Como Comunicar em Ambiente e Sade

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 Como Comunicar em Ambiente e Saúde
Some observations arising fromLate Lessons from
early warnings the precautionary principle
1896-2000, EEA 2001

• David Gee, Coordinator, Emerging Issues and
  Scientific Liaison, EEA
• Gulbenkian
• Lisbon, 23 November 2006

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Precaution is not a new idea
Precaution, whether or not described as a formal
principle has served mankind well in the past
and the history of public health instructs us to
keep the spirit of precaution alive and
well.   John Graham, Administrator, Office of
Information and Regulatory Affairs, OMB,
Washington, in Europes Precautionary Principle
promise and pitfalls, J of Risk Research, Vol 5,
No 4, Oct 2002., P375.
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Wisdom is to know, that you do not
know (Socrates) An early lesson, lately
forgotten?
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Towards A Clarification of Key Terms
Source Late Lessons, page 192
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Measuring is not KnowingThe Marine Environment
and the Precautionary Principle
Context 1

• The enormous number of papers in the marine
  environment means that huge amounts of data are
  available, but we have reached a sort of plateau
  in the understanding of what the information is
  telling us . We seem not to be able to do very
  much about it or with it. This is what led to the
  precautionary principle, after all we do not
  know whether, in our studied ecosystem, a loss of
  diversity would matter, and it might.
• Marine Pollution Bulletin, Vol 34, No. 9, pp.
  680-681, 1997

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Late Lessons is based on case studies

• Structured around 4 questions
• When were the first scientifically based early
  warnings ?
• When and what were the main actions, or
  inactions, by societys actors ?
• What were the costs and benefits (all kinds) of
  the actions/inactions and
• What lessons can be drawn that may help improve
  decisionmaking and reduce overall costs ?

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Late Lessons An Analysis of 14 False Negative
Case Studies

• False Negatives Whoops! It really is
  dangerous after all!
• (Citizens pay most of the costs of being
  wrong..)
• False Positives Whoops! It really isnt
  dangerous after all!
• (Producers pay most of the costs of being wrong.)

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Why So Many False Negatives?

• Sound science generates more false negatives
  than false positives ( good science but poor
  public policy)
• Short term economic/political interests can
  dominate longer term, total welfare interests.

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ON BEING WRONG Environmental and Health Sciences
and Their Directions of Error
1 Some features can go either way
(e.g.inapproriate controls) but most of the
features mainly err in the direction shown in the
table
EEA draft
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EEA draft
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A conclusion of the BTG2 conference, Stockholm,
2001

• Improved scientific methods to achieve a more
  ethically acceptable and economically efficient
  balance between the generation of "false
  negatives" and "false positives", are needed".
• (The JRC/EEA workshop on the Precautionary
  Principle and Scientific Uncertainty, "Bridging
  the Gap 2" conference)

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• What about False Positives?
• Harder to prove
• Failed to find authors for them
• Secondary Benefits often make them worthwhile
  eg. Y2K bug
• Vol 2 of Late Lessons will have a false
  Positive chapter

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Antimicrobial Feed Additives (AFA) Chapter An
Early Warning example

• 1969 UK Medical Research Councils Swann
  Committee
• Despite the gaps in our knowledge .. We believe
  on the basis of evidence presented to us, that
  this assessment is a sufficiently sound basis for
  action .. The cry for more research should not be
  allowed to hold up our recommendations
• Sales/use of AFA should be strictly controlled
  via tight criteria, despite not knowing
  mechanisms of action, nor foreseeing all effects
• More rewarding to improve animal husbandry than
  to feed diets containing AFA
• Source (HMSO, UK, Nov. 1969)

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CFCs Chapter Skin Cancer and Time Lags
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CFCs
Du Pont, the worlds first and largest producer
of CFCs, had set this out in a full page in the
New York Times (30 June 1975). It declared that
Should reputable evidence show that some
fluorocarbons cause a health hazard through
depletion of the ozone layer we are prepared to
stop production of the offending compounds. It
was to deny the existence of reputable evidence
until 1986. Joe Farman, Late lessons from early
warnings
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TBT Antifoulants A Tale of Ships, Snails and
Imposex (Chapter 13)

• An increased appreciation of scientific
  complexity and indeterminacy accompanied the
  unfolding of the TBT impacts story.
• Very low doses caused adverse impacts (i.e. in
  parts/trillion)
• High exposure concentrations were found in
  unexpected places e.g. the marine microlayer

EEA draft
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Endocrine Disrupting Substances (EDSs)Some
difficult features

• Timing of the dose
• Mixtures and Multi-causality
• Natural and synthetic EDSs
• Hormonal imprinting
• Endocrine systems cross-talk
• Generational impacts
• Impacts/Adverse impacts
• Adverse impacts due to imbalance between opposing
  affects in complex systems

EEA draft
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Twelve Late Lessons fromEarly Warnings

• A Identify/Clarify the Framing and Assumptions
• Manage risk, uncertainty and ignorance
• Identify/reduce blind spots
• Assess/account for all pros and cons
• Analyse/evaluate alternative options
• Take account of stakeholder values
• Avoid paralysis by analysis by acting to reduce
  hazards via the precautionary principle.

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How Can We Respond toIgnorance (Surprises)?

• Use intrinsic parameters as proxies for unknown
  but possible impacts (e.g. persistence and/or
  bioaccumulation potential of chemical substances.
  (See Case Studies on PCBs, MTBE, CFCs, TBT)
• Reduce specific exposures to potentially harmful
  agents on the basis of credible Early Warnings
  of initial harmful impacts (thus limiting the
  size of any other surprise impacts from the
  same agent, e.g. the asbestos cancers that
  followed asbestosis and PCB neurotoxicological
  effects that followed wildlife impacts). (See 5
  other responses to ignorance in Late Lessons
  supplementary report, EEA 2004)
• Promote a diversity of robust and adaptable
  technological and social options to meet needs
  (which limits technological monopolies such as
  asbestos, CFCs, PCBs etc., and therefore reduces
  the scale of any surprise).

EEA draft
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(CONT.)

• B Broaden Assessment Information
• Identify/reduce interdisciplinary obstacles to
  learning
• Identify/reduce institutional obstacles to
  learning
• Use lay, local and specialist knowledge
• Identify/anticipate real world conditions
• Ensure regulatory and informational
  independence
• Long term monitoring/research

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Some costs of inaction on hazardous agents
1900-2020

• Methodologies
• Lots of narrow, shallow, conventional CBA that
  routinely under-estimate benefits and
  over-estimate costs
• Values within CBA not usually transparent eg. on
  distributions discounting etc.

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Clarifying Benefits and Costs

• Of activity
• Benefits, e.g. jobs, profits, consumer products
• Real costs of production, consumption, disposal

• Of risk reduction
• Benefits of avoided costs of harm/damage
• Costs of risk reduction measures

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A definition of the PP based on Late Lessons
The PP provides justification for public policy
actions in situations of scientific complexity,
uncertainty and ignorance, where there may be a
need to act in order to avoid, or reduce,
potentially serious or irreversible threats to
health or the environment, using an appropriate
level of scientific evidence, and taking into
account the likely pros and cons of action and
inaction. EEA, 2002
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• Some Levels of Evidence..
• Beyond all reasonable doubt
• Reasonable certainty
• Balance of probabilities/evidence
• Strong possibility
• Scientific suspicion of risk
• Negligible/insignificant
• That are appropriate for different purposes

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Bradford Hill knew the limitations of his
criteria

• The presence of the canons contributes towards
  good evidence for causation however, their
  absence may not provide good evidence against an
  association.
• Differential standards of evidence,from
  relatively slight to very strong are needed,
  depending on the consequences.

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From simple genes to complex biological
systems.....

• Rather than having a single function, most genes
  probably play a small part in lots of tasks. by
  dissecting biology into its genetic atoms,
  reductionism failed to account for these
  multi-tasking genes
• Instead of focusing on key control points,
  systems biologists look at the system properties
  of the entire network

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Complexity is often neglected

• Historically, the cumulative and interactive
  effects of direct and indirect stressors and
  other multiple exposures have been neglected, in
  part because of the sheer complexity of these
  realities. Adding to the complexity are the
  different temporal and spatial scales over which
  stressors may operate and the different ecosystem
  components, including individuals, that may be
  vulnerable.
• Interconnections between Human Health and
  Ecological Integrity. SETAC 2002.

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Multi-causality and complexity in ecosystems

• We believe that this contextual interaction
  explains a substantial and significant component
  of ecological responses to environment factors,
  and this interaction is critical during ecosystem
  development.
• Source Biotic-Abiotic Interaction Experiment
• Beard, K.H., Wang, D., Waite, C.E., Decker,
  K.L., Hawley, G.J., DeHayes, D.D., Hughes, J.W.,
  and Cumming, J.R. 2004. Quantifying ecosystem
  controls and their contextual interactions on
  nutrient export from developing forest mesocosms.
  Ecosystems (accepted)

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Conventional Risk Assessment
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Cumulative Risk Assessment
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A Precautionary framework for risk analysis and
hazard control
12 Risk assessment
Broad framing of questions and goals
Scientific assessment of risk, uncertainties and
ignorance
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2
Action options assessment
EffectivenessEvaluations of Actions
Stakeholder participation and review
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4
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Communication andimplementation of assessments,
options, actions
56 Risk Communication
Action decisions(Precautionary trigger)
34 Risk Management
Source EEA based on US Presidential commission on
Risk (1992), Royal commission on environmental
pollution (1998) and CEC Communication on the
Precautionary Principle, 2000
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Take up of some late lessons features and the
PP

• WHO Geneva Framework on guiding PHP in areas of
  Scientific U/C, 2005
• EH Ministers Budapest .
• French Constitution.
• Cartegna Conv.
• SNIFFER (Scot. Irish EPAs)
• Research scientists eg Kriebel et al.
• Biodiversity/developing countries.
• Corporations.
• Etc.

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Guidelines for Applying the Precautionary
Principle

• Guideline 1 INCORPORATE
• Incorporate the Precautionary Principle
  explicitly into appropriate legal, institutional
  and policy frameworks for biodiversity
  conservation and natural resource management.

Guideline 3 OPERATIONALIZE Develop clear and
context-specific obligations and operational
measures for particular sectors and contexts, or
with respect to specific conservation or
management problems.
Source Biodiversity the Precautionary
Principle, edited by Rosie Cooney Barney Dickson
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• Guideline 8 ALLOCATE RESPONSIBILITIES FOR
  PROVIDING EVIDENCE
• Allocate roles and responsibilities for providing
  information and evidence of threat and/or safety
  according to who is proposing a potentially
  harmful activity, who benefits from it, and who
  has access to information and resources.

Guideline 10 BE PROPORTIONATE In applying the
Precautionary Principle adopt measures that are
proportionate to the potential threats.
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A corporate example of precautionary policy

• To act responsibly, Dell believes that if
  reasonable scientific grounds indicate a
  substance (or group of substances) could pose
  significant environmental or human health risks,
  even if the full extent of harm has not yet been
  definitively established, precautionary measures
  should be taken to avoid use of the substance(s)
  in products unless there is convincing evidence
  that the risks are small and are outweighed by
  the benefits.
• (Source Dell, 2005, cited in Rachels
• Precaution Reporter p. 18)

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Some Corporate Measures to Implement Precaution

• Maintaining a Banned and Restricted Substance
  Program
• Choosing designs and materials that avoid the use
  of substances of concern
• Prohibiting supplier use of these substances
  contractually, and
• Substitution of viable alternate substances.
• (Source Dell, 2005, cited in Rachels Precaution
• Reporter p. 18)

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An Example of Misunderstood Precaution

• REACH would extend to all chemicals
  produced in or imported into Europe the bogus
  precautionary principle, which holds that if
  the evidence about a product, technology, or
  activity is in any way incomplete, it should be
  prohibited or at least stringently regulated. But
  what is missing from precautionary calculus is an
  acknowledgement that even when technologies and
  products introduce new risks, most confer net
  benefits -- that is, their use reduces other, far
  more serious, hazards.
• (Miller, H., National Review, Dec. 12,
  2005, cited in
• Rachels Precaution Reporter p. 18)