Last year, I was invited by PlasticsEurope to speak at their conference on ‘Safety of plastics: Let’s talk about it!’. Ahead of this meeting, they asked speakers to answer a number of questions on the precautionary principle and innovation (http://plasticseurope.blogspot.co.uk/). Given current concerns that the proposed new structure of the European Commission is relegating the environment to a market-role, the perceived conflict between taking precautionary action to protect human health and the environment and innovation and competitiveness is more topical than ever. Here were my answers. What would you have replied?
Science, Politics and Industry
1. What should be the role of science in policy making?
It seems obvious that science should inform policy. I would struggle to find arguments against evidence-based policy. However, claiming that the interpretation of scientific evidence is always totally objective and devoid of any value-based judgements is probably naive. This rings particularly true where scientific evidence resulting from separate lines of inquiry has to be synthesised, where the weight accorded to different types of evidence can be related to a set of commonly held beliefs. The role of experts involved in such ‘weight-of-evidence’ analysis is then to try to clearly identify those beliefs to help policy makers form informed opinions.
2. What do you expect from policy makers?
The challenging task of policy maker is to remain critical and independent whilst not being scientific experts themselves. Their role is to translate science into policies that are fair, just and representative of the values of society at large.
3. Can you define robust science vs non-conclusive science?
I think that robust science can be inconclusive. I do not see both terms as mutually exclusive. In my view, the robustness of the science refers to the rigour of the methods used rather than its results. Robust science may not always lead to robust conclusions. In particular, some of the environmental challenges we face cannot be definitively tested experimentally. We do not have a spare earth to test experimentally what the effects of different courses of action may be in terms of climate change. Nor do we test the toxic effects of chemicals on humans. We have to rely on models, whether computer models, animals or otherwise and extrapolate. A set of assumptions will necessarily be involved in such extrapolations and the difficulty is to transparently identify those.
4. Is industry funded research to be trusted?
There are well-documented precedents with the tobacco and pharmaceutical industry, where it was found that the publication of studies that would have a negative impact on the financial interests of the sponsor of the research was suppressed. There is therefore an argument for greater transparency and the publication of scientific research publicly or privately funded. In the latter case, I recognise that this would also require mechanisms to protect intellectual property. Further, although any scientist would strive to be objective, there are also much more subtle biases that can influence the interpretation of scientific results. This would apply equally to any scientist regardless of the source of funding. Scientists are human beings, they are social beings within a community and influenced by the collective values or norms of their peers etc… (there is actually a branch of humanities dedicated to the social studies of science). Therefore a dose of healthy self-criticism is essential for any scientist.
5. How to avoid conflicts of interests hampering the credibility of independent agencies?
Transparency is key, about sources of funding, selection or appointment processes. It may be particularly useful to ensure that different perspectives are represented, whether it be in terms of scientific discipline, but also in terms of age, gender, ethnic or cultural background…
The divergence approaches to risk regulation between the EU and US
6. Does culture affect how we approach legislation? Can you give examples?
Culture will have an influence on how legislation or the regulation of risks is approached. This would be true even between different European countries as well as between the EU and the US. There is generally some history behind a regulatory system. An example of a striking difference between the EU and US would be that of firearms restriction. In the realm of the safety of chemicals, the EU and the US generally watch what is happening on the other side of the pond. In the US, government-funded science carried out in the USEPA or NIEHS is often leading, whereas the EU has taken a lead in terms of translating the science into regulation.
How to deal with unintended consequences of precautionism?
7. When should the precautionary principle be applied?
If one refers to the definition of the precautionary principle, it states that “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”. There are therefore two conditions to invoke the precautionary principle, the threat of serious or irreversible damage and lack of full scientific certainty. I was recently reminded of the classical distinction between risk and uncertainty. Risk is generally measurable and quantifiable and therefore does not preclude a rational choice, whereas uncertainty is qualitative, we are unable to assign probabilities to outcomes and the rules of rational choice theory are not applicable. In that context, it is the role of policy makers to decide what regulatory action is proportional and justified by the current state of scientific evidence.
8. How can the precautionary principle enhance innovation?
The UNEP ‘Global Chemical Outlook – towards sound management of chemicals’ report is quite enlightening in that respect. It presents evidence that strengthening of environmental regulations does in fact stimulate innovation. The example that is given is the boom in green technology as a result from international efforts on climate change.
In terms of mechanism, access to capital is necessary for innovation. In the chemical sector, as the number of investors who consider Environmental, Social, Governance risks grows, this should in turn give a competitive advantage to the ‘pro-active innovators’, those who focus on R&D and green chemistry, over the ‘regulation resisters’, those who focus on lobbying instead.
Is innovation possible in risk averse society?
9. Is Europe risk averse?
Whose risk are we considering? For consumers, risk perception is most often driven by the media. I see no evidence that European consumers are more averse to risk than their counterparts in other developed countries.
I feel it is important to distinguish internal versus external risks, i.e. the business or financial risk that a company may take versus the risks its activities may have on the general population. It is important that the latter is internalised rather than civil society taking the brunt of that risk, regardless of whether the mechanisms to internalise such risks are financial as discussed above or political through regulation.
10. Do we need to take risk to be innovative?
For high impact innovation, or disruptive innovation, we need to take big risks, yes. However much can be achieved through incremental innovation, where we innovate to optimise existing processes or products. All innovation requires to take some internal risk, generally in the form of a financial investment or other business risk. Sustainable innovation also considers external risks, such as potential environmental damage or human health effects, but aims to minimise those.
Health and Safety for Competitiveness
11. What would be your message to policy makers when it comes to the precautionary principle?
The ‘Late lessons from early warning’ reports are useful in terms of offering examples where it would have been beneficial to apply the precautionary principle as well as examples of regulatory actions proportional to the state of scientific evidence.
12. Can innovation (therefore, competitiveness) be possible with the application of the precautionary principle?
The precautionary principle can drive and guide innovation and therefore competitiveness.
13. In an ideal world, the scientific community, policy makers and industry should work together in order to guarantee the safety and health of all consumers, or should have be a healthy distrust between them to secure the health and safety of consumers?
A stakeholder missing from this scenario is NGOs to represent the concerns of the consumers. There is a need for dialogue between all these stakeholders, but according a blind trust to industry would be a situation begging for abuse, at least by some.