COMMENT BY: GAIL CHARNLEY, Ph.D., HealthRisk Strategies
SUBJECT: Precautionary Principle and Fear Threaten Risk Analysis, Public Policy
DATE: August 30, 1999

Charles J. Fromm
Executive Director
Center for Regulatory Effectiveness
11 Dupont Circle NW #700
Washington, DC 20036

Dear Mr. Fromm:

The lead story of the May 27, 1999 edition of Rachel's Environment & Health Weekly was titled The Waning Days of Risk Assessment. This came as a surprising revelation to me as a risk assessor and practitioner of a field that has, after all, officially been applied to public health and environmental decision-making only since the 1980s. But according to Rachel, "20 years of actual practice have badly tarnished the ideal of risk assessment and have sullied the reputation of many a risk assessor." Funny, I don't feel sullied!

Rachel's would have us believe that "dangerous discharges have increased geometrically [sic] during the period when risk assessment has been the dominant mode of decision-making"-a factually incorrect statement in the U.S. and western Europe if ever there was one-and that "It is now obvious to most people that risk assessment is a key part of the problem, not an important part of any solution." Obvious to whom? Part of what problem? We are healthier and live longer than at any time in history. Our communities, businesses, and regulators have worked hard over the past 25 years to achieve air, water, food, and workplaces that are cleaner than ever before, and risk assessment helped us do so. Where is the problem? The public health community tells us that many of our remaining environmental health problems are a consequence of motor vehicle use, poor diet, and smoking. How is that a condemnation of risk analysis?

The author's bottom line was that risk assessment is on its way out as a way to "rationalize government decision-making" and the precautionary principle is on the way in. In other words, the precautionary principle is a "new paradigm" (author's words) that is "taking the place" of risk assessment. While it is certainly not true that the precautionary principle is new, it is true that the precautionary principle is threatening to take the place of risk analysis as the basis for regulatory decision-making in a number of places, particularly in Europe. Increasingly, risk management decisions in Europe are being made on the basis of hazard, not risk, and the country of Sweden recently announced that it would no longer consider risk as the basis for regulation, relying on the precautionary principle instead. The European Commission is currently debating the appropriate role for the precautionary principle in consumer, public health, and environmental protection, and although it has not yet ruled out risk analysis, assuring that precaution does not trump science is an uphill battle.

The precautionary principle is not a substitute for risk-based decision-making. Risk assessment, after all, provides just part of the information used to protect public health and the environment. The extent to which the precautionary principle is applied in decision-making depends partly on the confidence that can be placed in a risk assessment but also on the nature and severity of the risk of concern, the likelihood that new data would change a risk management decision, the effectiveness and feasibility of the risk management action under consideration, and a wide variety of other considerations, like politics, public health, economics, and the law. The danger I see is that the precautionary principle will be used as license to ignore these other elements of risk management decision-making.

While it's easy for us to laugh at fear-mongering articles like Rachel's, we must remember that people actually believe these things. Some people still think that industrial emissions are a leading cause of death and disease and that only zero risk is acceptable. These are people who believe that the precautionary principle should be used instead of risk analysis. There is a growing anti-risk sentiment and a movement to eliminate risk assessment as a basis for risk management. We must recognize this and do our best to dispel the notion that risk assessment is a bogus discipline that threatens public and environmental health while the precautionary principle is the solution to all our problems. We must also find ways for government agencies to serve as honest brokers of science quality for the data that are used in risk assessments.

When used judiciously and constructively, the precautionary approach can be a useful component of decision-making and priority-setting. When used in the absence of considerations of risk, it promotes fear and politicizes science.