INFOTERRA: Re: Fw: Rachel #756: The Year of Precautionary Action
Dear Envtecsoc and Infoterra members,
First I wish all a very good 2003 with a good health and hopefully no world
conflicts.
Some comment on the precautionary principle...
While in itself a good principle, the practical application until now has
less to do with the principle itself than with other self-interests: the
NIMBY syndrome being one of them.
Lots of people wants to have a mobile phone, but nobody wants a signal
transmitter in his/hers backyard, because that "may" cause cancer. Thus the
precautionary principle is (ab)used to react against any attempt to built
one in one's neighbourhood.
Lots of people produce lots of garbage, but nobody wants a garbage
incinerator, dump or even recycling/composting installation in his/hers
neighbourhood, again the precautionary principle is (ab)used to stop such
installations.
Lots of people do use cars and planes to go everywhere, want to have easy
access to airfields and highways, but nobody wants an airfield, a highway
and certainly no refinary in their backyard...
Most people are pro alternatives for fossil fuels (if somebody else will
pay for it), but nobody wants nuclear plants, dams or even wind mills in
his/hers backyard...
So we can go on...
Others abuse the precautionary principle for economical or political or
ideological reasons. The ban on US meat and GM food imports in Europe has
more to do with economics than with fear for any adverse health effect.
The actions against GM foods now will have their first victims in Africa:
Some African countries have send US food aid back, for fear that these
could have adverse health effects. While millions of people are starving
because of lack of food... High percentages of non-commercial banana's in
several African countries are lost due to fungi, while a GM fungus
resistent banana, invented in the Louvain University (Belgium) is waiting
for years to do the first field trials, but the fear for GM food stopped
the politicians to give the approval.
Will those who are promoting the Wingspread statement please use their
power to convince some African leaders that the precautionary principle in
these cases is of no value, compared to the loss of lives?
There are several variants of the precautionary principle, one of them is
the Wingspread statement.
But even the Winspread statement is not followed by their own signers.
Especially one part of it:
"In this context the proponent of an activity, rather than the public,
should bear the burden of proof. The process of applying the Precautionary
Principle must be open, informed, and democratic and must include
potentially affected parties. It must also involve an examination of the
full range of alternatives, including no action." (SEHN, 2002)
Besides the problem that it is impossible to give proof of no harm in all
circumstances (even water is toxic in too large amounts at once), there is
not the slightest sign that the proponents of an outright ban on chlorine
and chlorine compounds like PVC have had an open process, have informed
people with both sides of the debate, are democratic or have included
potentially affected parties.
To the contrary, they only provided one-sided information, are not elected
in any way, and have excluded the industry from any debate. And certainly
haven't looked at the environmental and health effects for any alternative
they have proposed, including the status quo.
Even worse, if one reads the words of Joe Thornton from his book "Pandora's
Poison", at the SEHN web site (http://www.sehn.org/pdf/putvaluesfirst.pdf):
"No analyst of policy can be truly objective, because the process of
weighing options for social action always filters the findings of science
through a set of political and ethical assumptions and values. With that in
mind, I have tried to do two things: to make explicit the ethical and
political views that undergird my own evaluation of the science and to be
as fair as possible in my presentation of the scientific evidence. I cover
what I believe to be the most important information relevant to the case I
am making and evaluate its strengths and weaknesses, but I do not claim
balance or objectivity, because these are neither appropriate nor possible
in this kind of effort." (p. ix)
I have read Thornton's book. What he calls "as fair as possible in my
presentation of the scientific evidence" is so far from the truth, that
only a book as thick as his own (600 p.) can give the facts of all
omissions of scientific evidence and errors in his book. To give two
relevant examples:
In one of the first essays of Greenpeace against PVC, the VCM factory where
I work (then an Akzo Nobel/Shell joint venture - now Shin Etsu) was
situated at a place of large dioxin contamination of the river Rhine at km
665. But that was 350 km UPstreams from the real implant at km 1015. As
dioxins can't swim, this was a clear error which was corrected a few years
later in another Greenpeace work (without any apology...). 8 years later,
Thornton again uses that false argument in his book (p. 312), while he
should know of the error, because he has been (still is?) a Greenpeace
co-worker for many years.
Another example: to prove that all organochlorines are very persistent, he
gives a table of half-lives of different organochlorines in *pure* water.
This is scientific nonsense, as one will not find pure water anywhere in
the world, but bacteria everywhere. And these break down over 97% of all
organochlorines of a VCM factory in less than three days (figures of the
biological waste water treatment in the plant where I work). Comparable to
what a similar treatment does for non-chlorinated organics in a refinary.
E.g. 1,2 dichloroethane (EDC) is listed by Thornton with a half-life of 72
*years* in pure water, while that is a few weeks in nature, and a separate
treatment of groundwater (to prevent spread of a former tank leak) breaks
EDC down in a few *hours*, with the help of xanthobacter autotrophicus and
some air...
The work of Thornton is widely used to (ab)use the precautinary principle
against the use of PVC in health care... (see more at our web site:
http://www.ping.be/chlorophiles/en/answ/en_cl2_pandora.html )
To give an alternative, more scientific approach to the precautionary
principle, see the position paper of the CEFIC (European Chemical Industry
Council) at http://www.cefic.be/Position/sec/pp_sec05.htm :
- The Precautionary Principle is to apply where a significant threshold of
plausibility and gravity is reached. There must be a sufficient body of
evidence which establishes that serious and irreversible damage to health
or the environment could be caused by the challenged activity or product.
- Assuming that the above test is met, it is necessary to proceed with a
cost-benefit analysis of the challenged activity and of the abstention or
substitution which would follow the application of the Precautionary
Principle. All consequences - economic and social as well as environmental
- must be weighed in the light of existing scientific knowledge.
- As the Precautionary Principle may restrict freedom of citizens, of
enterprises, of consumers and of economic agents in general, and may
potentially encroach upon fundamental freedoms guaranteed under the EU
Treaty, any legislation or decision embodying or implementing the principle
is to be subjected to close scrutiny and its motives spelled out in order
to conform to Article 190 of the EU Treaty. Such decisions are subject to
judicial review.
- The principle of proportionality must then be applied, i.e. restrictive
measures are to be taken only if it is established that other measures less
restrictive of these freedoms cannot achieve a similar result for the
protection of health, safety and the environment.
- Substitution of one activity or product by another may be considered on
the basis of the Precautionary Principle only when all conditions below are
met :
- the substitute has a comparable function or effectiveness ;
- risk assessment and risk benefit analyses are performed and compared for
the original activity or product and the alternative proposed (Adequate and
comparative documentary evidence should always be provided) ;
- the economic impact is proportionate to the environmental benefit ;
- a less dangerous product is actually available on the market ;
- the substitute is not likely to cause an equally or more burdensome
effect on Health, Safety and Environment ;
- a comparative life-cycle analysis has been made, taking into account
functions and circumstances surrounding the activities and/or products.
------
I am still waiting for the first evidence that the alternatives for PVC
uses are better for the environment and/or less dangerous for health...
Sincerely,
Ferdinand Engelbeen
As chairman of the Chlorophiles
(a group of workers in chlorine/PVC works).
---------------------------------------------------------------
At 15:19 12/31/02 -0500, Claire W. Gilbert forwarded:
>----- Original Message -----
>From: "Rachel News" <rachel@RACHEL.ORG>
>To: <RACHEL-NEWS@LISTS.RACHEL.ORG>
>Sent: Tuesday, December 31, 2002 2:37 PM
>Subject: Rachel #756: The Year of Precautionary Action
>
>
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> > ==================Electronic Edition====================
> > . .
> > . RACHEL'S ENVIRONMENT & HEALTH NEWS #756 .
> > . ---November 14, 2002--- .
> > . HEADLINES: .
> > . THE YEAR OF PRECAUTIONARY ACTION .
> > . ========== .
> > . Environmental Research Foundation .
> > . P.O. Box 160, New Brunswick, N.J. 08903 .
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> > ==================================================
> >
> > THE YEAR OF PRECAUTIONARY ACTION
> >
> > Here we begin our review of 2002, a year dominated by war and
> > preparations for war (a subject to which we will return). But
> > first let's look at some positive developments of 2002.
> >
> > The principle of precautionary action really took off during
> > 2002. The groundwork was laid in 1998 by the Science and
> > Environmental Health Network (SEHN) which has worked since then
> > to embed the principle in everyone's thinking. See RACHEL'S #586
> > and http://www.sehn.org.
> >
> > During 2002, it became apparent that SEHN's work has paid huge
> > dividends. The precautionary principle is catching on. The
> > principle is simple enough: when there is reasonable suspicion
> > that harm is occuring or about to occur, we all have a duty to
> > take action to prevent harm even if some cause-and-effect
> > relationships have not been proven to a scientific certainty.
> >
> > The precautionary approach stands in stark contrast to "business
> > as usual" which dominates our culture and which says, "Do
> > whatever you want until someone can line up the dead bodies and
> > prove that harm is occurring." The precautionary principle is
> > best summed up as "better safe than sorry." As simple as it may
> > seem, precautionary action represents a completely different
> > approach to the protection of human and environmental health.
> >
-------------------------------------------------------------
Ferdinand Engelbeen
Chairman Chlorophiles
Oude Ertbrandstraat 12
B-2940 Stabroek
Belgium
Tel. +32-3-605.38.14
Fax +32-3-605.43.96
E-mail chlorophiles@pandora.be
Website Chlorophiles: http://www.chlorophiles.org/
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