Inclusion of risks and benefits in public policy decisions.

This in an exchange starting with an article by Daryll E. Ray in South West Farm Press.
Rick Roush argues in the follow up that Daryll is ignoring benefits.

Producers argue for sound science, some consumers prefer precautionary principle

Dec 14, 2005 9:40 AM
By Daryll. E. Ray

The precautionary principle is what our mothers were talking about when they told us that it is better to be safe than sorry.

U.S. agricultural and trade negotiators have been pressuring the Japanese to reopen their market, which has been closed to U.S. beef since BSE (Bovine Spongiform Encephalopathy or mad cow disease) was first detected in the U.S. herd at the end of 2003. The U.S. is also in a trade dispute with the EU (European Union) over the EU s restrictions on the importation of GMO (genetically modified organism) crops. In both cases the United States has argued that, on the basis of sound science, both of these trade restrictions ought to be lifted.?
Primedia Business - Southwest Farm Press, Click Here!

On the face of it, it would seem that the U.S. argument is very strong. After all, how could and why would one argue against sound science? For their part, the Europeans and the Japanese defend their actions on the basis of the precautionary principle. The precautionary principle is what our mothers were talking about when they told us that it is better to be safe than sorry. As long-term readers of this column know, we have written about these issues before. Our analysis of these two trade disagreements has been based on two ideas. The first is couched in economic terms arguing that the customer is always right.

If the Japanese are willing to pay for the BSE testing of every head of beef, the idea that the customer is always right would suggest that we would agree to the testing. Likewise, if the Europeans want non-GMO grain, then U.S. farmers ought to be working to provide them with non-GMO grain.?

Our second idea has been to identify why customers might assess the risk of GMO grains differently than the producers. After all, growing GMO crops makes it easier for producers to control weeds and insects. While producers receive the benefits, customers take the risks if at a later time it were to be shown that GMO crops posed some health risk. It makes no difference how low the probability of that event is? The probability is nonzero and therefore important in minds of some customers.?

This past summer we read a paper presented by Priya Om Verma and William R. Freudenberg at the 2005 Rural Sociological Society Annual Meeting that took a different look at the conflict between those advocating for the use of sound science and those advocating for the use of the precautionary principle in decision making. Verma and Freudenberg, of the University of California, Santa Barbara, argue that the precautionary principle may be the more scientific of the two approaches. ??The core of their analysis reduces the two arguments to their essentials. Those using the sound science as the justification for their policies - pressuring Europeans to buy GMOs or Japanese to purchase U.S. beef - are arguing that something is safe unless it is proven to be hazardous.

Thus, declaring something is safe runs the statistical risk that it is not.?Those supporting the precautionary principle are arguing that when there is a potential risk to life and safety, the prudent course of action is to err on the side of caution, risking the chance that one may reject an action or product as unsafe when in fact it may be safe.?Hurricane Katrina and the flooding of New Orleans provide us with a chance to apply these concepts to a situation most of us are familiar with. Those officials who supported cutting back on levee repairs were arguing that the likelihood of a Category 3 hurricane that would cause a breach in the levees was very small and that the money would be better spent elsewhere.

This is the sound science argument which takes the risk assuming the levees will hold when in fact they won t. Those who were arguing for the levee expenditures and protecting the wetlands surrounding New Orleans were basing their argument on the precautionary principle. As we have seen, the sound science argument favors short-term economic gain over against the potential of catastrophic long-term costs. In this case we can see that an ounce of prevention would have been worth more than a pound of cure.?Applying this back to the case of GMO sales to the Europeans, the United States is arguing in favor of immediate economic gains from increased trade over and against long-term health and/or safety problems that may arise if it were to turn out that GMOs pose a risk that does not show up for 10, 20, or 30 years.

Similarly, in the case of the sale of beef to the Japanese, the United States is arguing that the extra cost of testing each head of beef sold to the Japanese is unnecessary, given the low chance that any one animal would have BSE. The Japanese are arguing that given the long-term risks - if one imports enough untested beef, sooner or later a BSE positive animal will slip through - the cost of testing is a small price to pay for increased long-term safety.??As Verma and Freudenberg note, statistics teach us that these two risks are closely related. As one reduces the chance of making a short-term error - rejecting a product as unsafe when it is in fact safe - one increases the chance of making a long-term error.

There is a tradeoff between these two types of errors. We cannot have our cake and eat it too.?Their argument that the precautionary principle may be the more scientific of the two approaches is based on their contention that the precautionary principle recognizes the reality of scientific unknowns and acknowledges . . . scientific uncertainty.

They go on to say, Under conditions of scientific uncertainty, judging what is an acceptable level of risk for society is an inherently political responsibility . . . These are value-laden processes that reflect differing perspectives regarding what ought to be society s preferences for short-term economic risks versus longer-term risks to health and the environment.

Daryll E. Ray holds the Blasingame Chair of Excellence in Agricultural Policy, Institute of Agriculture, University of Tennessee, and is the Director of UT s Agricultural Policy Analysis Center (APAC). (865) 974-7407; Fax: (865) 974-7298; dray@utk.edu; http://www.agpolicy.org. Daryll Ray s column is written with the research and assistance of Harwood D. Schaffer, Research Associate with APAC



Not Just Sound Science or Precaution...But Risks and Benefits
RE
>http://southwestfarmpress.com/news/051214-sound-science-principle/

- Rick Roush, rtroush.at.ucdavis.edu (On Agbioview)



Dear Prof. Ray:
Your analysis with the example of GM crops is interesting, but overlooks the documented advantages of GM crops to consumers, including reduced and safer pesticide residues in the environment, maybe even on food, reduced erosion due to reduced tillage, and reduced fuel use, never mind the health advantages to farm workers. Of particular interest ought to be reduced fumonisins in corn. There has even been some evidence of lower costs to consumers. I realize that consumers may not care about farm workers, but this has to be seen as a selfish attitude with regard to the people who produce food and fiber. On the other hand, consumers express considerable interest reducing the environmental foo[t] print of ag. That is why many of us who actually do pest management see advantages to the crops.

Perhaps it is up to decision makers to consider these issues even if busy and media-overloaded consumers fail to become aware of them. This is not just about "GMO crops mak(ing) it easier for producers to control weeds and insects". It's not just about a precautionary principle and sound science. It is about considering all of the risks and benefits, including the known risks of failure to adopt new technologies, as well as the hypothetical risks of doing so. If you are unaware of the refereed literature for these benefits, I am sure that my colleagues and I would be happy to offer some.


Response to Roush on Agbioview 'More on 'Sound Science or Precautionary Principle'
- Harwood D. Schaffer, hdschaffer.at.utk.edu

Rick, I am Daryl Ray's research associate and thought I would take the time to respond to your email. It appears to me that you have confused a discussion of research methodology with a discussion of the content of that research. In our article we were talking about methodology and in your response you were talking about the content of that research.

In our article we took out some of the technical language contained in Verma and Freudenburg's article. In the original they contended that arguments for "sound science" as the basis of making public policy decision in matters like BSE and GMOs indicated a preference for reducing the chance of committing a Type I error. Similarly then those using the "precautionary principle" indicate a preference for reducing the number of Type II errors. No matter where one comes down on the details of the arguments, that is the nature of the issue at hand. For any given technology one cannot reduce the risk of committing a Type I error without at the same time increase the risk of committing a Type II error. I infer from your comments that you have confidence in the technology and therefore are concerned about reducing the possibility of committing a Type I error. From a statistical point of view you then have to admit that there is a concomitant shift in the risk of committing a Type II error.

In either case you are correct: the issue is not one of science vs. non-science. Rather it is a matter of difference in risk preferences with some striving to reduce the risk of committing a Type I error while others are trying to reduce the risk of committing a Type II error. Those risk preferences are influenced by values and at that point values become a relevant part of the discussion and decision-making process in a democratic society.

Our purpose in writing the article was to present the issue of the trade-off between "sound science" and "precautionary principle" between Type I and Type II errors to a general audience that is not as well versed in statistical issues as you are.

Thanks for your response and your interest in public policy issues.
Sincerely yours, Harwood Schaffer, Research Associate, Agricultural Policy Analysis Center, PhD candidate, Department of Sociology, University of Tennessee


Response to Harwood, from Rick Roush, rtroush.at.ucdavis.edu
Dear Harwood :
No, I have not confused a discussion of research methodology with a discussion of the content of that research. Your approach and discussion is all about a one-sided view of the precautionary principle that considers only risks to the new technology, not known hazards of the current technologies. The only mention of the word "benefit" in your article was in the context of benefits to producers, with consumers taking all of the risks. This is an inadequate research methodology, where the benefits to consumers are never considered. Reality is not that simple.

I suggest that you have never had to make real world regulatory decisions, as I have, or this would be clearer to you. It is a key role of government to study issues and make some decisions for a general public that hasn t the time or expertise to study the questions in detail. I work on this for ag, but have to trust other experts to make technical decisions for the military, power generation and distribution, local transit, sewage, water supply, etc. I suggest that it even extends to social welfare. If one went solely with what the majority of the public wanted, Mississippi would not have been integrated in the 1980s when I lived there. In fact, there still was no public kindergarten when I arrived, because it was seen as welfare for black kids; Governor William Winter had to force it through against popular sentiment.

Here in California, it has been the role of government to make tough decisions on the mechanics of cars that people buy and other tactics to reduce air pollution, for example, even if individual consumers don t like them because of extra costs and inconvenience. There are limits on the number of fish you can catch, and protections for national and state parks, even if there is no direct, short term benefit to consumers. I see current GM crops as in the same vein; there is overwhelming evidence that they are reducing the environmental footprint of human habitation with essentially no risk to consumers.

What about the risks? We accept the risks of allowing planes to fly overhead because of the benefits to travelers and the airlines, even though we know that some planes occasionally will kill the innocent below who did not specifically accept the risks (as with the recent Southwest flight). This is not just a recent phenomenon; in old New York City, being kicked or otherwise injured by horses was a common source of mortality even for those who didn t own or work with them, but horses were tolerated for their overall benefits.

Your methodology for GM crops does not consider their benefits to consumers as the general public, but focuses on the fears that people have about the risks. You have enhanced this by comparing BSE, with known risks and relatively low cost risk avoidance, with GM crops, where there are no known risks and the costs of avoidance (stopping their use) are enormous.

Reducing the risk of a Type I error seems warranted whenever the Type II error is not distinguishable from zero. In this case, the overwhelming evidence is that current GM foods are at least as safe as anything produced conventionally. At least they get a safety review; most of what we eat has never been reviewed for safety, and even for some cases that have been assessed and score badly at least in some circumstances (like transfats, peanuts, and raw milk), we continue to allow them on the market! No GM crop would be allowed with those risks; we banned Starlink even though there was good evidence that it wasn t allergenic.

No, our disagreement is not about the content of research, but about the philosophical framework of research methodology for risk assessment.
Sincerely, Rick