Don’t Trust the CDC, Question It

 Most of us tend to trust a centralized, official agency regardless of its performance. It’s much easier to look to the official, well-known source rather than to check multiple independent sources. Are you wondering when you can reasonably stop wearing a mask at work? In public places inside or out? Are you wondering whether your children should be back in school? Whether you can safely travel, especially after being vaccinated? If you are looking to the CDC for advice be aware that they have made an enormous mess. They have often failed to “follow the science”. They are a bureaucratic and politicized organization. To think of them as providing an objective, apolitical, reliable opinion is naïve. Look at the CDC’s advice, of course, but then question it and look elsewhere. 

Too many people hear the phrase “follow the science” and make two critical mistakes. The first is believing that there is a body of firm conclusions that constitute “the science” and all you have to do is accept them. Such an approach effectively turns science into religion, at least from the point of view of the believer. In a few physical sciences, there may be something very close to a core of firm conclusions – although even long-held laws in physics, chemistry, and cosmology can be and have been overturned – but the core of most sciences is much less firm. In the fields of nutrition, climate, and economic forecasting – to name just three – even many core principles and assumptions are highly contested and often on the brink of being falsified. It is fundamentally an error to see “science” as a thing. Science is a process of conjectures and refutations. 

The second critical mistake is to equate “the science” with official government agencies, such as the CDC, FDA, and all the other three- and four-letter agencies. Science is a highly distributed process. Today, a disturbing amount of its funding and publication has been centralized and brought under the control of government agencies and self-appointed gatekeepers. The CDC is a disturbing case in point. 

The CDC has been inexcusably wrong on too many major issues. They have been wrong on testing, wrong on masks, wrong on schools, wrong on travel, the effect of COVID on life expectancy, and now they are wrong on the effects of mask mandates and on-site dining. 

Testing: The CDC is directly responsible in large part for the failure in the USA to get up to speed on testing in the crucial early days, when test-and-trace might still have worked. When the coronavirus was spreading early on the in the USA, the CDC told state and local officials that its “testing capacity is more than adequate to meet current testing demands,” according to a Feb. 26 agency email seen by The Wall Street Journal. In the first week of February 2020, the CDC sent 160,000 tests to labs around the country. 

The agency botched that test kit, developed in one of their labs, leading to the retraction of many tests. After the tests were withdrawn still no approval was being given for private labs to produce tests. Private labs were eager to fill the gap but were barred. State officials and medical providers pled with the agency to open up testing, but the CDC turned away. Nor did health officials coordinate with private companies to ensure the availability of test-kit supplies. These delays at a critical early stage seriously damaged the country’s ability to contain the spread of the virus. The botched tests made it impossible to accurately assess how far and how fast the disease was spreading. 

Among those coercively prevented from improving early testing was infectious disease expert, Dr. Helen Y. Chu. (Her story is told in a March 10 New York Times article.) Her requests for permission to test nasal swabs from people experiencing symptoms were turned down by the CDC for weeks. The CDC told her that she needed approval from the FDA, but they would not give it. Finally, Dr. Chu did the tests without permission. She found a positive test for a teenager from Seattle who had not recently traveled – a discovery she would have made weeks earlier if not suppressed by the bureaucracy. They did not admit to their error or give her credit. Dr. Scott Lindquist, Washington state’s epidemiologist for communicable diseases, says, “What they [the CDC and the FDA] said on that phone call very clearly was cease and desist to Helen Chu. Stop testing.” 

The core problem here is coercive power and monopolization. No one could know precisely how the virus would spread. People other than the CDC should have been allowed to do what they thought best based on their distinctive view of the situation. This is a classic example of the value of economic freedom though what Friedrich Hayek, co-winner of the 1974 Nobel Prize in economics, understood as its allowing people to act on dispersed information, or what Hayek called knowledge of “particular circumstances of time and place.” The CDC ignored pleas from state officials and medical providers to broaden testing, and failed to work with outside companies to help the availability of test-kit supplies. (For more on this, see David Henderson’s “Capitalism is Still Working, Thank Goodness”) 

The CDC hasn’t always acted so disastrously and arrogantly. Just a decade ago, in the H1N1 flu epidemic, the CDC worked with private labs and medical facilities to get tests into people’s hands.  Even former director of the CDC (2009 to 2017) Tom Frieden said “This was kind of a perfect storm of three separate failures”, noting the botched test, overstrict FDA rules and sidelined private labs. Lacking reliable early testing, the opportunity to map early outbreaks and impose effective quarantines was blown. The World Health Organization (WHO) had sent out hundreds of thousands of testing kits to numerous countries and, on January 17, 2020 published a protocol of German origin that gave instructions that would help laboratories develop the tests. The same day, Dr. Nancy Messonnier, the director of the U.S. National Center for Immunization and Respiratory Diseases, stated that the CDC would produce its own version. (Learn more from “The Monumental Failure of the CDC”: 

Masks: The CDC (and Anthony Fauci) did not provide a consistent or evidence-based recommendation on masks. For several weeks, the CDC assured Americans that wearing a face mask in public was not necessary to stop the spread of COVID-19. They eventually changed their messaging but then played a major role in creating shortages of face masks, along with other federal agencies that prevented the importation of KN-95 masks. (The feds finally backed off on April 3, 2020.) Back-and-forth messaging first said that only health care workers and people who were sick needed to wear masks and then recommended that everyone wear face coverings when they’re out in public. The CDC utterly failed to provide clear and consistent communication. 

Along with the FDA, it was the CDC that played a major role in creating a face mask shortage. Hospitals are not allowed to purchase masks from any suppliers they think suitable. They may only buy from suppliers certified by both the CDC and the FDA. As demand for masks in America grew, supply was constrained by the slow certification process. The CDC’s own data shows that it takes an average of 95 days to approve new certifications for face mask suppliers. Numerous foreign companies that could have supplied us with masks were not allowed to do so. Even certified suppliers had to jump through bureaucratic hoops in our highly-interventionist economy before they could fill orders. (For more information, see “America Could Import Countless More Face Masks if Federal Regulators Would Get Out of the Way” 

In addition, the CDC’s messaging about masks has been inconsistent and even dishonest. As a result, many people have understandably lost trust in their guidance. For more, see this article from The Verge. 

Before COVID, there was never a demand that Americans be forced to wear masks outside of specific medical settings. Growing evidence, piled on top of pre-COVID evidence, suggests that they may be essentially useless (given the kinds worn and how they are worn) and may make things worse both in their direct effects and by lulling people into thinking that other measures no longer matter. Whatever your evaluation of the conflicting evidence, each individual should be free to decide whether or not to wear one, so long as they abide by the rules of each house and business they visit. Although the agency’s guidance is officially nonbinding, it has more power than many formal regulations while lacking transparency and public scrutiny. 

For links to evidence you probably haven’t seen: “Masking: A Careful Review of the Evidence”, and this  and this.

Schools: School closures were enforced for months despite the evidence and despite the tremendous downsides to forcing young children to stay home for a year. Some of the blame for this can certainly be placed on teachers’ unions. The unions have talked about “the science” when it suited them but ignored it when it became entirely clear that children were at very low risk of contracting or passing on the virus. Rather, they demanded that teachers stay home but continue to get paid. 

School closures have especially harmed those from poor backgrounds, often living in dense conditions in bad neighborhoods, and autistic children and others with special needs. Instead of the excessive CDC guidelines, schools could have followed the Israel approach of regular testing of teachers and students and self-isolation when infection is found. Despite the data being clear since mid-2020, the CDC only changed its guidance for schools in January 2021. Derek Thompson’s article in The Atlantic makes us ask why the media, government leaders and bureaucrats, and medical experts all act to damage our children with unsupported school closures. See more here. 

Travel: The CDC and President Biden acknowledge that it’s safe for fully vaccinated people to travel. Even so, they should not! They are over-cautious in a way that defies common sense. CDC Director Rochelle Walensky wailed “We’re all doomed because I feel it!” on one day after proclaiming the amazing power of COVID vaccines. The next, she undermines her previous statements by insisting that the fully vaccinated should continue to wear masks, socially distance, and avoid travel if they can. This confusing behavior can be understood if you understand that the CDC is a devotee of the precautionary principle, and doesn’t want people to do anything that carries the tiniest risk of harm. Apparently, avoiding tiny risks of harm is more important than anything else in life. 

For more, see Robby Soave’s “The CDC Says Vaccinated People Can Safely Travel, But Please Don't” and “Despite what the CDC says, domestic travel is safe for fully vaccinated people, even Biden is doing it” and “Stop telling people not to travel. Health officials should be teaching us how to do it safely” and “Even more evidence shows vaccinated people are unlikely to transmit the coronavirus or get asymptomatic infections”.

The six-foot mandate: How many Americans are aware that the six-feet distancing guideline is based on extremely little evidence? And that many countries in Europe and elsewhere have different guidelines? The United States has some of the strictest social distancing measures in the world. Europeans in many countries only have to stand 1 meter (about 3 feet) apart. Do they know more than us? Or are both prescriptive orders set arbitrarily? China, France, Denmark, and Hong Kong choose one meter. South Korea went for 1.4 meters; Germany, Italy, and Australia chose 1.5 meters. We still don’t know how the CDC arrived at 6 feet as the magic number. More: “The 6-Foot Mandate Was Bad Science” and “Where’s the Science Behind CDC’s 6-Foot Social-Distance Decree?” 

The WSJ article makes the point that the complaint is not that experts were wrong in the absence of good information. “The question is whether there is an effective process for establishing these measures and re-evaluating them as new information emerges. Science isn’t a set of unchanging truths handed down by a government agency.” Compounding the problem, the CDC “the CDC isn’t always clear on when the science is unsettled. This makes it harder for the American public to identify which recommendations are more open to discretion. The agency also doesn’t always identify the underlying science of its recommendations.” 

The extension of the unjust eviction ban: It’s been announced that the CDC will be extending its eviction moratorium through the end of June. While delinquent renters may welcome this, landlords will be rightly unhappy that they are banned from taking back their property from nonpaying tenants. Previously good tenants who have fallen behind on payments aren’t at much risk. With so many people unemployed, it’s difficult for landlords to find new, reliable tenants. Rental listing website Zillow found, in states where data are available, that actual evictions have come in far below predicted evictions. Claims about ridiculously large numbers of likely evictions are unsupported and use crazy assumptions. For more, see “CDC Keeps Extending Its Illegal Eviction Ban”. 

CDC misleadingly says COVID caused a reduction of one year in US life expectancy: A CDC spokesman has claimed that Covid has resulted in U.S. life expectancy falling by a year. (This was Elizabeth Arias. The real number is about 5 days or 0.013 years. How could the CDC be so badly wrong? How could it promote that false information to an already-traumatized public? 

In one sense, that estimate follows standard guidelines for calculating changes in life expectancy. When a change is expected to affect life expectancy each year in the future to about the same extent as in the latest year, the process produces reasonable results. The CDC calculated what the effect on life expectancy would be if mortality rates stayed at their 2020 level. In other words, they figured out how much Covid would reduce life expectancy if the pandemic were repeated every year forever. 

What the CDC should have assumed is that Covid-19 will increase mortality for only a brief period relative to the span of a normal life. The standard method of calculating life expectancy is extremely sensitive to passing events such as pandemics and wars. The CDC’s statement is concerning because almost everyone will take it to mean that Covid has shortened the life of every person by a year on average. For those in the 20-49 age group, the decline in life expectancy is less than one day. Even for seniors, the days lost comes to 87 days of discounted quality-adjusted life expectancy. 

Quick math: Counting the 362,000 deaths in 2020, and accepting the (possibly excessive) estimate of 12 years of life lost on average, you get 4,344,000 life years lost. Divide by population = 0.013 or 4.75 days. Counting all Covid deaths to date: 570,294 x 12 = 6,843,528 = 0.02 or 7.5 days. For more, see Peter B. Bach, “CDC estimated a one-year decline in life expectancy in 2020. Not so — try five days” <https://www.statnews.com/2021/02/25/cdc-one-year-decline-life-expectancy-really-five-days/> 

Excessively precautionary: Behind many of the CDC’s mistakes is its implicit attachment to the precautionary principle. (You can find plenty of thoughts about that principle elsewhere on my blog.) As Robby Soave from Reason notes, “It’s important to keep in mind that the CDC has always urged people to follow impractically cautious health guidelines. For instance, the CDC currently recommends that men consume no more than two alcoholic drinks and that women consume no more than one drink, each day. The agency’s clear preference is for people not to consume alcohol at all.” 

The CDC has gone beyond excessive caution to bad policies and embarrassing public doomsaying. Director Rochelle Walensky warned of “impending doom” if states reopen too quickly. As POLITICO put it, a “visibly shaken” Walensky stood in front of the cameras and said, “Right now, I'm scared” and implied that her feelings were a sound basis for us all to be deeply fearful. Of course, fear is an effective tool of control. 

The CDC has acted much as one would expect a centralized government agency to act. This is not the fault of the people working there. It’s the result of the agency’s structure and incentives. Unfortunately, most of the American public persists in the foolish belief that the CDC is doing fine and, if not perfect, that can be solved by throwing more taxpayer money at it and installing “the right people”. 

How deadly is COVID-19 to me, and people like me?

 

Is going out of your house for anything other than absolutely life-critical reasons comparable to going to an active shooter location? This is the claim made recently to me by a colleague. The same person tried to emphasize how awful the risk is by saying that I was 50 times more likely to die from COVID-19 than from influenza. More generally, how worried should someone of my age and health be about going to shop for groceries, getting take-out food, or other regular activities that could be avoided but that don’t involve getting close to unmasked people? And how should be most usefully frame that risk.

The numbers in this piece are for people like me. I’m male in the 55 to 64 age group with no major medical issues. I’m white, not desperately poor, not diabetic, not obese, and do not have reduced kidney function, stroke, or dementia, nor any neurological conditions. I do have other medical issues, but they have no bearing on my COVID risk.

In discussing how to communicate the risk to others, a colleague made two comparisons: The risk of dying from COVID as compared to dying from influenza; and the act of going out of your home for anything other than absolutely survival-critical reasons as being like entering an active-shooter location. Let’s take the flu comparison first.

My interlocutor said that males of our age (we are both between 55 and 64) are 50 times as likely to die from COVID as from flu. If you look at the CDC’s numbers for 2020, that will appear correct. Making that comparison is misleading because it would be natural to assume he wants you to compare the risk of dying from COVID to the usual risk of dying from fly. But flu killed only about a quarter as many as it typically does. So, the real number is that, if you catch flu, you are about 12 more likely to die of it compared to your fatality rate if you catch COVID.

The 50:1 ratio came from a June 23, 2020 article in BusinessInsider.

Other sources given a lower ratio even than my corrected 12:1. According to the October 2020 piece here: for males, 55-64, they are 5.97 times more likely to die of COVID than of flu.

between the beginning of February and January 2, 2021, there were around 318,786 deaths with confirmed or presumed COVID-19. There were also 8,846 fatalities involving influenza, which had pneumonia or COVID-19 also listed as a cause of death. If I were to use the same tactic by selecting a different year for flu, let’s say 2017-2018, I could change the picture greatly. That was an unusually bad year for influenza. According to the CDC, the overall burden of influenza for the 2017-2018 season was an estimated 45 million influenza illnesses, 20 million influenza-associated medical visits, 800,000 influenza-related hospitalizations, and 61,000 influenza-associated deaths. That’s 61,000 compared to 2020’s 8,846. I could then say that you are only 6.9 times more likely to die of COVID compared to flu. 

You could also compare the Flu vs COVID hospitalizations vs. deaths. As of 01/20/21:

Flu: 458,320/37,239 = 8.1%

COVID: 5,729,000/486,965 = 8.5%

So, risk of dying from COVID after hospitalization is almost the same as for flu.

Similarly, a study published in the December 15, 2020 BMJ put the death rate among COVID-19 patients at 18.5%, while it was 5.3% for those with the flu. Those with COVID were nearly five times more likely to die than flu patients.

But none of these comparisons to flu mortality is particularly helpful.

The relevant comparison with flu is not the chance of dying if you have flu, it’s the chance of catching flu/the chance of dying of flu. I don’t concern myself even a little about the mortality risk from flu. It’s so low that I find it an unhelpful point of comparison. (But I do get my flu shot every year, as early as possible, since non-lethal flu is nasty, and the shot costs me nothing other than a few minutes.) For males in my age group, flu is not even listed among the top 10 causes of death.

The active-shooter risk comparison

This is even less helpful than the comparison to flu mortality. I don’t happen to know the mortality risk of every type of event. I estimated it as higher than it is. (In so far as there are reliable numbers and definable groups-at-risk.) So, my conversant jumped on that as supporting his point. Except it didn’t. My response (the rational one) was NOT to increase my estimate of the risk of dying from COVID-19; it was to reduce my estimate of dying should I somehow find myself in an active shooter situation. It caused me to lower my (already very minor) concern about getting shot.

Even more so than for influenza, the relevant comparison is not the chance of dying in an active shooter situation. It’s the chance of getting into an active shooter situation/the chance of dying in such a situation. We are ALL in an active COVID situation! (Unless you are a very strict hermit.)

Most sensible measure of risk of dying from COVID-19

What is the most reasonable and useful measure of risk of dying from COVID-19? Again, to keep the discussion manageable, I’m focusing on the absolute annual level of risk for someone like me. A good first approximation puts the risk at 2.8%. But MY risk – and the risk to other males my age who also lack risk factors – is less. A more accurate number (which is hard to ascertain) would be much lower since I lack any of the risk factors. But here are the current stats on raised risks for each of the major risk factors that I lack, other than being male. [Source: https://www.rgare.com/knowledge-center/media/research/covid-19-mortality-by-age-gender-ethnicity-obesity-and-other-risk-factors]

The major factors increasing the mortality risk from COVID-19 are:

1.   High deprivation (low socioeconomic status)

2.   Male

3.   Obesity

4.   Uncontrolled diabetes

5.   Being black or Hispanic

6.   reduced kidney function

7.   stroke or dementia

8.   neurological conditions

The 2.8% fatality risk already includes being male, so let’s set that aside. When it comes to economic deprivation, “The magnitude of risk amplification [for COVID-19] is 0.41 and 0.23 for Quintiles 5 and 4, respectively.”

As for ethnicity, Asians have a slightly lower risk compared to white. Blacks have 1.48 times the risk. Surprisingly, this sources does not break out the risk for Hispanic people. That’s stunning, given the incredibly high proportion of all cases accounted for by Hispanics in Southern California.

Obesity: Risk increases from 1.40 to 1.92 depending on how obese you are. (I saw no definition of Type I and Type II obesity.)

Diabetes: 1.31 (controlled) to 1.95 (uncontrolled).

Reduced kidney function: eGFR 30-60: 1.33. eGFR <30: 2.52.

Stroke or dementia: 2.16.

Neurological conditions: 2.58.

Since I’m not clear on the overlap between these factors, I’m not going to try to compute an overall risk for people of my age and condition. But it’s very clear that the risk is much lower than 2.8%. My WAG is that my risk is around 1%. That’s very close to my risk of dying in any year from other causes in non-COVID times. (Obviously, that’s in addition to my normal background risk.)

To further keep my risk in perspective (and yours, with appropriate adjustments), I consider my normal risk of dying in a non-COVID year. I don’t have figures adjusted for multiple factors as above. I only have the average for a male my age. I’m about to turn 57. My death probability is given as 0.9156%. Interestingly, that’s awfully close to (probably higher than) my best current guess for my COVID-19 mortality risk.

My estimated mortality risk for COVID is probably around 1% (with fairly large error bars).

If you are not a male of my age group and health, I hope exercise helps you to estimate your mortality risk from COVID-19. Of course, where you live should certainly have a bearing on your evaluation of the risk. Not only the mortality rate in your state and county, but also the level of stress on medical facilities.

Also, mortality risk is far from the only consideration. Lung damage and “long COVID” actually concern me more than my own mortality risk. The evidence is too early to estimate risks of these, but it looks like a major problem.

Even the most intelligent people can get sucked into the pull of fear. It’s a huge problem in our thinking today. It helps to put risks in context by breaking them down and by comparing to other baselines, such as regular mortality rates.

The Perils of Precaution, full version

The combined six blog posts are now available in a single essay, with notes, on my main website: http://www.maxmore.com/perils.htm

Perils, Part 6: Fatal to the Future

Fatal to the Future

The precautionary principle is ultra-conservative. “Conservative” here does not mean “right-wing”, nor does it refer to the Republican Party in the USA or the Conservative Party in England. I mean it in the most literal sense: that which conserves the existing order. Factions of widely differing agendas may share an interest in the status quo. In the USA, this makes sense of the unholy alliance of religious conservatives and extreme environmentalists in their attack on biotechnology.

The ultraconservative nature of the principle explains support for it both by environmentalists and large political and even commercial bodies. Some businesses are highly conservative and opposed to innovation—those who lack confidence in their ability to innovate or don’t want to bother. These organizations can use the principle to lock down the status quo, protecting their position from disruption by new and potentially superior technologies.

Sonja Boehmer-Christiansen, environmental policy specialist and editor of the journal Energy and Environment, noted that “Virtually all scientific and technological discoveries create, initially at least, powerful losers who can activate the prevailing ideological and political system against the new.” The precautionary principle serves as a pretext for activists with anti-technology and anti-business agendas. Once the principle of precaution is in place, defenders of what is only have to raise the barest possibility of a harm to block the creative activity of the forces of what could be.

Defenders of national economic interests (as they see them) can easily invoke the precautionary principle. The protracted dispute between the European Commission and the United States and Canada over restrictions on hormone-treated beef cattle is a case in point. The EC explicitly argued that the precautionary principle justifies restricting imports of U.S. and Canadian beef from cattle treated with particular growth hormones. Perhaps we shouldn’t be surprised that the World Trade Organization (WTO) comes under heavy attack from environmental precautionists, given that this body ruled in favor of the United States and Canada. The WTO pointed out that even the EC’s favored scientific studies failed to demonstrate a real or imminent harm when these hormones were used according to accepted animal husbandry practices. This finding has not stopped the EC from enforcing restrictions on hormone-treated beef. The European Commission has promised that it will not allow the precautionary principle to be abused. Apparently the EC believes that promises are made to be broken.

Organizational learning experts have converged on the view that we learn best by experimenting, by learning in action. This is why companies shelling out their own money for corporate learning programs now favor learning on the job and simulations rather than traditional classrooms or standalone online learning courses. The precautionary principle is fatal to the future because it prevents us from learning by experimenting. Earlier in the chapter, we saw that the principle would have blocked most of the scientific discoveries of the past, as well as the technologies they enabled. Scientific and medical research necessarily gets going before we have all the information. We learned about some blood groups, for example, only by doing transfusions.

The precautionary principle, by halting activity, reduces learning and reinforces uncertainty. When the FDA responded with excessive precaution to the 1999 death of a patient in a University of Pennsylvania gene therapy trial for a genetic disease, work in gene therapy throughout the country and beyond was set back by years. The FDA might instead have taken measures to ensure more thoroughly informed consent, or have put additional safeguards in place without halting all research. We will uncover a wider range of both potential harms and benefits through action learning—what organizational theorist Karl Weick has called “looking while leaping.” Allowing a diversity of directions for technological advancement produces more learning and problem-solving than a single direction imposed by a centralized policy-making institution.

Practically all advances with a scientific basis come with some risk. If the mere possibility of harm—to someone, somewhere, somehow—is held up as sufficient reason to stop activity, we would have to say goodbye to all medical, engineering, and technological advances. Nor can precautionists reasonably require innovators to demonstrate the “necessity” of any particular advance. For one thing, necessity is in the eye of the beholder. The extreme environmental activist will judge just about every technological advance to be “unnecessary”.

Besides, each technology invariably forms a bridge to later technologies with even greater benefits and lower costs. We complain about burning fossil fuels for energy, understandably enough. But they are far cleaner than burning wood, may well be made cleaner, and without them we would not be able to invest the resources and knowledge necessary for the transition to the solar-hydrogen-nuclear future.

We saw that, compared with regulations for traditional breeding techniques, the regulation of gene-spliced crops is inconsistent, arbitrary, and not apportioned to risk. This has the effect of slowing innovation in impoverished parts of the world. Crop breeders who use traditional techniques test thousands of new genetic variants every year. When it comes to gene-spliced crops, however, requiring regulatory review of each and every variant effectively stifles research conducted with the most advanced and precise methods.

Lying next to the almost-dead body of agricultural biotechnology we find medical biotechnology. Carl Djerassi, emeritus professor of chemistry at Stanford University, is the father of the modern contraceptive Pill. According to Djerassi, “The precautionary principle is also the principal reason why we still have no such [contraceptive] Pill for men.”

Talking of dead bodies, if the precautionary principle is used to block genetic modification of insects and bacteria, bodies killed by Chagas’ disease will continue to pile up. This disease—accompanied by a resurgence of malaria, dengue fever, and yellow fever—has erupted in Latin America, infecting 12 million to 18 million people out of the 90 million in the area. Once infected with the protozoa Trypanosoma cruzi, carried by several species of insects, between 10 and 30 percent of people develop chronic, life-threatening maladies such as heart failure. Already, 50,000 people die from invasion by this organism each year.

No vaccine or cure exists for Chagas’ disease. That could change if the precautionary principle is kept at bay. Scientists hope to augment conventional public health measures with genetically modified insects and bacteria. They want to use the “sterile-insect technique” to combat Chagas’ disease—but will governments mouthing the precautionary principle allow the release of these genetically modified bugs?

Many medical techniques and technologies now familiar to us, such as open-heart surgery, and X-rays, had to pass through what Norman Levitt described as a “heroic stage.” This will be just as true of future medical technologies. Consistent application of the precautionary principle would halt developments in their heroic, experimental, poorly understood phase, preventing them from ever becoming the standard techniques. Levitt goes on to say:

At a more basic level, research programs in molecular biology would have been badly crippled. The now-standard tricks associated with 'genetic engineering' - restriction enzymes and the polymerase chain reaction - would have had a difficult time making their way into the armamentarium of investigators.

Change happens regardless of the precautionary principle. If we stifle changes initiated by our brightest, most creative minds, we will be left with inadvertent changes. The direction of those changes is far more likely to be one that we don’t like. The asymmetrical nature of the precautionary principle ignores natural, unchosen changes that have their origin in nature, chance, or the environment. But changes, advance, and progress that come from science are treated as the enemy.

As Ingo Potrykus, emeritus professor of Plant Sciences at the Swiss Federal Institute of Technology, and the inventor of Golden Rice, said: “The application of the precautionary principle in science is in itself basically anti-science. Science explores the unknown, and therefore can a priori not predict the outcome.”

The future is the realm of the unknown. We can do much better to understand, anticipate, and prepare for the possible futures that lie ahead, but a large element of the unknown will remain. If we are to continue improving the human condition—and possible even move beyond it—we must remain open to the unknown. We must throw out the precautionary principle. Friends of the future will see how the principle would prevent us from developing and applying practically all of the emerging technologies for enhancing and transforming the human condition: genetic techniques, neuromedical implants, nanotechnology, biotechnology, machine intelligence, and so on. Had the precautionary principle been in effect at any time in the past, today would never have arrived. The precautionary principle is the enemy of extropy.

If this principle should be avoided by policymakers and executives making a decision about the development, deployment, regulation, or marketing of a new technology, what are the alternatives? They should start out by thinking about the kind of decision they are making, then identify the optimal way to make it. This requires a structured decision-making process. The wisdom of ultimate precaution turns out to be false. Real wisdom comes from structure.

Perils, Part 5: Failures of the Precautionary Principle

Failures of the Precautionary Principle

Having seen the precautionary principle in action, we can identify its shortcomings quickly. Before I get to two of the problems with especially strong anti-innovation effects, I want to examine eight other defects that render the precautionary principle capable of generating only dangerously distorted conclusions.

Failure of Objectivity: Any decision procedure adequate for handling the complexities of technological and environmental risks affecting multiple parties must be objective. Objectivity here means “following a structured, explicit procedure informed by the relevant fields of knowledge.” Those fields include risk analysis, economics, the psychology of decision making, and verified forecasting methods. In the absence of a well-designed, structured procedure, assessment and decision making will be distorted by cognitive and interest-based biases, emotional reactions, ungrounded public perceptions and pressures from lobbyists, and popular but unreliable approaches to analysis and forecasting. The precautionary principle does nothing to ensure that decision makers use reliable, objective procedures. Several of the points below detail ways in which the principle lacks objectivity.

Distracts from Greater Threats: The precautionary principle distracts citizens and policy makers from established, major threats to health. The heavy emphasis on taking precautionary measures for any proposed danger, no matter how speculative, draws attention away from any comparative assessment of risks and costs. The principle embodies the imperative to eliminate all risk from some proposed source, ignoring the background level of risk, and ignoring other sources of risk that may be more deserving of action. Environmental activists usually target human-caused effects while giving the destructive aspects of “nature” a free ride. Nature itself brings with it a risk of harms such as infection, hunger, famine, and environmental disruption.

We should apply our limited resources first to major risks that we know are real, not merely hypothetical. The more we attend to merely hypothetical threats to health and environment, the less money, time, and effort will remain to deal with substantial health problems that are highly probable or thoroughly established. The principle errs in focusing on future technological harms that might occur, while ignoring natural risks that are actually occurring.

Vague and Unclear: Everything about the principle is easily interpreted in differing ways. As the authors of the May 2000 paper in Science, say, “its greatest problem, as a policy tool, is its extreme variability in interpretation.” The Treaty on European Union gives the principle great importance by referring to it, yet does not define it. Once given a specific interpretation, the principle is simple. Simplicity is the source of its appeal. Simplicity is a virtue—so long as it does not come at the expense of adequacy.

The precautionary principle is too simple. In versions that mention “irreversible harm”, no account is given of irreversibility. Most environmental changes can be reversed, though it may be costly to do so. Even when effects are truly irreversible, that fact alone does not make the changes significant. The principle lacks clarity also because it leaves us without any guidance in cases where resulting harm arrives along with benefits—and this is the rule rather than the exception. The principle leaves us in the dark as to how we should go about preventing harm. As we have seen, precautionary measures can themselves be harmful and costly.

Lack of Comprehensiveness: Any procedure that claims to be both rational and equitable in assessing the desirability of restrictions on productive human activity must be comprehensive. This means taking into account the interests of all affected parties with legitimate claims. It also means considering all reasonable alternative actions, including no action.

A comprehensive decision procedure balances the benefits of restricting an activity that brings with it possibly harmful side effects against two factors: the benefits of the activity in question, and the costs and risks of the restrictions, regulations, or prohibitions. If a proposal has been made to restrict a technology, responsible decision makers will estimate the opportunities lost by abandoning it. If needs that were being met by the technology or productive activity will be met by other means, the costs and risks of those alternatives should be estimated. When making these estimates, decision makers should carefully consider not only concentrated and immediate effects, but also widely distributed and follow-on effects.

The precautionary principle, with its typically agenda-driven, single-minded approach, fails the test of comprehensiveness. Officials and activists who use the principle routinely inadvertently or deliberately ignore costs and side-effects of regulations and prohibitions, as well as the potential benefits of a technology, both in the near term and as it might develop over time. As we saw in the case of drug regulation, regulators who start out doing something intended to be beneficial face incentives that encourage them to regulate excessively. The precautionary principle serves as a rationalization and an encouragement for regulators in making Type II errors.

Inappropriate Burden of Proof: The precautionary principle illegitimately shifts the burden of proof (“reverse onus”) by requiring innovators and producers to prove their innocence when anyone raises “threats of harm”. Activists enjoy a favored status since they can raise the prospect of precautionary measures with no more evidence than their fearful imagination. All they need to show is that a possibility of harm exists. No, not even this. All they need to show is that questions have been raised about the possibility of harm. Inventors and producers must then devote effort and resources to answering those questions.

Proponents of the principle portray it as a value-neutral procedure for deciding on policies. Yet it gives the trump card to the status quo and against productive activity and innovation by default—no real evidence is needed. Producing and innovating become de facto crimes whose perpetrators are guilty until proven innocent.

The content—even the very name—of the principle positions environmental activists as friends and protectors of the common citizen. By shifting the burden of proof, advocates of precaution position themselves as responsible protectors of humanity and the environment, while positioning advocates of proposed activities or new technologies as reckless. By using reverse onus, the activists can impose their preferences without providing evidence, and without being accountable for the results of overly-cautious policies.

To add to the fear-inducing power and chilling effect of the reverse onus, activists and regulators who invoke the precautionary principle invariably assume a worst-case scenario. Any release of chemicals into the environment might initiate a chain of events leading to a disaster. Genetically modified organisms might cause unanticipated, serious, and irreversible problems. By imagining the proposed technology or endeavor primarily in a worst-case scenario—while assuming that preventing action will have no disastrous consequences—the adherents of the principle immediately tilt the playing field in their favor. By combining reverse onus and catastrophic scenario-spinning, precautionists guarantee that managing perceptions of risk becomes more influential in policy-making than the reality of risk.

Asymmetrical: The precautionary principle inherently favors nature and the status quo over humanity and progress, while routinely ignoring the potential benefits of technology and innovation. As an example of this—meant only partly in jest—I would point to an odd dichotomy. Many environmentalists have been obsessed with opposing nuclear power. After all, to them, it represents advanced technology and humanity’s triumph over the vagaries of nature. At the same time, when have you ever heard environmentalists and fellow precautionists raising concerns and urging public action over the dangerous act of sunbathing? If this question seems a little peculiar, consider what sunbathers are doing: They are lying prone and helpless directly beneath a gigantic, unshielded nuclear fusion reactor!

The entirely serious point I want to make here is that the precautionary principle fails to treat natural and human threats on the same basis. Users of the principle routinely ignore the potential benefits of technology, in effect favoring nature over humanity. The principle does not account for the fact that the risks created by technological stagnation are at least as real as those of technological advancement. As biochemist Bruce Ames of UCLA has demonstrated, almost all of our exposure to dangerous chemicals comes in the form of natural chemicals, such as aflatoxins in peanuts—which are among the most carcinogenic substances known. Yet fear and attention are primarily directed toward synthetic chemicals. A particular chemical has the same effects regardless of whether its source is natural or synthetic. Despite this, activists treat human-derived chemicals as guilty until proven innocent, and naturally occurring chemicals as innocent until proven guilty.

We can see an excellent example of the asymmetrical favoring of nature over humanity—in other words, the condemnation of conscious creative activity—in the wildly divergent attitudes of hardcore environmentalists and other precautionists toward gene-spliced crops and their more traditional counterparts. Proponents of the precautionary principle—if not utterly opposed to gene-spliced crops in their public pronouncements—encourage authorities to apply a heavy regulatory burden. When it comes to conventional crops, the same precautionary regulations are never urged. This makes sense, precautionists will say, because genetically modified crops introduce new and poorly understood risks. But is this true?

Gene-splicing is simply the most scientifically advanced method of generating new plant varieties. More specifically, compared to other techniques, gene-splicing is more precise, restricted, and predictable than techniques devised earlier. Anti-technologists would have us believe that modern genetic techniques break radically with past practice. In reality, gene-splicing technology is a refinement of the less accurate, more uncertain techniques of the past. Those older methods—such as hybridization and induced-mutation breeding—lie behind the many new plant varieties introduced every year. No scientific review is required of them. No special labeling is required. Yet, because they are less precise, they bring potential hazards greater than those from the more precisely targeted method of gene-splicing.

Often these more traditional products result from “wide crosses”—applications of hybridization in which many genes are transferred from one species to another in a way that does not happen in nature. Wide crosses have many benefits such as introducing the hardiness of wild rice into cultivated rice, or integrating yellow dwarf virus tolerance and resistance into cultivated oats. But they could also lead to problems. By introducing thousands of foreign genes into an established plant variety, the result could be the accidental introduction of toxins or allergens, or qualities such as increased invasiveness in the field.

Similarly, a method in common use for the last 50 years called induced-mutation breeding, lacks the precision of gene-splicing. In this approach, plants used as crops are exposed to ionizing radiation or toxic chemicals in order to stimulate genetic mutations. No way exists to select the mutations; it is essentially a random process that leaves breeders with little idea of which mutations occurred or which ones produced a desired effect. Over the decades in which this method has been used, between one and two thousand mutation-bred plant varieties have been brought to market without any regulation to speak of. Although the results have typically been safe, problems have occasionally cropped up.

If the precautionary principle were actually a useful tool, we would expect to see stricter precautions being applied to these less accurate, less predictable types of genetic modification. But the opposite has been the case. Activists and regulators have put all their energies into severely regulating gene-spliced products out of all proportion to their risk. The regulators not only inflate the risks of gene-spliced or “genetically modified” foods, they ignore the ways in which the newer technique can actually reduce risks.

Aside from minimizing the dangers of introducing toxins, allergens, or other unwanted qualities, this technology makes it far easier to remove many natural allergens from the food supply. In addition, gene-spliced crops enable farmers to drastically reduce the use of pesticides. Unavailability of the better technology especially hurts farmers in poor countries, who continue to suffer from continual exposure to pesticides.

Fails to Accommodate Tradeoffs: The way in which the precautionary principle shifts the burden of proof is no accident. Many proponents of the principle fully intend its nature-deifying, human-denying values to force the innovator and producer onto a rocky path. Another consequence is the inability of the principle to handle tradeoffs between harm to humans and to the environment. Since unaltered nature is implicitly an absolute value in the principle, no tradeoffs are to be allowed. The precautionary principle is all about avoiding possible harm—and human-caused harm, and primarily harm to the environment—rather than respecting a wider set of values.

As the precautionary principle has come to be applied, all other values must bow to that of the precautionary activists. Anyone who expresses willingness to forego perfect environmental protection in favor of an easier life, greater health or wealth, or other values, needs to be shown the light according to the precautionist. In this way, the precautionary principle tends toward authoritarianism. If those poor, ignorant fools (no doubt blinded by the dark power of commercial advertising) cannot see what they should do, the activists will force them to do the right thing. Just as Lenin, Trotsky, and Stalin saw themselves as the vanguard of the proletariat, who knew the interests of the Russian workers far better than did the workers themselves, the precautionists wish to protect us from ourselves.

The precautionary principle, in its absolutist, univalued approach, conflicts with the more balanced approach to risk and harm derived from common law. Common law holds us liable for injuries we cause, with liability increasing along with foreseeable risk. By contrast, the precautionary principle bypasses liability and acts like a preliminary injunction—but without the involvement of a court. By doing this, the precautionary principle denies individuals and communities the freedom to make trade-offs in the way recognized by common-law approaches to risk and harm. No other values are admitted as reason not to pursue extreme precaution.

Vulnerable to Corruption: The inconsistent, discriminatory nature of precautionary regulations (as we saw in the case of gene-spliced foods) puts a kink in the rule of law. By giving regulators the power to insist on any degree of testing they choose, the precautionary principle opens up opportunities for corruption—undue influence, unfair targeting, and regulatory capture. It is the principle’s vagueness, inconsistency, and arbitrariness that appeals to regulators who enjoy expanding their powers and wielding them selectively. An increase in corruption and arbitrary regulatory power is further ensured by making precaution and prevention the default assumption.