April 10, 2010
How Much Risk Is Too Much?
An ancient common law principle has been hijacked by radical environmentalists. Life is full of trade-offs between the risks associated with our daily activities and the benefits. For environmental matters, the Precautionary Principle is a widely accepted idea that has now become a tool for environmental activists to effect social and economic change.
The Precautionary Principle is a human health and environmental protection philosophy that has been internationally accepted. It is most famously set forth as Principle 15 of the United Nations' 1992 Rio Declaration. As defined, the Precautionary Principle states, "...where there are threats of serious and irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation."
The Precautionary Principle in itself is not necessarily a radical environmentalist concept. The Principle has its basis in the same concepts of common law as "duty of care" or "reasonable care." In general, we are not to act in a manner that could be foreseen to harm others. The key word "foreseen" indicates that there is no guarantee, simply a probability or likelihood that no harm will come to others. These concepts pose an obligation of responsibility to others in society to act prudently and with due diligence, but they recognize that there are inherent risks to any activity.
The Precautionary Principle could also be seen as a part of individual life choices. It recognizes and weighs the relative certainty of harm, or risk, over a wide range of individual health threats, as examples: a high-fatty food diet, smoking, and just about any activity that starts with the phrase, "hold my beer and watch this." The Precautionary Principle is what allows us to drive 65 miles per hour on many of our highways instead of 25 miles per hour. In this example of the speed limit, the level of risk, or probability of harm traveling faster, is at an acceptable level. The risk associated with traveling in our cars could be eliminated only by banning car travel, which only then would result in a no-risk scenario for car travel.
In order to establish what is an acceptable amount of exposure to chemicals or compounds present in our environment, the Precautionary Principle is implemented daily by the federal Environmental Protection Agency (EPA). The EPA has established the Integrated Risk Information System (IRIS). IRIS provides consistent information on chemicals or compounds for use in risk assessments, decision-making, and regulatory activities. This information could be used in many ways, ranging from how much cleanup is needed at a toxic chemical contaminated property to the safe amount of chemicals that can be in food additives or food packaging to the safe amount of chemicals that can be present in toys, or even to the safe amount of chemicals that should be present in drinking water or air. When conducting their risk assessments in support of the IRIS database, the EPA prefer to use conservative input values, calculations, and assumptions to overestimate the risk rather than underestimate it -- i.e., the Precautionary Principle.
We cannot eliminate risk to our health from some of the chemicals and compounds we are exposed to daily; many are naturally occurring in the environment. As an example, surface water and groundwater contain toxic metals such as arsenic and chromium that are naturally occurring by these metals being dissolved from the rocks that make up the earth's crust. These toxic metals can be present within our drinking water sources at concentrations related to their prevalence within the local geologic rock structures, and at times, they can exceed the EPA's allowable probability of harm in drinking water concentration. If these toxic metals are present above this allowable concentration, then the drinking water must be first treated to meet at least the EPA's safe drinking water concentration prior to distribution to the consumers.
There needs to be a balance between the benefits and conveniences to our lives and the probability of being reasonably protective of our health. Mortality is well-established at 100%. There cannot be a no-exposure scenario; some amount of health risk from exposure to naturally-occurring and manufactured chemicals is inherent in being alive.
Environmental activists have twisted the Precautionary Principle subjectively and eliminated the consideration of cost-effectiveness. The activists are willing to freely spend others' money to whatever extent they determine is needed. The need to respond to an unreasonable quantifiable risk has been replaced by the activists with a new threshold of demonstrating a reasonable certainty of no harm -- the terms "reasonable certainty" and "no harm" being quite subjective.
For man-made contributions of chemicals to the environment, additions to the natural level of chemicals present typically occur not on a whim, but rather to enhance our daily lives, make them easier, provide products that extend our lives, or mitigate other issues that arise as a result of modern life. An example would be the production of chlorine. An unavoidable outcome for the production of chlorine is a group of carcinogenic compounds called dioxins, which are also produced as part of the chlorine-manufacturing process. While dioxins do pose a human health risk if released from the chlorine production process, the benefits of manufacturing chlorine far outweigh the potential risks associated with dioxins. Chlorine is used as a water purifier throughout our country and the world, and sustains millions of lives by providing potable water free of microbial contamination.
As a legal obligation, the chemical manufacturers work with the EPA to provide information regarding their products and materials. This allows an assessment of risk to be accurately developed by the EPA. Most recently, the administrator of the EPA has revisited prior risk assessments for certain chemicals and lowered their allowable or targeted concentrations, and this administrator has also initiated a new program to assess risks to various other chemicals. With the EPA acting under cover of implementing the law, the Society of Chemical Manufacturers and Affiliates (SOCMA), an industry group who represent the chemical manufacturing industry, is preparing for more stringent requirements that will affect their economic activities. The Precautionary Principle can be used as an environmental activist's tool for social and economic manipulation.
Consider the use of the Precautionary Principle as it applies to the mandate to phase out incandescent light bulbs in our homes and offices and replace them with compact fluorescent lights (CFLs) containing mercury. This change of lighting was mandated in order to reduce electrical use, thereby reducing electric utility power plant greenhouse gas emissions. Even if we were to accept the allegation of man-induced global warming, the risk associated with a slightly warmer climate is debatable, while the risk from exposure to mercury when a CFL is inevitably broken in our homes is not.
According to the Maine Compact Fluorescent Lamp Study, as a result of a CFL breaking, mercury concentrations in their study room air often exceeded their allowable exposure level, based on Maine's human exposure and mercury toxicological studies for the protection of human health. There are clear and permanent toxic health effects caused by an unacceptable exposure to mercury, based on the federal Agency for Toxic Substances and Disease Registry website's ToxFAQs for mercury.
With the addition of the mercury-containing CFLs into our homes and offices, the cumulative risk, or probability of harm to human health, has increased, as a result of actions taken to address alleged man-induced global warming. In this example, it is clear that the Precautionary Principle is being used by environmental activists to manipulate social and economic activity. On one hand, CFL bulbs for in-home use are mandated but are a clearly unacceptable risk activity, while on the other hand, the vast uncertainty over man-induced global warming is accepted and used as the basis to cause the unacceptable potential risk of exposure to toxic mercury.
Recent examples of environmental activist misuse of the Precautionary Principle are numerous, and the numbers are growing. We have come to a time in our country where precaution has become subjective prohibition, where humanistic vanity to control others is prevalent, and where proportionality addressing the pressing problems facing our world today has been lost. We should be spending our efforts wisely to maintain our own economic abundance so that we may continue to help ourselves and others. Our abundance allows us to maintain a relatively high standard of living that benefits all in our country, in addition to providing huge contributions throughout the world to assist poor nations to grow crops, access clean water, overcome diseases that are only history to us, and respond to natural and man-made disasters.
Instead, the environmental activists would rather have us deal with a subjectively applied Precautionary Principle, cripple ourselves economically, and diminish our ability to help others and ourselves. We should bear in mind that economic and social manipulation, not reasonable precautions, is the environmental activist's true principle.