Tuesday, June 15, 2010

Ounce of Prevention: is The Precautionary Principle a Sound Approach against Risk Analysis?

They say an ounce of prevention is worth a pound of cure. If that is true, why does the United States government dismissively permit laws and policies to go into effect that affect the health and future of its 300 million citizens without proper precautionary investigations?
The debate today is should the United States should have more of precautionary policy concerning important issues, such as chemicals that go into our food , bioengineering of our food, as well as allowing drilling in delicate environmental areas. Furthermore, should we should act on cap and trade policy to protect ourselves against the impending and imminent dangers of global warming, and last but not least, should we start to convert our policies to favor expansion of renewable fuels. If we neglect these most important relevant issues, our planet and our health might degrade to such an extent that it will mean the extinction of humanity.
Every day our scientists are making new discoveries that are important to our future survival and yet if they conflict with corporate interests (profits) they are systematically distorted and swept under the rug. Statistics of Green energy successes are either mocked or swept under the rug.
In the United States we have to prove a chemical is dangerous before it can be taken off of the market, whereas in Europe the opposite is true, a product has to be tested extensively before it is allowed to be used by the public. In the United States, we do not test chemicals that are put into our diets; we do not execute longevity tests on the genetically altered foods. We have not done enough to insure our waters will be clean and our planet will be safe.
The precautionary Principle
What is the precautionary principle most Americans have never heard of it? It is the rule that we should leave a margin of safety for unexpected developments. This principle implies that we should strive to prevent harm to human health and the environment even if risks are not fully understood (Cunningham, W.P. and Cunningham, M.A.2008) p.385). The precautionary principle has played an increasingly important part in environmental law ever since it first appeared in Germany in the mid-1960s. On the international scene, it has been applied to climate change, hazardous waste management, ozone depletion, biodiversity, and fisheries management. In 1992 Rio Declaration on Environment and Development, listing it as Principle 15, codified it thus: In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. When 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. "(Easton, T. 2008 p.3)
"The essence of the Precautionary Principle is that when lives and the future of the planet are at stake, people must act on these clues and prevent as much harm as possible, despite imperfect knowledge and even ignorance"( Easton, T. A. 2008 p.7). "Although some environmental policies are preventive, most have focused on cleaning up messes after the fact, this what environmentalists call: end of pipe solutions" Easton, T. 2008 p.8). This expression is ironic and apropos considering the Gulf oil spill disaster that is occurring as I write this essay. They are deciding what to do on the end of the pipe? The gulf incident in my opinion is a result of gross negligence that has taken place, a total lack of precaution, when the well was being designed and drilled. The fact that shoddy work to spare expense might cause irreversible harm and the death of many species of wildlife didn’t enter into the thoughts of those in charge nickel and diming our lives and our environmental sustainability. "The essence of the Precautionary Principle is that when lives and the future of the planet are at stake, people must act on clues and prevent as much harm as possible, despite imperfect knowledge and even ignorance.
Risk Analysis
In The United States the litmus test for providing new laws and safety for many years has been supposedly thorough risk analysis. “The industry typical technique for risk analysis is a graph or a plot with frequency of occurrence on one axis and severity of the consequences on the other. There are common errors in implementing this technique: failing to differentiate between types of risk, using estimated probability rather than frequency of occurrence, using ordinal instead of cardinal numbers, using different ranges for severity and frequency, using an inappropriate combining equation, using linear instead of logarithmic scales, explaining only intermediate risks, and confusing risk with uncertainty” (Bahill, A., & Smith, E. 2009). “Risk plots (graphs, charts. Figures) showing frequency of occurrence versus the severity of consequences was used in risk assessments of nuclear power systems (Joksimovic, Houghton, and Eon, 1977; Rasmussen, 1981). They were defined by Kaplan and Garrick (1981) and applied to civil engineering projects by Whitman (1984). Use of the risk plot was popularized by the Defense Systems Management College (1986); however, despite its popularity, the execution of this technique often has flaws” (Bahill, A., & Smith, E. 2009). There are many levels of risk: (1) system risk including performance, cost, and schedule of the product, (2) project risk, (3) business risk including financial and resource risks to the enterprise, and (4) safety, environmental, and risks to the public (Bahill, A., & Smith, E. 2009). The effect of a risk in one category may become the source of risk in another category. Interrelationships between the most common among them are: “1. Failing to differentiate between levels and categories of risk, 2. Using estimated probability of the event rather than its frequency of occurrence, 3. Using ordinal numbers instead of cardinal numbers for severity, 4. Using different ranges for severity and frequency, 5. Using an inappropriate combining equation, 6. Using linear scales instead of logarithmic scales, 7. Explaining only intermediate risks while seeming to ignore high and low risks, 8. Ignoring risk interactions and severity amplifiers, and, 9. Confusing risk with uncertainty” (Bahill, A., & Smith, E. 2009).
Opposing Opinions
"The U.S. Chamber supports a science-based approach to risk management; where risk is supposed to be assessed based on scientifically sound and technical rigorous analysis. Under this approach, regulatory actions are justified where there are legitimate, scientifically ascertainable risks to human health, safety, or the environment. Professor Bernard D. Goldstein argues that although the precautionary principle is potentially valuable, it poses a risk that scientific (particularly toxicological) risk assessment will be displaced to the detriment of public health, social justice, and the field of toxicology itself (Easton T 2008 p.3)
According to some of the largest corporations and congressionally elected government, people are worrying needlessly and they inhibit corporate growth, accordingly, in their opinion we should be more concerned about free enterprise rather than the environment. They feel too many constrictions and regulations on Corporations or on new product inhibit the economic growth and are a determent to their profits
Life sciences and biotechnology are widely regarded as one of the most promising frontier technologies for the coming decades and they may be used for a wide range of purposes" (Ghisleri, L. etc .2009) The Codex principles determine that risk assessment includes a safety assessment, which is carried out to identify whether a hazard, nutritional or other safety concern is present, and if present, to gather information on its nature and severity (Ghisleri, L. etc .2009)
Like any food, genetically modified or other novel foods are complex mixtures of thousands of different substances in varying proportions. With trusted foods that have been eaten for generations there is little concern and they are considered safe based on experience, not necessarily based on scientific proof. For novel or GM foods, proving safety is a legal obligation (Ghisleri, L. etc .2009).
Biotechnology may someday be considered a safe agricultural tool but studies suggest it may have harmful ecological consequences, such as: spreading genetically-engineered genes to indigenous plants increasing toxicity, which may move through the food chain disrupting nature’s system of pest control creating new weeds or virus strains
Transnational corporations (TNCs) such as Monsanto, DuPont, and Novartis, the main proponents of biotechnology, argue that cautiously planned introduction of these crops should reduce or even eliminate the enormous crop losses due to weeds, insect pests, and pathogens. In fact, they argue that the use of such crops will have added beneficial effects on the environment by significantly reducing the use of agrochemicals. Nevertheless, ecological theory predicts that as long as transgenic crops follow closely the pesticide archetype prevailing in modern agriculture, such biotechnological products will do nothing but strengthen the pesticide treadmill in agro ecosystems, thus legitimizing the concerns that many environmentalists and some scientists have articulated concerns about the possible environmental risks of genetically engineered organisms. In fact, there are several widely acknowledged environmental drawbacks associated with the rapid deployment and widespread commercialization of such crops in large monocultures including “Pests that show rapid evolution in resisting the pesticide properties of GMCs, toxic buildup in GMCs harms useful insects, the spread of transgenes to related weeds or nonspecific’s via crop-weed hybridization reduction of the fitness of non-target organisms through the acquisition of transgenic traits via hybridization the rapid evolution of resistance of insect pests such as Lepidoptera to Bt accumulation of the insecticidal Bt toxin, which remains active in the soil after the crop is ploughed under and binds tightly to clays and humic acids; disruption of natural control of insect pests through inter-trophic level effects of the Bt toxin on predators unanticipated effects on non-target herbivorous insects (i.e., monarch butterflies) through deposition of transgenic pollen on foliage of surrounding wild vegetation vector mediated horizontal gene transfer and recombination to create new pathogenic organisms (Altieri, M. 2001). Regulation (EC) No 1829/2003 of the European Parliament and of the Council of 22 September2003, on genetically modified food and feed, put in place a centralized and transparent consent procedure called “one door-one key” for the entire GM food and feed applications for placing on the market, whether they concern the GMO itself or the food and feed products derived there from, and sets out rules for labeling of foods and feeds, thereby enabling the consumer to make an informed choice and it also facilitates transactions between seller and purchaser. It draws from Regulation (CE) No 178/2002, which establishes the general principles and requirements of food legislation, and also by which the European Food Safety Authority (EFSA) has been created. (Ghisleri, L. etc .2009). “Considered in the risk assessment are the following: the characteristics of the donor and recipient organisms; the genes inserted and expressed; the potential consequences of the genetic modification; the potential environmental impact following a deliberate release; the potential toxicity and allergenicity of gene products and metabolites; the compositional, nutritional, safety and agronomic characteristics; the influence of food processing on the properties of the food or feed; the potential for changes in dietary intake and the potential for long-term nutritional impact” (Ghisleri, L. etc .2009)
The regulatory frameworks in other countries differ from nation to nation. In Canada and the USA), the regulation of genetically modified (GM) crops, livestock feeds and human foods, shares many similarities: both countries have a coordinated approach whereby regulatory responsibility is shared by several agencies; risk assessments are based on sound science; and each regulated product (sectorial legislation) is assessed on a case-by-case basis under different specific regulation and depending on the scope of application. In these two countries, their regulations consider genetically modified foods as novel foods, but not a separate entity with respect to other foods. Rather, the focus is on the altered characteristics brought about by genetic modification, and the intended use of the novel crop.
The U.S. Chamber supports a science-based approach to risk management; where risk is assessed based on scientifically sound and technically rigorous analysis. Under this approach, regulatory actions are justified where there are legitimate, scientifically ascertainable risks to human health, safety, or the environment. That is, the greater the risk, the greater the degree of regulatory scrutiny. This standard has served the nation well, and has led to astounding breakthroughs in the fields of science, health care, medicine, biotechnology, agriculture, and many other fields. According to them, the relatively new theory, Precautionary Principle is gaining popularity among environmentalists and other groups.
Summation
The Precautionary Principle says that when the risks of a particular activity are unclear or unknown, assume the worst and avoid the activity. It is essentially a policy of risk avoidance (Easton, T. 2008). On the other hand, we have seen some of the flaws of risk analysis and how the facts and statistics can be watered down and manipulated, almost to the point of a parlors trick of hand, by eliminating facts in analysis graphs, such as: Explaining only intermediate risks while seeming to ignore high and low risks, Ignoring risk interactions and severity amplifiers, and, Confusing risk with uncertainty, using estimated probability of the event rather than its frequency of occurrence, using ordinal numbers instead of cardinal numbers for severity, using different ranges for severity and frequency, or using an inappropriate combining equation,” (Bahill, A., & Smith, E. 2009) Perhaps one might surmise that the US Chamber of Commerce might be saying Let’s take risks despite the consequences known or unknown as long as we make a good profit. We can deal with the consequences later. When have we not seen irresponsibility when large amounts of money are to be made? “In the long term, they say, what is needed is a shift from materialist to post-materialist values, from anthropocentric to ecological worldview, and a redefinition of the good life.
Many feel an unregulated free market system is incompatible with sustainability. Experience has shown that if green technology threatens profits, green technology loses and profitability wins (Easton, T.A. 2008). A good example is that of The Union of Concerned Scientists that argues that opposition to the idea that global warming is real, due to human activities, and is a threat to human well-being has been orchestrated by ExxonMobil in a disinformation campaign very similar to the tobacco industry’s efforts to convince the public that tobacco was not bad for health. Scientists have known for more than a century that carbon dioxide and other greenhouse gases (including water vapor, methane, and chlorofluorocarbons) help prevent heat from escaping the earth’s atmosphere. In fact, it is this green house effect that keeps the earth warm enough to support life. Yet, of course there can be too much of a good thing. Ever since the dawn of the industrial age, humans have been burning vast quantities of fossil fuels, releasing the carbon they contain as carbon dioxide. Because of this, some estimate that by the year 2050, the amount of carbon dioxide in the air will be double what it was in 1850. By 1982 an increase was apparent. Less than a decade later, many researchers were saying that the climate had already begun to warm. Debate over the reality of the warming trend and its significance for humanity and the environment has been vigorous. In 2007, the Inter-governmental Panel on Climate Change (IPCC) issued its Fourth Assessment Report; it says in no uncertain terms that Warming of the climate system is unequivocal, as is now evident from observations of increases in global average air and ocean temperatures, widespread melting of snow and ice, and rising global average sea level. The impacts on ecosystems and human well-being (especially in developing nations) will be serious (Gore, A., Baucus, M., Leahy, etc.1989).
Should we throw care to the wind and forget to be precautionary as the Chamber of commerce is suggesting along with ExxonMobil, or should we be precautious in our approach to Global Warming? I feel we should be following the lead of successful countries, for instance: "Denmark has substantial oil and gas supplies under the North Sea, but the Danes have chosen to wean themselves away from dependence on fossil fuels. Currently the world leader in renewable energy, Denmark now gets 20 percent of its power from solar, wind, and biomass. Some parts of this small, progressive country have moved even further toward sustainability. One of the most inspiring examples of these efforts are the small islands of Samsø and Ærø, which now get 100 percent of their energy from renewable sources. Samsø and Ærø lie between the larger island of Zealand (home to Copenhagen) and the Jutland Peninsula. The islands are mostly agricultural. Together, they have an area of about 200 km2 (77 mi2) and a population of about 12,000 people. In 1997, Samsø and Ærø were chose in a national competition to be renewable energy demonstration projects” (Cunningham and Cunningham 2008 p.287) Several European countries, including Sweden, Denmark, and Finland, have higher standards of living than does the United States by almost any measure but use about half as much energy Cunningham and Cunningham 2008 .283) It is interesting to note that they do have to depend on fossil fuels and yet we are more diverse in natural resources choices if we wanted to have them.
According to Professor Keller of the University of California, “The estimated recoverable energy from solar energy is about 1000 times the present human global energy consumption of 10 TW (230 exajoules) per year. 10 weeks of solar energy is roughly equivalent to the energy stored in all known reserves of coal, oil, an actual gas on earth. Solar energy is absorbed at the earth's surface at an average of 120, 000 TW (one TW is 1012 W), which is 10,000 times more the total global demand for energy and wind energy provides similar potentials. It is believed that there's sufficient wind energy in Texas, South Dakota, and North Dakota, to satisfy the electric needs of the entire country total global demand for energy” (Keller A. 2001)
"Scientific uncertainty is a fact of life even when it comes to the most obvious environmental problems, such as the disappearance of species, and the most potentially devastating trends, for example climate change. Scientists seldom know for sure what will happen until it happens, and seldom have all the answers about causes until well after the fact, if ever. Nevertheless, scientific knowledge, as incomplete as it may be, provides important clues to all of these conditions and what to do about them. The United States should have a precautionary view concerning chemicals that go into our food and also bioengineering as well. Fossil fuels has been one of the largest problems of global warming , we carelessly drill , allow harmful chemicals into the sea to disperse our spills, Destroy our rainforests and other tree three forest manipulate rivers dangerously, pollute environments with dangerous radioactive materials as well as allow drilling in delicate environmental all for our fossils fuels which perpetuate global warming. Meanwhile the corporations that are making their profits from this are spending billions of dollars to block legislations and pay out fortunes in money to politician and to advance a campaign of misinformation, and studies, that are based on trumped up unscientific and non peer reviewed reports, blocking clean renewable energy which is their completion and our most urgent cure for global warming. It is very important that we move now to get the correct legislation into place and get the real truth out there, because our health and planet might degrade to such an extent that it will mean our extinction. “Throughout its history the Clean Air Act has been controversial. Victims of air pollution demand more protection; industry and special interest groups complain that controls are too expensive. “(Cunningham and Cunningham 2008 p.227)
I think the media is to blame for allowing ExxonMobil to get away with its misinformation campaign, for instance here are some of the action they are responsible for allowing this to happen. According to a report in the year 2006 from the Union of Concerned Scientists
“ExxonMobil has drawn upon the tactics and even some of the organizations and actors involved in the callous disinformation campaign the tobacco industry waged for 40 years. Like the tobacco industry, ExxonMobil has: Manufactured uncertainty by raising doubts about even the most indisputable scientific evidence. They have adopted a strategy of information laundering by using seemingly independent front organizations to publicly further its desired message and thereby confuse the public. They have according to the Union of Concerned Scientists report of 2007,” promoted scientific spokespeople who misrepresent peer-reviewed scientific findings or cherry-pick facts in their attempts to persuade the media and the public that there is still serious debate among scientists that burning fossil fuels has contributed to global warming and that human-caused warming will have serious consequences. They have attempted to shift the focus away from meaningful action on global warming with misleading charges about the need for sound science. Used its extraordinary access to the Bush administration to block federal policies and shape government communications on global warming. The report documents that, despite the scientific consensus about the fundamental understanding that global warming is caused by carbon dioxide and other heat-trapping emissions, ExxonMobil has funneled about $16 million between 1998 and 2005 to a network of ideological and advocacy organizations that manufacture uncertainty on the issue. Many of these organizations have an overlapping sometimes identical collection of spokespeople serving as staff, board members, and scientific advisors. By publishing and republishing the non-peer-reviewed works of a small group of scientific spokespeople, ExxonMobil funded organizations have propped up and amplified work that has been discredited by reputable climate scientists. (From Union of Concerned Scientists, 2007)

Conclusions
They say an ounce of prevention is worth a pound of cure. We need to change our policy and stop listening to paid off lobbyists who were politicians of past, we also need to have a higher standard in this country for drilling, and stronger laws for polluters . Not United States government to dismissively permit laws and policies to go into effect that can harm the health and future of its 300 million citizens without proper precautionary investigations.
Every time a bribed politician or an ex politician lobbyist says global warming isn’t real, cap and trade is a waste of money, alternative energies are not really effective or drilling the ocean isn’t the end of the world, you have to wonder, because, today might be the start of the end of the planet if we continue to make wrong decisions and allow money to buy the medias off and bury truth. "Making companies prove that their chemical products are safe before they are sold would be a revolutionary change. It is very difficult to conceive of the U.S. where corporate lobbyists spend millions of dollars influencing congressional legislation, the chances of ever having a similar regulatory regime to the one being implemented in Europe would be nearly impossible, but, if any time is the right it could be now, People who have passionate feelings on this subject must speak out by letters to their politically elected leaders by joining groups, signing petitions, blogging on prestigious, high profile sites, We must send out hard facts and opinions based on those facts, not just our opinions basted on intuition or emotion. Now is the time to do so, because we have a President willing to expand our renewable energies, is in favor of cap and trade, we also had that devastating spill incident in the gulf that showed us exactly how safe drilling is and what the consequences of the lack of precautions can result in. The weighting and balances of risks is not a wild idea, it is sensible and the right thing to do.
Reference
Altieri, M. (2001). The ecological impacts of agricultural biotechnology retrieved from http://www.actionbioscience.org/biotech/altieri.htm on June 1, 2010
Bahill, A. & Smith, E. (2009). An industry standard risk analysis technique Engineering Management Journal, 21(4), 16-29 retrieved from Academic Search Premier Database.
Cunningham, W.P. and Cunningham, M.A. (2008). Principles of environmental science: Inquiry and applications (Custom 5th Ed.). New York: McGraw-Hill.
Easton, T.A. (2008). Taking sides: Clashing views on controversial environmental issues. (Custom 13th ed.) New York: McGraw-Hill.
Ghisleri, L., Anadón, A. Recuerda, M. Peralta, P. Botija, F., Cañellas, A., et al. (2009). Risk analysis and GM Foods: Scientific risk assessment. European Food & Feed Law Review, 4(4), 235-250 retrieved from Academic Search Premier Database.
Gore, A., Baucus, M., Leahy, P., Stafford, R.T, Durenburger, D. and Humphrey, G. J. (1989). The potential effects of global climate change on the United States U.S. EPA Office of Policy, Planning, and Evaluation
Keller, E. A. (2001). Some facts about nuclear, solar, and wind power, University of California, Santa Barbara.