at risk. Yet far too little was done, and then only in the factories.
It wasn’t until 1982 that the British government started to restrict the use
of asbestos and look for alternatives, and only in 1998, the one hundredth
anniversary of Lucy Deane’s report, was asbestos banned altogether in the
UK and France.
Even then, the
Canadian government went to the World Trade Organisation to have the ban declared
an artificial restraint of free trade. The WTO rejected the appeal – it is
hard to see how even the WTO could have done anything else in view of the
overwhelming evidence – but this is a very clear example of how an industry
can put profit ahead of safety and how a government can support it.
Throughout the whole of
the twentieth century, governments consistently took an anti-precautionary
approach to asbestos. They waited for undeniable evidence of harm before taking
any action, which meant they always acted far too late.
What would have happened
if they had applied the precautionary principle? We don’t know, because we
can’t say when they would have banned asbestos or at least regulated its production
and use. That would have been a matter of judgement at the time.
We also do not have anything
like full records of the number of deaths due to asbestos or the cost of removing
it from places where it was used. Some partial data are, however, available
and they give us an indication of the scale of the problem. For example, it
has been estimated that between 1979 and 2001, over 200,000 people died in
the USA from diseases caused by asbestos. It has also been estimated
that there are about 250,000 mesothelioma deaths still to come in the EU even
though asbestos is no longer used; this is because the disease takes so long
to develop. The long time lag between first exposure and the actual onset
of the illness is yet another argument in favour of a precautionary approach.
As for the financial loss,
the Dutch have estimated that if they had banned asbestos in 1965, when the
mesothelioma evidence had been widely accepted, instead of in 1993, they would
have saved about $20 billion in construction and compensation costs. That’s
for one small country and assuming action was taken considerably later than
a precautionary approach would have implied, so you can imagine what the total
must be.
BST
Bovine somatotropin, commonly known as BST, is a growth hormone frequently given to cattle in the USA. The European Union prohibits the import of products from
these cattle on health and safety grounds. In 1996, the United States appealed to the World Trade Organisation,
claiming that the EU’s ban was an unfair restraint of trade.
Let’s see how
the precautionary principle operates. Are there good scientific grounds for
concern? There certainly appear to be, because we always have to be cautious
where hormones are involved. They are signal substances, telling the body
to do something rather than doing it themselves, and that means they can have
major effects even at very low dosages. And while BST normally acts in cattle,
hormones are not necessarily species specific, which means BST might act in
humans as well.
When we look
into the situation more closely, however, things look a bit better, at least
initially. Most of the BST in milk is destroyed by pasteurisation. What’s
more, any that survives can’t function as a growth hormone in humans
because the molecule is the wrong shape and doesn’t bind to the appropriate
receptors.
On the other hand, BST stimulates
the production of ‘insulin-like growth factors’ in cattle, and these are not
destroyed by pasteurisation. In humans, high levels of IGF-1 are associated with a greater risk of cancer [4].
At present, we don’t know whether it increases the risk or whether it is merely
a marker for cancer risk – i.e.
we don’t know if it is cause or effect – but it’s clearly something to be
concerned about.
There is also the problem that hormones often play more than one role. Even
if we know their chief function we may have no idea what else they do. So the
fact that BST can’t act as a growth hormone in humans doesn’t mean that it doesn’t
act in humans at all.
As in conventional risk assessment, we have to look at the other side as well.
How great a risk we are willing to take naturally depends on the cost of not
taking it. There is no shortage of milk in the EU; on the contrary, the EU has
had to impose quotas to reduce milk production by its own farmers.
Is BST a hazard to human
health? We don’t know. We don’t even know how likely that is. But that’s precisely
the point. If we were sure it was dangerous, there’d be no argument. It’s
when we aren’t sure that the
precautionary principle comes into play.
Here it surely leads us
to conclude that on the basis of the evidence currently available, the EU
is justified in not permitting the import of milk from BST treated cattle.
The WTO, however, generally
applies the anti-precautionary principle. It therefore ruled that it was up
to the EU to prove that BST is hazardous to human health and gave the EU a
year to do this. Not surprisingly, the EU was not able to comply, largely
because whatever harmful effects there are probably can’t be seen in such
a short time, even if we knew exactly what we were looking for, which of course
we don’t. After all, both asbestos and smoking can take 20 years or more to
act, and here one of the chief concerns is the possible effect of ingesting
small quantities of IGF-1 over a long period of time. In the end, the ban
was allowed to stand, but only for
the time being; the US is still trying to get it removed.
I was recently arguing with a leading British
opponent of the precautionary principle. I asked him several
times, in different ways, if he thought the WTO was right to insist that the
EU drop its ban on BST. He steadfastly refused to give me an answer, which
I’m sure was because he agreed the WTO was wrong but didn’t want to admit
that the precautionary principle can really work.
Finally, he said that it
didn’t matter whether we accepted the precautionary principle or not because
the Americans had told him that whatever the WTO decided, they’d force BST
products into the EU one way or another. That tells you where the opponents
of the precautionary principle really stand. They’re not interested in the
logic of the case. They just want to foist their products on us by whatever
means they can. That is exactly
what they are doing with GM crops.
GMOs
I’m not going to say much about GMOs because Mae Wan Ho will be dealing
with them in some detail. As she’ll explain, there are many good reasons for
being concerned about GMOs: it
is an inherently hazardous technology, the risks of horizontal gene transmission,
allergic effects, and so on [5].
I’d like to
comment on one further issue however, diversity. Here in the Philippines there are thousands of varieties of rice.
If you were to switch to GM rice, there would be at most a handful. The biotech
companies aren’t going to genetically modify large numbers of
varieties, and there wouldn’t be time for local types to evolve, even if farmers
were allowed to keep their seeds – which of course they are not.
This could leave
the Philippines highly vulnerable to any new pest or disease
that might appear. Remember, GM crops have been engineered to be resistant
to one particular challenge: a particular pest or a particular disease. They
are at least as vulnerable to other pests and diseases as conventional
crops, which makes relying on a single variety a very risky strategy.
It’s worth bearing in mind
that one of the reasons the famine in Ireland in the 19th
century was so devastating was that the country was very heavily dependent
on the potato, which is not indigenous to Ireland. It had been brought to
Europe comparatively recently from Peru. With little or no diversity when
the blight arrived, almost the entire crop was destroyed.
The precautionary principle
does not lead to the conclusion that we should stop all research into GMOs.
If we think that genetic engineering has the potential to improve crops, and
it may well have, then there’s no reason not to carry out research, providing
we do it in enclosed laboratories and greenhouses. The objection is to releasing
GMOs into the environment when there are so many unanswered questions concerning
their safety and their effect on the environment in general and other crops
in particular. We ought to be doing more research into understanding what
happens in genetic engineering and finding better and safer ways of doing
it, and of course devoting far more of our time, effort and resources to discovering
how we can improve our farms and our crops without using GMOs (many examples
in successive issues of Science in Society, especially #17, 23 and 28) [6-14].
Conclusion
In short, there’s nothing difficult about the precautionary principle.
It’s just common sense. The only
problem is getting our governments to accept that, and to act on it.
A fully referenced version of this paper is posted on ISIS members’
website. Details here
Making the World Sustainable & GM-Free
Dr. Mae-Wan Ho
Institute of Science in Society, PO Box 32097, London NW1 0XR, UK
www.i-sis.org.uk
Lecture tour in the Philippines
6-19 December 2005
Abstract
Decades of an “environmental
bubble economy” built on the over-exploitation of natural resources has accelerated
global warming, environmental degradation, depletion of water and oil, and
falling crop yields, precipitating a crisis in world food security with no
prospects for improvement under the business as usual scenario.
Genetically modified crops promoted to “feed the world” have the worst features
of industrial monocultures and are proving inherently hazardous to health. They
are a dangerous diversion from the urgent task of getting our food system sustainable
in order to really feed the world. Expanding the cultivation of GM crops across
the world is a recipe for global biodevastation, massive crop failures and global
famine.
There is a wealth of knowledge
for making our food system sustainable that not only can provide food security
and health for all, but can also effectively mitigate global warming by preventing
greenhouse gas emissions and creating new carbon stocks and sinks.
One of the greatest obstacles to implementing the knowledge is the dominant
economic model of unrestrained, unbalanced growth that has precipitated the
present crisis. I describe a highly productive integrated farming system based
on maximising internal input to illustrate a theory of sustainable organic growth
as alternative to the dominant model.
The complete paper with references posted on ISIS members’
website. Details here
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