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E-M:/ MDA and Lowell Statement on Science and the Precautionary Principle



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Enviro-Mich message from Praxis <praxis1986@triton.net>
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----- Original Message -----
From: Praxis
To: WyantD9@state.mi.us

Subject: December 17, 2001; Lowell Statement on Science and the 
Precautionary Principle, and Praxis, Allegan, Michigan.


Dear Mr. Wyant, Director Michigan Department of Agriculture.

Praxis thought that you would find this of interest.  Please notice the 
broad agreement in this document with our concerns.

Sincerely,
 
 
Patrick D. McKown
Samuel M. DeFazio
Jean E. McKown
 
Praxis
2723 116th Ave.
Allegan, MI  49010
 
                                                                                                         
Praxis
Lowell Statement on Science and the Precautionary 
Principle,               ( Praxis official complaints about State of 
Michigan
December 17, 2001; Statement from the International Summit 
on             institutions and agencies employee behavior, and
Science and the Precautionary Principle; Hosted by the 
Lowell                ambiguous authority, over the last 15 years.)
Center for Sustainable Production, University of Massachusetts
Lowell 20-22 September 2002.

Growing awareness of the potentially vast scale of human impacts        
( General failure to understand the significance of our
on planetary health has led to a recognition of the need 
to                       Integrated Biological Cybernetics invention and 
how it
change the ways in which environmental protection decisions 
are            differs from biological control by State of Michigan
made, and the ways that scientific knowledge informs 
those                    public officials. )
decisions. As scientists and other professionals committed to
improving global health, we therefore call for the recognition of
the precautionary principle as a key component of environmental
and health policy decision-making, particularly when complex and
uncertain threats must be addressed.

We reaffirm the 1998 Wingspread Statement on the Precautionary
Principle [see REHN #586] and believe that effective
implementation of this principle requires the following elements:

** Upholding the basic right of each individual (and 
future                      ( Violated by having MDA employees and 
others public generations) to a healthy, life-sustaining environment as 
called              Officials discourage biological control in general and
for in the United Nations Declaration on Human 
Rights;                         and Praxis and its biotool kit products 
in particular.)

** Action on early warnings, when there is credible evidence 
that          ( The many articles on pesticide risk especially to
harm is occurring or likely to occur, even if the exact 
nature                  women and school children we have sent to MDA.
and magnitude of the harm are not fully 
understood;                              we believe the majority of this 
information has been
                                                                                                        
ignored and not acted on.)
** Identification, evaluation and implementation of the 
safest                 ( Praxis has won awards for doing this.)
feasible approaches to meeting social needs;

** Placing responsibility on originators of potentially dangerous
activities to thoroughly study and minimize risks, and to
evaluate and choose the safest alternatives to meet a 
particular            ( e.g Praxis Academy Biotool Kits for Schools)
need, with independent review; 
and                                                     ( Not pesticide 
co-opted agencies and Institutions)

** Application of transparent and inclusive 
decision-making                  ( e.g.Repressing, and disparaging 
biological control)
processes that increase the participation of all stakeholders and
communities, particularly those potentially affected by a policy
choice.

We believe that effective application of the 
precautionary                      ( e.g. Official trivializing of 
pesticide risk in the State
principle requires interdisciplinary scientific research, as 
well                  of Michigan by some public officials)
as explicitness about the uncertainties involved in this research
and its findings.

Precautionary decision-making is consistent with "sound science,        
( Praxis and our understanding of complex biological
interactive and cumulative impacts of multiple 
systems                          systems, in the interconnectedness of 
organisms,
because of the large areas of uncertainty and even ignorance 
that           and the potential for interactive and cumulative multiple
persist in our understanding of complex biological systems, 
in                benefits.)
the interconnectedness of organisms, and in the potential for
interactive and cumulative impacts of multiple hazards. Because
of these uncertainties, science will sometimes be incapable of
providing clear and certain answers to important questions about
potential environmental hazards. In these instances, policy
decisions must be made on the basis of sound judgment, open
discussion, and other public values, in addition to whatever
scientific information is available. We believe that waiting for
incontrovertible scientific evidence of harm before preventive
action is taken can increase the risk of costly mistakes that can
cause serious and irreversible harm not only to ecosystem and
human health and well-being, but also to the economy.

Some of the ways that scientific information is currently applied        
( A long-standing complaint of Praxis to decision makers in formulating 
policy can work against the ability to take                     the 
State of Michigan)
precautionary action, for example by misrepresenting limitations
in the state of scientific knowledge. Decision-makers frequently
look for high levels of proof of causal links between a
technology and a risk before acting, so that their decisions will
be protected from accusations of being arbitrary. But often, high
levels of proof cannot be achieved, and are not likely to be
forthcoming in the foreseeable future. A more complete and open
presentation from scientists on the current limitations in
understanding of environmental risks will encourage the
acceptance on the part of government decision-makers and the
public of the idea that precautionary action is a prudent and
effective strategy when potential risks are large and
uncertainties are large as well.

It is not only the communication between scientists and 
policy              ( e.g. "Life form efficacy testing", and "Good Science")
makers, however, which needs improvement. We believe that there
are ways in which the current methods of scientific inquiry may
also retard precautionary action. For example, research
frequently focuses on narrow, quantifiable aspects of problems,
thus inadvertently excluding from consideration potential
interactions among different components of the complex biologic
systems of which humans are a part. The compartmentalization of
scientific knowledge further impedes the ability of science to
detect and investigate early warnings and develop options for
preventing harm when far-reaching health and environmental risks
are involved. Unfortunately, limitations in scientific tools and
in the ability to quantify causal relationships are often
misinterpreted by government decision-makers, scientists, and
proponents of hazardous activities as evidence of safety.
However, not knowing whether an action is harmful is not the same
thing as knowing that it is safe.

We contend that effective implementation of the precautionary           
( Co-opted "science" being used to control public policy
principle demands improved scientific methods, and a 
new                   and the marketplace. A long standing Praxis complaint)
interface between science and policy that stresses the continuous
updating of knowledge as well as improved communication of risk,
certainty, and uncertainty. With these objectives in mind, we
call for a re-evaluation of scientific research agendas, funding
priorities, science education, and science policy. The ultimate
goals of this effort would include:

** A more effective linkage between research on hazards and            ( 
This policy was adopted by Praxis at its inception)
expanded research on primary prevention, safer technological
options, and restoration;

** Increased use of interdisciplinary approaches to science and         
( also known as Integrated Biological Cybernetics)
policy, including better integration of qualitative and
quantitative data;

** Innovative research methods for analyzing the cumulative and         
( A common complaint by Praxis to the State of Michigan)
interactive effects of various hazards to which ecosystems and
people are exposed; for examining impacts on populations and
systems; and for analyzing the impacts of hazards on vulnerable
sub-populations and disproportionately affected communities;

** Systems for continuous monitoring and surveillance to avoid           
( Part of all Biotool Kit products Praxis sells)
unintended consequences of actions, and to identify early
warnings of risks; and

** More comprehensive techniques for analyzing and communicating  ( 
Praxis complaint to the State of Michigan)
potential hazards and uncertainties (what is known, not known,
and can be known).

We understand that human activities cannot be risk-free. However,     ( 
This could describe Praxis and its product line)
we contend that society has not realized the full potential of
science and policy to prevent damage to ecosystems and health
while ensuring progress towards a healthier and economically
sustainable future. The goal of precaution is to prevent harm,
not to prevent progress. We believe that applying precautionary
policies can foster innovation in better materials, safer
products, and alternative production processes.

We urge governments to adopt the precautionary principle in              
( Consistant with our behavior and business policy)
environmental and health decision-making under uncertainty when
there are potential risks, as well as to take timely preventive
and restorative actions in cases where damage has been
demonstrated. The elements of decision-making processes
incorporating the precautionary principle, as outlined above,
represent necessary aspects of sound, rational processes for
preventing negative impacts of human activities on human and
ecosystem health. This approach shares the core values and
preventive traditions of medicine and public health.

==========

[1] Michael Pollan, "Precautionary Principle," NEW YORK TIMES
MAGAZINE Dec. 9, 2001, pgs. 92, 94.

[2] Wirthlin Worldwide, "The Precautionary Principle: Throwing
Science Out with the Bath Water," WORTHLIN WORLDWIDE ISSUES
PERSPECTIVE February, 2000. pgs. 1-8; available at http://-
209.204.197.52/publicns/report/PPFINAL.PDF.

[3] Indur M. Goklany, THE PRECAUTIONARY PRINCIPLE; A CRITICAL
APPRAISAL OF ENVIRONMENTAL RISK ASSESSMENT (Washington, D.C.:
Cato Institute, 2001). ISBN 1-930865-16-3.

[4] Juan Almendares Bonilla, MD, MS, Professor of the 
Medical                            (A list of Signatories with common 
concerns.)
School of Honduras, Honduras; Molly Anderson, PhD, MS, Director
of the Tufts University GIS Center, Tufts University, USA;
Nicholas Ashford, PhD, JD, Professor of Technology & Policy,
Massachusetts Institute of Technology, USA; Katherine Barrett,
PhD, Research Associate of Environmental Law and Policy,
University of Victoria, Canada; Kamaljit Bawa, PhD, MS,
Distinguished Professor of Biology, University of Massachusetts
Boston, USA; Pushpa Bhargava, PhD, Founding Director, Centre for
Cellular and Molecular Biology, India; Finn Bro-Rasmussen, PhD,
MSc, Professor Emeritus of Environmental Science and Ecology,
Danmarks Tekniske Universitet, Denmark; David Brown, ScD, Public
Health Toxicologist, Northeast States for Coordinated Air Use
Management, USA; Donald Brown, JD, MA, Director; Pennsylvania
Consortium for Interdisciplinary Environmental Policy, USA; Phil
Brown, PhD, Professor of Sociology and Environmental Studies,
Brown University, USA; Richard Clapp, DSc, Associate Professor of
Public Health, Boston University School of Public Health, USA;
Terry Collins, PhD, Professor of Chemistry, Carnegie Mellon
University, USA; Barry Commoner, PhD, Director of the Center for
the Biology of Natural Systems, Queens College, USA; Anthony
Cortese, ScD, President, Second Nature, USA; Carl Cranor, PhD,
MSL, Professor of Philosophy, University of California Riverside,
USA; Cathy Crumbley, MS, Program Director, Lowell Center for
Sustainable Production, University of Massachusetts Lowell, USA;
Dianne Dumanoski, MA, Author, USA; Paul Epstein, MD, MPH,
Associate Director, Center for Health and the Global Environment,
Harvard Medical School, USA; Thomas Estabrook, PhD, Worker Health
Educator, University of Massachusetts Lowell, USA; Daniel Faber,
PhD, Associate Professor of Sociology, Director of the
Philanthropy and Environmental Justice Research Project,
Northeastern University, USA; Marian Flum, MS, Project Director
of the Environmental Justice Minority Worker Training Program,
University of Massachusetts Lowell, USA; Ken Geiser, PhD,
Director of the Toxics Use Reduction Institute, University of
Massachusetts Lowell, USA; Michael Gilbertson, PhD, Biologist,
Canada; Elizabeth Guillette, PhD, Visiting Scholar, Tulane and
Xavier Universities, USA; Marissa de Guzman, Research Assistant,
University of the Philippines, Diliman, Philippines;
Mary-Elizabeth Harmon, PhD, Toxics Campaign Scientist,
Greenpeace, USA; May Hermanus, MSc, Chief Inspector of Mines,
Department of Minerals and Energy, Mines Health and Safety
Inspectorate, South Africa; Christina Holcroft, ScD,
Post-doctoral Research Fellow, University of Massachusetts
Lowell, USA; Polly Hoppin, ScD, Public Health Scientist, USA;
James Huff, PhD, Toxicologist, National Institute of
Environmental Health Sciences, USA; Carel Ijsselmuiden, MD,
Director of the School of Health Systems and Public Health,
University of Pretoria; South Africa; Sheila Jasanoff, PhD, JD,
Professor of Science and Public Policy, Harvard University, USA;
Matthias Kaiser, DPhil, Director, National Committee for Research
Ethics in Science and Technology, Norway; Tom Kelly, PhD,
Director of the Office of Sustainability Programs, University of
New Hampshire, USA; Lee Ketelsen, New England Director, Clean
Water Fund, USA; Misa Kishi, MD, DrPH, Senior Environmental
Specialist, JSI Research and Training Institute, USA; David
Kriebel, ScD, Co-Director of the Lowell Center for Sustainable
Production, University of Massachusetts Lowell, USA; John Lemons,
PhD, MS, Professor of Biology and Environmental Science,
University of New England, USA; Richard Levins, PhD, Professor of
Population Sciences, Harvard School of Public Health, USA; Edward
Loechler, PhD, Professor of Biology, Director of the Program in
Biochemistry and Molecular Biology, Boston University, USA; John
MacDougall, PhD, Professor of Regional Economic and Social
Development, University of Massachusetts Lowell, USA; Marco
Martuzzi, PhD, Epidemiologist, WHO European Centre for
Environment and Health, Italy; William Mass, PhD, MPH,
Co-Director of the Center for Industrial Competitiveness,
University of Massachusetts Lowell, USA; Arlene McCormack, PhD,
Professor of Regional Economic and Social Projects Director of
the Science and Environmental Health Network, USA; David Ozonoff,
MD, MPH, Professor Environmental Health, Boston University, USA;
Romeo Quijano, MD, MS, Associate Professor at the College of
Medicine, University of Philippines Manila, Philippines; Margaret
Quinn, ScD, Professor of Work Environment, University of
Massachusetts Lowell, USA; Carolyn Raffensperger, JD, MA,
Executive Director, Science and Environmental Health Network,
USA; Jorge Riechmann, PhD, Research Coordinator, Instituto
Sindical de Trabajo, Ambiente y Salud, Spain; Anthony Robbins,
MD, Professor, Department of Family and Community Health, Tufts
University School of Medicine, USA; Per Rosander, Chemical Policy
Advisor, Kemi & Miljo AB, Sweden; Ruthann Rudel, MS, Senior
Environmental Toxicologist, Silent Spring Institute, USA; Hans
Sanderson, Aquatic Ecotoxicologist, Roskilde University, Denmark;
Ted Schettler, MD, MPH, Science Director for the Science and
Environmental Health Network, USA; Reinmar Seidler, Biologist,
University of Massachusetts, Boston, USA; Vandana Shiva, PhD,
Director and Founder, Research Foundation for Science,
Technology, and Ecology, India; Caroly Shumway, PhD, Principal
Investigator for Aquatic Biodiversity, New England Aquarium, USA;
Carlos Eduardo Siqueira, MD, ScD, MPH, Research Assistant
Professor of Work Environment, University of Massachusetts
Lowell, USA; Craig Slatin, ScD, MPH, Assistant Professor,
University of Massachusetts Lowell, USA; Carlos Sonnenschein, MD,
Professor of Cellular Biology, Tufts University School of
Medicine, USA; Colin Soskolne, PhD, Professor of Epidemiology,
University of Alberta, Canada; Ana Soto, MD, Professor of Cell
Biology, Tufts University, USA; Doreen Stabinsky, PhD, Science
Advisor, Genetic Engineering Campaign, Greenpeace; USA; Andy
Stirling, Dphil, MA, Senior Lecturer and Senior Fellow, Science
Policy Research Unit; Sussex University, UK; Cato ten
Hallers-Tjabbes, PhD, Netherlands Institute for Sea Research,
Netherlands; Boyce Thorne-Miller, MSc, Consultant, USA; Joe
Thornton, PhD, Research Scientist, Columbia University, USA; Joel
Tickner, ScD, Research Assistant Professor of Work Environment,
University of Massachusetts Lowell, USA; Alejandro Valeiro, PhD,
Agronomic Engineer, National Institute for Agricultural
Technology, Argentina; Miguel Vales, PhD, Senior Researcher,
Institute of Ecology and Systematics, Cuba; Reginald Victor, PhD,
Director of the Centre for Environmental Studies and Research,
Sultan Qaboos University, Sultanate of Oman; Wendy Wagner, JD,
MA, Professor, University of Texas School of Law, USA; Cathy
Walker, National Health and Safety Director, Canadian Auto
Workers, Canada; Tom Webster, DSc, Assistant Professor of
Environmental Health, Boston University School of Public Health,
USA; David Wegman, MD, MSc, Professor of Work Environment,
University of Massachusetts Lowell, USA; John Wooding, PhD,
Professor of Regional Economic and Social Development, University
of Massachusetts Lowell, USA.
 




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