THE PRECAUTIONARY PRINCIPLE PROJECT
ONLINE CONSULTATION
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From: Joel Tickner
Affiliation: Lowell Center for Sustainable Production, Univ. Massachussetts. USA
Remote Name: user-3387.l2.c5.dsl.pol.co.uk
Time: 11:47:52 +0100
In general I think a really nice job has been done with this - congratulations. I think having a concrete step by step approach to precaution, like the EU Communication, is not the right way to go, and you have set out general guidelines. At any rate, there may be some steps in an approach to decision-making that guides more precautious decisions - ie new or existing activity - look at alternatives, consider the whole of the evidence, include affected communities. Much of this is in the guidance, but spelling it out in a decision-tree or something like that may be useful (ie what types of questions should one ask about problems?) Overall I think this is on the right track. Some more specific comments: The guidance needs to have some kind of opening that explains the process and how you got to this interpretation of the pp’s implementation. Not sure you need a definition of the pp here but some may argue that is important. Re guideline 2: Not sure where this fits in but many countries – like the US, are pushing highly quantitative risk assessment methods that are not appropriate for developing countries – they would be too costly or time consuming to be able to effectively respond to threats. Re guideline 3: Though I think you could say that there are approaches to decision making that can help support more preventive and cautious decisions – impact assessment, alternatives assessment, more systems level scientific analysis, broader participation of effected communities – it is true that the exact policy or management measures will depend on the case but the approach could be similar across problems. Re guideline 4: The uncertainties should not be just quantifiable ones but also an acknowledgement of indeterminacy, ignorance, and the power of scientific tools to detect effects and of course suspicion built on accumulated knowledge. Re guideline 5: However the potential for risk tradeoffs should not be used as a reason to forestall precautionary measures – it is important to consider these trade offs and institute whatever measures necessary to mitigate them and have follow up systems to change course if necessary Re guideline 7: Good but shouldn’t also consider not just proximate causal information but also systems level information, analogy, etc. Re guideline 12: Often this continued monitoring assumes that things get better when having more information – ie reducing uncertainty makes the problem go away – at least in public health this is rarely the case – things often turn out much worse than predicted originally. The guidance needs to make clear it is not saying this.
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