A lot of the Brussels conversation over the precautionary principle is misguided.
By 2030, the European Union’s “Farm to Fork” strategy aims to reduce the use of pesticides significantly. The EU deals in percentages of the total use of chemical substances it wants to cut, whether or not their scientific safety assessment was in any shape or form negative. This in essence makes it a political ambition, not an evidence-based policy.
When reading articles, blog posts, or policy papers related to the use of pesticides, we often hear the word “hazard”. “Highly-hazardous” chemicals or substances are in the focus of many environmental groups, who demand that the EU cleans up its act on the alleged ‘poison’ in our food. Theirs is a misunderstanding of the scientific meaning of “hazard” and “risk”.
Risk-based regulation manages exposure to hazards. For instance, the sun is a hazard when going to the beach, yet sunlight enables the body’s production of vitamin D and some exposure to it is essential to human health. As with everything else, it is the amount of exposure that matters. A hazard-based regulatory approach to sunlight would shut us all indoors and ban all beach excursions, rather than caution beach-goers to limit their exposure by applying sunscreen. The end result would be to harm, not protect human health.
The same logic of hazard-based regulation is all too often applied in crop protection regulation, where it creates equally absurd inconsistencies. For instance, if wine was sprayed on vineyards as a pesticide, it would have to be banned under EU law, as alcohol is a known and quite potent carcinogen at high levels of consumption. All this is rationalized through an inconsistent and distorted application of the precautionary principle. In essence, hazard-based regulation advocates would endorse outlawing all crop protection methods that cannot be proven completely safe at any level, no matter how unrealistic — a standard which, if applied consistently, would outlaw every organic food, every life-saving drug, and indeed every natural and synthetic substance.
By ignoring the importance of the equation Risk = Hazard x Exposure, hazard-based regulation does not follow a scientifically sound policy-making approach.
As risk-management expert David Zaruk writes on his blog The Risk-Monger:
“So why then are there individuals in Brussels who think that a regulator’s job is to remove all hazards, regardless of our ability to control exposure to the hazard, regardless of the limited exposure levels, regardless of the lost benefits? For these lobbyists (often activists for environmental-health NGOs), a hazard is considered as identical to a risk (regardless of exposure) and the regulatory goal (for them) is to remove all hazards. They support the approach known as: Hazard-based regulation.
Hazard-based regulation implies that the only way to manage risks is to remove the hazard. If synthetic pesticides are hazardous, remove them. If we cannot be certain that a chemical has no effect on our endocrine system (at any dose), then deny authorisation.”
This concept of differentiating hazard and risk in the scientific and regulatory language is also supported by EFSA — the European Food Safety Authority, which advises the European Union on things such as chemical approvals.
Understanding hazard and risk is essential when addressing all questions as they relate to the precautionary principle. Artificial intelligence is prone to fall victim to a similar level of over-regulation the advocates of extreme caution get their way. Instead, the European Union should choose the road to innovation. Evidence-based policy-making is about assessing risks, but it is also about managing risks for the sake of allowing for innovation while ironing out problems as they appear.
We cannot allow ourselves to fall behind in the global race for innovative technology because we are too afraid of changes.
This article was first published by The Conservative.
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