The Precautionary Principle or Junk Science?

What should public health and environmental agencies be ethically bound to do?

October 20, 2003


Marjorie J. Clarke, Ph.D.

Adjunct Professor, Urban Environmental Health, Lehman College / 212-567-8272


As a scientist, Iím ethically bound to refrain from making pronouncements about my research until Iíve collected enough data, tested my hypotheses, had my work reviewed by other scientists, and verified in their laboratories.EPA has repeatedly given the media reassuring statements without enough data or peer review.


Clearly, in the case of the World Trade Center, there was a need for a speedy answer to the question:Is the Air safe to breathe?†† What is the correct answer, if there is potential for harm, but not enough data?†† We Donít Know, but in the meantime, we are collecting data and we recommend precautions to minimize exposure.


How does one resolve the need for an answer when you donít have enough data, and when the consequences of doing nothing or making a wrong answer are so great that peoplesí lives and health are possibly at serious risk?


As medical doctors must uphold the oath:ďFirst, Do No HarmĒ, environmental and health scientists should be ethically bound to uphold the Precautionary Principle: ďWhen in doubt and there is potential for harm, err on the side of caution.Ē


When there is an environmental disaster, and there is potential for illness, death or damage to the environment, all the science agencies (USEPA, NYSDEC, NYSDOH, NYCDEP, NYCDOH) who are responsible for protecting public health and the environment, should have upheld the Precautionary Principle, choosing protective measures until thorough investigations Proved that the risk to public health was less than EPAís benchmark, one in one million cancers.Emergency response agencies should also uphold this principle.


The Precautionary Principle is not only the best course of action from an ethical point-of-view, but it is also more effective and cheaper to Prevent harm than to try to Undo damage to peoplesí health and their environment.Remediation of a contaminated environment, and cure of those suffering environmental illnesses, is not always possible. Studies continue to show that the benefits to public health from regulating industrial emissions far outweigh costs of controls.


These health and environmental agencies should Not have seen it as their business to reassure to public when they had not collected data on many of the air pollutants, had not collected data indoors, and had not collected data in Brooklyn or Chinatown..Pronouncing environmental safety without definitive supporting data, as everyone downtown could smell the toxic fumes and while thousands of indoor environments were contaminated with dust containing dozens of toxic and carcinogenic pollutants, exposing a large population to serious respiratory diseases and possibly cancer, is tantamount to espousing Junk Science.This is a serious policy flaw in our public health and environmental agencies, and Must change.


The agencies should have IMMEDIATELY mobilized resources from around the country to thoroughly assess concentration, extent, and health impacts of the toxic air and dust.Scientists and laboratories would have gladly responded to the call.Instead, EPA Region II rejected offers of trained personnel and air sampling equipment!


Once the full extent of the environmental disaster was characterized, the agencies should have publicized the nature of the dangers, argued for funds to evacuate contaminated areas and to thoroughly remediate and test every part of every building as quickly as possible.


That the agencies left it to residents and janitors to clean toxic waste from indoor environments, this needlessly exposed thousands of people to the toxic dust.The policy of these agencies not taking responsibility for protecting the health and environment in times of environmental disaster Must change.


Even at this late date, the Precautionary Principle can still be used to protect the health of those living and working in contaminated areas.Toxic dust is still present in indoor environments and ventilation systems, potentially exposing people for decades.Children, the elderly, and those with compromised immune systems are particularly at risk.The health and environmental agencies still have the opportunity to reduce health impacts from the WTC disaster.Itís Time for them to do their job.