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Date:

April 26, 2000

Subject:

precautionary principle and green policies.

 

AgBioView - http://www.agbioworld.org, http://agbioview.listbot.com

Dr. Trewavas,
Your comments on the precautionary principal and that we "should throw it
right back at them"
is a critical part of the debate, not only on biotechnology but on a host of
other issues.
Indeed, there are many groups and individuals directly taking on the
precautionary principle on a range of issues in the policy arena. One such
is Julian Morris of the London-based Institute of Economic Affairs, who is
editing a book dealing with the PP in many of its incarnations and guises.
Dr. Henry Miller at the Hoover Institute in Palo Alto, CA has dealt with
this topic in relation to biotechnology. Fred Smith of Competitive
Enterprise Institute in DC has written and spoken extensively on this topic.
Smith and others note that the PP addresses only one side of the risk
equation -- one must evaluate the risk of innovation (e.g., biotechnology)
but also the risk of stagnation (restricting that technology). He also
focuses on "decision making under uncertainty" and the divergent approaches
to deal with a perceived threat -- one is a prevention strategy (prevent the
threat from occurring at all costs), the other a resiliency strategy
(develop the knowledge, technology and skills -- through a strong economy --
to be able to meet a myriad of threats).

In a soon-to-be-available monograph I wrote on the Cartagena Protocol and
its use of the PP, I develop several of the points you also raise. Below are
some of the relevant (edited, footnotes deleted) sections.

The precautionary principle is increasingly being invoked as an approach
that governments should embrace to deal with risks, especially environmental
risks, arising from new technology or new products. First recognized in the
World Charter for Nature, adopted by the United Nations General Assembly in
1982, the principle was subsequently included in other international
agreements, most notably in the Rio Declaration during the UN Conference on
Environment and Development in 1992. The Rio Declaration states this
approach in its Principle 15:
“In order to protect the environment, the precautionary approach shall
be widely applied by States according to their capabilities. 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 degradation.”

Essentially, this approach embodies a concept that, at first glance,
sounds sensible: Shouldn’t governments take action to protect human health
and the environment even when there is no conclusive evidence of harm?
However, some governments, such as the European Commission (EC), have
taken this principle further in some instances and have insisted that, when
scientific evidence “is not black and white, policy should err on the side
of caution so that there is zero risk to the consumer.” They want to err on
the side of caution not only when the evidence is not conclusive, but when
no evidence exists that would indicate that harm is possible.
Although the EC in a more recent communication on the precautionary
principle has backed away from that zero-risk endorsement, implementation of
the principle readily leads to an approach that attempts the impossible task
of eliminating risk. Furthermore, the precautionary principle can never be
satisfied as long as an inventive alarmist can think of yet one more
hypothesis about a possible risk that has not yet been absolutely proven not
to exist.
The precautionary principle as used in the Protocol states that even
when there is a lack of scientific evidence that products produced through
biotechnology are likely to cause harm, a country can take action to ban the
import of those products. The Protocol invokes the precautionary principle
in its Preamble and several other specific references and thus enshrines it
as a key principle in the agreement.
This explicit and repeated reference to the precautionary principle in
the Protocol did not go unnoticed. Less than a week after it had been agreed
to, the EC Communication on the precautionary principle noted that the
Protocol “confirmed the key function of the Precautionary Principle . .” and
that the principle “has been progressively consolidated in international
law, and so it has since become a full-fledged and general principle of
international law.” That same day – February 2 – Greenpeace International’
s web site noted: “The battle was won for the precautionary principle to be
the basis for decision-making on transboundary movements of all living
modified organisms, including for commodities.”
No action or activity is risk-free. Biotechnology, as does any new
technology, creates some new risks while reducing older risks. Both have to
be considered and evaluated – the risks of change have to be balanced
against the risks of stagnation. New technologies have tended to reduce
overall risk, and that fact is ignored in the precautionary principle and
its use in the Cartagena Protocol.
The precautionary principle as used in the Protocol has the most
serious implications for people in poorer, developing countries. That is
where potential benefits of new technology, such as biotechnology, can be
halted before they have begun to be felt.
The human and environmental benefits of agricultural biotechnology
could be dramatic and widespread. Higher crop yields per acre not only can
provide larger food output to feed the world’s hungry, but also reduce the
amount of land required for farming, which helps preserve forests and
habitats. Reductions in the use of pesticides made possible by
bioengineering resistance into the plants can enhance the environment. The
ability to grow crops in previously barren areas can help keep pace with the
needs of growing populations, especially in developing countries. Enhanced
nutritional levels of staple crops, such as rice, can prevent diseases that
are life-threatening or debilitating. Possible reduction of allergens in
certain foods can lower health risks to many people. Longer shelf life of
fresh foods can reduce costs and improve availability.
These and other potential crops might raise safety issues related to
specific foods and production methods, and those risks should be carefully
examined. However, the fact that biotechnology is the process used to
create them does not in itself raise any safety issues. The rote
application of the precautionary principle, with its strong bias against
innovation, to broad classes of biotech products creates high risks that
extraordinarily useful products will be suppressed in exchange for no gain
in safety.

Frances B. Smith
Executive Director
Consumer Alert
Phone: 202-467-5809
Fax::202-467-5814
www.consumeralert.org




-----Original Message-----
From: Tony Trewavas
To: AgBioView
Date: Tuesday, April 25, 2000 12:42 PM
Subject: precautionary principle and green policies.

> - http://www.agbioworld.org, http://agbioview.listbot.com
>
>Dear All
>
>I read the excellent report on the precautionary principle by Andrew Apel
this a.m. while waiting for the
>dentists drill. it seems to me that we need to throw this principle which
they are so keen on right back at
>them.
>