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The
Precautionary Principle:
Protecting Public Health and the Environment1
Ted
Schettler, Katherine Barrett, Carolyn Raffensperger
Science and Environmental
Health Network
The precautionary principle is a guide to public policy decision making
(Raffensperger and Tickner 1999,
Schettler et al. 2002). It responds to
the realization that humans often cause serious and widespread harm to
people, wildlife, and the general environment. According to the precautionary
principle, precautionary action should be undertaken when there are credible
threats of harm, despite residual scientific uncertainty about cause and
effect relationships.
History
of the Precautionary Principle:
The
term "precautionary principle" comes from the German "Vorsorgeprinzip"--
literally, "forecaring principle." Its origins can be traced
to German clean air environmental policies of the 1970's that called for
Vorsorge, or prior care, foresight, and forward planning to prevent harmful
effects of pollution (Boehmer-Christiansen
S. 1994). The precautionary principle has since
been invoked in numerous international declarations, treaties, and conventions,
and has been incorporated into the national environmental policies of
several countries. It has been applied to specific decisions on food safety,
protection of freshwater systems, land development proposals, fisheries
management, and the release of genetically modified organisms, among others.
Formulations of the precautionary principle
One
formulation of the precautionary principle is found in the 1992 Rio Declaration
of nations participating in the United Nations Environment Program treaty
negotiations:
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Where
there are threats of serious or irreversible damage, lack of full
scientific certainty shall not be used as a reason for postponing
cost-effective measures to prevent environmental degradation (Rio
Declaration 1992) (Shabecoff 1996). |
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In
1998 a group of scientists, environmentalists, government researchers,
and labor representatives from the United States, Canada, and Europe convened
at the Wingspread Conference in Wisconsin to discuss ways to formalize
and implement the precautionary principle. They formulated the precautionary
principle as:
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"When
an activity raises threats of harm to human health or the environment,
precautionary measures should be taken even if some cause and effect
relationships are not fully established scientifically." (Wingspread
Statement, 1998) |
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The
precautionary principle says we should attempt to anticipate and avoid
damages before they occur or detect them early. However formulated, each
version of the precautionary principle is based on underlying values and
three core elements:
- potential
harm—predicting and avoiding harm, or identifying it early, should
be a primary concern when contemplating an action;
- scientific
uncertainty—the kind and degree of scientific uncertainty surrounding
a proposed activity should be explicitly addressed; and
- precautionary
action
Why
the Precautionary Principle?
Humans
have transformed land, sea, and air, dominating the earth’s ecosystems
in unprecedented ways (McCally 2002). Although
many of these impacts were or could have been predicted, often they were
surprises. Degradation of life support services, loss of biodiversity,
and direct impacts on human health are a result (Lubchenco
1998, Johnson et al. 2001).
Patterns of human disease are changing throughout the world. To remain
focused on life expectancy and decreases in childhood mortality is to
miss these changing patterns.
Newly
emerging infectious diseases and new geographical distribution of older
infectious diseases illustrate the capacity of microorganisms to evolve
and adapt to changing circumstances. Antibiotic resistance is increasingly
common. Chronic diseases like hypertension, heart disease, diabetes, and
asthma are increasing throughout much of the world. Depression and other
mental health disorders are becoming new public health threats in many
parts of the world with profound consequences for individuals, families,
and communities. Developmental disabilities, including learning disorders,
attention deficit hyperactivity disorder, and autism are increasingly
common (Schettler et al. 2000).
The age-adjusted incidence of a number of different kinds of cancer in
the US has increased over the past 25 years (SEER).
The incidence of some birth defects is increasing (Paulozzi
1999, Pew 2001). Sperm density is declining
in some parts of the world (Swan et al.
1997). Asthma prevalence and severity is sharply increasing throughout
the world and is often of epidemic proportions (Pew
2001).
Recognizing
the limits of science, the precautionary principle is intended to enable
and encourage precautionary actions that serve underlying values, based
on what we know as well as what we do not know. It encourages close scrutiny
of all aspects of science, from the research agenda to the funding, design,
interpretation, and limits of studies, for potential impacts on the earth
and its inhabitants.
Elements
of the precautionary principle:
Underlying
values:
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The
precautionary principle contains a specific directive to take precautionary
action and, as with all guiding principles, carries its own values.
The principle is based on recognizing that some activities may cause
serious, irreparable, or widespread harm and that people have a
responsibility to prevent harm and to preserve the natural foundations
of life, now and into the future. The needs of future generations
of people and other species and the integrity of ecosystems are
worthy of Vorsorge, of forecaring, and of respect.
A
precautionary approach asks how much harm can be avoided rather
than asking how much is acceptable. The precautionary principle
acknowledges that the world is comprised of complex, interrelated
systems, vulnerable to harm from human activities, and resistant
to full understanding. Precaution gives priority to protection of
these vulnerable systems. |
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The
potential for harm:
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Precautionary
action is appropriate when there is credible evidence that a particular
technology or activity might be harmful, even if the nature of that
harm is not fully understood. This means that decision makers must
consider potential hazards that have been identified or that are
plausible, based on experience, what is known, and/or predicted.
Threats of serious, irreversible, cumulative, or widespread harm
are of more concern than trivial threats and demand precautionary
action commensurate with their nature.
Harm
can occur at the level of the cell, organism, population, or ecosystem.
Impacts may be biological, ecological, social, economic, or cultural,
and they may be distributed equally or disproportionately among
individuals, populations, or geographically, now or in the future.
Because systems are complex and outcomes are not always predictable,
it becomes extremely important for decision makers to specifically
identify the parameters that are used to assess the potential impacts
of a proposed activity. Moreover, the standard against which an
impact is measured must also be defined. Asking whether a proposed
agricultural pesticide is safer for use than another, for example,
is very different from asking whether either is necessary at all.
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Scientific
uncertainty:
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Recognition
of scientific uncertainty is central to the precautionary principle.
We are often unable to predict or even identify in advance the consequences
of a proposed action in complex biological or social systems (Perrow
1984). When inputs are modified, the behavior of complex systems
is often surprising. By the time impacts are documented, considerable
harm may have occurred. Despite early warnings, the use of lead in
gasoline and paint, for example, damaged the brain function of generations
of children (Markowitz and Rosner
2000). Sometimes, a system crosses a threshold and operates at
a new state of relative equilibrium from which there is no turning
back. For example, exotic species may be introduced into ecosystems
where they did not previously exist, allowing them to become established
and cause irreversible harm. Understanding
cause and effect relationships in complex systems is limited by
different kinds of uncertainties. Uncertainty sometimes results
from more than a simple lack of data or inadequate models and is
not easily reduced because of the nature of the problem being studied.
In those circumstances, a requirement of absolute "proof"
of harm before action can be taken is either ideologically motivated
or deprived of a fundamental understanding of the limits of science.
Most
complex problems have a mixture of three general kinds of uncertainty—statistical,
model, and fundamental—each of which should be explicitly
considered before deciding how to act.
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Statistical uncertainty:
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Statistical
uncertainty is the easiest to reduce or to quantify with some precision.
It results from not knowing the value of a particular variable at
a point in time or space but knowing, or being able to determine,
the probability distribution of the variable. An example is IQ distribution
in a population of individuals. In this case, valid decisions can
be based on knowing the likelihood of a variable having a particular
value.
Typically,
however, real-world decisions are made in the context of multiple,
interactive variables. For example, the incidence of cancer attributable
to exposure to a carcinogen in genetically and geographically diverse
people is inherently more difficult to determine than the incidence
of cancer in a group of genetically similar rodents exposed to the
same carcinogen living in controlled laboratory conditions. When
more than one variable is involved, a model is typically constructed
with certain assumptions and simplifications, introducing a new
kind of uncertainty. |
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Model uncertainty:
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Model
uncertainty is inherent in systems with multiple variables interacting
in complex ways. Even if the statistical uncertainty surrounding
the value of a single variable can be defined or reduced, the nature
of relationships among system variables may remain difficult to
understand. This is particularly problematic for any model of complex
systems. We may decide that there will be a tendency for the system
to behave in a certain way, but the likelihood of that behavior
is difficult to estimate.
Moreover,
complex models can include only a finite number of variables and
interactions. The real world, however, is a confluence of biological,
geochemical, ecological, social, cultural, economic, and political
systems. No experimental model can fully account for each of these
and their interrelationships. Ongoing research, monitoring, and
model refinement may help to reduce uncertainties, but imprecision
is inevitable. Indeterminacy, which increases when moving from statistical
to model uncertainty, is, at some point, more correctly called ignorance.
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Fundamental uncertainty:
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Fundamental
uncertainty encompasses this extension of indeterminacy into ignorance.
Ignorance that results from the complexity or uniqueness of a system
is of particular concern. This kind of uncertainty is inherent in
novel or complex systems where existing models do not apply. Fundamental
uncertainty can result from having no valid knowledge of the likelihood
of a particular outcome. Fundamental uncertainty can also result
from no knowledge of what some of the outcomes may be. Here we don't
even know what we don't know. Chemical regulators, for example,
were unaware of the existence and functions of a stratospheric ozone
layer that would be damaged by chlorofluorocarbons when allowing
them to be marketed as safe for commercial use. Fundamental uncertainty
is extremely difficult to reduce or otherwise manage and demands
respect and humility.
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Scientific uncertainty and scientific proof:
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It
is imperative to keep these kinds of uncertainty in mind when considering
the notion of scientific proof. Proof is a value-laden concept that
integrates statistics, empirical observation, inference, research
design, and the research agenda into a political and social context.
Strict criteria may be useful for establishing "facts",
but by the time a fact or causal relationship has been established
by rigorous standards of proof, considerable avoidable harm may
already have occurred. The impacts of lead exposure on children’s
brain development or asbestos on lung cancer risk are examples.
Guided by the precautionary principle, therefore, we are as concerned
with the weight of available evidence as we are with the establishment
of fact by rigorous standards of proof.
By convention, a considerable amount of consistent evidence is necessary
to establish factual "proof" of a cause and effect relationship.
Traditionally, in a study of the relationship between two variables,
a correlation is said to be statistically significant only if the
results show the two to be linked, independent of other factors,
with greater than 95% likelihood that the results of the study truly
depict the real world. But correlation does not establish causation.
In epidemiology, a series of additional criteria, for example, those
of Hill, are usually added before causation can be claimed (Hill
1965). Hill criteria include not only establishment of a statistically
significant correlation between two variables, but also require
that the causal variable precede the effect, a dose-response relationship,
elimination of sources of bias and confounding, coherence with other
studies, and understanding of a plausible biological mechanism.
Tobacco smoking, for example, was known to be associated with lung
cancer for more than fifty years before a plausible biological mechanism
was finally described. At that point, it became impossible to deny
that tobacco "causes" cancer.
When
exposure to environmental hazards causes immediate and obvious harm,
scientific uncertainty about cause and effect relationships is minimal.
However, under other circumstances, scientific uncertainty increases
dramatically and is often difficult to resolve.
Conditions with long latency periods between a hazardous exposure
and the appearance of an adverse health outcome are difficult to
study. Study design is necessarily complex and implementation is
expensive. Intervening variables that must be considered in a comprehensive
study complicate the analysis. Subjects may also be lost to follow
up during a prolonged study.
Investigative
challenges are also increased when the health outcome is subtle
and detectable only by detailed, complex testing. For example, subtle
changes in immune system or brain function may be of significant
practical importance but difficult to document easily.
Finally,
adverse health outcomes are often non-specific and multifactorial
in origin. Many diseases, for example, asthma or developmental disorders
like learning disabilities are caused by complex interactions of
genetic, environmental, and social factors and are not easily linked
to single variables. As a result, determining causation with precision
is difficult, if not impossible, and some residual uncertainty will
always remain. It then becomes the task of policy makers or health
care providers to decide how to act in the face of uncertainty.
Under these circumstances, according to the precautionary principle,
preventive or anticipatory measures are appropriate.
Meanwhile,
lack of "proof" of harm is often used to justify ongoing
or proposed activities when the weight of credible evidence suggests
that harm is plausible and perhaps even likely. Given the limits
of scientific inquiry in the world of complex systems, establishing
a high bar of proof as a pre-requisite for taking action is certain,
in some instances, to result in unnecessary and often irreversible
harm (Beauchamp and Steinbock
1999, Kriebel et al. 2001).
Under the precautionary principle, shifting the burden of proof
from one party to another, depending on weight of evidence, lack
of evidence, scientific uncertainty, and the nature of the harm
of concern is one way to address these complexities. Depending on
circumstances, differing standards of evidence for demonstrating
harm (or safety) may also help protect public health and the environment.
For example, concluding that something is more likely than not to
cause harm is a very different standard from concluding that it
will cause harm beyond a reasonable doubt.
The
precautionary principle reminds us that, when dealing with complex
systems, evidence is rarely sufficient to quantify or predict the
consequences of human activity beyond doubt. Yet, failure to take
action, because of a lack of quantifiable proof of harm, is, in
itself, a form of action.
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Precautionary
action
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Finally,
in order to serve the values that underlie the precautionary principle,
action should be anticipatory, in order to prevent harm to public
health and the environment, despite underlying scientific uncertainty.
The precautionary principle does not specify which actions are appropriate
under particular circumstances. It is a guiding principle, not a
set of binding rules. The choice(s) among potential anticipatory
actions, however, should be informed by:
- full
consideration of the weight of evidence for potential harm
- the
kind and degree of scientific uncertainty associated with that
evidence
- participation
of potentially affected parties, and
- an
assessment of potential alternative actions.
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Implementing
the precautionary principle
The
precautionary principle requires a systematic look at the potential for
various kinds of harm, associated scientific uncertainty, underlying fundamental
values, and then counsels precautionary action.
1)
Goal setting
Goal
setting is particularly important for establishing environmental and health
policies. Goal setting requires us to ask, "Where do we want to be
at some future time? What are we trying to accomplish? Starting with agreed
upon goals and then looking at where we are now can help in developing
a strategy for getting from here to there. Of course, not all goals are
generally agreed upon or represent shared visions. But as goals are made
explicit, the values and assumptions underlying decision-making processes
will also become more transparent and may result in processes for reconciling
differences.
2)
Assessing alternatives
A
truly precautionary approach includes examination of a range of options
for meeting policy goals. Currently, in most settings there are few requirements
for comprehensively assessing a range of alternatives to proposed activities.
For example, current regulatory policies emphasize a risk assessment/risk
management framework. This approach attempts to estimate the probability
of harm (risk) from a proposed activity and then asks whether that harm
is acceptable. Risk management techniques are intended to minimize the
risks of the proposed activity, but not to question if the activity is
necessary for achieving broader goals.
Alternatives
assessment instead asks whether the harm is necessary and if there might
be other ways to achieve agreed upon goals that would avoid harm altogether.
When alternatives assessment is applied earlier rather than later in policy
decision making, innovative approaches that reflect societal goals, ecological
principles, and the values that underlie the precautionary principle are
more likely to emerge. Assessing alternatives can also lead to actions
that truly respect the level of uncertainty in given circumstances.
3)
Adopting transparent, inclusive, and open processes
A
precautionary approach requires open, inclusive, and transparent processes
that are initiated early in decision making, beginning with goal setting,
where the health and well-being of the public and environment are at stake.
A participatory approach is justified by a belief in the fundamental fairness
of democratic decision making and by the thought that a broad range of
experience leads to better science and decision-making. Transparency also
helps to ensure accountability among decision-makers.
4)
Analyzing uncertainty
A
precautionary approach requires explicit recognition of the scientific
uncertainty inherent in understanding the potential for harm from an ongoing
or proposed activity.
Statistical
uncertainty may be reduced with more data collection. Model and fundamental
uncertainty, however, are more difficult to reduce. When model or fundamental
uncertainty predominate, a requirement to resolve uncertainty as a pre-requisite
for decision making shows a fundamental lack of understanding of the limits
of science or alternatively, may be nothing more than a tactic to maintain
the status quo. In the US, for example, President Bush used scientific
uncertainty about the impacts of greenhouse gases on global climate to
justify US rejection of the Kyoto treaty on global climate change and
to promote an energy policy weighted heavily in favor of increasing fossil
fuel extraction and consumption.
5)
Burden of proof and responsibility
Under
the precautionary principle, the burden of proof regarding the safety
of an activity may shift with the nature of potential harm and scientific
uncertainty. Requirements for evaluating the safety of a proposed activity
also vary with the political context. The precautionary approach suggests
that the burden of proof is better thought of as the burden of persuasion
and responsibility. This avoids the fruitless assertion that absolute
safety can never be "proven." Rather, it acknowledges that,
as the potential for serious, irreversible harm and scientific uncertainty
increase, the proponent of an activity has an increasing obligation to
account for the safety of the activity and take responsibility for adverse
impacts that may result from it. Then, more comprehensive testing, monitoring,
and assumption of liability shift the onus onto the proponent.
6)
Learning and adaptation
Under
the precautionary approach, appropriate research and monitoring are essential.
Decisions must be periodically re-examined, based on new information.
The research agenda of private and public institutions may be designed
to reflect broad social goals that extend well beyond developing marketable
products. In this way the precautionary approach is designed with feedback
loops that search for and take into account new information and unintended
consequences of provisional decisions.
7)
Options for precautionary action
Choices
among potential precautionary actions are made only after full analysis
of potential harms and scientific uncertainty. Precautionary action can
take a number of directions. At the level of regulation, when research
and development of a product or technology are complete, and only regulatory
approval is needed for production and marketing, the options are ordinarily
limited to yes, no, with limits, with monitoring, with labeling, or with
posting of a performance bond.
At
a pre-regulatory level, however, precautionary action might include a
closer look at problems that proposed technologies are intended to solve.
How was the problem defined and by whom? Was the problem framed in the
only or best way? Are there alternatives to the proposed technology?
Evaluating
a full range of possible precautionary measures again requires a multidisciplinary,
participatory approach in order to elicit relevant knowledge and set priorities.
Responses to scientific uncertainty, as well as various kinds of harm,
legitimately vary among individuals, societies, and cultures. It is obviously
easier to consider alternatives, multiple sources of information, and
priorities earlier in the process than when a developed product or technology
is presented for regulatory approval.
The Relationship of the Precautionary Principle to Risk Assessment:
A risk assessment approach to public policy decision making dominates
in the US and many parts of the world. With few exceptions, risk assessments
attempt to estimate the potential risks of proposed products or activities
on a case-by-case basis without consideration of the complete context
in which the activity will be carried out and rarely with any consideration
of alternatives to the proposal (O'Brien 2000).
The
relationship between the precautionary principle and risk assessment reflects
differing views of a number of factors, including how much we know, how
much we can know, how broadly questions should be framed, which questions
should be asked, who should frame the questions, the value of non-human
life, our responsibility to future generations, and how we plan for the
future.
Quantitative
risk assessments usually respond to narrowly-framed questions and are
often flawed by simplifying assumptions. Risk assessments almost always
fail to consider a full range of biological, ecological, social, cultural,
and economic impacts and how they are distributed. Advocates of a regulatory
system dominated by quantitative risk assessments argue that they are
inherently precautionary through the use of conservative assumptions and
safety factors. Risk assessors, however, often fail to distinguish among
various kinds of uncertainty and tend to misclassify some model and fundamental
uncertainty as statistical, to which they apply "uncertainty"
factors. When model and fundamental uncertainty predominate in a system,
this approach may lead to large underestimates of risk, failure to predict
adverse impacts removed in time and space, and of course, will completely
fail to predict surprises or novel impacts.
Risk
assessors often claim that the precautionary principle is "anti-science"
or a tool to keep certain technologies from the marketplace. In fact,
a precautionary approach encourages more science rather than less, acknowledging
the need for precautionary action while addressing scientific uncertainty
that may be intractable using available tools.
Decision
making in the face of uncertainty is, of course, necessary, frequently
difficult, and requires assessment of relative risks. Guided by an overarching
precautionary principle, however, these assessments are not the exclusive
domain of risk analysts, can be fully participatory and include a full
consideration of a range of alternatives.
Conclusion:
A
precautionary approach is based on the ethical notions of taking care
and preventing harm. It arises from recognition of the extent to which
scientific uncertainty and inadequate evaluation of the full impacts of
human activities have contributed to ecological degradation and harm to
human health. It can be used to help address these circumstances, bringing
together ethics and science, illuminating their strengths, weaknesses,
values, or biases. The precautionary principle encourages research, innovation,
and cross-disciplinary problem solving. It serves as a guide for considering
the impacts of human activities and provides a framework for protecting
children, adults, other species, and life-sustaining ecological systems
now and for future generations.
For
example: Montreal Protocol on Substances that Deplete the Ozone Layer
(1987); Ministerial Declaration of the Second World Climate Conference
(1990); Bergen Ministerial Declaration on Sustainable Development (1990);
Bamako Convention on Hazardous Wastes within Africa (1991); Framework
Convention on Climate Change (1992); United Nations Conference on Environment
and Development (1992); Helsinki Convention on the Protection and Use
of Transboundary Watercourses and International Lakes (1992); Maastrict
Treaty on the European Union (1994); US President’s Council on Sustainable
Development (1996); Cartagena Protocol on Biosafety (2000); Stockholm
Convention on Persistent Organic Pollutants (2001).
1Adapted
from an essay by Schettler et al. in:
McCally 2002.
References
Beauchamp
DE and B Steinbock (eds.). 1999. New Ethics for Public's Health. New York:Oxford
University Press.
Boehmer-Christiansen
S. 1994. The precautionary principle in Germany—enabling government.
In: Interpreting the precautionary principle. Ed: O'Riordan T, Cameron
J. Earthscan Publications, Ltd.; London.
Hill AB. 1965. The environment and disease: association
or causation? Proc R Soc Med 58:295.
Johnson N, C Revenga and J Echeverria. 2001.
Managing water for people and nature. Science 292:1071-1072.
Kriebel D, J Tickner, P Epstein, J Lemons
et al. 2001. The Precautionary Principle in Environmental Science.
Environ Health Perspect 109(9):871-876.
McCally M.(ed.) 2002. Life Support: The Environment
and Human Health. Cambridge, MA:MIT Press.
Lubchenco J. 1998. Entering the century of
the environment: a new social contract for science. Science 279:491-497.
Markowitz G and D Rosner. 2000. "Cater
to the children": the role of the lead industry in a public health
tragedy, 1900-1955. Amer J Pub Health 90(1):36-46.
O'Brien M. 2000. Making Better Environmental
Decisions: An alternative to risk assessment. Cambridge, MA, MIT Press.
Paulozzi L. 1999. International trends in rates
of hypospadias and cryptorchidism. Environ Health Perspect 107(4):297-302
Perrow C. 1984. Normal Accidents: Living with
High Risk Technologies. New York: Basic Books.
Pew
Environmental Health Commission.
Raffensperger C, and J Tickner.
(eds). 1999. Protecting Public Health and the Environment: Implementing
the Precautionary Principle. Ed: Island Press, Washington DC.
Rio Declaration on Environment and Development.
1992.
SEER Cancer Statistics Review, 1973-1996. Bethesda
MD: National Cancer Institute.
Schettler T, K Barrett and C Raffensperger.
2002. The Precautionary Principle. In: Life Support: The Environment and
Human Health. Ed: McCally M. Cambridge, MA:MIT Press.
Schettler T, Stein
J, Reich F, Valenti M. 2000. In Harm's Way: Toxic Threats to Child Development.
Greater Boston Physicians for Social
Responsibility.
Shabecoff P. 1996. A New Name for Peace: International
Environmentalism, Sustainable Development, and Democracy. Hanover and
London:University of New England Press pp 86, 156, 172.
Swan S, E Elkin and L Fenster. 1997. Have sperm
densities declined? A reanalysis of global trend data. Environ Health
Perspect 105:1228-1232.
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