[ RadSafe ] Risk, Responsibility, Regulation Whose Risk Is It Anyway?

[Muckerheide, Jim (CDA)]

> -----Original Message-----
> From: radsafe-bounces at radlab.nl 
> [mailto:radsafe-bounces at radlab.nl] On Behalf Of Dawson, Fred Mr
> Sent: Wednesday, October 18, 2006 2:45 AM
> 
> For those of you with an interest in the wider debate about risk, you
> might be interested in the flowing report and press article. There may
> be a read across to Government policy on radiation and risk, only time
> will tell.

Fred,

The report touches on this peripherally, in a sidebar page 19: 

Regards, Jim 
=============

The Precautionary Principle - licence to interfere?

Several people have raised concerns about the use (or misuse) of the
precautionary
principle as a justification for legislation. The precautionary
principle states that if the
potential consequences of an action are severe or irreversible, in the
absence of full
scientific certainty the burden of proof falls on those who would
advocate taking the
action. Where there is scientific uncertainty the precautionary
principle establishes an
impetus to make a decision that seeks to avoid serious damage if things
go wrong.

We have heard accusations that the precautionary principle is
ill-defined and ambiguous.
As such, it is a poor basis for preparing legislation. It rarely
encourages consideration of
opportunity costs, such as an impact on innovation. Further, where many
degrees of
precaution are possible and in the absence of evidence, it is not clear
where to stop.

Clearly, as we are arguing that decisions should be based on evidence of
the
magnitude and impact of the risks being managed, together with
transparency over
costs and benefits, the precautionary principle presents a problem. It
can lead to overreaction
such as the decommissioning of nuclear sites, where the precautionary
principle is said to be a significant brake on progress and inflator of
costs. On the other
hand, however, mistakes with the precautionary principle can also lead
to underreaction,
as with the BSE crisis in the 1990's.

We were interested to read in the European Environment Agency (EEA)'s
publication "Late lessons
from early warnings: the precautionary principle 1896 - 2000" [10 Jan
2002] that there are
certainly two sides to the story. It acknowledges that over-reaction is
expensive in terms of lost
opportunities from innovation and lost lines of scientific enquiry.
However, neglecting to take
timely, preventative action is also costly, as cleaning up the results
of environmental damage
and compensating victims can be much more costly than preventing the
pollution in the first
place. The EEA calls for a better balance between promoting innovation
and protecting from
hazards and highlights some good lessons from the case studies it
examined:

 Acknowledge and respond to ignorance and uncertainty, identify gaps in
scientific knowledge.

 Monitor early warnings.

 Be interdisciplinary (anticipate possible side effects/assess
composite risks).

 Evaluate a range of options.

 Use specialist expertise as well as lay and local knowledge.

 Take account of assumptions and values of stakeholder groups.

 Avoid paralysis by analysis.

These are suggestions that the BRC is pleased to endorse as a pragmatic
way to
ensure that the precautionary principle is not misused to bring in
legislation in an
opaque or smothering way without a sound evidence base or risk analysis.