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 Report on Mobile Phones and Health, in 2000, 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

ALARA stands for As Low As Reasonably Achievable. It is not a new concept, it is how researchers and responsible businesses think and act. I would call it “common sense”. Any research engagement, any innovation 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 time-frame? This is what happened with the mobile phone industry and they were very successful (although I had personally witnessed how the EEA’s David Gee threatened the mobile phone 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 localised measles outbreaks). 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 a 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. 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).

Chemicals and Common Sense

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 (RM note: Now DG Santé) 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. (RM note: This blog was originally written in 2011 and has proven to be sadly correct.) 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.

The European Commission’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.

The Inconvenient ALARA

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. Activist 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 valued 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 (REA  or the JRC) should prepare a Communication on ALARA.

Postscript 2017: ALARA and Glyphosate

As we have seen, glyphosate is a clear watershed in the failure of precaution as an EU policy-making tool. If ALARA were to be used in the decision process, the outcome of the glyphosate debate would be entirely different both in tone and rationality.

ALARA steps in a glyphosate risk management process:

• A study by a cancer agency says it is not impossible for farmers to develop cancer from exposure to glyphosate (based on a few mouse tumours).
• Assuming exposure data were significant (in reality they are not), the first thing a regulator would do is examine the value of the herbicide.
• Alternative products would be assessed and most would conclude that the alternatives are not as effective or sustainable.
• The benefits are high for farmers and consumers so rather than pure precaution, a risk management approach would be taken – meaning ALARA.
• Farmers using the herbicide will be advised to use personal protection equipment.
• Neighbours will need to be warned when the herbicide is being applied (perhaps spray nozzle technology will be refined or specified). Aerial spraying may be restricted.
• For consumers, maximum residue levels will be established and measured.

Glyphosate would be approved for use with continued surveillance and incentives to innovate to further lower exposure levels without losing benefits.

Precaution steps in the glyphosate uncertainty (hazard) management process:

• A study by a cancer agency says it is not impossible for farmers to develop cancer from exposure to glyphosate (based on a few mouse tumours).
• Public is made alarmed by activist campaigns and opportunists.
• Regulators are not convinced that glyphosate is proven to be 100% safe.

Glyphosate is banned under the precautionary principle without any impact assessment, study of alternatives or consideration of consequences.

No wonder NGO activists are demanding an hazard-based precautionary approach to EU policy. Only in the Age of Stupid could such a scenario be tolerated.