Toxicology 181–182 (2002) 127–130

The relationship between risk analysis and the precautionaryprinciple�

Julian MorrisEn�ironment and Technology Programme, Institute of Economic Affairs, 2 Lord North Street, London SW1P 3LB, UK

Abstract

Definitions of the precautionary principle (PP) are reviewed with particular reference to the role of risk assessment.In general, the PP is employed as a means of justifying decisions that are contrary to the conclusions of a formal riskassessment. Even where risk assessment is accepted as part of a precautionary approach, its importance in subsequentdecision-making tends to be undermined by application of the PP. The implications for the future of riskassessment-based decisions in areas as diverse as environmental protection and food safety are briefly considered.© 2002 Published by Elsevier Science Ireland Ltd.

Keywords: Precautionary principle; Risk; Uncertainty; Regulation; Environment; Health

www.elsevier.com/locate/toxicol

1. Introduction

Risk is ubiquitous and unavoidable. To a greatextent, therefore, our modus operandi as humanbeings must involve assessment and managementof risk. Much of this is informal. Directly observ-able risks are assessed and managed throughheuristic processes. In many cases, however, directobservation is insufficient to establish the natureand extent of a risk. In such cases, we rely onother institutions, especially reputation and therule of law. In the private sector, corporationsseek to balance the costs and benefits of avoidingrisks. Manufacturers and retailers have strongincentives to avoid legal actions and protect their

reputations, so they put in place cost-effective riskassessment and management systems that willlimit their legal liabilities and reputation damage(Morris and Bate, 1999).

In the public sector, by contrast, risk manage-ment is driven by different criteria. Politiciansseek to maximise their chances of re-election. Thismeans that they claim credit for good outcomesand avoid blame for bad outcomes. Ministerstend to be in thrall to the groups who will mosteffectively alter their chances to be elected. Agri-culture ministers tend to favour farmers and soplay down risks associated with farming. Environ-ment ministers tend to favour environmental pres-sure groups and so willingly repeat theexaggerated risks those groups highlight. This of-ten leads to conflicts. For example, environmentministers may be under pressure to exaggerate therisks of using pesticides, whilst agriculture minis-

� Note: The views expressed in this paper are those of theauthor and not of the Institute (which has no corporate view),its Advisors, Directors or Trustees.

E-mail address: jmorris@iea.org.uk (J. Morris).

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J. Morris / Toxicology 181–182 (2002) 127–130128

ters are under pressure to do the opposite. Theresults are often perverse. One of the main driversof excessive pesticide use is agricultural subsidies,so the most obvious first step in reducing their usewould seem to be the removal of subsidies. How-ever, this is rarely even contemplated as an op-tion. Instead, governments are now contemplatingthe imposition of taxes on pesticides whilst main-taining general subsidies.

2. The emergence of the precautionary principle

The precautionary principle (PP) emerged inthe context of this highly politicised process ofrisk management. In the 1970s, the German gov-ernment began employing the Vorsorgeprinzip, or‘foresight principle’, according to which a distinc-tion is to be made between human actions thatcause ‘dangers’ and those that merely cause‘risks’. In the case of dangers, the government isto prevent these by all means; in the case of risk,the government is to carry out a risk analysis andmay order preventative action if deemed appro-priate. But the subjective nature of the distinctionbetween ‘risk’ and ‘danger’ enables action to betaken on a more-or-less arbitrary basis. Accordingto O’ Riordan (1994): ‘For the Ger-mans…precaution is an interventionist measure, ajustification of state involvement in the day to daylives of its lander and its citizenry in the name ofgood government. Social planning in the econ-omy, in technology, in morality and in socialinitiatives all can be justified by a loose and openended interpretation of precaution’.

In the late 1970s and early 1980s academics andpressure groups promoted the application of amore formalised ‘precautionary principle’ as ajustification for imposing restrictions on the use oftechnologies such as nuclear power. The basicprecepts of this principle are: a reversal of theburden of proof, and a raising of the standard ofproof. In extremis, it is averred that the develop-ers of new technologies should have to prove theirsafety before they may use them. In the context ofa demand for international regulation of so-calledgreenhouse gases, Leggett of Greenpeace assertedin 1990 that:

‘‘For organizations like Greenpeace, whatcomes first must be the needs of the environ-ment…the modus operandi we would like to seeis: ‘Do not admit a substance unless you haveproof that it will do no harm to the environ-ment’— the precautionary principle…the factthat proof of harm might come too late—orthat proof is invariably hard to demonstratewith absolute certainty—only augments the li-cense given to the polluters.’’ (Leggett, 1990)

According to this definition of the PP, riskassessment is futile, since it is impossible to provethe absence of harm.

3. International precaution

Much of the focus of those who promote thePP has been on creating international agreementsthat limit the use of technologies. The reasons forthis are twofold. First, environmentalists claimthat the risks associated with modern technologiesare global in nature, so any solution to theseproblems must also be global. Second, in manycases it has been difficult to obtain restrictionsnationally because of the kind of competitivedynamic in policymaking described above. So,pressure groups have sought to elevate their causeto an international sphere, where there is lesscompetition over policy formation. Internationalenvironmental treaties are typically negotiated byenvironment ministers, who are, as noted, moresympathetic to the lobbying efforts of environ-mental groups (Rabkin and Sheehan, 1999; Mor-ris, 2000b).

But even environment ministers are not entirelyin thrall to the environmentalists. In contrast tothe extreme version of the PP promoted by envi-ronmentalists, policymakers have generally fa-voured a much looser definition. ConsiderPrinciple 15 of the Rio Declaration (the Ministe-rial Declaration of the UN Conference on Envi-ronment and Development, 1992), perhaps themost widely cited definition of the PP:

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‘Where there are threats of serious or irre-versible damage, lack of full scientific certaintyshall not be used as a reason for postponingcost-effective measures to prevent environmen-tal degradation’. (UNCED, 1992)

This definition is wonderfully vague. On theone hand, it can be used to justify a risk–benefitapproach in which the seriousness and probabilityof damage is first assessed and appropriate actionthen taken. On the other hand, it might also beused to justify taking action against almost anythreat regardless of its probability of occurrenceas long as the action taken is nominally ‘cost-effective’.

To see how problematic even this weak defini-tion of the PP might be, consider the problem ofprotecting the Earth from the threat of an as-teroid. One course of action that might be takento prevent such an impact would be to develop anarray of orbiting satellites containing nuclear mis-siles that are capable of blowing such an asteroidoff course. However, there is also a possibilitythat the missile guidance system would eitheraccidentally or intentionally target the missiles atearth, killing the entire human population (Rubin,2000). In other words, the PP applied to merepossibilities of harm, or ‘threats of harm’, de-mands both action and inaction, which is clearlycontradictory.

The crux of the problem with the Rio definitionof the PP is the unacknowledged subjective andcontextual nature of ‘seriousness’, which makesthe principle inherently unworkable. Considerbiotechnology: people in rich countries by andlarge do not want for food, clothing or shelter, sothey have little reason to be enthusiastic about atechnology that might shave a few percentagepoints off their shopping bill. In the absence ofpositive reasons to support biotechnology, and inthe context of generally good nutrition but height-ened fears about food, it is not surprising thatenvironmental and consumer groups were able togenerate a panic over genetically modified organ-isms (GMOs). In reality, of course, the futurebenefits of agricultural biotechnology are likely tobe significant and the results of failing to adopt it

could be serious, including not only reduced eco-nomic output but also unemployment. Inasmuchas both unemployment and reduced income aresignificant harms, resulting in depression and evensuicide, as well as lower life expectancies, it couldplausibly be argued that the PP militates in favourof adopting agricultural biotechnology. For poorcountries the benefits are more obvious— includ-ing higher yields, enabling many to escape fromthe penury of subsistence. Environment and con-sumer groups, however, argue that uncertaintiesover the potential adverse impacts of agriculturalbiotechnology mean that application of the PPjustifies banning its use. The PP itself provides noguidance as to which view is correct, so its appli-cation can only lead to arbitrary decisions. In thecontext of a powerful environmental lobby andweak opposition, the PP has been employed as ajustification for restrictions on trade in GMOsthrough the Cartagena Protocol on Biosafety.

4. The wider implications of precautionarythinking

General application of the PP may preventpeople from being exposed to some new risks, butit also prevents them from reducing their exposureto existing risks. New technologies generallyprovide net benefits; if they did not, there wouldbe little incentive to produce them. Examples ofsuch benefits include higher crop yields; speediercommunication; better medicine; and better, lesspolluted, water (Morris, 2000a).

To be sure, new technologies bring with themnew challenges and often result in the displace-ment of old jobs. In this process of ‘creativedestruction’ some people lose out and that isunfortunate. But the benefits of creation generallyoutweigh the costs of destruction. Who woulddeny that the replacement of coal fires with gascentral heating was a net benefit, though it cameat the cost of unemployed miners, coal merchants,and chimney sweeps? (In addition to its benefits interms of convenience, improved protection fromthe elements, and lower pollution, central heatingof course led to the creation of jobs in the gas,plumbing and boiler-making industries.) And

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even those who are obsessed with protectingjobs cannot deny that technological stasis re-duces mankind’s capacity to cope with the manythings that are not under his control. Droughts,floods, earthquakes, volcanoes, and other natu-ral events cause disruptions that may require hu-mans to adapt or die. In Ethiopia, two years ofdrought mean crop failure, malnutrition, diseaseand death. In technologically more advanced(and hence wealthier and more resilient) Aus-tralia, two years of drought mean little morethan an increase in food imports and some addi-tional whingeing from farmers.

That new technologies have provided netbenefits to humanity is obvious from long termtrends in available food supplies, infant mortal-ity, access to safe water and sanitation, and lifeexpectancy, all of which have improved remark-ably over time (Goklany, 1999, 2000a). As aresult, mankind is now better nourished, less fre-quently exposed to water-borne pathogens andair pollution, and less likely to die or suffer illeffects as a result of disease (Goklany, 2000b). Asecond result is a generally higher quality of life,resulting from lower cost, better quality goodsand services of all kinds. The general point isthat although new technologies usually bringnew risks, they often replace technologies thatpose greater risks, or reduce the cost of tech-nologies (such as fresh fruit and vegetables—mi-cronutrient delivery systems) that enable us toreduce our exposure to certain risks (such ascancer). Applying the PP may prevent the adop-tion of technologies that would make the worlda safer place.

5. Conclusion

Risk assessment proceeds from an assumptionthat risks can be assessed probabilistically, em-ploying a combination of statistical evidence andscientific understanding of causal relationships.By contrast, the PP proceeds from an assump-tion that probabilistic assessments of risk areinadequate and must be supplemented or re-placed by other criteria. Whilst it is true thatnot all threats can be assessed probabilistically

and whilst it is desirable to supplement risk as-sessments with other decision criteria when man-aging risk, it is not clear that the PP offersappropriate guidance in this context. Applyingthe PP might have devastating consequences: re-tarding technological development, underminingtrade, slowing economic growth, and ultimatelyexposing people to higher levels of risk.

Political management of risk involves the bal-ancing of many competing interests and ideas.Biasing this process by mandating that politicaldecision-makers follow the PP would force thosedecision-makers to give more weight to the mis-anthropic views of environmentalists and otherundemocratic pressure groups who claim tospeak for the public.

References

Goklany, I.M., 1999. ‘The Future of the Industrial System.’International Conference on Industrial Ecology and Sus-tainability. University of Technology of Troyes, France,September 22–25.

Goklany, I.M., 2000a. Economic Growth and Human Well-being, Working Paper. Political Economy Research Cen-ter, Bozeman, MT.

Goklany, I.M., 2000b. Applying the Precautionary Principle toGenetically Modified Crops. Center for the Study of Amer-ican Business, Washington University, St. Louis.

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