Safety of Plastics: Let's talk about it
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| Axel Singhofen |
Science, Politics and Industry
1. What should be the role of science in policy making?
The role of science should be to inform policy making. It should be objective, transparent about any interests and clearly state its limits and uncertainties. Good science looks at short-term and long-term effects and gives full weight to qualitative aspects (instead of looking primarily at short term quantifiable effects such as business costs). And very importantly, scientists that want to remain credible should not venture into lobby campaigns to try to influence imminent decisions. The recent unprecedented joint editorial attack of the European Commission's work on determining criteria for endocrine disrupters by Dietrich et al. is a perfect example for both bad science and disrespect for the role of scientists in policy making (rebuttal by Bergman et al.). Scientists are most welcome to make their views and concerns heard, and to make recommendations, as they did for example with the 2013 Berlaymont Declaration on Endocrine Disrupters. However, they should not try to be the better politicians, especially not if they did not even declare their interests, as Grandjean and Ozonoff remind us.
2. What do you expect from policy makers?
I expect from policy makers to inform themselves about the problem at hand as comprehensively as possible, and that they listen to all sides, carefully assessing the specific interests (public, private) at hand, consider the costs to society of inaction - and then take their decision. I expect them to act for the good of society as a whole and not wrongly equate the narrow economic interests of a few with those of society at large. Finally, they should not hide behind uncertainties. Life is highly complex and thus inherently fraught with uncertainties. Policy makers need to have the courage to take decisions in light of these uncertainties according to their best knowledge, and not make believe that science can sooner or later provide the definitive answer.
3. Can you define robust science vs. non-conclusive science?
This question creates a false dichotomy. Robust science does not necessarily mean conclusive science, and science is not conclusive only when it has established full scientific proof of cause and effect. Good laboratory practice certainly does not make any study robust as such. For me, robust science is published science that is peer-reviewed, that relies on generally accepted principles of science and respects its limits.
The role of science should be to inform policy making. It should be objective, transparent about any interests and clearly state its limits and uncertainties. Good science looks at short-term and long-term effects and gives full weight to qualitative aspects (instead of looking primarily at short term quantifiable effects such as business costs). And very importantly, scientists that want to remain credible should not venture into lobby campaigns to try to influence imminent decisions. The recent unprecedented joint editorial attack of the European Commission's work on determining criteria for endocrine disrupters by Dietrich et al. is a perfect example for both bad science and disrespect for the role of scientists in policy making (rebuttal by Bergman et al.). Scientists are most welcome to make their views and concerns heard, and to make recommendations, as they did for example with the 2013 Berlaymont Declaration on Endocrine Disrupters. However, they should not try to be the better politicians, especially not if they did not even declare their interests, as Grandjean and Ozonoff remind us.
2. What do you expect from policy makers?
I expect from policy makers to inform themselves about the problem at hand as comprehensively as possible, and that they listen to all sides, carefully assessing the specific interests (public, private) at hand, consider the costs to society of inaction - and then take their decision. I expect them to act for the good of society as a whole and not wrongly equate the narrow economic interests of a few with those of society at large. Finally, they should not hide behind uncertainties. Life is highly complex and thus inherently fraught with uncertainties. Policy makers need to have the courage to take decisions in light of these uncertainties according to their best knowledge, and not make believe that science can sooner or later provide the definitive answer.
3. Can you define robust science vs. non-conclusive science?
This question creates a false dichotomy. Robust science does not necessarily mean conclusive science, and science is not conclusive only when it has established full scientific proof of cause and effect. Good laboratory practice certainly does not make any study robust as such. For me, robust science is published science that is peer-reviewed, that relies on generally accepted principles of science and respects its limits.
When it comes to non-conclusive science, this
is not to be mixed with controversial findings. Non-conclusive science often
results when people try to quantify issues that are hard or impossible to
quantify. That is bad - but even worse is when certain interests try to
undermine robust science by trying to render it non-conclusive - see e.g. Merchants of Doubt.
4. Is industry funded research to be trusted?
I wished it could - but there are too many examples of industry funded research being biased towards the interest of the funder (e.g. Arthur D. Little study on REACH, Industry-funded BPA studies, studies by drug and medical device companies). This does not mean that industry studies disqualify as such, but "Industry funding or other conflict of interest may raise the risk of bias in design, analysis, and reporting. Reviewers suspecting high risk of bias because of industry funding should pay attention to the risk of selective outcome reporting" (Viswanathan et al. 2012).
4. Is industry funded research to be trusted?
I wished it could - but there are too many examples of industry funded research being biased towards the interest of the funder (e.g. Arthur D. Little study on REACH, Industry-funded BPA studies, studies by drug and medical device companies). This does not mean that industry studies disqualify as such, but "Industry funding or other conflict of interest may raise the risk of bias in design, analysis, and reporting. Reviewers suspecting high risk of bias because of industry funding should pay attention to the risk of selective outcome reporting" (Viswanathan et al. 2012).
5. How to avoid conflicts of interests hampering
the credibility of independent agencies?
By clearly following the recommendations set out by the Court of Auditors in its special report of 2012 Management of conflict of interest in selected EU Agencies (inter alia assessing ECHA and EFSA). By not putting experts with clear links to industry into committees or working groups that are meant to provide independent advice.
By clearly following the recommendations set out by the Court of Auditors in its special report of 2012 Management of conflict of interest in selected EU Agencies (inter alia assessing ECHA and EFSA). By not putting experts with clear links to industry into committees or working groups that are meant to provide independent advice.
The divergence approaches to risk regulation between the EU and US
6. Does culture affect how we approach legislation? Can you give examples?
Of course it does. In the EU, a majority of citizens still expects the government to actually govern and to take action for the good of society. When the failure of chemicals legislation to adequately protect public health and the environment against harmful chemicals became obvious in the late 90's, the EU set out for a complete overhaul of EU chemical legislation, which resulted in the adoption of REACH in 2006. In the U.S., the possibilities of the Federal Government to take action are hindered by a deep division in society, partisan ideologies - just think of the current "government shutdown" - and a strong belief in individualism and free market. These at least partially explain why the U.S. is still in the last millenium when it comes to chemical control with its completely inadequate Toxic Substances Control Act of 1976.
How to deal with
unintended consequences of precautionism?
7. When should the precautionary principle be
applied?
The European Environment Agency has adopted a good working definition of the precautionary principle: "The precautionary principle provides justification for public policy actions in situations of scientific complexity, uncertainty and ignorance, where there may be a need to avoid, or reduce, potentially serious or irreversible threats to health and the environment, using an appropriate strength of scientific evidence, and taking into account the pros and cons of action and inaction".
The European Environment Agency has adopted a good working definition of the precautionary principle: "The precautionary principle provides justification for public policy actions in situations of scientific complexity, uncertainty and ignorance, where there may be a need to avoid, or reduce, potentially serious or irreversible threats to health and the environment, using an appropriate strength of scientific evidence, and taking into account the pros and cons of action and inaction".
The difficult question is what level of
evidence is required before taking action. This cannot be answered in abstract
- as it depends to a large extent of the nature of the risks in question, and
what can actually be found out in a reasonable time.
One does not need to refer to the
precautionary principle to restrict PVC - more than enough is known about its
hazardous additives, its notoriously poor recyclability and the manifold
problems it causes in incinerators and landfills.
When it comes to halogenated flame
retardants, there are still many unknowns - but what we know about them today
is of appropriate strength for me to substitute them - as is already being done
by at least some of the big players in the electronics industry. The same
applies to Bisphenol A: enough is known to justify ending its use in all food
contact materials - not just in baby bottles.
8. How can the precautionary principle enhance
innovation?
Innovation is only beneficial if the resulting benefits clearly outweigh the corresponding harms - for society as a whole, not just for certain players. The precautionary principle teaches us to respect the limits of science, and to err on the side of protection of health and the environment in case of doubt. If it were properly considered by those who take decisions about innovation (rather than ignored or even dismissed), it could be a major tool to steer innovation in the direction of sustainable development.
Innovation is only beneficial if the resulting benefits clearly outweigh the corresponding harms - for society as a whole, not just for certain players. The precautionary principle teaches us to respect the limits of science, and to err on the side of protection of health and the environment in case of doubt. If it were properly considered by those who take decisions about innovation (rather than ignored or even dismissed), it could be a major tool to steer innovation in the direction of sustainable development.
Is innovation
possible in risk averse society?
9. Is Europe risk averse?
The suggestion that Europe might be risk averse is one of the classics in the rhetorical toolbox of the chemical industry. There is no point in taking risks that are not likely to be outweighed by corresponding benefits. There are zero benefits for society from GMO plants. There are zero benefits for children from phthalates in toys. The benefits of halogenated flame retardants are clearly outweighed by their risks. The real question is whether Europe is courageous enough to tackle relevant risks in time before they have caused significant or even irreversible harm.
10. Do we need to take risk to be innovative?
Every innovation is a risk, but not every innovation is worth taking a risk. The question should rather be: Do we need innovations that take a risk with human health and the environment? Or should industry not rather innovate to deliver true benefits for society and replace current risks?
The suggestion that Europe might be risk averse is one of the classics in the rhetorical toolbox of the chemical industry. There is no point in taking risks that are not likely to be outweighed by corresponding benefits. There are zero benefits for society from GMO plants. There are zero benefits for children from phthalates in toys. The benefits of halogenated flame retardants are clearly outweighed by their risks. The real question is whether Europe is courageous enough to tackle relevant risks in time before they have caused significant or even irreversible harm.
10. Do we need to take risk to be innovative?
Every innovation is a risk, but not every innovation is worth taking a risk. The question should rather be: Do we need innovations that take a risk with human health and the environment? Or should industry not rather innovate to deliver true benefits for society and replace current risks?
Health and Safety for
Competitiveness
11. What would be your message to policy makers when
it comes to the precautionary principle?
Read the reports from the European Environment Agency "Late Lessons from Early Warnings, Volume I (2001) and Volume II (2013) - or at least the summaries - and learn the lesson!
Read the reports from the European Environment Agency "Late Lessons from Early Warnings, Volume I (2001) and Volume II (2013) - or at least the summaries - and learn the lesson!
12. Can innovation (therefore, competitiveness) be
possible with the application of the precautionary principle?
Innovation is not a value in itself. Competitiveness is not a value in itself. Both are only - and should only be - means to an end. But what should be the end that they should serve? To my mind, there is only one answer: sustainable development. Competitiveness is possible without the precautionary principle, innovation is possible without it, but surely not desirable, as it will not lead to sustainable development, rather the contrary.
Innovation is not a value in itself. Competitiveness is not a value in itself. Both are only - and should only be - means to an end. But what should be the end that they should serve? To my mind, there is only one answer: sustainable development. Competitiveness is possible without the precautionary principle, innovation is possible without it, but surely not desirable, as it will not lead to sustainable development, rather the contrary.
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?
In your ideal world of cooperation, you are missing a key interest: that of civil society. Partial cooperation that excludes vital interests will not lead to the protection of these vital interests. As long as industry continues to follow a blind pro-innovation pro-competitiveness stance that seeks to disregard or even discredit the precautionary principle and to instrumentalize inherent uncertainties in science to stop protective action, it fuels the very distrust that it would like to get.
In your ideal world of cooperation, you are missing a key interest: that of civil society. Partial cooperation that excludes vital interests will not lead to the protection of these vital interests. As long as industry continues to follow a blind pro-innovation pro-competitiveness stance that seeks to disregard or even discredit the precautionary principle and to instrumentalize inherent uncertainties in science to stop protective action, it fuels the very distrust that it would like to get.
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