Precautionary principle and the new Swiss synthetic nanomaterial matrix

The precautionary principle appears to be much loved by civil society groups such the ETC Group and Friends of the Earth. They tend to cite it with some frequency as a means of managing scientific research or, as some might suggest, as a means of stopping research. I have to admit I’ve tended to view the precautionary principle as a way of saying ‘don’t do anything unless you can prove it’s safe’, and that is a gross misunderstanding of the principle. The recent announcement from Switzerland about developing a precautionary matrix for synthetic nanomaterials had me revisiting my ideas.

I found this description of the principle in a July 18, 2010 posting about nanosunscreens by Andrew Mayanard on his 2020 Science blog,

The Precautionary Principle is one approach – and a very misunderstood and misused one – to addressing this [risk and uncertainty], and one brought up by FoE and others in the context of sunscreens.  It has many formulations – it’s not a hard and fast principle.  But it is currently described in the European Union in this way:

The precautionary principle should be informed by three specific principles:

  • implementation of the principle should be based on the fullest possible scientific evaluation. As far as possible this evaluation should determine the degree of scientific uncertainty at each stage;
  • any decision to act or not to act pursuant to the precautionary principle must be preceded by a risk evaluation and an evaluation of the potential consequences of inaction;
  • once the results of the scientific evaluation and/or the risk evaluation are available, all the interested parties must be given the opportunity to study of the various options available, while ensuring the greatest possible transparency.

This is a pragmatic principle that looks to using evidence and an evaluation of consequences in making informed decisions in the face of uncertainty.  It certainly does not preclude the development or implementation of a new technology until there is certainty on safety.

The emphasis on the potential consequences of inaction are particularly relevant to today’s world, where we are stuck on a technological tight-rope, and where the consequences of not doing something may be more harmful than taking action. [emphasis mine]  Richard Jones [author Soft Machines and a Professor of Physics and the Pro-Vice Chancellor for Research and Innovation at the University of Sheffield] picked up on this in his suggestion for a more relevant application of the Precautionary Principle to emerging technologies:

  1. what are the benefits that the new technology provides – what are the risks and uncertainties associated with not realising these benefits?
  2. what are the risks and uncertainties attached to any current ways we have of realising these benefits using existing technologies?
  3. what are the risks and uncertainties of the new technology?

This seems a useful place to start from when faced with the reality of having to make the best possible decisions in the face of uncertainty, and where inaction isn’t an option.

But to make decisions – even when there are gaping holes in the data – you need something to go on.

The new Swiss matrix helps to further flesh out the precautionary principle (from the July 29,2011 news item on Nanowerk),

The precautionary matrix provides a structured method to assess the “nanospecific precautionary need” of workers, consumers and the environment arising from the production and use of synthetic nanomaterials.

The matrix is a tool to help trade and industry meet their obligations of care and self-monitoring. It helps them to recognise applications which may entail risk and to take precautionary measures to protect human health and the environment. In the case of new developments, the matrix can contribute to the development of safer products. It enables users to conduct an initial analysis on the basis of currently available knowledge and indicates when further investigations are necessary.

The matrix can be found on this page of the Swiss Federal Office of Public Health (scroll to the right of the page for the guidelines, matrix, FAQs, etc.).

One question keeps popping up. The phrase ‘consequences of inaction’ has me asking how do we define inaction? My suspicion is that a research nanoscientist and a representative from a civil society organization may have two very different answers to that question, i.e., ‘we must continue with the research to solve the problem’ as opposed to ‘we must stop the actions that caused the problem in the first place’.

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