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A suggested procedure for ensuring impartial and reliable
safety assessment of commercial applications of science
For the reasons presented in "The
Fallibility of Scientific Authorities", we think it is most important
not to appoint scientific experts involved in a certain field of science to be in charge of safety assessment of its applications. Instead, an interdisciplinary commission of scientists from many disparate disciplines should be appointed. We suggest the following procedure and principles:
- The chairman should be a scientist with extensive experience of interdisciplinary research, skilled in systemic ("holistic") evaluation of complex phenomena.
- Scientists in fields directly related to the application should not be members of the commission. Instead, they should be the prime interview objects of the commission. The only exception would be experts who have clearly documented an independent and impartial stance on the issue under question.
- The commission members should be renowned for having a high degree of integrity. They should be clearly independent of industrial interests and free from political bindings.
- To exclude any possibility of biased selection it is necessary that the commission is selected by NGO:s that are free from governmental and industrial influences.
- The commission should carefully investigate the research of all potential hazards of the application, scrutinizing the scientific quality and reliability of the factual evidence and the opinions presented by various experts on the application in question. Its duty would be to answer the question whether the amount and quality of the research has been enough to reliably assess all conceivable potential hazards.
- Every critical opinion pronounced by scientists in the society (irrespective of position in the scientific hierarchy), every observation indicating potential hazards and every doubt expressed by non-scientists has to be considered and openly assessed by the commission in a pedagogical manner so that everybody can judge if their conclusion is logical, impartial and objective. Thereby, it will be possible for people and decision-makers to judge the objectivity of the safety assessment of the commission.
- Every single part of the conclusions about safety must be very clearly motivated on the basis of carefully documented evidence. No conclusions may be made on the basis of beliefs or assumptions (this has generally not been the case in present conclusions about safety of GE organsisms).
- The work of the commission should be fully transparent. It should be presented in televised national public hearings.
- The analysis has to be presented in such a language that it is possible for non-scientists to understand it. Every observation that lies at the basis of the judgement has to be assessed and presented in the same pedagogical way.
- If the conclusion of this procedure is that the evidence of safety are found to be insufficient, required scientific investigations should be done by research institutions that are fully independent of the industry.
The industrial interests proposing the new application should be obliged to finance these studies. This means that the whole burden of proof of safety has to lie on the agent responsible for the introduction of the application (see also An introduction to the Precautionary Principle).
- Finally, and most importantly, the commission should address the question if there are alternatives that are safer to Health and Environment and have a better compatibility with sustainable ecological and socioeconomical development. If such alternatives are available, there is no reasonable justification to allow a potentially hazardous application.
If there is no alternative, it is most necessary to judge whether there is a reasonable relation between the risks and benefits of the application. If not, exploitation of the application should not be allowed.
The suggested procedure is fundamentally different from present practices. An extreme example of the opposite to the above suggested procedure was the assessment of the safety of the CIBA maize made by scientists appointed by the European Union in 1997. In this case, the assessment documentation was kept secret (but leaked out). Only the conclusion that the maize was safe was published (scientifically such a statement counts as nothing but an unqualified opinion). Another extreme example is the suppression by US FDA of findings indicating harmful effects of a GE food (the tomato FlavrSavr) and suppression of warnings from their own scientists that GE foods are not safe, see Biodeception.
The suggested procedure might perhaps help prevent the history of biased authorities to repeat itself in the case of the exploitation of new and powerful technologies. At least it would be a considerable improvement compared to present practices.
If the suggested procedure had been applied before market release, the exploitation of Genetically Engineered foods would most certainly not have been allowed. And the so far very limited benefits of the GE products would not have justified taking any unkown risk.
Considering the demonstrated power of today's science and technology to create new applications that may cause serious environmental damage and endanger public health at a global scale, it is necessary to start fully transparent public investigations of the suggested kind in all cases of potentially hazardous applications.
- Starting immediately with genetically engineered food and the release of all kinds of genetically engineered organisms into the environment.
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"Evaluation of global concerns, particularly in public health and environmental integrity, should not be entrusted to a non-transparent and unaccountable cabal of self-appointed experts, such as the proposed NAS1-modeled IAC2, whose views may reflect special interests rather than the public. Instead, highly qualified independent scientists acceptable to or working with non-governmental organizations (NGO's) should play a major role in an international science advisory body, such as the recently proposed World Academy of Science in Society or the Physicians and Scientists for Responsible Application of Science and Technology (PRAST)".
Excerpt from a letter to the Editor of Science by professor Samuel Epstein, M.D. and professor Mae-Wan, Ho Ph.D.
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1) NAS = US National Academy of Sciences.
2) IAC = International Academy Council
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Published in May 1997. Latest revision August 16, 2000.
Physicians and Scientists for Responsible Application of
Science and Technology
"Genetically Engineered Food - Safety Problems"
Published by PSRAST
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