Norfolk Genetic Information Network (ngin)
http://members.tripod.com/~ngin
---
3 shortish pieces on the general issue of 'sound science' and precaution
that perfectly put into context the EPA's recent decision to declare
everything hunk-dory with Bt crops.

Items:
*1. Science or precaution in environmental protection? Andy Stirling
Quote: Although not known for his postmodern anxieties over risk, it was
Winston Churchill who said "science should be on tap, not on top". The
precautionary approach recognises this. Those calling for reliance on
‘sound science’ do not. Ironically, to miss this essential point is to
be thoroughly unscientific about the limits to science.

*2. Politics, sound science and the precautionary principle - Phil Bereano

Quote: Ruckelshaus was brought back into that role [as head of the EPA]
as part of the larger Reaganite agenda to role back the "democratic
paradigm" of
public policy and install a "technocratic" one... This maneuver has
helped the Government deflect popular environmental and consumer
concerns while
calling for endless technical studies. By these means, any constraints
on industry practices have been substantially delayed (and
simultaneously, citizen groups have been discredited as anti-rational
and selfish...) "Sound science" thus became a mantra to obscure the
exercise of partisan political power.

*3. 'Sound science' as ideology - Les Levidow
Quote: For potential harm to non-target insects, however, new evidence
of risk has been disparaged as unsound. Such evidence has been
criticized on various grounds -- e.g. 'unrealistic' experimental
conditions or statistical anomalies -- which could apply just as well to
evidence of safety. Yet the latter was favorably cited by companies and
largely accepted by regulators. Thus double standards have served to
protect safety claims. Moreover, some comments have implied that any
plausible harm would be acceptable, e.g. by favorably comparing Bt maize
to harm from agrochemical usage -- as if the comparison needed no
evidence  and involved purely technical issues. In sum, the slogan
'sound science' tends to conceal value-laden features of safety claims,
their weak scientific basis, their normative framing and their
socio-political influences. In these ways, 'sound science' operates as
an ideology...
---
1. Science or precaution in environmental protection?
http://www.cid.harvard.edu/cidbiotech/comments/comments89.htm
Andy Stirling, Ph.D., mailto:a.c.stirling@sussex.ac.uk
Senior Lecturer and Fellow
Science and Technology Policy Research (SPRU)
University of Sussex, United Kingdom

The precautionary principle is becoming increasingly prominent in the
environmental protection debate. Principle 15 of the
1992 Rio Declaration provides a classic definition: "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".

Though neatly addressing several key issues, this begs a number of
questions. When does a ‘fear’ become a ‘threat’? How do
we measure ‘seriousness’? What are the criteria for ‘irreversibility’?
Who decides on ‘full scientific certainty’? How should we
account for ‘costs’? With what margins of safety should we ‘prevent
environmental degradation’?

For many, these questions ring alarm bells. The high economic and
political stakes amplify the clamor. How does precaution
fit with established approaches to environmental protection? Over the
years, techniques like risk and cost-benefit analysis have
come to epitomize the use of ‘sound science’ in this tricky area. Such
methods aim to offer robust and objective aids to
decision-making. Precaution, by contrast, seems rather ambiguous and
impractical. For some, precaution threatens even to
undermine science by opening the floodgates to subjectivity.

But is this true? How robust and objective are the results of
‘science-based’ techniques like risk assessment? The answers to
these questions are well established but surprisingly neglected.

First, there’s the issue of robustness. Risk assessment requires at
least some basis for assigning probabilities. Under
conditions of uncertainty, however, this can be obstructed by the
novelty or complexity of the processes involved. Under even
less tractable conditions of ignorance, some possibilities themselves
may be unknown. Even experts don’t know what they
don’t know! Here - as with Bovine Spongiform Encephalopathy (BSE), the
ozone hole or hormone-mimicking chemicals -
 we face the prospect of surprise. By definition, risk assessment is
therefore inapplicable under some important and pervasive
characteristics in environmental decision making. To pretend otherwise
is quite simply unscientific.

Then there’s the issue of objectivity. Although often very precisely
formulated, the pronouncements of risk assessment are
highly sensitive to starting assumptions. In areas ranging from energy,
through chemicals to GMOs, results of different risks
assessments can vary radically - with profound implications for which
option comes out looking best. Yet the choice of
which assumptions to adopt is often intrinsically subjective. Nobel
Prizes have been awarded for work that shows there can be
no single ‘rational’ way to combine such subjective perspectives.
Therefore, instead of making apparently definitive assertions
over risk, a truly scientific approach would systematically explore how
the picture changes depending on how it is viewed.

Despite their authoritative status, ‘science-based’ approaches like risk
assessment evidently beg very similar questions to those
raised above over precaution. What does this mean for the relationship
between science and precaution? Much depends on what
we mean by these terms.

The concept of ‘science’ is complex and contested. But a number of key
features are quite fundamental and uncontroversial. In
short, science implies empirical grounding, systematic methods,
transparent argumentation, a culture of skepticism,
independence from special interests, openness to learning, professional
accountability and peer review. Though not
always achieved in practice, these are crucial distinguishing
characteristics of science. Of course, they are also essential
elements in any effective approach to environmental protection.

A ‘precautionary approach’ also displays a series of key
characteristics. It builds on principles that ‘prevention is better than

cure’; that ‘the polluter should pay’; that we should look for ‘no
regrets’ options, that alternatives should be appraised at
the level of production systems taken as a whole and that we should
recognize the intrinsic value of non-human life (a
‘biocentric ethic’). It acknowledges the complexity and variability of
the real world and embodies a certain humility about
scientific knowledge. It implies recognition of the vulnerability of the
natural environment and prioritizes the rights of
those who stand to be affected. It requires scrutiny of all available
alternatives and an examination of justifications and
benefits as well as risks and costs. In short, a precautionary approach
involves the adoption of long-term, holistic and
inclusive perspectives in environmental protection.

What is striking about these key features, is that there is no necessary
tension between science and precaution! Science
provides some essential disciplinary rigor. Precaution is about
‘broadening out’ the regulatory process to include a wider range
of issues, options, criteria, possibilities and perspectives. Indeed,
since broadening out the process allows the validation and
testing of different possible assumptions, precaution has a good claim
to offer a more scientific approach to environmental
protection than does narrow prescriptive risk assessment!

Although not known for his postmodern anxieties over risk, it was
Winston Churchill who said "science should be on tap,
not on top". The precautionary approach recognises this. Those calling
for reliance on ‘sound science’ do not. Ironically, to
miss this essential point is to be thoroughly unscientific about the
limits to science.

References

Dr. Stirling was the co-ordinator of a study on science and precaution
in the management of technological risk conducted with
Andreas Klinke, Ortwin Renn, Arie Rip and Ahti Salo for the Forward
Studies Unit of the European Commission. The report,
which is prominently cited in the recent Commission Communication on
Precaution, can be found at:
http://www.jrc.es/pages/f-ourrole.html (follow ‘reports, ‘search form’
then ‘2000’).

A second report, which exemplifies one way in which science and
precaution may be reconciled in the regulatory appraisal of
agricultural GMO's, is available at:
http://www.sussex.ac.uk/Units/gec/gecko/refs.htm
---
2. Politics, sound science and the precautionary principle [excerpt]
http://www.cid.harvard.edu/cidbiotech/comments/comments92.htm
Professor Philip L. Bereano, mailto:phil@uwtc.washington.edu
Department of Technical Communication
College of Engineering, University of Washington
Seattle, Washington, U.S.A.
and
Washington Biotechnology Action Council
Seattle, Washington, U.S.A.

.... the current dominant paradigm still claims that risk assessment is
a matter for "sound science" rather than
politics or social values; these other messy factors must wait until
after the risk is assessed when they can come into play as
part of "risk management." This bifurcation is historically traceable to
William Ruckelshaus’ second tenure as head of the US
EPA.

Ruckelshaus was brought back into that role as part of the larger
Reaganite agenda to role back the "democratic paradigm" of
public policy and install a "technocratic" one (in the terminology of
David Dickson, a reporter/editor with Science, Nature,
New Scientist). This maneuver has helped the Government deflect popular
environmental and consumer concerns while
calling for endless technical studies. By these means, any constraints
on industry practices have been substantially delayed (and
simultaneously, citizen groups have been discredited as anti-rational
and selfish, while liberal scientists have been alienated
from those movements to which they otherwise might have given pro bono
advice.) "Sound science" thus became a mantra to
obscure the exercise of partisan political power.

Throughout the negotiations over the Biosafety Protocol, the US
delegation always challenged those who promoted the
Precautionary Principle as being emotional and attacking sound science.
Yet, as a recent lengthy paper sponsored by
Consumers International has documented, US law is full of precautionary
provisions. There is no evidence whatsoever that
they have hindered the application of science to assessing various
risks. We need to undo the false distinction Ruckelshaus
originated, and admit that risk assessment itself involves subjective
elements and that management decisions occur from the
very beginning of the policy assessment. When we do, we will see that
the Precautionary Principle is a logical component of
that process, assuring that we fully address issues of the sufficiency
of information and assigning responsibility for carrying it
out.

As the EU environmental ministers made clear in a meeting with NGOs in
Montreal last January, just prior to the final
negotiation of the Biosafety Protocol, they are politicians chosen to
make political (hence subjective) decisions after science
has told us all that it can. Their responsibilities should not be
sloughed off onto unaccountable scientists in the guise that
some mysterious "sound science" itself can tell us the right choices to
make.
---
3. 'Sound science' as ideology
http://www.cid.harvard.edu/cidbiotech/comments/comments91.htm
Les Levidow, Ph.D., mailto:l.levidow@open.ac.uk
Research Fellow
Centre for Technology Strategy
Open University, Milton Keynes, United Kingdom

In the risk debate over genetically modified (GM) crops, Europe's
regulatory delays have often been branded as 'political', i.e.
not based on science. According to some proponents of 'sound science',
precautionary regulation is misguided on several
grounds: that it imposes an unrealistic burden of proof for safety; that
it discriminates against GM crops; and that it ignores
the lower risk of GM products relative to the agrochemical risks of
cultivating their non-GM counterparts. In this view,
precautionary delays are a proxy for 'non-risk' issues, e.g. about trade
policy or intensive agriculture; beneficial products have
been sacrificed to accommodate public protest and irrational fears.

That diagnosis begs some questions: How can sound science be
distinguished from unsound science? When research provides
new evidence of risk (or of uncertainty), does the earlier science
become unsound, retrospectively? Alternatively, is the new
evidence to be discredited as unsound? Moreover, can there be an
apolitical way of basing decisions upon science? To answer
these questions, insect-protected Bt maize provides a case study for
trans-Atlantic comparison.

As a general perspective on this case study: The regulatory role of
science depends upon various socio-political influences.
Risk regulation makes judgments about what 'environment' must be
protected, what uncertainties matter for risk assessment,
what research is needed to clarify them, and what counts as meaningful
evidence. In practice the criteria are framed by
regulatory institutions, official expertise, policy language,
agricultural models and assumptions about a desirable society. For
GM crops, the 'sound science' slogan has tended to restrict and conceal
such political judgments, while 'the precautionary
principle' has tended to open them up.

In early decisions to approve Bt maize, the US and EU procedures framed
the risk issues within an intensive agricultural
model. A 'genetic-pesticide treadmill' was accepted as if Bt were
dispensable, replaceable by chemical pesticides. Non-target
harm was deemed implausible. Superficial laboratory tests were accepted
as evidence of safety.

Public protest led to a change in this initial framing, though with some
trans-Atlantic differences. After US protest campaigns
turned insect resistance into a risk issue, regulators acted upon and
solicited new scientific evidence about insect-resistance
pathways. After GM crops overall became contentious in Europe, its
precautionary approach was reinterpreted; national
regulators there too imposed greater controls for various risks,
including non-target harm.

The protest stimulated more stringent norms of acceptable effects, as
well as further scientific research on cause-effect
uncertainties which were previously neglected. In such ways, the risk
debate stimulated new bodies of knowledge, rather than
simply shift the burden of evidence within existing knowledge. For
example, new research has undermined optimistic
cause-effect models of Bt resistance mechanisms and of available
alternative genes. This new knowledge stimulated and
informed more stringent protocols for Bt Insect Resistance Management.

For potential harm to non-target insects, however, new evidence of risk
has been disparaged as unsound. Such evidence has
been criticized on various grounds -- e.g. 'unrealistic' experimental
conditions or statistical anomalies -- which could apply just
as well to evidence of safety. Yet the latter was favorably cited by
companies and largely accepted by regulators. Thus double
standards have served to protect safety claims. Moreover, some comments
have implied that any plausible harm would be
acceptable, e.g. by favorably comparing Bt maize to harm from
agrochemical usage -- as if the comparison needed no evidence
and involved purely technical issues.

In sum, the slogan 'sound science' tends to conceal value-laden features
of safety claims, their weak scientific basis, their
normative framing and their socio-political influences. In these ways,
'sound science' operates as an ideology, pre-empting
debate on its framing of cause-effect uncertainties. By contrast 'a
precautionary approach' can more readily identify scientific
unknowns, while acknowledging the agricultural-environmental values
which inform risk assessment.

Therefore, a purely 'science-based' regulation can never be achieved.
The choice is not between 'science versus politics', but
rather between ways of linking them.

[Note: This statement is based on a jointly-authored article in the
International Journal of Biotechnology 2(1-3): 257-273.]
 

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