It is time for the European Environment Agency (EEA) to get serious and not let their activist dogma guide their publicly funded “research”. In their second version of Late Lessons from Early Warnings (Chapter 2), the EEA pretended to address the issue of precautionary false positives – where decisions taken for precautionary reasons have led to greater errors and increased loss of life. The first volume of Late Lessons did not address precautionary false positives, saying that they could not find any. After years of jeers, the EEA included a chapter on this subject, addressing 88 case studies levied against the first edition, but deciding to downplay all but four mild or lame cases. Conclusion: we should not worry about false positives when using the precautionary principle. Political whitewash over reality at its best.
But the Risk-Monger does worry. If humans can make mistakes that affect the environment (why environmental activists want human activity controlled and limited), what makes the EEA conclude that humans would not make the same mistakes trying to act according to some contrived precautionary principle. Precautionary actions are essentially fear-based (fear of uncertainty) and I wonder how acting from fear is inherently more rational than relying on the best available science. Simple example: someone afraid of flying will take the precautionary measure of driving across Europe to get to his or her destination. Statistics will confirm that this person’s fear-based decision will increase the risk of dying (and killing others). While the EEA is very quick to lambast humans for not knowing everything, they show an enormous tolerance for the ignorant who make decisions based on bias, fear and irrationality.
So where is the magic in their rhetoric? Rather than addressing false positives clearly, the EEA conjure up different categories to deal with what they referred to as 88 “alleged false positives”. Categories such as: real risks (ie, not false positives), unregulated false alarms (ie, only false positives that have been regulated count in their assessment), risk-risk tradeoffs (one risk versus another – so it does not matter if more people die from such tradeoffs), too narrow of a definition of risk (cases where the feared hazard was unfounded but there still might be other problems) and my favourite, a category called “the jury is still out” (a genuine attempt to ignore scientific evidence in favour of dissenting, mostly anti-industry voices the EEA prefers to agree with). With this clever rhetoric, the EEA wizards were able to make 84 of the 88 alleged false positive case studies disappear. Only four were deemed to truly be false positives (US swine flu, saccharin, food irradiation, and Southern leaf corn blight), but given that the consequences of these situations were so minimal (only a few unintended deaths from swine flu vaccines), there really wasn’t any problem at all and any fear of false positives in precautionary applications were, simply put, “misplaced”.
Much of this is recategorisation is pure nonsense. Unregulated alarms don’t seem to count even though the public fear may linger for decades (for example, enzymes in detergents or fluoridated water). Too narrow a definition of risk ignores the fact that the risk under question was erroneous and does not look seriously at other unrelated risks (for example, nuclear power, second-hand smoke and breast cancer or video display terminals). Those dispelled because the jury is still out fail to consider overwhelming bodies of evidence that indicate false positives (MMR, GMOs, PVC and bloodbags, acrylamide and breast implants). Because these issues are politically charged and activists and anti-industry campaigners have chosen to ignore the scientific consensus, the jury is giving them the benefit of the doubt. What we have here is not a real study but a series of contrived excuses to displace valid concerns on false positives for political reasons – shabby and illegitimate by any academic standard.
The Risk-Monger is offended by this manipulative pooh-poohing of such a serious issue. When false positives occur, the consequences are often catastrophic. A few no-brainers for those who prefer to think rather than let their bias run roughshod on reality.
- During the Great Plague of London (1665-66), authorities took the precautionary measure of killing all the cats (based on a superstitious belief that the cats were spreading the plague). As the rat population exploded, thousands more died from this great precautionary act.
- The banning of DDT on precautionary grounds (on a suspicion proven to be unfounded and unscientific) before malaria was eradicated in Africa has led to a decade’s long infanticide, with an average of 3000 people, mostly children, dying every day (more than a million deaths a year), in part responsible for subjecting Africa into a perpetual poverty trap. Jacqueline McGlade had the audacity to deny that DDT was ever banned (providing a creative interpretation of the Stockholm Convention rather than admitting the reality of this precautionary disaster). Bias has a way of interfering with intellectual accuracy.
- The precautionary promotion of biofuels (regulations and subsidies) to combat global warming has led to a massive destruction of biodiversity, rain forests, water tables, traditional farming practices and indigenous lifestyles in developing countries, increased food prices, food scarcity and famines, and, let us not forget, an overall increase in greenhouse gas emissions.
Of course, one of the rhetorical beauties of precaution is that most false positives never see the light of day. The very sniff of a levied precautionary claim would normally, in advance of any legislation, blacklist a substance, process or technology (eg, brominated flame retardants or bisphenol A), forcing the supply chain to re-align its sourcing or production process rather than to wait for research to give the “guilty until proven innocent” substance or process a clean bill of health. By the time the error of precaution will have been proven, the market will have moved on and it would be in nobody’s interest to go back.
So now that regulators no longer have to fear the risk of precautionary false positives, the conclusion is clear: use the principle more liberally. Don’t worry about being wrong when imposing precaution, for example, on a wide group of pesticides because you hope it will save the bees. A false positive is highly unlikely (despite the overwhelming evidence that CCD is actually caused by something else: the Varroa mite virus) and no one will ever trace the ensuing food security crises and famines back to your decision. Sadly such politically contrived reassurances that the EEA provides in this chapter are irresponsible.
But one must ask the EEA why such a large number, 84 out of 88 alleged false positives, were false alarms. Well, that seems obvious (time to bring out the paranoid conspiracy theorists):
The scarcity of genuine false positives compared to the large number of ‘mistaken false positives’ could partly be the result of a deliberate strategy in risk communication. … Manufacturing doubt, disregarding scientific evidence of risks and claiming over‑regulation appear to be a deliberate strategy for some industry groups and think tanks to undermine precautionary decision‑making. (LLII pg 65-66)
So all of these claims of false positives that the EEA has managed to cleverly pooh-pooh are the results of evil industry attempting to undermine the benign work of the precautionary missionaries. Risk communicators like me are to blame! We have grown accustomed to this type of myopic vitriol against industry from paranoid groups like Corporate Europe Observatory or Friends of the Earth, but to see such subjective, anecdotal bias allowed to be published in an official EU document is absolutely disgraceful, and enough justification to demand the immediate sacking of David Gee and Jacqueline McGlade.
My next blog on Late Lessons II will examine David Gee’s new and enhanced definition of precaution. In the meantime, if you are in Brussels on March 21st, you are welcome to watch the Risk-Monger discuss the value of precaution at the DODS European Public Affairs Action Day 2013 conference.