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Re: THE PRECAUTIONARY PRINCIPLE: "RISK-RISK ANALYSIS



Below is the full text of Goklany's "Risk-Risk" article in Nature
Biotechnology as requested by MichaelP.

Incidentally, MichaelP's argument that "doing nothing" can not increase an
existing risk is surely wrong. To take a less emotive example - we now know
that open wood and dung fires commonly used for cooking and heating by the
rural poor in developing countries has created a huge cancer and lung
damage risk, as bad as the worst city pollution. This risk was not
recognised originally because few cared and the rural poor rarely lived
long enough to turn up in the cancer statistics. 

If we know the numbers of rural poor are increasing or that their
conditions are deteriorating because of increased poverty, then this is an
increasing risk as well. Or one could argue that as rural poor life
expectancy increases (eg. through mass vaccination), so long term chronic
problems like air pollution become more tangible, so their "risk"
increases.

One effective solution would be to supply villages with electricity which
is totally clean for the user. But electricity brings risks too -
electrocution, fires from overheating wiring, damage to the environment
from fossil fuel burning and erecting transmission lines. Even with local
solar arrays, making solar cells requires toxic chemical processes and they
have to be transported to the villages which uses fossil fuel. And solar is
in its infancy so we even don't know the long term consequences of
deploying it on a large scale.

So the alternative comes with its own set of risks, some of which are
novel. Does the precautionary principle really tell us to do nothing - that
"known" old risks are ab initio "less" than "unknown" new risks? Surely
not. We have to proceed by balancing off both sets of risks - and both sets
of benefits. 

If we don't have all the answers, we proceed cautiously, we don't just stop
and twiddle our thumbs. The option of doing nothing may look safe and make
everyone (the already comfortable anyway) happy, but it doesn't require
much imagination to see that it is a sure way in practice  to condemn a
large part of humanity.

As the progressive politician Robert Kennedy once said: "Some people see
things as they are and say, Why? I dream things that never were and say,
Why not?"

----------------------

From Precautionary Principle To Risk-Risk Analysis
Nature Biotechnology, November 2002 Volume 20 Number 11 p 1075 

Indur M. Goklany is a manager with the US Department of the Interior's
Office of Policy Analysis. Views expressed here are his alone and not
necessarily those of any unit of the US government e-mail:
Igoklany@ios.doi.gov

Both proponents and opponents of the precautionary principle have often
argued that it substitutes for risk analysis. The principle itself received
a ringing endorsement when The New York Times Magazine's year-end review of
the best ideas of 2001 hailed it as "revolutionary," suggesting that it
offered a superior approach to managing potential risks associated with new
technologies (or actions or policies) than the risk-analysis paradigm
currently employed by US society and the World Trade Organization 1.

On the other hand, opposition to the precautionary principle has coalesced
around precisely the point that it seems to reject the risk-analysis
approach 2. But I would argue that to take the precautionary principle
seriously means we must, in fact, employ not just risk analysis, but
Risk-risk analysis.

Although there is no single definition of the precautionary principle, all
its formulations call for reducing, if not eliminating, risks to public
health, the environment, or both 3. One popular formulation is the
so-called Wingspread Declaration: "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 established
scientifically"4.

Taking the precautionary principle at face value means that when, or if, it
is applied, the objective ought to be to ensure that the outcome of an
action is at least "risk-neutral": that is, it should not cause
environmental and public health risks to increase. And if the precautionary
principle is used to choose between different technological or policy
options, its application should favor the one that reduces overall risks
the most.

This objective is easily met if a policy only reduces risks. In this case,
clearly we should adopt the policy. Similarly, if a policy only increases
risks, the decision is equally simple: avoid the policy. But most policy
options reduce some public health and environmental risks while increasing
or prolonging others 3. Cases in point include policies that would
foreswear the use of either genetically modified (GM) crops or
dichlorodiphenyl trichloroethane (DDT).

What do we do in such ambiguous situations? To ensure that a policy is
truly precautionary - that is, reduces net risks or is risk-neutral - one
should compare the risks of adopting the policy against the risks of not
adopting it (or the risks of the default policy). This inevitably forces us
into Risk-risk analysis. Thus, despite claims that risk analysis differs
from, or is incompatible with, the precautionary principle, the latter
logically ends up with Risk-risk assessment.

Unfortunately, none of the versions of the precautionary principle provides
any guidance on how it should be applied if a policy might be foreseen to
lead to both positive and negative outcomes where, moreover, both sets of
outcomes are uncertain. Accordingly, I have proposed a framework for
employing the precautionary principle in such ambiguous situations based on
a set of common-sense criteria that allow risks to be ranked and compared
based on their nature, severity, magnitude, certainty, immediacy,
irreversiblility, and other characteristics 3. For instance, all else being
equal, the immediacy criterion gives greater weight to threats that are
more immediate, the uncertainty criterion to threats that are more certain,
the expectation value criterion to those that are larger, and the
adaptation criterion to those that are more difficult or costly to cope
with3.

One criterion, however, relies more on ethics than common sense. This is
the two-part public health criterion. The first part, the human mortality
criterion, essentially holds that the risk of death to a human being
outweighs similar risks to members of other species, regardless of the
species. The second part, the human morbidity criterion, is less absolute3

Remarkably, with or without this (unapologetically) anthropocentric
criterion, applying this framework to evaluate whether a global ban on GM
crops would indeed be precautionary leads the conclusion that a ban would,
in fact, increase net risks to both global public health and the global
environment. Thus, any version of the precautionary principle should
actually require the use of GM crops, provided due caution is exercised
before commercialization of individual GM crops3. This result contradicts
conventional environmental wisdom.

To appreciate the why and wherefore of this result with respect to public
health, consider that 800 million people worldwide suffer from hunger and
undernourishment, and over 2 billion from malnutrition. As a result, hunger
and malnutrition kill over 5 million children annually worldwide.

In addition, poor nutritional habits are significant contributors to
diseases of affluence (heart disease, strokes, and cancers), which kill
almost 20 million more3. To reduce the future toll of hunger, malnutrition,
and poor nutritional habits, despite the almost inevitable future increase
in human population, means that the quantity and nutritional quality of
food must be enhanced. The faster this occurs, the fewer casualties there
will be. And GM crops should increase the quantity and nutritional quality
of food supplies faster than conventional crops.

Thus, a GM crop ban would retard reductions in global hunger, malnutrition,
and diseases of affluence. On the other side of the ledger, the health
effects of ingesting GM crops, if any, are not only much more uncertain,
they are not now - and unlikely to be in the future - comparable in
magnitude to the global toll from hunger and malnutrition. Therefore, a GM
crop ban is likely to increase net harm to public health, condemning large
numbers to premature death3.

With respect to environmental risks, consider that conventional
agriculture, with its enormous demands for land, water, pesticides, and
fertilizers, is the major stress on global biodiversity, and a significant
source of greenhouse gases3. These environmental pressures can be reduced
or contained more rapidly (and more certainly) with GM crops than with only
conventional crops because the former are more likely to increase
agriculture productivity (in terms of land and water) and to do so faster
and with fewer or less toxic chemicals.

In summary, to be true to itself, the precautionary approach requires
Risk-risk analysis. This suggests an alternative formulation for the
principle: "Public health and environmental policies should attempt to
minimize net risks to public health and the environment based on the best
available scientific information and their net anticipated costs to
society". Or, more succinctly: "All things considered, thou shalt attempt
to minimize net risks".

REFERENCES 
1. Pollan, M. New York Times Sunday Magazine 9 May (2001), 92, 94. 
2. Miller, H. & Conko, G. Nature Biotechnology 18, 697 (2000). 
3. Goklany, I.M. The Precautionary Principle: A Critical Appraisal of
Environmental Risk Assessment (Cato Institute, Washington, DC, 2001). 
4. Raffensperger, C. & Tickner, J., (eds.). p. 8 in Protecting Public
Health & the Environment: Implementing the Precautionary Principle (Island
Press, Washington, DC; 1999).



Message text written by INTERNET:gentech@gene.ch
>On Fri, 8 Nov 2002, David Kendra wrote:

[snip]
Thus, Goklany concludes that a global ban on GM crops would increase net
risk to global public health and the global environment. Therefore, any
version of the precautionary principle should actually require the use of
GM crops, provided due caution is exercised before commercialization of
individual GM crops.

Goklany's commentary can also be downloaded at
http://www.nature.com/cgi-taf/DynaPage.taf?file=/nbt/journal/v20/n11/full/n
bt1102-1075.html
======================

Sad to say this downloading is only available to subscribers. It would be
an educational service - in such cases - to have the full version posted 
to the gentech list.

I'd like to know more about 'Goklany concludes that a global ban on GM
crops would increase net risk to global public health and the global
environment'. It's not an obvious conclusion.

 I'd say it's not true as to immediate effect; doing nothing in the sense
of not planting GM crops as replacement for what is otherwise planted
can't increase a risk that's posed by the existing patern.

And as to a projected effect - well you still have to do a decent risk
assesment obaout what is already being done before you can assess the
comparative risk of innovation.

 And so we go round again. We've not been convinced about the current need
for increasing crops, to preserve global public health and the global
environment - and the proponents of GM crops are really relying on the
asymptotic extrapolation of population growth for the assesment of risk

Cheers
 MichaelP <