The Risk-Monger

In my last blog, I briefly outlined seven reasons why the EU’s dependence on the precautionary principle (EEA interpretation) as its main environmental-health policy tool was destructive (to the public trust in science, to the environment, to public health and to a sustainable supply chain). Although a natural impulse, precaution uses a non-scientific logic that allows it to be manipulated by environmental activists and policy-makers. It should be relegated as a policy tool and certain EU directives and regulations should be revised and clarified before the damage becomes irreversible.

Revised to what? You cannot just remove a major policy tool without considerations for how people act or respond to situations. Fortunately there is an alternative to precaution that we also have been using, but the tendency is less reactive, more rational (and it does not lead to catastrophic consequences).

Look back a little more than a decade ago when we started using mobile phones. Those first clunker handsets were radiation transmission devices and the base stations hummed and almost glowed. They were terribly unhealthy phones that even the UK’s Stewart Commission could not absolutely reassure us on. But the benefits of mobile access were enormous and like other unhealthy habits, we were addicted – the public judgement was that the benefits outweighed the risks. We did not use the precautionary principle then, and still do not now – giving up the use of mobile phones and reorganising societal structures to go back to the use of land lines and cables was not in the cards. Rather, the mobile phone health risks were managed. Policy-makers worked with researchers and industry to ensure that mobile technology developed in a manner that reduced exposures and health risks to individuals. How low should the exposures be reduced to? The answer is obvious: as low as reasonably achievable.

ALARA stands for As Low As Reasonably Achievable. It is not a new concept, it is how researchers and responsible businesses think and act. Any research engagement first discovers, then develops and then refines. Any human aspiration is to make things better, and where there are risks, it is natural to want to reduce exposure to them. Unlike precaution, which is black or white (prove to me that mobile phones are safe, then you can sell them), ALARA promotes a continuous process of improvement. The discussion is not over whether something is safe or not, but rather, given the risks, costs and benefits, what is reasonably achievable. Reason enters into the dialogue: is this the best product, substance or process to achieve this benefit; if so, how can we reduce the risks further or refine the process? Can you meet that target? In what timeframe? This is what happened with the mobile phone industry and they were very successful (although the EEA’s David Gee threatened the industry at a Commission EMF conference in 2009 that their mandate could be revoked).

ALARA is a risk management tool (unlike precaution which has become an uncertainty management tool – see previous blog) which concentrates on improving safety while ensuring continued benefits for society. It fits well in fields where the benefits are significant. Take the example of vaccines. Vaccination leads to a substantial number of deaths every year, but the alternative, no vaccines, would be even worse. We do not use the precautionary principle here (except for some in the UK who chose not to vaccinate their children for MMR, leading to a localised measles outbreak). Policy-makers work with pharmaceutical companies and research organisations to ensure that the number of deaths or negative reactions are kept as low as reasonably achievable. Determining what is reasonable depends on the nature of the risk (flu pandemic, measles or less serious risks like chicken pox). Should we vaccinate for foot and mouth or cull the herds? This is not a black or white, prove to me that is safe discussion but a dialogue about moving forward in reasonable manner. ALARA as a policy tool encourages communication, cooperation, engagement and trust.

The nuclear industry is the only instance today where ALARA is articulated as a policy tool. If you Google ALARA, that is what you would find. This does not mean, as is often assumed, that ALARA is a tool for the nuclear industry only. Risk management as a field grew out of the nuclear industry in the 1960s, but RM is not a tool for that industry only. We use ALARA intuitively but do not articulate it at the policy level (I have heard people argue superficially that ALARA is simply a form of precaution). The chemical industry, without stating it, practices ALARA in its concepts of Responsible Care® and Product Stewardship (in promoting continuous improvement and supply chain responsiveness). Voluntary initiatives like Vinyl 2010 for PVC or VECAP for deca brominated flame retardants are examples of industry efforts to reduce exposures as low as reasonably achievable which encouraged dialogue and cooperation with regulators. These initiatives showed far better success than any regulations or precautionary measures would have achieved. The chemical industry needs to articulate ALARA since it is in line with the scientific logic they use (rather than the precautionary logic).

What is happening with the pesticide industry is tragic. They had long applied ALARA in their risk management process through continuous reductions and monitoring of maximum residue levels (MRLs) and Safe-Use campaigns to ensure worker safety when applying pesticides. They had been so successful in providing plant protection while reducing MRLs to the point that an entire year’s MRL exposure contained fewer health risks than that contained in a single cup of coffee (Google: Bruce Ames + coffee + pesticides or see my Moral Residue Levels blog). This, to me, as a caffeine addict, is a reasonable level of risk to achieve and most rational people would find such MRL levels acceptable. DG Sanco does not appear to be so rational. The Pesticide Directive is proposing to apply the precautionary principle instead of ALARA. No pesticides will be allowed if science cannot prove that they are free from endocrine disrupting properties. This will be very hard to prove with certainty and we can expect a significant number of plant protection products will fail the precautionary burden and be removed from market with no safer alternative available. EU farm production will be reduced and global food security largely affected. If ALARA were articulated in the Pesticides Directive, then endocrine disrupting properties would be considered by evaluating the means for reducing exposure levels (as MRLs continuously do) and comparisons to exposures to other endocrine disruptors in the environment would be made. If it is found that two soy beans contain more endocrine disrupting properties than a year of MRL exposure to pesticides, then it should not be too difficult to determine what is reasonably achievable and much of the nonsense of the last few years would have stopped.

Sanco’s behaviour though is less scientific and more in line with an angry mob of activists that is treating the plant protection industry like some big tobacco-like scourge of the earth. This is not good science, not good policy, not good for food security nor public health. This is wrong and evidence of how precaution can be a dangerous policy tool.

Environmental NGOs do not like ALARA since it removes the clear-cut wins that they need to reinforce their idealism. How many activist lobbyists could go back to their constituents and say: Well, they did not ban chlorine, but they are reducing the exposure risks to a reasonable level? Won’t happen. Their campaigns are designed for winning (check out Chris Rose’s Campaign Strategy newsletters), not about making progress in improving public health while maintaining benefits. Keeping NGOs engaged in the process when their precautionary logic does not fit the needs of society is not good policy. ALARA needs to be the primary policy and dialogue tool for risk management.

The European Commission needs to articulate ALARA as the point of policy initiation. When risks are identified, researchers and industry need to be engaged to determine how to reduce risks or refine processes. A certain adaptation stage needs to be delineated (timelines, exposure reduction targets, measurables, alternatives …) before anyone considers “invoking” the precautionary principle. Precaution should be a point of last resort (when benefits must be sacrificed) rather than a point of first instance. This will ensure a better relationship of trust and cooperation between the public and science, with the benefits of research held in esteem and future research objectives values and promoted (not threatened or shunned).

Articulating ALARA as an alternative policy tool to precaution is part of a research project I have recently initiated. The blog structure is too limited to do an intensive analysis but I hope in the next year that people in the European Commission will participate in this assessment. Ultimately, the European Commission (RTD or the JRC) should prepare a Communication on ALARA. The first opportunity is tomorrow (10 February) when I will be giving a talk at a Science Policy Breakfast in the European Parliament entitled Trust in Science and the Precautionary Principle. I am looking forward to continuing the discussion then.

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  1. I think when people are starving and dying from hunger and mediaeval diseases here and now within the latest borders of EU we should face with it and rearrange priorities!

  2. Well, they did not ban chlorine, but they are reducing the exposure risks to a reasonable level?
    This does not take into account that some chemicals, even at very low levels, are highly toxic. Also, it does not address the issue of bio-accumulative chemicals, such as dioxins, PCB, Furans, which irrespective of very low “reasonable’doses build up in the fat tissue of humans and other animals. A “reasonable level” is not scientific and is based on assumption and lack of data. See the work of Dr Sam Epstein

  3. I think the discussion centres around the word “reasonable” John. During my talk in the European Parliament yesterday, nobody tried to argue that the precautionary principle was reasonable – it is very emotive. It is not incorrect to argue that a reasonable person avoids cancer risks, but not all risks are the same. Risks first need to be put into context. Reasonable here refers to relational decision vectors (I suspect you are using the term for estimating exposure levels – another subject that the nano-tech world is struggling with). It is reasonable to say that an infant’s exposure to a low dose of lead (any level) is unacceptable. This does not then imply, as many who scream “Precaution!” in Brussels do, that any low dose, to any chemical (synthetic chemicals since they never look at toxicity of natural chemicals) will be a risk (because we just don’t know!!!). Reasonable means that we must look at the dose, the exposure, the toxicity and, yes, the benefits (in relation also to alternatives), and from that, make a reasonable decision on what action to take. The IPCS was reasonable in its work on side-effects of disinfectants when it concluded that although there were some side-effects to chlorine, the benefits were far more important (billions of lives saved). It is not unreasonable for researchers to continue to reduce exposures to chlorine decades after the UN body passed judgement – that is what science does – ALARA. Telling scientists that they have to prove chlorine safe and free from side effects (any, including those from low doses that may build up in our fat tissues over decades in possible combination with millions of other chemicals that might, in a small percentile expose them to dioxins that have the toxic equivalent of one cigarette over fifty years), and only then can you use it to disinfect and save lives would, in my opinion, not be reasonable, not to the researchers and not the the billions who are alive today because of that nasty chemical.

  4. Thanks for your reply. Would it be fair to say that ALARA is really a Cost Benefit Analysis tool, acknowldeging that in the real world exposure to synthetic chemicals is a given? I don’t know if you are familiar with the work of Dr Samuel Epstein?

  5. ALARA is more than a decision tool – it is a risk management process where policy-makers engage with science and industry when risks need addressing. It is meant to be a trust-building activity when it works well (eg, the mobile phone industry’s reduction of exposures to risks in phone masts and EMFs). When it doesn’t work well (eg, when the EU auto industry promised to reduce CO2/emissions and then actually increased it), at that point, the trust is broken and policy-makers have every right to use precautionary measures to slap regulations on them. Precaution enters when trust is lost (if you don’t trust your footing on an icy stairway, you reach for the handrail) – there should be some form of engagement and trust-building first and not to enter with precaution from the beginning. The Commission though needs to better articulate the process (eg, when to use ALARA, what is reasonably achievable and how long before we then invoke precaution).
    Of course we are exposed to chemicals with every breath we take and every bite we consume (chemicals are not man-made, rather, man is made of chemicals). Many natural chemicals are very nasty, and the main reason why we produce chemicals like chlorine.
    The risk world has its silos – I tend to swim in the SRA sociologist or SSTS ponds – so I have unfortunately never had the opportunity to meet Dr Epstein. I can see the angle that he is coming from, and I don’t disagree with his approach to reduce risk exposures in general (nobody wants to take unnecessary risks). How that translates into policy is another question.

  6. funny enough or possibly, ALARA was applied to market the low energy bulbs, the gas contained in them is poisonous as it contains 5mg of vapour mercury. In fact if they break you should open the window to aireate the room. But then wasn’t mercury banned from all the home appliances like the thermometer? One of the problems I see is that sometimes ALARA is used and other times the precautionary principle, I don’t even want to hint at what makes the policy makers go for one or the other, but I suggest the polite word Lobbying.

    1. All policy-making results from lobbying (whether it is industry, NGO, Member State or internal in governments) – we should not be alarmist about it. Those with their act in gear can lobby proactively for ALARA. What I always find interesting is how bad industry actually is at lobbying – they are often reacting to influence campaigns and are easily wrong-footed mostly because of the time needed to build consensus within trade associations (I should do a blog on some of my experiences there). They end up paying through the nose for public affairs firms to try to undo the problems industry actors got themselves into, usually too late and usually too crass. Patrick, your point got me thinking. A good part of industry was lobbying against low energy bulbs (against subsidies and export controls as they feared that the Chinese would put them out of business). WWF led the charge in favour of these toxic timebombs despite the pleading from HEAL re their mercury campaign. So I wonder: if industry could get their act together, and not just spend their lobbying budget reacting to precautionary charges, could they too put forward ALARA lobbying campaigns that stress benefits that we cannot afford to lose?

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