August 16, 2010
This is the third part in a summer series that looks at real risks that we should be afraid of.
After old people and poverty, the third biggest real risk to humans is policy-makers. If the road to hell is paved with good intentions, then public policy-makers work for the road construction company. In the risk world, it is known as the “risk-risk paradigm”, a phrase coined by John Graham to refer to situations where we try to avoid one risk but bring on other, potentially greater risks as a consequence. For example, if someone is afraid of flying and the risks of dying in an airplane crash, he or she may elect to drive to their destination (although there is a far greater risk of death from driving than flying).
The poison that makes this cocktail so deadly to humans is that EU policy-makers are trapped in an irrational decision-making process called “stakeholder dialogue” which puts more value in the perceived representational strength of interest groups than the logic of their arguments (this is part of what I had once referred to as the end of the knowledge-based society and the danger of the influence-based society). Evidence, scientific facts and emerging research don’t matter in our influence-based society, so policy-makers committed to engaging with constituents and their concerns, rather than common sense, have become quite prone to risk-risk mistakes. Some examples:
Human destruction in the attempt to save the planet. For years, environmental NGOs have been calling for alternative energy sources like wind, solar and biofuels. As there were other stakeholders interested in biofuels (farmers, the chemical industry, refiners), policy-makers did not have to think about this one – just listen to the stakeholders and react by throwing money, subsidies, incentives and fuel-mix requirements at the public. Everyone felt good about themselves until people started dying in developing countries from food riots, the UN WFP had a funding crisis due to the increased costs of food aid, and global food stocks were reaching dangerously low levels. Never mind the facts that producing many biofuel feedstocks emitted more CO2 than oil, used up enormous amounts of water and resulted in an increase of forest destruction and the devastation of indigenous populations in Africa and Asia – once again, facts don’t matter in the stakeholder dialogue decision-making process. The land-grab is still going on, with many Chinese companies now taking over large tracks of land in Africa – we sit by and observe as subsistence farmers across Africa soon will be pushed off the land they have used to feed their families as second-generation biofuels are planned to be produced at an industrial level. Environmental NGOs, now campaigning against biofuels, are outraged that policy-makers would have been so stupid as to have listened to them.
Human destruction in an attempt to save our health. The revision of the Pesticide Directive 91/414 showed the EU (DG Sanco) at its most evidence-shy, selective stakeholder-engaging best. Faced with claims from farmers and Member States of impending doom to EU food production levels (and worse scenarios of how it would affect African farmers hoping to export to Europe) should the controls in the Pesticide Directive go forward, the EU still resisted calls to commission an impact assessment. In other words, Sanco put forward policies knowing full well that they had no sound evidence basis. An impact assessment would have produced facts that could have interfered with a nice, clear stakeholder consensus that was forming between NGOs, food groups and a few farmers (who had no care for the threat of food shortages caused by implementing such restrictions). There was also no time for an impact assessment since any delays in pushing the directive through would have coincided with the increasing death toll from food shortages and rioting in developing countries (brought on from our biofuel policy).
If one wonders about the potential human destruction from policy-makers who decide things on public pressure rather than science or facts, look at the mother of all risk-risk paradigms: the global ban on DDT. More than four decades ago, DDT was banned because of the potential risk it posed to egg shells and an impassioned populist plea from Rachel Carson. The hypotheses behind this policy decision proved to be mistaken and tragically we have lost the benefits of DDT in eradicating malaria. Today, as four decades ago, Rachel’s Curse continues and we lose three thousand lives a day (mostly children, and mostly in Africa) to malaria. No alternatives have been found, no apologies made and policy-makers continue to wonder when this terrible thing will go away.
So what should policy-makers do? Because such terrible things can happen from their decisions, the precautionary principle has become the tool of choice in the EU. They use the David Gee version – what I call PPP – the political precautionary principle – which is totally fact-free and evidence shy (it is based on the principle that anything NGO activists say should be followed; anything industry says should be mistrusted; and we know that science can never fully satisfy our demand for safety). PPP is responsible for DDT and biofuels, so one wonders why policy-makers continue to use such a dangerous tool. Simply put, PPP is a policy tool designed for stakeholder dialogue conflicts, where the loudest voices are not necessarily the most rational. Without the courage to stand up to activists running often personal campaigns, or try to defend facts in front of frightened populations, policy-makers prefer to pull back and claim precaution. But, however innocent and blameless, precaution costs lives.
So how can we keep policy-makers locked in a deadly decision-making process from killing so many innocent people? A few years back, I had the privilege to be involved in a working paper for the EPC Risk Forum – entitled “Enhancing the role of science in the decision-making process of the European Union” (Bruce Ballantine, 2005). The European Commission is starting to implement some of its recommendations but there is still a lot to be done. One of the recommendations of the EPC paper is to provide a means to enforce that proper scientific evidence is used in EU decision-making. Sounds logical until you put it within the stakeholder dialogue context. If such a means were implemented, it would go far in protecting humanity from the real risks posed by policy-makers.David Zaruk