‘SOUND SCIENCE’  AS  IDEOLOGY  VS  PRECAUTION

Three 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 manoeuvre 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...

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

.... 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 manoeuvre 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.

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.]