Western risk managers (authorities, policymakers, political actors…) have lost their capacity to implement a coherent risk management process. Most have confused an uncertainty management tool (the precautionary principle) with risk management. Their lack of understanding and preparation in the months leading up to the COVID-19 coronavirus pandemic led to a catastrophic management failure resulting in elevated loss of life and disastrous social and economic consequences from the hastily arranged precautionary lockdowns of Western society.
This Post-COVID-19 Blueprint series has attempted to examine what went wrong: how precaution failed, what were the social drivers behind what had become a docilian mindset (demanding a world with zero-risk) and what risk management steps should have been taken. In preparing this strategy document to restore the art of risk management in Western policy arenas (once we recover from this terrible virus outbreak and the economic and social collapse from our bungled responses), I am acutely aware that influential forces are lobbying our leadership for an alternative solution: more precaution and less technology. I feel there needs to be a discussion on how risks should be managed but I am afraid that our numbers are few and our voices too soft.
How can our Western leaders not now see the poison of precaution? Why would they continue to use the policy tool that left them so unprepared especially with the multiple crises Western societies are presently facing? There will be more, greater failures should the precautionistas be allowed to continue to masquerade as risk managers. How many more people will have to die and suffer before we finally have this debate on the role of precaution in the risk management process?
Many of the dialogue tools and public participatory policy ideals introduced at the beginning of the millennium have shown to be inadequate as our social engagement process has evolved into closed online echo chambers and anti-social tribes of interest. With the failure to manage the COVID-19 coronavirus, there is an urgent need to introduce a risk management process fit for the 21st century.
I offer these twelve strategies in hopes they might be worthy of discussion.
Twelve Strategies for Better Risk Management
These twelve strategies may not fit each culture or every set of circumstances. In some countries certain practices are already in place while in others proper risk management tools have been dismantled (for political interests). But I would hope this can start the debate on taking governance and risk management seriously. One thing is certain: continuing business as usual with a precaution-based reactive (docilian) mindset demanding our risk managers run from all risk and uncertainty will further devastate and impoverish Western society.
1. Place Precaution Properly in the Risk Management Process
Taking precaution (stopping or disallowing an activity, substance or process) is an important decision as it can have significant consequences on social and economic well-being (lost benefits). As the previous section in this series demonstrated, precaution should come at the end of the risk management process when our capacity to prevent harm has failed or the value of the benefits could not be justified (see image above). The risk management process must attempt to reduce exposures, prevent harm and ensure benefits and social goods. If they fail to reduce risks to a reasonable level (ALARA), then precaution would be applied with care taken for the consequences of any lost benefits.
But the European Environment Agency’s version of precaution (the reversal of the burden of proof) demands the precautionary principle be applied at the beginning of the risk management process. Unless you can prove your substance, process or activity is safe, precaution must be taken (the hazard is banned, stopped or disallowed). The problem is that this regulatory demand is placed on emerging technologies (like gene editing techniques) excluding any risk management process since blanket demands of certainty and safety are applied prior to any data or analysis can be developed.
The European Environment Agency’s version of precaution is a clever ruse to reject any important emerging technology. And for two decades, these activists have managed to masquerade this campaign tool at the heart of EU risk management policy.
The architects of this policy tool knew they could apply the emotional demands for safety and certainty to any policy that did not fit their political ideology so precaution has been selectively applied. It has been used to preempt technological developments like CRISPR, to ban energy solutions that lower carbon emissions and to remove effective chemicals and medical solutions. As the tool of choice for the environmentalist lobby, the irony is not lost how their dogmatic reliance on the precautionary principle has often resulted in very unsustainable practices.
There was no debate in the European Commission on how to apply precaution, which definition and where in the policy process it should be invoked. It was imposed by one relentless activist in the European Environment Agency (EEA), David Gee, as a tool to ban chemicals, pesticides and emerging technologies. He managed to slide the mention of the precautionary principle into important EU treaties like Lisbon and regulations like REACH and the Sustainable Use Directive. When Gee started cavorting with the anti-mobile phone crowd and his boss, Jacqueline McGlade was fired from the EEA in disgrace, he had lost his influence in Brussels, but by then the damage had been done. Gee had recruited an army of zealots.
2. Create Government Risk Management Units
A good part of governance is risk management (protecting the public from harm) but when I refer to government officials as risk managers, they seem confused. For the last 20 years a naive zero-risk expectation had taken root: that all we had to do is make the “bad things go away” and life would be wonderful. Precaution became a luxury policy tool for a privileged elite and there were no elements within the governance process who could present both oversight and foresight. A policy process built on public engagement meant, ironically, that only the loudest, best funded and most motivated were able to get themselves heard.
Financial institutions have risk managers to provide oversight and foresight to ensure good governance capacity. Following the 2008-09 financial crisis it was revealed how certain (failed) banks had sidelined or actively ignored the warnings of the risk managers when exposure to risks had grown too high. Such a unit at government level (like the US OMB during the time of Professor George Gray) could cut through the noise and ensure that policies taken would not expose populations to greater risks or unnecessary sacrifices.
In the case of COVID-19, a government risk management unit could have sounded the alarm bells in the first weeks of 2020 and provided a preventative, risk reduction plan for the most vulnerable. When faced with the possibility of nation-wide lockdowns, such a unit could have highlighted potential consequences while suggesting alleviation strategies within a public dialogue forum.
3. Guarantee Scientific Independence from other Institutions
Such a risk management unit, as a voice of reason and conscience, needs to be independent from the messy nature of politics. Any risk assessment process needs to be outside of the political process and their findings need to be publicly accessible. While Churchill’s saying: “Scientists should be kept on tap, but not on top” stands as a truism of modern democracies and accountability, it does not mean that political leaders can be allowed to try to hide facts or deny evidence by pressuring their advisers. A risk manager has the right to ignore the risk assessment, but he or she must do so at their own peril.
For example, the head of the European Food Safety Authority, Bernhard Url, acknowledged during a speech to the European Parliament that his risk assessment institution was forced to apply the non-scientific (draft) Bee Guidance Document in its scientific evaluations (that compelled them to discard field test evidence on the safety of neonicotinoids) in order to justify the EU’s imposition of the precautionary principle.
As the European Commission’s goal was to justify the use of precaution to ban an important class of pesticides (to appease the French government’s internal politics), nobody was expected to have discovered the fraud and EU scientists were simply told to shut up. In an unaccountable world driven by the precautionary mindset, this behaviour goes unnoticed; in a world committed to managing risks and respecting science, it is disgraceful and should never have been allowed or tolerated.
4. Promote a Scenario Building Governance Process
Contrary to common practice in policymaking today, it is not a sign of weakness to have a Plan B or consider alternative eventualities. Examining a multitude of scenarios allows a risk manager to prepare for any situation, avoid black swans and limit unforeseen consequences. In most cases it is common sense: you better reduce your exposure to risks if you can imagine a wide range of scenarios and likelihoods and suitably prepare for them.
In the early 2000s, I was involved in scenario building processes that involved taking a variety of possible worlds and anticipating decision theories based on different stakeholder assumptions. For example, an oil company might consider a series of action plans for a world operating along business as usual, or one where different energy sources competed freely, vs a world where governments intervened to favour one source over others and a scenario where climate shocks created a reorganisation of the economy and energy use. They would then feed as many variables into their models as possible, including different ways certain populations would react to uncertainties (and which ones). At the end of the process, the oil company would draw up a variety of action plans and use them to guide their decision-making process.
As an indication of how foreign this risk management approach has become, Exxon-Mobil was charged by the New York Attorney General for knowing about the costs of climate change and not acting or informing their shareholders. The source of their charge was an internal scenario planning exercise. Reason prevailed and Exxon was acquitted, but the New York legislator’s inability to understand what scenario-building exercises were implied a lack of internal government foresight – a situation that could only be tolerated in an intellectual environment dominated by the precautionary mindset.
Today gamification has become a key part of scenario building. I have had the pleasure of being involved in the development of several of these exercises (on climate change and nanotechnology). Actors are brought into a room to role-play certain stakeholders who address potential situations (eg, investing in a new energy technology). Different timelines are exploited related to events that define how certain worlds evolved. The more the game is played, the more the potential number of events are played out, enabling better foresight and planning.
Western government risk managers had ten weeks to prepare and plan for the COVID-19 crisis between Wuhan and Bergamo. I cannot see any evidence of scenario building or foresight of the potential events and preventative action plans. Most European countries locked their populations in their homes during the weekend of 14 March 2020 with no clear strategies communicated and no understanding of the consequences this would have on vulnerable populations. Perhaps each government had foresight departments or planning units, but the risk managers were not engaging, listening or using their advice. See Recommendations 2 and 3.
5. Ensure Expertise lies at the Foundation of Risk Management
Would the European Union have acted sooner in protecting Europeans from the coronavirus pandemic if the President of the European Commission had still had a chief scientific adviser down the hallway from her, providing timely advice in January? Could this person have coordinated with other national European Member State chief scientific advisers? One of the great environmental activist achievements was to have abolished the post of chief scientific adviser, essentially removing the voice of science from the heart of EU policy-making. Dame Anne Glover was building a network of European science advisers, something which, post-COVID-19, makes perfect sense. But Dr Glover supported the science behind biotechnology, so, according to the precaution-driven activists, her post had to be removed.
The European Commission has just closed a consultation on their Roadmap for a future chemicals strategy (an important part of their flagship Green Deal). The title of the consultation sought a ‘toxic-free EU environment” and the text indicates their preference for a hazard-based policy approach. Yes, the architects of the future risk management strategy affecting all elements at the heart of technological innovation have indicated they have no basic understanding of chemistry and toxicology. The EU could have avoided some public embarrassment if they had had a scientist available to double-check their strategy documents. True to form, months later the chemophobic European Parliament voted overwhelmingly in favour of this scientific ignorance, demanding even further use of the precautionary principle.
The European Commission should not have cowered to the threats of the activist community and should immediately reinstall a Chief Scientific Adviser at the heart of EU policymaking. Such ignorance frequently seen in the European Commission and Parliament has not only become embarrassing, in the case of COVID-19, it has cost hundreds of thousands of lives. (Martin Pigeon, how can you possibly wash your hands of this crime?)
Risk management needs to be based on the best evidence, not the strongest political ideology but as precaution serves as an easy, expedient, blameless solution, the battle to undo its dominance will be challenging.
6. Bring in Different Sources of Expertise
I can’t count how many times in 2020 I have heard public officials declare they would never sacrifice public health for the economy. But except for the arrogant affluent class, we do … all of the time. Otherwise there would be cures for all rare diseases and we would all be living in protective bubbles. At the individual level as well, people make decisions every day knowing they are compromising their health. So when risk managers acted to lock down economies and psychologically torture their citizens, they were acting on only one type of advice (if at all) coming from one particular part of the medical establishment concerned about one negative consequence. Limiting your advice pool is how mistakes are made.
I can’t count how many times in 2020 I have heard people talk about “the” science as if you simply needed to put a question into a machine and the answer would come out. Science is complex, often contested and defines itself by a method of challenging its theories and paradigms. Only consensus-loving neophytes (and a Swedish teenager) would talk about “the” science as if it meant something certain. Part of the risk management process is to plan out scenarios based on the best available scientific voices at that time.
It goes without saying that policymakers need to gather as much evidence and advice from as many experts as possible. As important though is that there needs to be a wide range of advice and dialogue. Risk managers must actively seek out this different advice from different expert backgrounds rather than allowing the loudest, nearest voices to drown out discussions and cloud thinking. The failed 2004 EU EMF Directive (where the architects of that legislation forgot to consult hospitals) should be a lesson to any risk manager about the dangers from not bothering to consult important experts.
With COVID-19, most Western risk managers acted only on the advice of their health advisers. It is outrageous to realise how societies could be locked down, global economies shuttered, individuals with special needs and vulnerabilities ignored, supply chains broken and poverty, joblessness and suffering institutionalised without government officials at least consulting other experts on other possibilities or long-term consequences. Within weeks, farmers were dumping milk while dairy prices increased, PPE was being auctioned to government authorities at the highest price, ghost planes were flying to keep their slots. Health experts knew nothing about supply chains. After the disastrous consequences of the rushed March COVID-19 lockdowns became obvious in April and May, 2020, most Western countries let it be known they would not go back into such a situation again.
Applying the precautionary principle (saying “No!” to any uncertainty) does not require any expert consultation as the objective is merely to stop the source of the uncertainty; consequences are not taken into consideration (why citizen panels are sufficient). I draw from firsthand experience how the activists pushing precautionary decisions have become very good at the unethical art of silencing dissenting views. The precautionary decision process was simplified: when things get uncertain, officials simply state: “Come back to me when the evidence guarantees safety.”
Simple is what everyone wants, but life (and governance) is not like that. Risk management, on the other hand, weighs the consequences of lost benefits against other means of reducing exposures to risks. They need the best evidence from the widest range of advisers.
7. Accept that Risk Management is not about Assuring 100% Safe
The zero-risk mindset assumes there is a world possible without risk. This naive fantasy has driven the precautionary strategy of banning or not allowing any uncertainties. In reality, nothing could be proven with certainty to be safe. When no risk reduction measures were taken and many Western healthcare systems were facing being overwhelmed by the COVID-19 pandemic, people realised this promise of safety was an illusion.
Governments got used to the (false) pretence promising they could keep their populations safe. Europeans were assured they would be safe from the coronavirus if they just stayed home and washed their hands. We should have been told the truth – that this pernicious virus would spread (we were not safe) and we would have to work hard to strengthen our immunity (to make us safer).
Worse, our demands for “safe” provided a false sense of security, making us complacent and docile. Western populations were not prepared for the reality of a significant health risk we could never be kept safe from and, as a recent article noted, populations were not adequately empowered with the capacity to make ourselves safer.
The last part of this series looked at how pesticide development over the last 70 years has made residue levels on many foods so low as to often be undetectable. This has allowed farmers to produce safer food without risking lost crops … continuously safer, better and more abundant. And there is nothing saying food cannot always be made even safer. But the organic food industry activists demanding “safe” are using the precautionary principle to stop this 70-year pesticide risk reduction process, and weak regulators in the EU are complying.
Risk management is about continuously working to make systems and substances safer. Think of road safety measures, reductions in chemical exposures, food processing regulations … it has been a long, continual process of risk reduction measures and product improvements. The demand for certainty on safety is unrealistic, unreasonable and naive.
Working towards “safer” is reasonable.
8. Use ALARA as a Return to Risk Realism
This zero-risk mindset, this demand for total safety, is built on a false objective. We should not be aiming for safe, but rather safer. But what level of safer is safe enough? Like any situation with uncertainty, it depends on the circumstances, needs and realities. If you are dying of thirst in a desert, what level of water purity will you accept? This is always a question of what is reasonably achievable. The principle goal for risk managers is to reduce exposure to hazards (risks) to as low as reasonably achievable (ALARA).
ALARA is the key to risk management. Risks are only taken when there are perceived benefits so we need to measure our means to reduce exposure and still attain the benefits. As any investor knows, high risks suggest higher benefits, lower risks provide lower returns. The goal of course is to reduce risk exposure as low as possible without sacrificing benefits. There will always be a risk (nothing is 100% safe) but any reasonable person should be aiming at safer. (Note some risk analysts also refer to it as ALARP: As Low As Reasonably Practicable.)
But what goes into “As Low as Reasonably Achievable”? Some say it is simply a cost-benefit analysis (and then they would add that you cannot put a price on a human life). Every risk is different (to everyone) and the variables affecting our reasoning range from resources, available equivalent alternatives, time to undesired consequences, public perception of the risk, traditional practices, accountability, trust relations and the public willingness to change certain lifestyle habits.
So there is no one rule guiding risk management as ALARA. Each situation looks at what is reasonable and what is achievable. Dreamers and idealists want a world that is simply unachievable; pragmatists could probably achieve more. Continuous improvement is a key element to ALARA. It is not just to lower the risk to what is reasonably achievable, but to then push that exposure reduction even lower … continuously in an iterative, reasonable process.
9. Abandon the Precautionary Logic
Scientific logic used in risk management is fundamentally different from precautionary logic. In some speaking engagements I would bring out my umbrella on a sunny day (a precautionary measure). I would ask the audience if I was right to bring my umbrella … of course not. But was I wrong to bring my umbrella? No, I was playing it safe (and I would bring my umbrella tomorrow even if the forecast was for another sunny day). In the precautionary logic, not being right is not the same as being wrong … with precaution, you are never wrong (just quite often not right). “Better safe than sorry” is not a question of right or wrong and so precaution does not obey our normal rules of logic.
A scientific logic says either you are right or wrong (either it works or it doesn’t). In risk management, we need to know what works, what is right, and that must guide our decision-making process. While I understand how many expedient policymakers prefer to never be wrong (thus the attraction of precaution), like safe, there is no such thing as “never being wrong”. But unlike this mythical world driven by precautionary idealists, in managing risks we need to take responsibility for the consequences of our decisions.
A future risk management strategy needs to confront the attraction of the precautionary logic. This will be difficult. Many people in my network still feel today that the COVID-19 situation made the mass lockdowns necessary and unavoidable (ie, not wrong). This logic does not allow for alternatives or consequences to be considered – it is blameless (and quite unreasonable as there were severe consequences).
Precautionistas have to accept how their logic failed. Western Europe was once affluent and could afford to take decisions where consequences and lost technologies didn’t matter. But with the failed management of the coronavirus crisis, Europe is witnessing a decimation of jobs, entire industries and lost financial stability that will have repercussions for at least the next decade, we no longer have the wealth to promote a negative growth strategy and we can no longer afford to not be right just to appease the idealistic dreamers.
While Asian countries benefited from risk management strategies and reopen their less-battered economies, the European Commission has returned to their pre-COVID-19 strategy of saving the world with their precaution-laden Green Deal, blithely unaware of the poverty they have imposed on their citizens. The precautionary logic can continue to operate in defiance of facts and reality for only so long.
10. Develop a Viable Means for Public Consultation
Policy decisions need to be evidence-based but policymakers are accountable to the public. What happens if a public rejects certain beneficial technologies or evidence-based solutions (think nuclear energy, GMOs, vaccines…)? Prior to the risk era (prior to the 1980s) the public were rarely consulted and decisions were made in backrooms by men in white coats. In the 1990s and 2000s, scientists began trying to communicate risks to the public in hopes of gaining their buy-in (leading to the creation of the fields of risk communications and sci-comm). But in the last ten years, with the decline in public trust, the dominance of social media tribes as main information sources and activist groups spreading “alternative facts”, it has become clear that a publicly accountable, evidence-based risk management strategy was impossible. This left precaution as the only easy tool of choice for policymakers.
Now activists in groups like Friends of the Earth, Test-Biotech and Extinction Rebellion are stepping forward to remove the evidence-based element from the risk assessment process entirely. They are proposing, with some initial success in certain countries, to fill the trust gap with citizen panels (which would simply employ non-specialists to eliminate any technology or product that does not satisfy their precautionary prerequisites). By “non-specialists” they mean “people like them”. This will destroy Western society’s capacity to protect itself.
Science and facts are not democratic. French President, Emmanuel Macron, convened a citizens climate convention and their proposals included banning large supermarkets and stopping 5G. Consultation does not mean that the citizens are always right, but this is what the NGOs lobbying for this expect. What would happen should the majority of a population be convinced that vaccines are a dangerous Bill Gates conspiracy or that all food must be organically grown? Asking a public made afraid by alarmist social media opportunists for advice on policy is pure folly.
Sadly governments in France, Germany and the UK are moving in this direction. They are confusing the desire for legitimacy with legitimate policy. This will complicate responsible risk management. While government risk managers need to find a means to engage with the public, they should be very careful about empowering an enraged mob to spread irrational fear and undermine societal goods.
Risk managers need to communicate at the community level.
11. Create a Community Trust / Communications Mechanism
Trust in regulators, industry and science has been in a downward spiral for decades, worsened by the rise of social media echo chambers and the increased use of precaution (with its guilty until proven innocent burden of proof demand). In the Blockchain Trust series, I showed how those like us have more influence in trust-building relationships than the voices of experts or authorities. This accounts for why science communicators have largely failed to increase trust in vaccines, seed technologies, chemicals and pharmaceuticals during the opportune early days of social media tribalism. Shouting facts at people who feel vulnerable is hardly effective risk communication; sadly today science communicators are wasting too much energy shouting at each other.
The top-down, trust the expert, approach is no longer legitimate so regulators are toying with a bottom-up citizen panel approach to restore trust, but this is a dangerous experiment, if, as indications have shown, the fear-laden turkeys will vote for Christmas. As the policy world is polarising, consensus is becoming rare and often impotent. This should not be surprising. I have argued that as every new communications tool challenges the status quo, populations are easily manipulated by opportunists.
Our communications structures and tools have changed first with the digitalisation and then the socialisation of knowledge. As the cascading (military) communications approach will no longer persuade large parts of populations, any risk management strategy will need to be communicated with the support of influencers, gurus and tribal leaders. In other words, governments will have to take a page out of online millennial marketing strategies to engage populations on risk issues.
Given how the public needs to be engaged but not empowered, policy outreach via community networks creates the best opportunity for dialogue and public buy-in. When the public eventually adapts more to the communications tools and can discern facts from opportunism, these communities will learn to listen more than shout.
Perhaps this is wishful thinking in the short term but the present risk management buy-in process has failed miserably (adding to the default attractiveness of precaution), a longer-term strategy needs to be coordinated.
12. Promote a Risk Resilient Population
Two decades of the precaution-based cancel/ban/disallow policy approach has developed a population with a predominantly zero-risk mindset. These docilians have expectations of a protectionist state guaranteeing 100% safety and certainty. This risk aversion has left Western societies more vulnerable to inevitable hazard exposures with populations not capable of managing risks. We no longer have “Handle with Care” or “Keep out of Reach of Children” to ensure we have efficient products we entrust consumers to use responsibly. Now we have “Toxic-free” or “Ban Chemical X, Y and Z” because we don’t trust anyone. Wither risk resilience. Wither efficient products. Wither public trust and responsibility.
In the case of COVID-19, the public was advised how to avoid exposure to the virus (by staying at home, social distancing and washing their hands). Western risk managers effectively left their populations waiting for the infection, and for too many, waiting to die (without empowering them to have a fighting chance). So what should have been done?
Empowerment is important but that depends on trust. I take a risk (eg, using the stairs) if I trust my capacity. I take precaution if I don’t trust my capacity, information or behaviour. I empower others if I trust them. In the case of COVID-19, people needed to be empowered with the tools to build up their immunity to battle the virus while being informed and trusted to not spread the virus to others. Nanny States do not trust their citizens and prefer to enforce rules rather than responsibilise populations. No wonder Western societies have become docile and risk averse.
Many Asian countries, having faced so many economic, epidemic and political shocks, have become more risk resilient. Living in an environment regularly exposed to earthquakes, volcanic eruptions, typhoons, stifling heatwaves and deadly predators and diseases, most Asian populations understand and adapt to risks on a daily basis. So when the COVID-19 coronavirus swept through Asia, its populations proved more ready to adapt, reduce hazard exposures and return to a new normalcy. Meanwhile the Western risk managers couldn’t decide or enforce something as simple as the wearing of face coverings. … And their risk-ignorant populations weren’t prepared to comply.
15 articles later, I’ve had my say
I conclude my Post-COVID-19 Blueprint with this proposal for a strategy to rebuild our capacity for risk management. I fear it will merely be shared among a small tribe of risk policy analysts while the precautionistas continue to enjoy the ear of our key influencers and decision-makers. I write this from my dusty basement. I do not have the millions of euros of foundation-fed interests, the guru-led tribal passion or activist-driven fear-making machinery of the privileged zealots. What that crap-cash has bought them over the past two decades (relying on a misplaced precautionary policy tool) is expedience, irresponsibility and catastrophic risk management failure. And now as these relentless fundamentalists line up again at the public trough, we are facing economic collapse, famine and their insistence on even more precaution.
Precaution has been a failed policy tool for two decades but it is only becoming apparent after our Western affluence withered in the face of the COVID-19 coronavirus. It is time for us to go back to a risk management strategy fit for the 21st century. I present these 12 steps as an alternative policy approach for rational discussion … hopefully worth consideration by people much more important than this mere monger.