Prescribing Caution with Precautionary Principle

Precautionary Principle matrixNot long ago, Tracey Brown, managing director Sense About Science , a British advocacy group that shares many interests with us here at the American Council, wrote an essay in The Guardian entitled "The Precautionary Principle is a blunt instrument." To many in the chemophobic, anti-technology camp, the precautionary principle (PP) is akin to the 11th Commandment: Thou shalt make no scientific or industrial progress without first ascertaining that such progress, as it involves introducing anything innovative into the stream of commerce, cannot first be proven safe.

OK yes, I paraphrased it substantially. The actual definition of the PP sounds comfortingly academic and rational: "When an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically."

Well, the devil is in the unstated details of this pronouncement which by the way is the official guiding principle of risk assessment and regulatory philosophy in the EU. The crux is in the definition of "threats of harm" to who- or whatever: such threats are in the eye of the beholder, more often than not. And to those of us who favor not unbridled, but reasonably independent scientific progress and innovation without hyper-regulatory dampening that eye is too often jaundiced by unscientific (at best, perhaps by emotional or ideological prejudice) or corrupt (at worst) influences. To those, calling upon the PP for backup to advocate bans and onerous restrictions is an easy call.

Here is the essence of Ms. Brown's discussion:

"A world of over seven billion people faces some pretty complex questions about the trade-offs involved in producing food, using resources, reducing disease and achieving the societies and environments in which we want to live. There's a collision between short-term and long-term outcomes, narrow interests and broader ones, and between problems and opportunities ¦ the consequences of which may be unforeseeable. Fear of the unforeseeable gives the precautionary principle influence, but was there ever such a mismatch between a challenge and a solution?"

She continues: "However simple we might wish managing uncertainty about the future to be, it's not. The precautionary principle misleads us into thinking it is. Its advocates arm-wave about complexity and the unknown future, but they are producing a response that implies the exact opposite. In place of informed, real-world choices that include the potential implications of both doing something and not doing it, we have simplistic bans, precaution's monotonous answer to every challenge. It is irresponsible."

Elided in the official statement is the difference between "threat," or risk, which can be quantitated to some degree, and "uncertainty," which by definition cannot be assigned a numerical risk, other than by vague comparison to known risks. All innovation and progress entailed some element of uncertainty until implemented, and to demand "proof" of lack of "threat" before a product or technology is even available would bring all progress to a screeching halt. Citing the PP to Dr. Jonas Salk in the early 1950s would have left us without the polio vaccine, most assuredly. I could go on all day with other examples ("Golden" Rice; banning DDT with its resultant resurgent malaria consequences would be others).

There is a vast difference between invoking the PP as a "slow down if there are danger signs" cautionary the interpretation that gets closest to the most widely used formulations of the principle and guides many technical decisions and using it for political or ideological ends, justifying needless, counterproductive bans and restrictions. In fact, I could argue (and have done so) that stringent implementation of the PP is, in itself, a violation of the Principle, since not taking action to introduce a probably beneficial substance, drug or technology out of an "excess of precaution" would do more harm to "human health or the environment" than plunging ahead, even into the midst of less-than-100% certainty.