News & Insights The continuing benefits of the precautionary principle I am attending a conference on the safety of plastics in a few days and one of the questions we’ve been asked to consider is this: “how to deal with the unintended consequences of precautionism?” So where exactly did this word “precautionism” come from? To be honest, I haven’t done a retrospective linguistic analysis, but I can pretty much guarantee that it was first used by one of those companies or individuals who see anything to do with precaution-based research, development and regulation as being anti-growth, anti-progress and anti-science. First, a little case study. A few days ago, the International Agency for Research on Cancer added airborne pollution (essentially, high levels of particulate matter) to its list of Group 1 carcinogens – where there is “sufficient evidence” that they cause cancer in humans: “the risk of developing cancer is significantly increased in people exposed to air pollution.” This came hot on the heels of data demonstrating that air pollution killed 3.2 million people in 2010, including 230,000 cancer-related deaths. The debate about the link between air pollution and cancer has been going on for more than 20 years. Throughout that time, many scientists and activists who urged caution in terms of the potential carcinogenic impacts of those pollutants were subject to constant hostility and occasional vilification. I doubt they’ll be taking much comfort from having been vindicated. In our day-to-day lives, precaution comes naturally. By and large, we do look before we cross the road, and we tend to think that insuring our homes or cars (or bikes, in my case!) just makes good sense. Managing risk – taking precautions – comes naturally at that level. But that’s not what we’re talking about here. If it means anything, I suspect “precautionism” refers to the perceived application of caution far beyond what common sense might dictate – and doing so in certain cases not just to slow down developments but to stop them altogether. On GM applications, for instance, there are organisations that are fundamentally opposed to all GM in all situations for all time. For me, personally, this is not particularly smart. In the field of biotechnology, for instance, it may well prove to be the case that the use of GM-modified organisms (algae or bacteria, for instance) will bring significant benefits in terms of providing bio-based feedstocks and fuels to substitute for today’s fossil fuel-based feedstocks and fuels. If these new, more efficient processing technologies can be completely contained in closed (factory) environments, I can see no inherent problem with such developments – subject to rigorous and consistent regulation, with a great deal of precaution baked into the process from the very start. Taking an appropriately precautionary approach in any new innovation process makes a lot of sense. Seeking to set aside all such precautionary approaches is as stupid as using the “need for precaution” as a pretext to stop potentially good things happening. But determining what “appropriate precaution” means in practice in dozens of contemporary controversies is still a fine art. Which brings me on to the latest efforts of the world’s biggest agri-businesses to attack precautionism and get the precautionary principle relegated once and for all to the margins of regulatory history. The CEOs of Bayer, Dow Chemical, Novartis and Syngenta (but not Monsanto, incidentally, prompting the thought that the CEOs of Bayer, Dow Chemical, Novartis and Syngenta did not want their brands “contaminated” by association with the whipping-boy of anti-GM campaigners!) sent letters to the Presidents of the European Commission, Parliament and Council calling on them to stop applying the precautionary principle to risk assessments, and start applying the “Innovation Principle” to stimulate economic recovery in Europe. It was pretty crude stuff, unashamedly self-interested, and I suspect will get short shrift from the recipients of those letters. But those companies will undoubtedly carry on attacking the precautionary principle. And I rather suspect that “Golden Rice” (GM rice specifically “enriched” with the nutrient beta-carotene to deal with Vitamin A Deficiency (VAD) in South-East Asia) will continue to be used as their poster child for just how “wicked” the precautionary principle is. I use that word “wicked” deliberately, for that’s the word used by Owen Paterson, our Secretary of State at DEFRA, to describe those who continue to campaign against the immediate rollout of Golden Rice. He has accused them, in effect, of being directly responsible for the death of tens of thousands of children from VAD. As such, he has enthusiastically joined the ranks of today’s “GM fundamentalists”, who are so obsessively pro-GM that they will distort the truth about any particular debate, will misrepresent, demonise and unashamedly lie to ensure that any alternatives to GM are ignored by the media. Let me be clear here: I would be content if Golden Rice was able to clear all its regulatory hurdles, and could be safely included in broad-based campaigns to improve the overall diets of the 120 million people suffering from VAD today. This is indeed a huge and continuing problem - but one that demands long-term, integrated approaches to improving nutrition rather than some GM silver bullet. As it happens, Golden Rice 2 (Golden Rice 1 proved not to have the desired benefits its originators hoped for) isn’t yet ready to be rolled out. There are no published safety assessments regarding possible health impacts, and no published environmental impact assessments – which anyone but a GM-fundamentalist like Owen Paterson would probably consider to be the minimum level of precaution needed before such a major development. Allow me therefore to quote from the International Rice Research Institute, a prestigious research institute that is emphatically not anti-GM, and which even Owen Paterson would acknowledge has rather more knowledge about rice than his “Uncle Ben” ignorance. “It has not yet been determined whether daily consumption of Golden Rice does improve the Vitamin A status of people who are Vitamin A deficient, and could therefore reduce related conditions such as night blindness. Golden Rice will only be made available in the Philippines if it is approved by regulators and shown to reduce VAD in community conditions. This process may take another two years or more.” Two years! How “wicked” is that, you may be asking? No more and no less wicked than those arguing that the precautionary principle still has a vital role to play in good regulatory processes.