The Precautionary Principle: All Style and No Substance?
In this article, I will examine the highly-vaunted “Precautionary Principle” (PP) so often invoked in discussions on the safety of cosmetics. The basis of this principal seems to be that, if there is any doubt over the safety of a substance, it should be banned – period. If this is not the actual basis of the principal, it is certainly the basis on which it is being evoked in the discussions in which I have been involved. I believe that there are several issues with this type of thinking, and some important questions should be raised:
1) What are the causes of the doubts over the safety?
- Are the doubts raised as a result of sound scientific studies?
- Are they due to misinterpretation of sound scientific studies?
- Are the studies that form the basis for concern sound in the first place?
2) Who actually doubts the safety – scientists or lobby groups?
- Do the lobby groups have sufficient evidence for doubt – to the extent that a ban could be justified?
- Do the scientists have any vested interest in sowing the seeds of doubt (i.e. gaining funding for more work on the substance in question)?
3) Has the relationship between the hazard identified and the potential human exposure been fully assessed?
- Does the Precautionary Principle allow for any type of risk assessment?
These are all important considerations, because it is very difficult to know where to draw the line in terms of assessing a substance as being “dangerous”, or “unsafe”. What may be unsafe in one application may be perfectly safe in another. It is becoming something of a cliché, but water can be a dangerous substance – there are many documented cases of long-distance athletes dying from drinking excessive quantities.
Should we invoke the PP in the case of water? Clearly, the answer is “no”, but where should the line be drawn? How much anecdotal evidence should be required before a substance should be banned in the absence of firm scientific evidence? Salt (sodium chloride) has clearly been shown to be linked to high blood pressure, yet low doses are essential to survival. Who makes the decision on the risk/benefit calculation?
In 1996, the legendary toxicologist, Professor Bruce Ames (as in the Ames Test for mutagenicity) made the following statement:
Of the 1000 natural chemicals in a cup of coffee, 28 have been tested for carcinogenicity [in rodents] and 19 of them came out positive.
At least 19 carcinogens (possibly more have been identified in the subsequent 16 years since that statement was made) would appear to present a very strong case for invoking The Precautionary Principle, but I am not aware of any of the lobby groups calling for coffee to be banned.
A study conducted by the University of Heidelberg in Germany and the University of Milan indicates that just one alcoholic drink per day can increase a woman’s risk of developing breast cancer by 5%. Those women who are heavy drinkers, consuming three or more drinks each day, increase their risk of the disease by up to 50%. It is believed that alcohol affects oestrogen levels, which can trigger certain forms of breast cancer. Although the link between alcohol and breast cancer is already known, until now it has been unclear whether there was an increased risk with low levels of consumption or a ‘safe’ threshold, below which there was no effect on breast cancer. The full findings are published in the journal Alcohol and Alcoholism. The link between alcohol consumption and breast cancer is well-established and yet, again, the groups who take such a keen interest in consumer health are not calling for alcohol to be banned.
From The Ecologist:
But the most controversial part of the soya debate is that surrounding its impact on human health. The main reason for concern is the isoflavones, a type of phyto-oestrogen, present in significant quantities in soya. According to Kate Arthur, a spokesperson for the British Dietetic Association (BDA), the issue is that these phyto-oestrogens are often confused with human oestrogen. ‘There have been studies done on soya isoflavones, or plant oestrogens, and fertility but all those studies have been on animals or in test tubes,’ she explains. ‘All the human data out there suggests that soya is safe to consume.’ Dr Kaayla Daniel, nutritionist and author of The Whole Soy Story is more concerned. ‘Thousands of studies link soy to malnutrition, digestive distress, thyroid problems, cognitive decline, reproductive disorders, immune system breakdown, even heart disease and cancer,’ she argues. ‘Possible benefits are far outweighed by proven risks.’ The Vegan Society’s Amanda Baker says that soya needs to be looked at in a more level-headed way. ‘What we do know is that soya is a good source of protein and including a moderate amount of soya protein can help to reduce cholesterol levels,’ she comments. ‘Really, other claims both positive and negative are almost entirely controversial – they’re not proven.’
In 2003, the Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment released a report identifying three groups of people who, evidence suggested, were potentially at risk. These were infants fed on soy-based formula, people with hypothyroidism and women with breast cancer. With babies, the fear is that the high levels of isoflavones may affect development. The BDA says soya is fine from the age of six months but before that, breast milk is best. Arthur also says soya is a good option for those avoiding dairy as it contains amino acids and is often fortified with things like calcium and vitamin D. The Department of Health agrees but says breast milk it better up to a year old and that people should speak to their GP about alternatives.
For the full article, see ‘The dark side of soya: how one super crop lost its way‘
The fact that there is controversy over soy suggests that human consumption should be banned, according to the Precautionary Principle.
On a lighter note, there is surely an argument to ban babies – their breath contains measurable levels of formaldehyde – a known carcinogen: ‘Toxic Baby Alert‘
So the question seems to be:
“Why are some materials a target for the Precautionary Principle, whereas others (coffee, alcohol, soy, babies) appear to be immune from attack”?
This is totally inconsistent, especially when the link to dangers are much stronger (for alcohol especially) than for many of the cosmetic ingredients under attack.
The real issue seems to be one of bias. If something is a “chemical” (i.e. a synthetic substance) then it is acceptable to invoke the Precautionary Principle, but if the material occurs “naturally” (coffee, soy, etc.), then the PP doesn’t matter. The basic problem appears to be an attack of chemophobia – it’s as simple as that! The Precautionary Principle is a weapon used/misused to promote the agenda of those who believe all/most synthetic chemicals are bad. It should be ignored and decisions on the banning of ANY substance should be taken on the basis of sound science; not on the ill-informed speculation of those with an agenda who neither consider nor understand the science.
More about the author: Dene Godfrey has been involved with preservatives for cosmetics since 1981, from both technical and commercial angles and has a degree in chemistry. Read more from this author