by Judith Curry
The unfortunate reality is that efforts to regulate one risk can create other, often more dangerous risks. – Jonathan Adler
The philosophical and political debate surrounding the precautionary principle is highlighted in two recent articles.
Jeremy Rifkin has an article in the Guardian entitled A precautionary tale. Subtitle: The EU plans new regulations for scientific risk-taking, based on the principle of sustainable development. US big business is furious. Excerpts:
Chances are that most people have never heard of “the precautionary principle”. This relatively new term is the most radical idea for rethinking humanity’s relationship to the natural world since the 18th-century European Enlightenment. Its potential impact is already being felt within the business community and the halls of government, with profound implications for all of us.
At issue is a proposed EU directive that would force companies to prove chemical products introduced into the marketplace are safe before being granted permission to market them. Under the proposed EU standards, companies would be required to register and test for the safety of more than 30,000 chemicals at an estimated cost of nearly €6bn (£4bn) to the industry.
What’s at stake here goes far beyond the chemical industry. The EU is attempting to establish a radical new approach to science and technology based on the principle of sustainable development and global stewardship of the Earth’s environment.
At the heart of the precautionary principle is a radical divergence in the way Europe has come to perceive risks compared to the US. In Europe, intellectuals are increasingly debating the question of the great shift from a risk-taking age to a risk-prevention era. That debate is virtually non-existent among American intellectuals. Risks of all kinds are now global in scale, open-ended in duration, incalculable in their consequences, and not compensational. When everyone is vulnerable, and all can be lost, then traditional notions of calculating and pooling risks become virtually meaningless. This is what European academics call a risk society.
The precautionary principle is deeply at odds with the traditional Enlightenment idea about science. Risk taking is at the heart of modern science. To attempt to put limits on scientific pursuits, in lieu of greater certainty about their potential impacts on the environment, is, some scientists say, tantamount to squelching our very notion of progress.
Recent advances in biotechnology promise tremendous benefits, including fast growing, resilient crops, more nutritious foods, new medicines and vaccines, and even new technologies for environmental decontamination. Yet modern biotechnology also inspires fear and trepidation.
The full promise of genetic engineering has yet to be discovered. For some, the possibility of unforeseen risks is cause for regulation until the uncertainty can be resolved, irrespective of the benefits that reliance on biotechnology could bring. Advocates of this “precautionary” approach urge adoption of an international biosafety protocol-negotiated under the United Nations Convention on Biological Diversity-to regulate the use and international transfer of GMOs.
Calls for precautionary regulation of biotechnology may seem compelling-until one considers the trade-offs. Government regulation of new technology inevitably slows its development and adoption. Imposing additional regulatory burdens on a given technology lowers the expected returns from new innovations. This, in turn, provides disincentives for research. As a result, excessive regulation may sacrifice the benefits of innovation in the interest of “safety.” In the case of biotechnology, excessive precautionary regulation could, for example, limit the introduction of high-yield crops, nutritionally-enhanced foodstuffs, or new vaccines. While regulation of new technology is supposed to make the world a safer place, precautionary regulation of biotechnology could leave the world less safe than it would be otherwise. In short, an international biosafety protocol could make us more sorry than safe.
The precautionary principle holds that “[w]hen 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 other words, regulate first, assess the risks later. As applied in the environmental context, this means that it is better to err on the side of regulating or controlling new technologies than to risk new or unforeseen problems. In the ideal, new technologies should be proven “safe” before they are used.
The precautionary principle appeals to the common sense idea that “it is better to be safe than sorry.” In practice, the precautionary principle biases regulatory decisions against the introduction of any new technology. While those who advocate adoption of the precautionary principle purport to be acting in defense of public health and the environment, the precautionary principle may well leave us more sorry and less safe. As noted by the late Aaron Wildavsky, “The empirical question is whether the health [and environmental] gains from the regulation of the substances involved are greater or lesser than the health [and environmental] costs of the regulation.”
The problem is that by focusing on one set of risks-those posed by the introduction of new technologies with somewhat uncertain effects-the precautionary principle turns a blind eye to the harms that occur, or are made worse, due to the lack of technological development. “The truly fatal flaw of the precautionary principle, ignored by almost all the commentators, is the unsupported presumption that an action aimed at public health protection cannot possibly have negative effects on public health.” The unfortunate reality is that efforts to regulate one risk can create other, often more dangerous risks.
Insofar as regulations divert resources away from potentially life-saving or safety-enhancing activities, they make people worse off. At the extreme, regulations that impose substantial costs can even increase overall mortality.
Higher economic growth and aggregate wealth strongly correlate with reduced mortality and morbidity. This should be no surprise as the accumulation of wealth is necessary to fund medical research, support markets for advanced life-saving technologies, build infrastructure necessary for better food distribution, and so on. In a phrase, poorer is sicker, and wealthier is healthier. “There is no free health. “ Much the same can be said for environmental protection.
The precautionary principle dominates climate policy. At the heart of the policy debate is whether the climate ‘cure’ in terms of CO2 emissions policy is worse than the climate ‘disease’.
Rifkin remarks that the precautionary principle reflects the great shift from a risk-taking age to a risk-prevention era, with substantial socioeconomic implications. Further, the precautionary principle turns out notion of justice on its head: guilty until proven innocent, versus innocent until proven guilty.
So, if we are to dismiss the precautionary principle, then how should we proceed. Well, we can proceed with caution. Or better yet is the Proactionary principle: The proactionary principle valorizes calculated risk-taking as essential to human progress, where the capacity for progress is taken to define us as a species.
The precautionary principle is only one of a number of decision-analytic frameworks for dealing with deep uncertainty, one which IMO is not well suited to a wicked problem like climate change. Alternative frameworks for decision making under deep uncertainty have been discussed in these previous CE posts:
- Why the decision to tackle global warming isn’t simple
- Can we make good decisions under ignorance?
- Uncertainty, risk, and (in)action
- Decision making under climate uncertainty
Uncertainty is key information in these alternative decision- analytic frameworks, and consensus is not required!
So, maybe its time to move on from the precautionary principle in terms of dealing with the complex, wicked climate change problem.