The Environment and Environmental Hysteria
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Fanatics see everything in absolutes.
Perspective means nothing to them(425).
In this essay I will focus on the events surrounding the regulation of Alar (diaminozide) up to and including 1985, as a case-study of knowledge and decision-making amidst uncertainty (418-19). I pick this time period in particular, because it is when the NRDC and other public interest groups began their campaign in protest against the EPA's decision to not ban Alar. My analysis of the events surrounding Alar will take shape around a critique of Michael Fumento's article "Environmental Hysteria: The Alar Scare," in which he paints the NRDC as "fanatics" launching a "smear campaign" not founded in any rational decision-making. This is an important argument to counter, because it has not only been taken up by many to condemn citizen-group action in the case of Alar, but to criticize their activities in many other regulatory processes. The chief framework used to devalue public action in these cases is the technocratic model, wherein it is believed that decisions can be best made by objective, rational experts acting based upon scientific knowledge.
In this case, we can see a perfect example of when a decision was decided by scientific experts, in accordance with the technocratic model. Fumento and other supporters of the technocratic mode privilege the scientific knowledge of bodies such as the Scientific Advisory Panel in this case over other forms of knowledge. He denounces NRDC as fanatics based on his claim that they acted in spite of, and in contradiction to scientific declarations and reports which indicated that their "Alar alarm" did not correspond to the evidence at hand (423). However, the Alar saga is typical of many regulatory decision-making processes in that the scientists and administrators were forced to act before scientific opinion has solidified around a certain determination of the dangers of the chemical. In this case, the scientists cannot simply rely on the accepted scientific verdict, but they need to make value judgements about what evidence and opinion to include in their decision-making and what to exclude. In this type of scenario, I will first argue, the technocratic model is imperfect for our democratic country, as it privileges the value judgements of scientists over those of the populace. I further suggest that scientists themselves should not be considered above subjectivity nor fanaticism, but rather in some cases their rigorous abidance to objectivity can be seen as a certain type of blind"fanaticism.
" With this critique in mind, I will close with a defense of the value of the precautionary principle when dealing with matters of great uncertainty such as these.
In his discussion of the regulatory process for Alar (diaminozide) and the activities of the Natural Resource Defense Council (NRDC) surrounding it, Fumento paints a picture wherein the NRDC "did not engage in "real scientific process" or a proper consideration of "the facts", but rather engaged in "one of the slickest, most cynical fear campaigns in recent American history (424)." To back his claim, he reviews the progress of regulatory action on Alar and demonstrates how the NRDC's actions were untenable given the conclusions reached as to Alar's toxicity. A brief time-line of the events begins with the EPA's Office of Pesticide Programs (OPP) recommending that Alar be banned, based on scientific studies from the 1970s and 80s. Shortly after, a Scientific Advisory Panel (SAP) met and thoroughly discounted the EPA's decision as based on outdated science employing methods and standards which were no longer scientifically acceptable. Fumento goes on to review scores of independents reviewers who uphold the SAP's decision and denounce the EPA for eventually banning Alar due mainly to pressure from the NRDC and other citizen groups. It is this NRDC pressure, which accepted the initial EPA decision and rejected the SAP recommendation, which Fumento recounts as "a touchdown of terror," based on "'inappropriate data'" and specious reasoning (425, 422, 422).
II: "Environmental Hysteria" vs Scientific "Fanatics"
If Fumento is correct in the further progression of events after the 1985 meeting of the EPA's Office of Pesticide Programs with the SAP, then it is fairly clear that these groups did act out of accordance with scientific opinion. However, even assuming that he is correct, we might still decide that they were justified in their beliefs about the dangers of Alar and even justified in their "media hype"(422). Fumento would undoubtedly disagree that I could prove such a claim, because the later invalidation of their position because for him further scientific studies necessarily pulls the rug out from under any justification they might have. However, it is with his idea that absolute scientific knowledge is the only justifiable knowledge that I object. Below I will briefly lay out the three major reasons why the NRDC was justified in its position and actions despite countervailing scientific opinion. The fourth reason leads me into a discussion of the precautionary principle, in section III.
Firstly, the NRDC had good reason to believe that there was scientific opinion behind them. The Toth and other contemporaneous scientific studies of the toxicity of Alar were published in respected scientific journals. In order to have been admitted into the journals, they must have met with the approval of the peer reviewing scientists, and thus, they had every mark of veritable science.
Secondly, they had the weight of the calculated and reasoned decision of the EPA behind them. In general, the analysts of the OPP "knew from experience that perfect (or state of the art) toxicity studies were rarely available for substances regulated under FIFRA [(Federal Insecticide, Fungicide and Rodenticide Act)] (119)." Thus, based on their examination of the data for Alar, they concluded that "[b]y comparison with that of many other products, the toxicological dossier on diaminozide appeared more complete and consistent (119). The SAP rejected OPP's determination as based on ill-performed and inadequate scientific methodology. However, especially given the EPA's mission to "safeguard public health," the NRDC justifiably saw OPP's conclusion as "seemingly on the basis of well-established principles of decision-making. The data were strong enough to support a qualitative determination of carcinogenicity (119, 120)." I will return to this issue of decision-making amidst uncertainty at the end of section II.
Thirdly, the NRDC seems justified in the belief that the SAP was not upholding Fumento's "'real scientific process'" (424) as much as he thought they were. Furthermore, the NRDC has a justifiable complaint that as they did not have a representative present, they were not able to argue their perspective once the SAP deviated from "pure science." As Jasanoff reports, the SAP was not nearly as objective and
fair as Fumento has portrayed them to be; It
was not sufficiently representative of the scientific disciplines relevant to assessing pesticide risk. In particular, the panel contained no biostatisticians, although this professional group would by training have been the most
sympathetic to [the types of analyses that the OPP had performed"(120)
Additionally, the fact that the panel actually did side with Uniroyal (Alar's manufacturer) in its acquittal of Alar, the NRDC can be seen as having a reasonable basis for rejecting the SAP's verdict. The NRDC's lack of representation at the meeting, in opposition to Uniroyal and the Apple growers is important, for given the uncertainty, rather than absoluteness of this decision-making process, it was impossible to have made decisions based solely on scientific fact. This is evidenced by the scientists' implementation of their "policy values" when they decided that "waiting for more data would not jeopardize the public exposed to diaminozide (121)."
Finally, I would argue that in a case such as Alar, where uncertainty and risk is high, the precautionary principle should govern decision making. In other words, decision-makers should err on the side of caution rather than on the side of boldness. I will use an analysis of Fumento's argument to provide a framework for explicating my assertion.
III: Uncertainty and the Precautionary Principle
Fumento firmly rejects "'erring on the side of caution'" as "not even an argument at all; in fact it is not even a nonargument." he justifies his position by claiming that "You can't prove a negative. You can never say a chemical is not an animal carcinogen, simply because no matter how many tests have been run, the next one may show a positive result (425)." I want to object to his claims on three grounds: 1) his notion of proof is not shared by any legitimate scientist 2) his point about positive and negative claims is without any basis 3) the notion of "proof" that is scientifically accepted provides a strong reason for adopting the precautionary principle, especially when the consequences of being mistaken are severe.
Fumento's assertions are correct only if we allow his fallacious definition of proof to stand. He is wrong to single out "negative's" as not being able to stand up to this test of proof, because no hypothesis can stand up to this notion of proof. He apparently thinks that nothing is proven unless we can be sure that the next test will not refute our hypothesis. However, do not throw all your faith in science out the window just yet, for this notion of proof is a notion of proof which no scientist uses. Just because the sun might not rise tomorrow does not mean that it is not a scientific fact that it will. What science in fact uses as its standard of "provenness" is based on "statistical significance," not certainty. In short, a hypothesis about certain data is statistically significant if there is a probability of less than 5% that the observed results were a result of random chance, rather than due to the hypothesized reasons. What Fumento seems thus to have forgotten is that the standard for accepted results in science is that of 95% rather than 100% certainty.
Lastly, Fumento ignores the fact that in the case of toxicological knowledge, in particular, the positive claims about toxicity are subject to a great amount of uncertainty. We have not been able to get anywhere near the same level of certainty about the harmfulness of most toxins as we have about the force of gravity, for example. In other areas, we have not even begun to approach the 5%"boundary" What I think this question boils down to then, is the matter of who decides what level of risk is acceptable. Scientists who do not acknowledge a risk as present until "there is evidence amounting to proof beyond a reasonable doubt" lead society to a situation where "experts in effect tolerate risks that the general public might consider unacceptable (121)." The precautionary principle places the burden on proving that a substance is safe rather than that it is not. It is based upon the idea that it is more important to avert a possible disaster (the probability is never zero) and forgo a potential great benefit, than risk the disaster because either we are not sure how likely it is to happen, or because the benefits are great. In other words, this is a corollary belief that it is not acceptable to let technology and industry act unhindered, under the assumption that they are improving life. Rather, it draws on the vast stor e of cases where "the facts" have "come in" (425) to implicate technology as having decreased rather than increased our quality of life, and rejects this vision of ever-progressing technology. Instead, it argues, we must take cautious steps which recognize the value of preserving the present, as well as considering the promise of the future. Especially when possible missteps are irreversible, the precautionary principle seems very wise indeed.
Extrapolating from this case, therefore, it seems necessary to acknowledge that scientific expertise should not be privileged to the exclusion of other interpretations when the issue at hand contains "many technical uncertainties (121)." The justification for giving scientist the ultimate authority "relies int he implicit assumption that the panel's expertise and structural position sufficiently qualify it to serve as the final authority on the view of risk (123)." However, (especially) in circumstances of uncertainty, it is necessary to make value judgements, because the facts are not well enough known. Indeed, looking back on the absoluteness with which the SAP rejected the OPP's stance as "unscientific" we might wonder whether scientists shouldn't be named "fanatics" due to their inability to acknowledge the uncertainties underlying their decisions. Determinations such as "whether the risk of additional exposure was warranted" should be made not by an elite cadre of experts (121). Rather, decisions should be made either by agencies such as OPP, which need be accountable to the public through the courts and the media, or via participatory decision-making where everyone's viewpoint has a chance to be heard. In a democracy, we simply cannot allow a small group of insulated individuals make value judgements (or possibly even decisions about matters of fact) for the entire populace.