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#31 -- Reenergizing Public Health, 29-Mar-2006

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Rachel's Precaution Reporter #31

"Foresight and Precaution, in the News and in the World"

Wednesday, March 29, 2006............Printer-friendly version
www.rachel.org -- To make a secure donation, click here.
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Table of Contents...

Reenergizing Public Health Through Precaution
For more than 100 years the main goal of public health has been to
prevent disease and injury, and to foster conditions in which people
can be healthy. Unfortunately, in 1970, the U.S. chose to create a new
bureaucracy to "protect the environment" -- thus dividing
"environmentalists" from the public health community. Now
environmentalists are adopting the goal of preventing harm, so perhaps
the artificial barrier between environmental protection and public
health can disappear, natural allies can find each other, and new
partnerships can blossom.
300 Cosmetics and Body Care Companies Pledge Safer Products
More than 300 private manufacturers of cosmetics and personal care
products have signed a pledge to avoid the use of certain chemicals,
and to engage in a constant search for safer alternatives.
Nations Call for Global Moratorium On Genetically Engineered Trees
At an international conference on the United Nations Convention on
Biodiversity (CBD), delegates from around the world called for a
moratorium on the release of genetically engineered trees.
Tony Blair Invokes Precaution for Global Warming Treaty
"If we operate on anything like the precautionary principle, you
have to say that the science [of global warming] is sufficiently clear
and, in my view, is pretty much certain that it would be deeply
irresponsible not to take action." -- British Prime Minister Tony
Blair.

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From: American Journal of Public Health, Sept. 1, 2001
[Printer-friendly version]

REENERGIZING PUBLIC HEALTH THROUGH PRECAUTION

By David Kriebel and Joel Tickner**

Summary

The precautionary principle has provoked a spirited debate among
environmentalists worldwide, but it is equally relevant to public
health and shares much with primary prevention. Its central components
are (1) taking preventive action in the face of uncertainty; (2)
shifting the burden of proof to the proponents of an activity; (3)
exploring a wide range of alternatives to possibly harmful actions;
and (4) increasing public participation in decision making.

Precaution is relevant to public health, because it can help to
prevent unintended consequences of well-intentioned public health
interventions by ensuring a more thorough assessment of the problems
and proposed solutions. It can also be a positive force for
change.Three aspects are stressed: promoting the search for safer
technologies, encouraging greater democracy and openness in public
health policy, and stimulating reevaluation of the methods of public
health science.

In March, 1999, the Los Angeles Unified School District, the nation's
largest school district, announced a new policy on use of pesticides
in its school buildings. The district committed to a policy of
integrated pest management, giving priority to nonchemical approaches
to pest control, and set a long-term goal of eliminating all chemical
controls. In establishing this policy, the school district invoked the
precautionary principle, saying:

The Precautionary Principle is the long-term objective of the
District. The principle recognizes that:

1. No pesticide product is free from risk or threat to human health,
and

2. Industrial producers should be required to prove that their
pesticide products demonstrate an absence of [human health risks]
rather than requiring that the government or the public prove that
human health is being harmed.[1]

By stating a set of basic tenets (all pesticides are potentially
harmful, and nonchemical methods shall be preferred) and a long-term
objective ("to provide for the safest and lowest risk approach to
control pest problems while protecting people, the environment, and
property"), the policy stimulates the search for safer alternatives
without tying the hands of the district when no alternative to a
pesticide can be found. The policy is also significant for what it
does not include: there is no list of banned substances, nor a
stipulation of an "acceptable" level of risk. Whether or not one
agrees with this approach to pesticide management (we do), it seems
clear that the school district's invocation of the precautionary
principle raises important issues for public health scientists and
activists.

In this commentary, we briefly describe the key elements of the
precautionary principle, emphasizing several aspects important to
public health. Our perspective is informed by a university-community
collaborative effort to refine the meaning of the precautionary
principle and develop strategies for applying it to environmental
health policy.[2,3] We argue that the precautionary principle is good
for public health because it promotes the search for safer
technologies, encourages greater democracy and openness in public
health policy, and stimulates reevaluation of the methods of public
health science.

PRECAUTIONARY PRINCIPLE DEFINED

The definition of the precautionary principle developed for the Rio
Declaration of 1992 is often cited,[4] and the 1998 Wingspread
Statement contains similar language:

"when an activity raises threats of harm to human health or the
environment, precautionary measures should be taken even if some cause
and effect relationships are not fully established scientifically."[5]
The statement also lists 4 central components of the principle: (1)
taking preventive action in the face of uncertainty, (2) shifting the
burden of proof to the proponents of an activity, (3) exploring a wide
range of alternatives to possibly harmful actions, and (4) increasing
public participation in decision making.

The term "precautionary principle" was introduced into English as a
translation of the German word Vorsorgeprinzip. An alternative
translation might have been "foresight principle," which carries a
connotation of anticipatory action -- a positive, active idea --
rather than precaution, which to many sounds negative. In German
environmental policy, the Vorsorgeprinzip stimulates social planning
for innovation, sustainability, and job creation.[6]

In the United States, the precautionary principle is being promoted by
environmental and public health advocates.[3] To these groups, US
environmental policy often seems to be more reactionary than
precautionary, requiring a high degree of certainty of harm before
preventive action is taken and emphasizing management of risks rather
than prevention. The precautionary principle is viewed as an
opportunity to shift the terms of environmental debates by calling for
preventive action even when there is uncertainty (but with credible
evidence of potentially significant impacts), by shifting the burden
of monitoring and hazard assessment onto those who propose potentially
hazardous policies and by emphasizing alternatives and democracy.[5]

The American Public Health Association recently passed a resolution
reaffirming its support of the principle and urging its application in
the protection of children's health from environmental hazards.[7]
Strong support for precaution is also found in the environmental
policies of the European Union.[8]

The precautionary principle has been advocated for public health
because of the importance of anticipating unintended health
consequences of well-intentioned public health interventions.[9]
Seeking to avoid creating new problems while solving existing ones is
an important aspect of the precautionary principle, but it is not the
only way in which precaution can benefit public health.

FORESIGHT AND THE STIMULATION OF NEW TECHNOLOGIES

The identification of safer alternatives and opportunities for
prevention is central to the precautionary principle. Too frequently,
policymakers ask the question "How much risk does this activity pose,
and is it significant?" or "What level of risk is acceptable?" These
questions, deeply ingrained in the regulatory approaches of many
government agencies, tend to focus on the quantification of potential
hazards rather than the prevention of pollution.[10-12] They often
provoke a sharp debate about whether the risk has been characterized
accurately. When public health advocates and environmentalists enter
into this debate, they may inadvertently be ceding the most powerful
position, that of questioning whether the hazardous substance or
intervention is needed at all.

A different, and potentially more precautionary, way to think about
uncertain risks is to begin from a different set of questions: Is the
proposed activity needed, and if so, how much contamination can be
avoided while still achieving societal goals? and Are there
alternatives to this activity that clearly avoid hazards? For example,
chlorinated solvents fulfill a cleaning function that can often be
accomplished by aqueous solutions. This shift in perspective requires
a set of skills not always found in regulatory agencies -- technology
and product design, full-cost accounting and other management systems.
It also requires the broadest possible perspective on the potential
unintended consequences of policy choices.

A variety of methodologies exist with which to evaluate policy
alternatives and identify potential unintended consequences. Tradeoff
analysis has been proposed as an alternative to traditional cost-
benefit analysis and risk assessment; in trade-off analysis, the full
range of risks and benefits of competing technology options are
assessed without the requirement to translate the potential impacts
into a single quantitative figure.[13] Health impact assessments
provide a means to detect the negative health implications of non-
health-related governmental policies.[14] Work-environment impact
assessments can be used to identify ways in which an intervention in
the work environment may result in unanticipated health risks to
workers,[15] and the Pollution Prevention Options Analysis System
provides a comprehensive semiquantitative approach to comparing and
evaluating the potential adverse effects of technologies designed to
reduce chemical use and waste.[16]

Shifting the questions that frame the problem reorients the focus of
environmental policy from quantification of risks to analysis of
solutions and thus permits a broader examination of all the available
evidence on hazard, exposure, uncertainty, and alternatives. The
precautionary principle is a means of saying yes to innovative,
cleaner technologies (although critics have argued that it will only
lead to stopping new technologies). A thorough alternatives assessment
may identify needs for cleaner technologies, which in turn can inform
the planning of sustainable economic development activity.[11]

Quantitative risk assessment plays a central role in environmental
health policy in the United States. Weighing policy alternatives will
inevitably involve assessing and comparing risks, but the
determination of whether a risk is too big depends in part on whether
there are alternatives to reduce that risk. Availability of a safer
alternative can obviate the need for a costly, contentious, and
potentially misleading quantitative risk assessment.

The decision to ban the use of certain phthalate plasticizers in toys
provides an illustration. The Danish Environment Agency justified this
action with the following reasoning: There is evidence of children's
exposure and evidence of toxicity to animals; children are
particularly susceptible to many toxic substances; alternative
materials exist; and the product serves no necessary function. The
agency concluded that the plasticizers should not be used in toys (L.
Seedorf, MS, Director, Chemicals Division, Danish Environmental
Protection Agency, oral communication, May, 1999). The US Consumer
Product Safety Commission reached a similar decision, but only after a
costly, time-consuming quantitative risk assessment. The commission
concluded that given uncertainties in the size of the risk,
manufacturers should voluntarily remove these substances from
toys.[17] In the end the outcomes were the same, but the decision-
making approach and the costs to the public were quite different.

Foresight should involve setting long-term goals, a practice that is
fairly common in public health. Examples are the smallpox eradication
campaign, the US Public Health Service Healthy People 2010 priorities,
and national nutrition goals. Goal setting focuses not on what future
events are likely to happen but rather on how desirable future
outcomes can be obtained.[18] Once established, goals help to focus
attention on the development of policies and measures to achieve goals
while minimizing social disruption and unintended consequences.

With regard to hazardous substances, goals could include reducing
exposures to such substances, reducing production of hazards (e.g.,
phasing out the most hazardous chemicals), and reducing the incidence
of environmentally related diseases. Another suggested goal is to
reduce general population body burdens of broad classes of potentially
toxic substances by 5% to 10%.[19] Such an effort is likely per year.
to have a positive health impact, even though it may never be possible
to understand all of the ways in which mixtures of low concentrations
of chemicals may affect health.

DEMOCRACY AND PRECAUTION

Participation and transparency are essential components of a more
precautionary approach to public health decision making. Fiorino has
identified several reasons for democratizing environmental decision
making. First, because nonexperts think more broadly and are not bound
by disciplinary constraints, they see problems, issues, and solutions
that experts miss. Second, lay judgments reflect a sensitivity to
social and political values and common sense that experts' models do
not acknowledge. Third, the lay public may be better than experts at
accommodating uncertainty and correcting errors.[20] Openness brings
different perspectives, which may reduce the danger of an unintended
consequence. Also, the weighing of alternative policies should include
many points of view, because the benefits and costs of public health
and environmental policy choices may accrue to different groups.

When there is much uncertainty about alternative courses of action, it
is risky for experts to decide without input from affected
communities. The usual strategy is to attempt to present the options
as clear and the science as convincing. However, a long series of
public health and environmental crises that were apparently unforeseen
by scientists have undermined public confidence, making it more
difficult for simple reassurances to be effective. The list includes
the Three Mile Island and Chernobyl nuclear accidents, Love Canal, the
destruction of the ozone layer, and global warming. An increasingly
educated citizenry has begun to challenge the apparent confidence of
the experts. Add to this the successful campaigns of AIDS activists
and breast cancer survivors to participate in the planning of health
research, and it appears to be time to fundamentally change the way
that the public participates in the use of public health science.

Broader public participation processes may increase the quality,
legitimacy, and accountability of complex decisions. Given the public
nature of environmental decisions (which involve highly uncertain,
contested values), more effective processes for involving affected
communities could increase trust in government. Such processes must be
both fair and competent, meaning that they allow all those who want to
participate to have substantive access to the decision-making process
from the beginning and that they provide financial and technical
resources so citizens can participate on equal terms with experts.21
In addition, there must be clearly defined mechanisms by which citizen
input is fed into the policymaking process.

A long-term educational strategy to increase the public's
understanding of the strengths and limits of scientific evidence is
needed as part of increasing public participation. The Danish Board of
Technology has been experimenting for several years with innovative
forms of decision making on broad technology policy decisions. These
"consensus conferences" involve lay panels trained in the science and
other aspects of a contemporary concern, resulting in a focused
dialogue between the general public and experts. To date, more than 20
such conferences have been held in Denmark, informing government
policy on topics including genetically modified foods, the human
genome project, and air pollution.[22]

SCIENCE FOR PRECAUTION

Environmental scientists study highly complex, poorly understood
systems, in which causal links between exposures and disease are
difficult to quantify. In this uncertain terrain, what are the
appropriate standards of evidence for science to inform public health
policy? The answer must be tailored to the task. We believe that there
are ways in which the methods of scientific inquiry often implicitly
impede precautionary action, making it more difficult for policymakers
to take action in the face of uncertainty.[2] Often, scientific
research focuses on narrowly defined quantifiable aspects of a problem
while the reality is more complex, requiring systems-level thinking
and interdisciplinary research methods.

Public health scientists may be able to assist in the cause of
precaution by choosing research methods, well within the bounds of
good practice, that would be more helpful to policymakers faced with
high-stakes decisions and scientific uncertainty. For example, more
and better investigation and communication of uncertainties (what we
know, what we do not know, and what we cannot know) in study results
will assist a more open decision-making process. Public health
scientists could also use qualitative methods more effectively to
characterize the complexities of the populations, communities, and
ecosystems from which quantitative results are drawn.

Finally, the precautionary principle should challenge scientists to
explore new areas of research -- interactions, cumulative effects, and
effects on different levels of systems (individuals, families,
communities, nations) -- and new collaborations between disciplines
and scientists and the lay public. Multidisciplinary teams will be
more likely to develop hypotheses that lead to insights not possible
from narrow disciplinary viewpoints, as well as to identify data that
may not be accessible to one particular group. The development of the
environmental endocrine disruption hypothesis provides one
example.[23]

The precautionary principle represents a call to reevaluate the ways
in which science informs policy, and in particular the ways in which
scientific uncertainty should be handled. Scientific research plays an
essential role in evaluating the costs, risks, and benefits of
proposed public health policies, but the scientific data are often
limited by large areas of uncertainty. In these gray areas, activities
that potentially threaten public health are often allowed to continue
because the norms of traditional science demand high confidence to
reject null hypotheses and so detect harmful effects. This scientific
conservatism is often interpreted as favoring the promoters of a
potentially harmful technology or activity when the science does not
produce overwhelming evidence of harm. Being "conservative" in science
is not the same as being precautionary.

When there is substantial scientific uncertainty about the risks and
benefits of a proposed activity, policy decisions should be made in a
way that errs on the side of caution with respect to the environment
and the health of the public.[2]

PRECAUTION OR REACTION?

The precautionary principle has been criticized for being overly
vague.[24,25] To some extent the critics are correct, but much work is
now under way to define what precaution means in practice and how it
can improve decision making regarding uncertain, complex
hazards.[2,26,27] This is an opportunity for the public health
community to affect the ways in which precaution is defined in
practice. At the same time, there is a risk that proponents of the
principle will be held to an unrealistically high standard -- an
assumption that all public health problems should somehow be resolved
through the application of precaution. Where science and politics
collide, there will always be ambiguity and contention, and it seems
unreasonable to expect any single new idea to sweep these away
entirely. We should be careful not to overuse the precautionary
principle, particularly when there is clear evidence that damage has
been done or there is no reasonable evidence to suspect a risk to
public health.

If the precautionary principle represents a desirable goal in public
health, one may ask, What is the "not sufficiently precautionary
principle" on which policies are currently based? Too often, we
believe, public health and environmental policies are based on a
principle of reaction rather than precaution. Government regulatory
agencies are often put in the position of having to wait until
evidence of harm is established beyond all reasonable doubt before
they can act to prevent harm. A shift from reaction to precaution is
entirely consistent with the core values of public health practice. We
believe that public health officials, researchers, and advocates
should embrace the precautionary principle as an opportunity to
reinvigorate the great preventive tradition of public health action in
the face of uncertainty.

About the Authors

The authors are with the Lowell Center for Sustainable Production,
Department of Work Environment, University of Massachusetts, Lowell.

Requests for reprints should be sent to David Kriebel, ScD, Department
of Work Environment, University of Massachusetts Lowel, 1 University
Ave, Lowell, MA 01854 (e-mail: david_kriebel@uml.edu).

This commentary was accepted March 29, 2001.

Acknowledgments

This work was supported in part by grants from the John Merck Fund,
the Jessie B. Cox Charitable Trust, the New York Community Trust, the
V. Kann Rasmussen Foundation, and the Mitchell Kapor Foundation.

The Science and Precaution Working Group participated in discussions
that helped to define and clarify our understanding of the
precautionary principle. We thank Dr. Margaret Quinn for many helpful
comments. Dr. Carlos Eduardo Siqueira suggested that it might be
useful to define reaction as the status quo principle impeding
precaution.

References

1. Los Angeles Unified School District, unpublished policy, cited in
Rachel's Environment & Health News No. 684, January 27, 2000.
Accessed June 18, 2001.

2. Kriebel D, Tickner J, Epstein P, et al. The precautionary principle
in environmental science. Environ Health Perspect. Vol. 109, No. 9
(September 2001), pg. 871 and following pages
.

3. Ketelsen L. The Massachusetts Precautionary Principle Project: a
model for public health organizing and integrating public values into
"public" health. Paper presented at: Annual Meeting of the American
Public Health Association; Boston, Mass; November 15, 2000.

4. Rio Declaration on Environment and Development. Accessed June 18,
2001.

5. Raffensperger C, Tickner J, eds. Protecting Public Health and the
Environment: Implementing the Precautionary Principle. Washington, DC:
Island Press; 1999.

6. Boehmer-Christiansen S. The precautionary principle in Germany --
enabling government. In: O'Riordan T, Cameron J, eds. Interpreting the
Precautionary Principle. London, England: Earthscan; 1994:31-61.

7. APHA policy statement 200011: the precautionary principle and
children's health. Am J Public Health. 2001; 91:495-496.

8. Commission of the European Community. Communication from the
Commission on the Precautionary Principle
. Brussels, Belgium:
Commission of the European Community; 2000. Publication COM(2000)1.

9. Goldstein BD. The precautionary principle also applies to public
health actions. Am J Public Health. 2001;91:1358-1361.

10. Gauging Control Technology and Regulatory Impacts in Occupational
Safety and Health. Washington, DC: Office of Technology Assessment, US
Congress; 1995. OTA-ENV-635.

11. Quinn MM, Kriebel D, Geiser K, Moure-Eraso R. Sustainable
production: a proposed strategy for the work environment. Am J Ind
Med. 1998;34:297-304.

12. Commoner B. Making Peace with the Planet. New York, NY: Pantheon;
1990.

13. Ashford N. The role of risk assessment and cost/benefit analysis
in decisions concerning safety and the environment. In: FDA Symposium
on Risk/Benefit Decisions and the Public Health. Colorado Springs,
Colo: Office of Public Affairs, Food and Drug Administration;
1980:159-168.

14. Scott-Samuel A, Birley M, Ardern K. Merseyside Guidelines for
Health Impact Assessment
. Merseyside, UK: Merseyside Health Impact
Assessment Steering Group; 1998.

15. Rosenberg BJ, Barbeau EM, Moure-Eraso R, Levenstein C. The work
environment impact assessment: a methodologic framework for evaluating
health-based interventions. Am J Ind Med. 2001;39:218-226.

16. Tickner J. Pollution Prevention Options Analysis System -- P2OASYS
-- Users Guide. Lowell: Massachusetts Toxics Use Reduction Institute;
1997.

17. The Risk of Chronic Toxicity Associated with Exposure to
Diisononyl Phthalate (DINP) in Children's Products
. Washington, DC:
US Consumer Product Safety Commission; 1998. Also available at:
Accessed June 18, 2001.

18. Dreborg K. Essence of backcasting. Futures. 1996;28:813-838.

19. Jackson R. Unburdening ourselves. Silent Spring Review. Fall 2000.
Available at: http://www.silentspring.org. Accessed June 18, 2001.

20. Fiorino D. Citizen participation and environmental risk: a survey
of institutional mechanisms. Issues in Science and Technology.
1990;15:226-243.

21. Renn O, Webler T, Wiedermann P. Fairness and Competence in Citizen
Participation. Dordrecht, the Netherlands: Kluwer Academic Publishers;
1995.

22. Deniel P, Renn O. Planning cells: a gate for "fractal" mediation.
In: Renn O, Webler T, Wiedemann P, eds. Fairness and Competence in
Citizen Participation: Evaluating Models for Environmental Discourse.
Boston, Mass: Kluwer Academic Publishers; 1995:141-156.

23. Colborn T, Clement C. Chemicaly Induced Alterations in Sexual and
Functional Development: The Wildlife/Human Connection. Princeton, NJ:
Princeton Scientific Publishing Co; 1992.

24. Bodanksy D. The precautionary principle in US environmental law.
In: O'Riordan T, Cameron J, eds. Interpreting the Precautionary
Principle. London, England: Earthscan; 1994:203-228.

25. Graham J. Perspectives on the precautionary principle. Human and
Ecological Risk Assessment. 2000;6:383-385.

26. Tickner J, Raffensperger C, Myers N. The Precautionary Principle
in Action: A Handbook. Windsor, ND: Science and Environmental Health
Network; 1999.

27. Tickner J, Raffensperger C. The American view on the precautionary
principle. In: O'Riordan T, Cameron J, Jordan A, eds. Reinterpreting
the Precautionary Principle. London, England: Cameron & May; 2001.

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From: Campaign for Safe Cosmetics, Mar. 28, 2006
[Printer-friendly version]

300 COSMETICS AND BODY CARE COMPANIES PLEDGE SAFER PRODUCTS

Movement Toward Toxic-free Cosmetics Gains Momentum

SAN FRANCISCO -- More than 300 cosmetics and body care products
companies have promised to replace ingredients linked to cancer, birth
defects, hormone disruption and other negative health effects with
safer alternatives.

The Campaign for Safe Cosmetics announced today that it had more
than tripled the number of companies who have signed the "Compact for
the Global Production of Safe Health and Beauty Products
," in the
past year, signaling a shift toward healthier products in the
cosmetics industry. By signing the Compact, companies pledge to phase
out toxic ingredients within three years.

Women and girls use an average of 12 personal care products daily,
according to a 2004 survey conducted by the Campaign for Safe
Cosmetics. One out of every 100 personal care products on the market
contains known or probable carcinogens and 89 percent of ingredients
in products have not been assessed for safety, according to Skin
Deep
, an online, brand-by-brand safety guide that contains in-depth
information on more than 14,000 products and their ingredients by the
Environmental Working Group.

Compact signers include The Body Shop, Burt's Bees, Avalon Natural
Products, Aubrey Organics, Osea Skin Care, Jason Natural Products, Zia
Skin Care, EO Products and Kiss My Face. The names of all signing
companies can be found here.

The Campaign for Safe Cosmetics is a coalition of U.S.-based health
and environmental groups working to protect cosmetics consumers from
toxic chemicals and hold companies accountable for the safety of their
products.

"The surge in the number of companies signing the Compact shows that
corporate executives are listening to the voices of concerned
consumers," said Bryony Schwan, national campaigns director for
Women's Voices for the Earth, one of the founding members of the
Campaign for Safe Cosmetics. "Each new company that signs puts more
pressure on the major cosmetics manufacturers to get on board and
clean up their products too."

Despite repeated requests, multinational cosmetics companies such as
L'Oreal, Revlon, Estee Lauder, Gap, Avon, OPI and Proctor & Gamble
have refused to sign the Compact, known as the "Compact for the Global
Production of Safe Health and Beauty Products," which requires that
manufacturers meet several criteria, including:

-- Meeting new EU standards banning chemicals linked to cancer and
birth defects globally;

-- Conducting an inventory of all ingredients to determine whether
they use chemicals that pose health hazards including cancer, hormone
disruption, genetic mutation, reproductive toxicity, developmental
harm and neurotoxicity;

-- Implementing substitution plans that replace chemicals of concern
with safer alternatives; and

-- Reporting on their progress in meeting these goals to the public.

Contrary to what many consumers may believe, the FDA does not review
or regulate cosmetics products or ingredients for safety before they
are sold to the public and has no legal authority to require safety
assessments of cosmetics.

The EU has led the charge for safer cosmetics. European Union
Directive 76/768/EEC
, which became law in 25 European countries on
October 1, 2004, requires products to be free of chemicals that are
known or strongly suspected of causing cancer, genetic mutation or
birth defects.

"Companies that market themselves with images of health and beauty
should not be selling us products with ingredients like formaldehyde,
coal tar, lead acetate, phthalates, parabens and toluene, which pose
cancer risks and raise other health concerns," Schwann said.

# # #

Founding members of The Campaign for Safe Cosmetics include:

Alliance for a Healthy Tomorrow

Breast Cancer Fund

Commonweal

Friends of the Earth

Women's Voices for the Earth

Environmental Working Group

National Black Environmental Justice Network

National Environmental Trust.

For more information and background on the campaign, and a link to the
Skin Deep database, visit www.SafeCosmetics.org.

Lisa Archer
Campaigns Coordinator
Health and Environment Program
Friends of the Earth-US
larcher@foe.org
202-222-0712
www.foe.org
www.safecosmetics.org

Contacts:
Genevieve Roja
Breast Cancer Fund
(415) 346-8223 x31

Stacy Malkan
Campaign for Safe Cosmetics
(510) 848-5343 x105

Dick Bell
Friends of the Earth
202-222-0742

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From: Upside Down World, Mar. 28, 2006
[Printer-friendly version]

NATIONS CALL FOR GLOBAL MORATORIUM ON GENETICALLY ENGINEERED TREES

By Global Justice Ecology Project

On Wednesday, 22 March, delegates from countries around the world
raised the call for a moratorium on the release of genetically
engineered trees into the environment at the UN Convention on
Biological Diversity's (CBD's) Eighth Conference of the Parties in
Curitiba, Brazil.

Additional delegates also insisted that the CBD [UN Convention on
Biological Diversity] launch a thorough global examination of the
risks and impacts of genetically engineered trees -- risks which have
not, at this point, been adequately examined.

"Yesterday was truly an historic day," stated Orin Langelle, Co-
Director of the Global Justice Ecology Project and Coordinator of the
STOP GE Trees Campaign. "The alarm bells we have been sounding about
the genetic engineering of trees have finally been heard," he
continued.

"Promoters of this irresponsible and dangerous technology have now
officially been put on notice that people and countries around the
world stand firmly opposed to genetically engineered trees -- just as
GM crops and terminator technology are already opposed," stated
Lambert Okrah, of the Ghana chapter of the Global Forest Coalition.
"We further applaud the courageous and far-sighted positions of
countries such as Ghana, Iran, Norway, Madagascar, Egypt, Philippines,
Senegal, Malawi and others in raising the call for a moratorium on
genetically engineered trees," he continued.

Interventions in support of the call for a moratorium were presented
by Global Justice Ecology Project for the Women's Caucus, the
International Indigenous Forum on Biodiversity, Global Forest
Coalition
, Greenpeace, and the Federation of German Scientists.

"Because there is insufficient scientific data regarding the
biological impacts of transgenic trees, as well as an absence of
socio-economic and cultural impact assessments, it is good scientific
practice to invoke the Precautionary Principle, which is enshrined in
the CBD," stated Dr. Ricarda Steinbrecher of the Federation of German
Scientists. "This means no release of transgenic trees into the
environment whilst this research is on-going," she added.

The release of transgenic trees will inevitably and irreversibly
contaminate native forests, which will themselves become contaminants
in an endless cycle. The potential effects include destruction of
biodiversity and wildlife, loss of fresh water, desertification of
soils, collapse of native forest ecosystems, cultural destruction of
forest based traditional communities and severe human health impacts.
The negative effects of transgenic trees will impact many generations
to come.

Press release issued by Global Justice Ecology Project, Global Forest
Coalition, World Rainforest Movement, Friends of the Earth
International, EcoNexus and the STOP GE Trees Campaign.

Contact: Anne Petermann, Global Justice Ecology Project,
+1-802-578-6980

Simone Lovera, Global Forest Coalition, 41-9978-3582

========================================================

Intervention from the Women's Caucus Regarding Transgenic Trees.
March 22, 2006

Delivered by Anne Petermann

My name is Anne Petermann and I am the co-Director of Global Justice
Ecology Project. I am speaking today on behalf of the Women's Caucus
on the issue of transgenic trees, SBSSTA recommendation X1/11 para. 9.

People all over the world are rising up to oppose transgenic trees,
including 2,000 organizations that have signed onto a ban. Transgenic
trees are a unique case. Trees live for centuries if not millennia.
Pollen models created in 2004 by Duke University researchers
demonstrated pollen from native forests in the Southeast U.S.
traveling in air currents for more than 1,200km north into eastern
Canada. This means that transgenic trees cannot be regulated only at
the national level. Transboundary contamination of native forests with
transgenic traits is virtually assured. The Biosafety Protocol, which
is based on national borders, is not adequate.

The release of transgenic trees will inevitably and irreversibly
contaminate native forests, which will themselves become contaminants
in an endless cycle. The potential effects include destruction of
biodiversity and wildlife, loss of fresh water, desertification of
soils, collapse of native forest ecosystems, cultural destruction of
forest based traditional communities and severe human health impacts.
The negative effects of transgenic trees will impact many generations
to come.

Women are the ones who think in terms of generations. It is women in
rural and indigenous communities who will bear the greatest burden of
the impacts of GM tree plantations, just as they currently bear the
brunt of the impacts from conventional monoculture tree plantations.

The potential human health impacts of transgenic trees, especially Bt
trees, have not been adequately researched.

Numerous studies have raised serious questions about the potential
health impacts of Bt toxin. A series of published studies found that
Bt provokes a potent systemic immune reaction. Because the risk is
greater with inhalation than ingestion, engineering trees to produce
Bt toxin could be very dangerous. Plantations of Bt trees could
potentially lead to widespread outbreaks of sickness. Women and
children will bear the brunt of this.

In July, 2005 the FAO [United Nations Food and Agriculture
Organization] published a report entitled "Preliminary Review of
Biotechnology in Forestry Including Genetic Modification." In it, over
half of researchers surveyed reported the environmental threat of
escape of transgenic pollen or plants into native ecosystems and
forests and their impacts on non-target species as a major concern.
The FAO report concludes, "New biotechnologies, in particular genetic
modification, raise concerns. Admittedly, many questions remain
unanswered for both agricultural crops and trees. Given that genetic
modification in trees is already entering the commercial phase with GM
populus in China, it is very important that environmental risk
assessment studies are conducted with protocols and methodologies
agreed upon at a national level and an international level and that
the results of such studies are made widely available."

In conclusion, the genetic engineering of trees is being driven by
corporate profit. There is no need for GE trees. Just as women and
indigenous peoples have been the traditional caretakers of
biodiversity, so must this body take action to prevent the ecological,
social, cultural and health disasters that will be unleashed by
genetically engineered trees.

The speed with which the technology is progressing is outpacing
regulation and risk assessment. There has been a severe lack of study
of the risks of GM trees, especially on a global scale. This lack of
risk assessment makes it common sense that there not be any further
forward motion in the release of transgenic trees. The CBD must impose
a moratorium on the technology and launch a thorough and global
examination of its risks. In addition, we ask those countries with
outdoor releases of GM trees to take immediate steps to halt the
further release of GM trees and to address those releases that have
already occurred.

For more details see our a briefing paper on the issue.

For more information, visit Globaljusticeecology.org.

Return to Table of Contents

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From: HindustanTimes.com (New Delhi, India), Mar. 29, 2006
[Printer-friendly version]

'CLIMATE CHANGE DEAL TO FAIL WITHOUT CHINA, INDIA'

By Agence France-Presse

Auckland, New Zealand -- British Prime Minister Tony Blair called on
Wednesday for an international agreement on tackling climate change.

But warned that any deal would fail unless it included the United
States, China and India.

Speaking at the end of a brief stop in New Zealand in which global
warming has dominated the agenda, Blair said failing to address the
issue would be handing on an irresponsible legacy to future
generations.

"What's necessary is to get an international agreement that has got a
framework with a stabilisation goal in it, so that we can set a very
clear objective for everybody to aim at," he told journalists after
talks with counterpart Helen Clark.

"Without the participation of America and the emerging economies of
China and India there isn't going to be a solution," Blair said.

The United States rejected the 1997 UN Kyoto Protocol to cut
greenhouse gas emissions as too expensive for its oil-dependent
economy and the booming economies of China and India are two of the
fast-growing users of fossil fuels.

Blair said seizing the initiative on the issue would require changes
in lifestyle and radical technological solutions.

"You've got to develop the science, the technology and the changes in
behaviour necessary to meet that goal.

"But it won't be done unless there is a development of the technology
that, I think, needs to be as revolutionary as the Internet was for
information technology."

His own government's climate policy review, published Tuesday,
indicated Britain is likely to better Kyoto's target of a 12.5 per
cent reduction in overall carbon emissions.

But it also suggested London would fall short of its own long-standing
commitment to cut carbon dioxide gases by 20 per cent of 1990 levels
by 2010.

Instead CO2 emissions were likely to be cut by 15-18 per cent, the
report said.

Climate change figured high on the agenda of the New Zealand leg of
Blair's Asia-Pacific tour.

He earlier told a conference in Wellington that any failure to strike
a deal would hand an appalling legacy to future generations.

Blair said the world had to build on the emerging consensus about the
man-made causes of climate change at meetings of the Group of Eight
richest nations in St Petersburg, Russia, and G8 plus five in Mexico
in September.

"If we operate on anything like the precautionary principle, you have
to say that the science is sufficiently clear and, in my view, is
pretty much certain that it would be deeply irresponsible not to take
action," he said.

He added: "I do not want it on the conscience certainly of me and
people of my generation that we were told what this problem was in the
early part of the 21st century, did nothing about it and then my
children and their children end up having to deal with the
consequences."

Clark told a joint news conference with Blair in Auckland that the
visit -- the first bilateral visit by a British prime minister since
1958 -- had strengthened the relationship between their two countries.

Their talks included Afghanistan, where both countries have been
involved in reconstruction and counter-narcotics efforts following the
fall of the hardline Islamist Taliban regime, plus bilateral
immigration and investment.

They also agreed to set up annual security talks covering counter-
terrorism, combating arms proliferation, organised crime, narcotics as
well as global and regional issues.

Blair leaves New Zealand on Wednesday for Indonesia.

Return to Table of Contents

:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::

Rachel's Precaution Reporter offers news, views and practical
examples of the Precautionary Principle, or Foresight Principle, in
action. The Precautionary Principle is a modern way of making
decisions, to minimize harm. Rachel's Precaution Reporter tries to
answer such questions as, Why do we need the precautionary
principle? Who is using precaution? Who is opposing precaution?

We often include attacks on the precautionary principle because we
believe it is essential for advocates of precaution to know what
their adversaries are saying, just as abolitionists in 1830 needed
to know the arguments used by slaveholders.

Rachel's Precaution Reporter is published as often as necessary to
provide readers with up-to-date coverage of the subject.

As you come across stories that illustrate the precautionary
principle -- or the need for the precautionary principle --
please Email them to us at rpr@rachel.org.

Editors:
Peter Montague - peter@rachel.org
Tim Montague - tim@rachel.org

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Table of Contents...

Reenergizing Public Health Through Precaution
For more than 100 years the main goal of public health has been to
prevent disease and injury, and to foster conditions in which people
can be healthy. Unfortunately, in 1970, the U.S. chose to create a new
bureaucracy to "protect the environment" -- thus dividing
"environmentalists" from the public health community. Now
environmentalists are adopting the goal of preventing harm, so perhaps
the artificial barrier between environmental protection and public
health can disappear, natural allies can find each other, and new
partnerships can blossom.
300 Cosmetics and Body Care Companies Pledge Safer Products
More than 300 private manufacturers of cosmetics and personal care
products have signed a pledge to avoid the use of certain chemicals,
and to engage in a constant search for safer alternatives.
Nations Call for Global Moratorium On Genetically Engineered Trees
At an international conference on the United Nations Convention on
Biodiversity (CBD), delegates from around the world called for a
moratorium on the release of genetically engineered trees.
Tony Blair Invokes Precaution for Global Warming Treaty
"If we operate on anything like the precautionary principle, you
have to say that the science [of global warming] is sufficiently clear
and, in my view, is pretty much certain that it would be deeply
irresponsible not to take action." -- British Prime Minister Tony
Blair.

::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::
From: American Journal of Public Health, Sept. 1, 2001
[Printer-friendly version]

REENERGIZING PUBLIC HEALTH THROUGH PRECAUTION

By David Kriebel and Joel Tickner**

Summary

The precautionary principle has provoked a spirited debate among
environmentalists worldwide, but it is equally relevant to public
health and shares much with primary prevention. Its central components
are (1) taking preventive action in the face of uncertainty; (2)
shifting the burden of proof to the proponents of an activity; (3)
exploring a wide range of alternatives to possibly harmful actions;
and (4) increasing public participation in decision making.

Precaution is relevant to public health, because it can help to
prevent unintended consequences of well-intentioned public health
interventions by ensuring a more thorough assessment of the problems
and proposed solutions. It can also be a positive force for
change.Three aspects are stressed: promoting the search for safer
technologies, encouraging greater democracy and openness in public
health policy, and stimulating reevaluation of the methods of public
health science.

In March, 1999, the Los Angeles Unified School District, the nation's
largest school district, announced a new policy on use of pesticides
in its school buildings. The district committed to a policy of
integrated pest management, giving priority to nonchemical approaches
to pest control, and set a long-term goal of eliminating all chemical
controls. In establishing this policy, the school district invoked the
precautionary principle, saying:

The Precautionary Principle is the long-term objective of the
District. The principle recognizes that:

1. No pesticide product is free from risk or threat to human health,
and

2. Industrial producers should be required to prove that their
pesticide products demonstrate an absence of [human health risks]
rather than requiring that the government or the public prove that
human health is being harmed.[1]

By stating a set of basic tenets (all pesticides are potentially
harmful, and nonchemical methods shall be preferred) and a long-term
objective ("to provide for the safest and lowest risk approach to
control pest problems while protecting people, the environment, and
property"), the policy stimulates the search for safer alternatives
without tying the hands of the district when no alternative to a
pesticide can be found. The policy is also significant for what it
does not include: there is no list of banned substances, nor a
stipulation of an "acceptable" level of risk. Whether or not one
agrees with this approach to pesticide management (we do), it seems
clear that the school district's invocation of the precautionary
principle raises important issues for public health scientists and
activists.

In this commentary, we briefly describe the key elements of the
precautionary principle, emphasizing several aspects important to
public health. Our perspective is informed by a university-community
collaborative effort to refine the meaning of the precautionary
principle and develop strategies for applying it to environmental
health policy.[2,3] We argue that the precautionary principle is good
for public health because it promotes the search for safer
technologies, encourages greater democracy and openness in public
health policy, and stimulates reevaluation of the methods of public
health science.

PRECAUTIONARY PRINCIPLE DEFINED

The definition of the precautionary principle developed for the Rio
Declaration of 1992 is often cited,[4] and the 1998 Wingspread
Statement contains similar language:

"when an activity raises threats of harm to human health or the
environment, precautionary measures should be taken even if some cause
and effect relationships are not fully established scientifically."[5]
The statement also lists 4 central components of the principle: (1)
taking preventive action in the face of uncertainty, (2) shifting the
burden of proof to the proponents of an activity, (3) exploring a wide
range of alternatives to possibly harmful actions, and (4) increasing
public participation in decision making.

The term "precautionary principle" was introduced into English as a
translation of the German word Vorsorgeprinzip. An alternative
translation might have been "foresight principle," which carries a
connotation of anticipatory action -- a positive, active idea --
rather than precaution, which to many sounds negative. In German
environmental policy, the Vorsorgeprinzip stimulates social planning
for innovation, sustainability, and job creation.[6]

In the United States, the precautionary principle is being promoted by
environmental and public health advocates.[3] To these groups, US
environmental policy often seems to be more reactionary than
precautionary, requiring a high degree of certainty of harm before
preventive action is taken and emphasizing management of risks rather
than prevention. The precautionary principle is viewed as an
opportunity to shift the terms of environmental debates by calling for
preventive action even when there is uncertainty (but with credible
evidence of potentially significant impacts), by shifting the burden
of monitoring and hazard assessment onto those who propose potentially
hazardous policies and by emphasizing alternatives and democracy.[5]

The American Public Health Association recently passed a resolution
reaffirming its support of the principle and urging its application in
the protection of children's health from environmental hazards.[7]
Strong support for precaution is also found in the environmental
policies of the European Union.[8]

The precautionary principle has been advocated for public health
because of the importance of anticipating unintended health
consequences of well-intentioned public health interventions.[9]
Seeking to avoid creating new problems while solving existing ones is
an important aspect of the precautionary principle, but it is not the
only way in which precaution can benefit public health.

FORESIGHT AND THE STIMULATION OF NEW TECHNOLOGIES

The identification of safer alternatives and opportunities for
prevention is central to the precautionary principle. Too frequently,
policymakers ask the question "How much risk does this activity pose,
and is it significant?" or "What level of risk is acceptable?" These
questions, deeply ingrained in the regulatory approaches of many
government agencies, tend to focus on the quantification of potential
hazards rather than the prevention of pollution.[10-12] They often
provoke a sharp debate about whether the risk has been characterized
accurately. When public health advocates and environmentalists enter
into this debate, they may inadvertently be ceding the most powerful
position, that of questioning whether the hazardous substance or
intervention is needed at all.

A different, and potentially more precautionary, way to think about
uncertain risks is to begin from a different set of questions: Is the
proposed activity needed, and if so, how much contamination can be
avoided while still achieving societal goals? and Are there
alternatives to this activity that clearly avoid hazards? For example,
chlorinated solvents fulfill a cleaning function that can often be
accomplished by aqueous solutions. This shift in perspective requires
a set of skills not always found in regulatory agencies -- technology
and product design, full-cost accounting and other management systems.
It also requires the broadest possible perspective on the potential
unintended consequences of policy choices.

A variety of methodologies exist with which to evaluate policy
alternatives and identify potential unintended consequences. Tradeoff
analysis has been proposed as an alternative to traditional cost-
benefit analysis and risk assessment; in trade-off analysis, the full
range of risks and benefits of competing technology options are
assessed without the requirement to translate the potential impacts
into a single quantitative figure.[13] Health impact assessments
provide a means to detect the negative health implications of non-
health-related governmental policies.[14] Work-environment impact
assessments can be used to identify ways in which an intervention in
the work environment may result in unanticipated health risks to
workers,[15] and the Pollution Prevention Options Analysis System
provides a comprehensive semiquantitative approach to comparing and
evaluating the potential adverse effects of technologies designed to
reduce chemical use and waste.[16]

Shifting the questions that frame the problem reorients the focus of
environmental policy from quantification of risks to analysis of
solutions and thus permits a broader examination of all the available
evidence on hazard, exposure, uncertainty, and alternatives. The
precautionary principle is a means of saying yes to innovative,
cleaner technologies (although critics have argued that it will only
lead to stopping new technologies). A thorough alternatives assessment
may identify needs for cleaner technologies, which in turn can inform
the planning of sustainable economic development activity.[11]

Quantitative risk assessment plays a central role in environmental
health policy in the United States. Weighing policy alternatives will
inevitably involve assessing and comparing risks, but the
determination of whether a risk is too big depends in part on whether
there are alternatives to reduce that risk. Availability of a safer
alternative can obviate the need for a costly, contentious, and
potentially misleading quantitative risk assessment.

The decision to ban the use of certain phthalate plasticizers in toys
provides an illustration. The Danish Environment Agency justified this
action with the following reasoning: There is evidence of children's
exposure and evidence of toxicity to animals; children are
particularly susceptible to many toxic substances; alternative
materials exist; and the product serves no necessary function. The
agency concluded that the plasticizers should not be used in toys (L.
Seedorf, MS, Director, Chemicals Division, Danish Environmental
Protection Agency, oral communication, May, 1999). The US Consumer
Product Safety Commission reached a similar decision, but only after a
costly, time-consuming quantitative risk assessment. The commission
concluded that given uncertainties in the size of the risk,
manufacturers should voluntarily remove these substances from
toys.[17] In the end the outcomes were the same, but the decision-
making approach and the costs to the public were quite different.

Foresight should involve setting long-term goals, a practice that is
fairly common in public health. Examples are the smallpox eradication
campaign, the US Public Health Service Healthy People 2010 priorities,
and national nutrition goals. Goal setting focuses not on what future
events are likely to happen but rather on how desirable future
outcomes can be obtained.[18] Once established, goals help to focus
attention on the development of policies and measures to achieve goals
while minimizing social disruption and unintended consequences.

With regard to hazardous substances, goals could include reducing
exposures to such substances, reducing production of hazards (e.g.,
phasing out the most hazardous chemicals), and reducing the incidence
of environmentally related diseases. Another suggested goal is to
reduce general population body burdens of broad classes of potentially
toxic substances by 5% to 10%.[19] Such an effort is likely per year.
to have a positive health impact, even though it may never be possible
to understand all of the ways in which mixtures of low concentrations
of chemicals may affect health.

DEMOCRACY AND PRECAUTION

Participation and transparency are essential components of a more
precautionary approach to public health decision making. Fiorino has
identified several reasons for democratizing environmental decision
making. First, because nonexperts think more broadly and are not bound
by disciplinary constraints, they see problems, issues, and solutions
that experts miss. Second, lay judgments reflect a sensitivity to
social and political values and common sense that experts' models do
not acknowledge. Third, the lay public may be better than experts at
accommodating uncertainty and correcting errors.[20] Openness brings
different perspectives, which may reduce the danger of an unintended
consequence. Also, the weighing of alternative policies should include
many points of view, because the benefits and costs of public health
and environmental policy choices may accrue to different groups.

When there is much uncertainty about alternative courses of action, it
is risky for experts to decide without input from affected
communities. The usual strategy is to attempt to present the options
as clear and the science as convincing. However, a long series of
public health and environmental crises that were apparently unforeseen
by scientists have undermined public confidence, making it more
difficult for simple reassurances to be effective. The list includes
the Three Mile Island and Chernobyl nuclear accidents, Love Canal, the
destruction of the ozone layer, and global warming. An increasingly
educated citizenry has begun to challenge the apparent confidence of
the experts. Add to this the successful campaigns of AIDS activists
and breast cancer survivors to participate in the planning of health
research, and it appears to be time to fundamentally change the way
that the public participates in the use of public health science.

Broader public participation processes may increase the quality,
legitimacy, and accountability of complex decisions. Given the public
nature of environmental decisions (which involve highly uncertain,
contested values), more effective processes for involving affected
communities could increase trust in government. Such processes must be
both fair and competent, meaning that they allow all those who want to
participate to have substantive access to the decision-making process
from the beginning and that they provide financial and technical
resources so citizens can participate on equal terms with experts.21
In addition, there must be clearly defined mechanisms by which citizen
input is fed into the policymaking process.

A long-term educational strategy to increase the public's
understanding of the strengths and limits of scientific evidence is
needed as part of increasing public participation. The Danish Board of
Technology has been experimenting for several years with innovative
forms of decision making on broad technology policy decisions. These
"consensus conferences" involve lay panels trained in the science and
other aspects of a contemporary concern, resulting in a focused
dialogue between the general public and experts. To date, more than 20
such conferences have been held in Denmark, informing government
policy on topics including genetically modified foods, the human
genome project, and air pollution.[22]

SCIENCE FOR PRECAUTION

Environmental scientists study highly complex, poorly understood
systems, in which causal links between exposures and disease are
difficult to quantify. In this uncertain terrain, what are the
appropriate standards of evidence for science to inform public health
policy? The answer must be tailored to the task. We believe that there
are ways in which the methods of scientific inquiry often implicitly
impede precautionary action, making it more difficult for policymakers
to take action in the face of uncertainty.[2] Often, scientific
research focuses on narrowly defined quantifiable aspects of a problem
while the reality is more complex, requiring systems-level thinking
and interdisciplinary research methods.

Public health scientists may be able to assist in the cause of
precaution by choosing research methods, well within the bounds of
good practice, that would be more helpful to policymakers faced with
high-stakes decisions and scientific uncertainty. For example, more
and better investigation and communication of uncertainties (what we
know, what we do not know, and what we cannot know) in study results
will assist a more open decision-making process. Public health
scientists could also use qualitative methods more effectively to
characterize the complexities of the populations, communities, and
ecosystems from which quantitative results are drawn.

Finally, the precautionary principle should challenge scientists to
explore new areas of research -- interactions, cumulative effects, and
effects on different levels of systems (individuals, families,
communities, nations) -- and new collaborations between disciplines
and scientists and the lay public. Multidisciplinary teams will be
more likely to develop hypotheses that lead to insights not possible
from narrow disciplinary viewpoints, as well as to identify data that
may not be accessible to one particular group. The development of the
environmental endocrine disruption hypothesis provides one
example.[23]

The precautionary principle represents a call to reevaluate the ways
in which science informs policy, and in particular the ways in which
scientific uncertainty should be handled. Scientific research plays an
essential role in evaluating the costs, risks, and benefits of
proposed public health policies, but the scientific data are often
limited by large areas of uncertainty. In these gray areas, activities
that potentially threaten public health are often allowed to continue
because the norms of traditional science demand high confidence to
reject null hypotheses and so detect harmful effects. This scientific
conservatism is often interpreted as favoring the promoters of a
potentially harmful technology or activity when the science does not
produce overwhelming evidence of harm. Being "conservative" in science
is not the same as being precautionary.

When there is substantial scientific uncertainty about the risks and
benefits of a proposed activity, policy decisions should be made in a
way that errs on the side of caution with respect to the environment
and the health of the public.[2]

PRECAUTION OR REACTION?

The precautionary principle has been criticized for being overly
vague.[24,25] To some extent the critics are correct, but much work is
now under way to define what precaution means in practice and how it
can improve decision making regarding uncertain, complex
hazards.[2,26,27] This is an opportunity for the public health
community to affect the ways in which precaution is defined in
practice. At the same time, there is a risk that proponents of the
principle will be held to an unrealistically high standard -- an
assumption that all public health problems should somehow be resolved
through the application of precaution. Where science and politics
collide, there will always be ambiguity and contention, and it seems
unreasonable to expect any single new idea to sweep these away
entirely. We should be careful not to overuse the precautionary
principle, particularly when there is clear evidence that damage has
been done or there is no reasonable evidence to suspect a risk to
public health.

If the precautionary principle represents a desirable goal in public
health, one may ask, What is the "not sufficiently precautionary
principle" on which policies are currently based? Too often, we
believe, public health and environmental policies are based on a
principle of reaction rather than precaution. Government regulatory
agencies are often put in the position of having to wait until
evidence of harm is established beyond all reasonable doubt before
they can act to prevent harm. A shift from reaction to precaution is
entirely consistent with the core values of public health practice. We
believe that public health officials, researchers, and advocates
should embrace the precautionary principle as an opportunity to
reinvigorate the great preventive tradition of public health action in
the face of uncertainty.

About the Authors

The authors are with the Lowell Center for Sustainable Production,
Department of Work Environment, University of Massachusetts, Lowell.

Requests for reprints should be sent to David Kriebel, ScD, Department
of Work Environment, University of Massachusetts Lowel, 1 University
Ave, Lowell, MA 01854 (e-mail: david_kriebel@uml.edu).

This commentary was accepted March 29, 2001.

Acknowledgments

This work was supported in part by grants from the John Merck Fund,
the Jessie B. Cox Charitable Trust, the New York Community Trust, the
V. Kann Rasmussen Foundation, and the Mitchell Kapor Foundation.

The Science and Precaution Working Group participated in discussions
that helped to define and clarify our understanding of the
precautionary principle. We thank Dr. Margaret Quinn for many helpful
comments. Dr. Carlos Eduardo Siqueira suggested that it might be
useful to define reaction as the status quo principle impeding
precaution.

References

1. Los Angeles Unified School District, unpublished policy, cited in
Rachel's Environment & Health News No. 684, January 27, 2000.
Accessed June 18, 2001.

2. Kriebel D, Tickner J, Epstein P, et al. The precautionary principle
in environmental science. Environ Health Perspect. Vol. 109, No. 9
(September 2001), pg. 871 and following pages
.

3. Ketelsen L. The Massachusetts Precautionary Principle Project: a
model for public health organizing and integrating public values into
"public" health. Paper presented at: Annual Meeting of the American
Public Health Association; Boston, Mass; November 15, 2000.

4. Rio Declaration on Environment and Development. Accessed June 18,
2001.

5. Raffensperger C, Tickner J, eds. Protecting Public Health and the
Environment: Implementing the Precautionary Principle. Washington, DC:
Island Press; 1999.

6. Boehmer-Christiansen S. The precautionary principle in Germany --
enabling government. In: O'Riordan T, Cameron J, eds. Interpreting the
Precautionary Principle. London, England: Earthscan; 1994:31-61.

7. APHA policy statement 200011: the precautionary principle and
children's health. Am J Public Health. 2001; 91:495-496.

8. Commission of the European Community. Communication from the
Commission on the Precautionary Principle
. Brussels, Belgium:
Commission of the European Community; 2000. Publication COM(2000)1.

9. Goldstein BD. The precautionary principle also applies to public
health actions. Am J Public Health. 2001;91:1358-1361.

10. Gauging Control Technology and Regulatory Impacts in Occupational
Safety and Health. Washington, DC: Office of Technology Assessment, US
Congress; 1995. OTA-ENV-635.

11. Quinn MM, Kriebel D, Geiser K, Moure-Eraso R. Sustainable
production: a proposed strategy for the work environment. Am J Ind
Med. 1998;34:297-304.

12. Commoner B. Making Peace with the Planet. New York, NY: Pantheon;
1990.

13. Ashford N. The role of risk assessment and cost/benefit analysis
in decisions concerning safety and the environment. In: FDA Symposium
on Risk/Benefit Decisions and the Public Health. Colorado Springs,
Colo: Office of Public Affairs, Food and Drug Administration;
1980:159-168.

14. Scott-Samuel A, Birley M, Ardern K. Merseyside Guidelines for
Health Impact Assessment
. Merseyside, UK: Merseyside Health Impact
Assessment Steering Group; 1998.

15. Rosenberg BJ, Barbeau EM, Moure-Eraso R, Levenstein C. The work
environment impact assessment: a methodologic framework for evaluating
health-based interventions. Am J Ind Med. 2001;39:218-226.

16. Tickner J. Pollution Prevention Options Analysis System -- P2OASYS
-- Users Guide. Lowell: Massachusetts Toxics Use Reduction Institute;
1997.

17. The Risk of Chronic Toxicity Associated with Exposure to
Diisononyl Phthalate (DINP) in Children's Products
. Washington, DC:
US Consumer Product Safety Commission; 1998. Also available at:
Accessed June 18, 2001.

18. Dreborg K. Essence of backcasting. Futures. 1996;28:813-838.

19. Jackson R. Unburdening ourselves. Silent Spring Review. Fall 2000.
Available at: http://www.silentspring.org. Accessed June 18, 2001.

20. Fiorino D. Citizen participation and environmental risk: a survey
of institutional mechanisms. Issues in Science and Technology.
1990;15:226-243.

21. Renn O, Webler T, Wiedermann P. Fairness and Competence in Citizen
Participation. Dordrecht, the Netherlands: Kluwer Academic Publishers;
1995.

22. Deniel P, Renn O. Planning cells: a gate for "fractal" mediation.
In: Renn O, Webler T, Wiedemann P, eds. Fairness and Competence in
Citizen Participation: Evaluating Models for Environmental Discourse.
Boston, Mass: Kluwer Academic Publishers; 1995:141-156.

23. Colborn T, Clement C. Chemicaly Induced Alterations in Sexual and
Functional Development: The Wildlife/Human Connection. Princeton, NJ:
Princeton Scientific Publishing Co; 1992.

24. Bodanksy D. The precautionary principle in US environmental law.
In: O'Riordan T, Cameron J, eds. Interpreting the Precautionary
Principle. London, England: Earthscan; 1994:203-228.

25. Graham J. Perspectives on the precautionary principle. Human and
Ecological Risk Assessment. 2000;6:383-385.

26. Tickner J, Raffensperger C, Myers N. The Precautionary Principle
in Action: A Handbook. Windsor, ND: Science and Environmental Health
Network; 1999.

27. Tickner J, Raffensperger C. The American view on the precautionary
principle. In: O'Riordan T, Cameron J, Jordan A, eds. Reinterpreting
the Precautionary Principle. London, England: Cameron & May; 2001.

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From: Campaign for Safe Cosmetics, Mar. 28, 2006
[Printer-friendly version]

300 COSMETICS AND BODY CARE COMPANIES PLEDGE SAFER PRODUCTS

Movement Toward Toxic-free Cosmetics Gains Momentum

SAN FRANCISCO -- More than 300 cosmetics and body care products
companies have promised to replace ingredients linked to cancer, birth
defects, hormone disruption and other negative health effects with
safer alternatives.

The Campaign for Safe Cosmetics announced today that it had more
than tripled the number of companies who have signed the "Compact for
the Global Production of Safe Health and Beauty Products
," in the
past year, signaling a shift toward healthier products in the
cosmetics industry. By signing the Compact, companies pledge to phase
out toxic ingredients within three years.

Women and girls use an average of 12 personal care products daily,
according to a 2004 survey conducted by the Campaign for Safe
Cosmetics. One out of every 100 personal care products on the market
contains known or probable carcinogens and 89 percent of ingredients
in products have not been assessed for safety, according to Skin
Deep
, an online, brand-by-brand safety guide that contains in-depth
information on more than 14,000 products and their ingredients by the
Environmental Working Group.

Compact signers include The Body Shop, Burt's Bees, Avalon Natural
Products, Aubrey Organics, Osea Skin Care, Jason Natural Products, Zia
Skin Care, EO Products and Kiss My Face. The names of all signing
companies can be found here.

The Campaign for Safe Cosmetics is a coalition of U.S.-based health
and environmental groups working to protect cosmetics consumers from
toxic chemicals and hold companies accountable for the safety of their
products.

"The surge in the number of companies signing the Compact shows that
corporate executives are listening to the voices of concerned
consumers," said Bryony Schwan, national campaigns director for
Women's Voices for the Earth, one of the founding members of the
Campaign for Safe Cosmetics. "Each new company that signs puts more
pressure on the major cosmetics manufacturers to get on board and
clean up their products too."

Despite repeated requests, multinational cosmetics companies such as
L'Oreal, Revlon, Estee Lauder, Gap, Avon, OPI and Proctor & Gamble
have refused to sign the Compact, known as the "Compact for the Global
Production of Safe Health and Beauty Products," which requires that
manufacturers meet several criteria, including:

-- Meeting new EU standards banning chemicals linked to cancer and
birth defects globally;

-- Conducting an inventory of all ingredients to determine whether
they use chemicals that pose health hazards including cancer, hormone
disruption, genetic mutation, reproductive toxicity, developmental
harm and neurotoxicity;

-- Implementing substitution plans that replace chemicals of concern
with safer alternatives; and

-- Reporting on their progress in meeting these goals to the public.

Contrary to what many consumers may believe, the FDA does not review
or regulate cosmetics products or ingredients for safety before they
are sold to the public and has no legal authority to require safety
assessments of cosmetics.

The EU has led the charge for safer cosmetics. European Union
Directive 76/768/EEC
, which became law in 25 European countries on
October 1, 2004, requires products to be free of chemicals that are
known or strongly suspected of causing cancer, genetic mutation or
birth defects.

"Companies that market themselves with images of health and beauty
should not be selling us products with ingredients like formaldehyde,
coal tar, lead acetate, phthalates, parabens and toluene, which pose
cancer risks and raise other health concerns," Schwann said.

# # #

Founding members of The Campaign for Safe Cosmetics include:

Alliance for a Healthy Tomorrow

Breast Cancer Fund

Commonweal

Friends of the Earth

Women's Voices for the Earth

Environmental Working Group

National Black Environmental Justice Network

National Environmental Trust.

For more information and background on the campaign, and a link to the
Skin Deep database, visit www.SafeCosmetics.org.

Lisa Archer
Campaigns Coordinator
Health and Environment Program
Friends of the Earth-US
larcher@foe.org
202-222-0712
www.foe.org
www.safecosmetics.org

Contacts:
Genevieve Roja
Breast Cancer Fund
(415) 346-8223 x31

Stacy Malkan
Campaign for Safe Cosmetics
(510) 848-5343 x105

Dick Bell
Friends of the Earth
202-222-0742

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From: Upside Down World, Mar. 28, 2006
[Printer-friendly version]

NATIONS CALL FOR GLOBAL MORATORIUM ON GENETICALLY ENGINEERED TREES

By Global Justice Ecology Project

On Wednesday, 22 March, delegates from countries around the world
raised the call for a moratorium on the release of genetically
engineered trees into the environment at the UN Convention on
Biological Diversity's (CBD's) Eighth Conference of the Parties in
Curitiba, Brazil.

Additional delegates also insisted that the CBD [UN Convention on
Biological Diversity] launch a thorough global examination of the
risks and impacts of genetically engineered trees -- risks which have
not, at this point, been adequately examined.

"Yesterday was truly an historic day," stated Orin Langelle, Co-
Director of the Global Justice Ecology Project and Coordinator of the
STOP GE Trees Campaign. "The alarm bells we have been sounding about
the genetic engineering of trees have finally been heard," he
continued.

"Promoters of this irresponsible and dangerous technology have now
officially been put on notice that people and countries around the
world stand firmly opposed to genetically engineered trees -- just as
GM crops and terminator technology are already opposed," stated
Lambert Okrah, of the Ghana chapter of the Global Forest Coalition.
"We further applaud the courageous and far-sighted positions of
countries such as Ghana, Iran, Norway, Madagascar, Egypt, Philippines,
Senegal, Malawi and others in raising the call for a moratorium on
genetically engineered trees," he continued.

Interventions in support of the call for a moratorium were presented
by Global Justice Ecology Project for the Women's Caucus, the
International Indigenous Forum on Biodiversity, Global Forest
Coalition
, Greenpeace, and the Federation of German Scientists.

"Because there is insufficient scientific data regarding the
biological impacts of transgenic trees, as well as an absence of
socio-economic and cultural impact assessments, it is good scientific
practice to invoke the Precautionary Principle, which is enshrined in
the CBD," stated Dr. Ricarda Steinbrecher of the Federation of German
Scientists. "This means no release of transgenic trees into the
environment whilst this research is on-going," she added.

The release of transgenic trees will inevitably and irreversibly
contaminate native forests, which will themselves become contaminants
in an endless cycle. The potential effects include destruction of
biodiversity and wildlife, loss of fresh water, desertification of
soils, collapse of native forest ecosystems, cultural destruction of
forest based traditional communities and severe human health impacts.
The negative effects of transgenic trees will impact many generations
to come.

Press release issued by Global Justice Ecology Project, Global Forest
Coalition, World Rainforest Movement, Friends of the Earth
International, EcoNexus and the STOP GE Trees Campaign.

Contact: Anne Petermann, Global Justice Ecology Project,
+1-802-578-6980

Simone Lovera, Global Forest Coalition, 41-9978-3582

========================================================

Intervention from the Women's Caucus Regarding Transgenic Trees.
March 22, 2006

Delivered by Anne Petermann

My name is Anne Petermann and I am the co-Director of Global Justice
Ecology Project. I am speaking today on behalf of the Women's Caucus
on the issue of transgenic trees, SBSSTA recommendation X1/11 para. 9.

People all over the world are rising up to oppose transgenic trees,
including 2,000 organizations that have signed onto a ban. Transgenic
trees are a unique case. Trees live for centuries if not millennia.
Pollen models created in 2004 by Duke University researchers
demonstrated pollen from native forests in the Southeast U.S.
traveling in air currents for more than 1,200km north into eastern
Canada. This means that transgenic trees cannot be regulated only at
the national level. Transboundary contamination of native forests with
transgenic traits is virtually assured. The Biosafety Protocol, which
is based on national borders, is not adequate.

The release of transgenic trees will inevitably and irreversibly
contaminate native forests, which will themselves become contaminants
in an endless cycle. The potential effects include destruction of
biodiversity and wildlife, loss of fresh water, desertification of
soils, collapse of native forest ecosystems, cultural destruction of
forest based traditional communities and severe human health impacts.
The negative effects of transgenic trees will impact many generations
to come.

Women are the ones who think in terms of generations. It is women in
rural and indigenous communities who will bear the greatest burden of
the impacts of GM tree plantations, just as they currently bear the
brunt of the impacts from conventional monoculture tree plantations.

The potential human health impacts of transgenic trees, especially Bt
trees, have not been adequately researched.

Numerous studies have raised serious questions about the potential
health impacts of Bt toxin. A series of published studies found that
Bt provokes a potent systemic immune reaction. Because the risk is
greater with inhalation than ingestion, engineering trees to produce
Bt toxin could be very dangerous. Plantations of Bt trees could
potentially lead to widespread outbreaks of sickness. Women and
children will bear the brunt of this.

In July, 2005 the FAO [United Nations Food and Agriculture
Organization] published a report entitled "Preliminary Review of
Biotechnology in Forestry Including Genetic Modification." In it, over
half of researchers surveyed reported the environmental threat of
escape of transgenic pollen or plants into native ecosystems and
forests and their impacts on non-target species as a major concern.
The FAO report concludes, "New biotechnologies, in particular genetic
modification, raise concerns. Admittedly, many questions remain
unanswered for both agricultural crops and trees. Given that genetic
modification in trees is already entering the commercial phase with GM
populus in China, it is very important that environmental risk
assessment studies are conducted with protocols and methodologies
agreed upon at a national level and an international level and that
the results of such studies are made widely available."

In conclusion, the genetic engineering of trees is being driven by
corporate profit. There is no need for GE trees. Just as women and
indigenous peoples have been the traditional caretakers of
biodiversity, so must this body take action to prevent the ecological,
social, cultural and health disasters that will be unleashed by
genetically engineered trees.

The speed with which the technology is progressing is outpacing
regulation and risk assessment. There has been a severe lack of study
of the risks of GM trees, especially on a global scale. This lack of
risk assessment makes it common sense that there not be any further
forward motion in the release of transgenic trees. The CBD must impose
a moratorium on the technology and launch a thorough and global
examination of its risks. In addition, we ask those countries with
outdoor releases of GM trees to take immediate steps to halt the
further release of GM trees and to address those releases that have
already occurred.

For more details see our a briefing paper on the issue.

For more information, visit Globaljusticeecology.org.

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From: HindustanTimes.com (New Delhi, India), Mar. 29, 2006
[Printer-friendly version]

'CLIMATE CHANGE DEAL TO FAIL WITHOUT CHINA, INDIA'

By Agence France-Presse

Auckland, New Zealand -- British Prime Minister Tony Blair called on
Wednesday for an international agreement on tackling climate change.

But warned that any deal would fail unless it included the United
States, China and India.

Speaking at the end of a brief stop in New Zealand in which global
warming has dominated the agenda, Blair said failing to address the
issue would be handing on an irresponsible legacy to future
generations.

"What's necessary is to get an international agreement that has got a
framework with a stabilisation goal in it, so that we can set a very
clear objective for everybody to aim at," he told journalists after
talks with counterpart Helen Clark.

"Without the participation of America and the emerging economies of
China and India there isn't going to be a solution," Blair said.

The United States rejected the 1997 UN Kyoto Protocol to cut
greenhouse gas emissions as too expensive for its oil-dependent
economy and the booming economies of China and India are two of the
fast-growing users of fossil fuels.

Blair said seizing the initiative on the issue would require changes
in lifestyle and radical technological solutions.

"You've got to develop the science, the technology and the changes in
behaviour necessary to meet that goal.

"But it won't be done unless there is a development of the technology
that, I think, needs to be as revolutionary as the Internet was for
information technology."

His own government's climate policy review, published Tuesday,
indicated Britain is likely to better Kyoto's target of a 12.5 per
cent reduction in overall carbon emissions.

But it also suggested London would fall short of its own long-standing
commitment to cut carbon dioxide gases by 20 per cent of 1990 levels
by 2010.

Instead CO2 emissions were likely to be cut by 15-18 per cent, the
report said.

Climate change figured high on the agenda of the New Zealand leg of
Blair's Asia-Pacific tour.

He earlier told a conference in Wellington that any failure to strike
a deal would hand an appalling legacy to future generations.

Blair said the world had to build on the emerging consensus about the
man-made causes of climate change at meetings of the Group of Eight
richest nations in St Petersburg, Russia, and G8 plus five in Mexico
in September.

"If we operate on anything like the precautionary principle, you have
to say that the science is sufficiently clear and, in my view, is
pretty much certain that it would be deeply irresponsible not to take
action," he said.

He added: "I do not want it on the conscience certainly of me and
people of my generation that we were told what this problem was in the
early part of the 21st century, did nothing about it and then my
children and their children end up having to deal with the
consequences."

Clark told a joint news conference with Blair in Auckland that the
visit -- the first bilateral visit by a British prime minister since
1958 -- had strengthened the relationship between their two countries.

Their talks included Afghanistan, where both countries have been
involved in reconstruction and counter-narcotics efforts following the
fall of the hardline Islamist Taliban regime, plus bilateral
immigration and investment.

They also agreed to set up annual security talks covering counter-
terrorism, combating arms proliferation, organised crime, narcotics as
well as global and regional issues.

Blair leaves New Zealand on Wednesday for Indonesia.

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Rachel's Precaution Reporter offers news, views and practical
examples of the Precautionary Principle, or Foresight Principle, in
action. The Precautionary Principle is a modern way of making
decisions, to minimize harm. Rachel's Precaution Reporter tries to
answer such questions as, Why do we need the precautionary
principle? Who is using precaution? Who is opposing precaution?

We often include attacks on the precautionary principle because we
believe it is essential for advocates of precaution to know what
their adversaries are saying, just as abolitionists in 1830 needed
to know the arguments used by slaveholders.

Rachel's Precaution Reporter is published as often as necessary to
provide readers with up-to-date coverage of the subject.

As you come across stories that illustrate the precautionary
principle -- or the need for the precautionary principle --
please Email them to us at rpr@rachel.org.

Editors:
Peter Montague - peter@rachel.org
Tim Montague - tim@rachel.org

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