TIG comments on the WHO Draft Precautionary Framework

TIG comments on the WHO Draft Precautionary Framework

The TETRA Industry Group welcomes the opportunity to comment on the development of the Framework, and we look forward to contributing to further iterations of the Framework. Our comments are set out below under 8 headings.

1 Consistency

It is vital that there is consistency of approach in developing the Framework. Firstly, the approach taken in the Framework should be consistent with existing WHO advice, and also with the views of the EU and other relevant bodies around the world on precautionary approaches. We understand that the precautionary approach is less accepted in the US and the Far East than it is in Europe, but the Framework needs to be developed so that it is applicable world-wide. Secondly, the definition of the key terms on which the Framework is predicated should be clear and consistently applied throughout the Framework (see 3 below). In our view the current draft could benefit from being refined and clarified in both these respects.

2 The importance of Science-based Standards

We are pleased to note that the Framework is not intended to replace a science-based standards approach. However, we are concerned that there are a number of statements in the document which could appear to contradict this precept. In our view, the continued application of science-based standards is essential, and the Framework should give more weight to this aspect. We support the view expressed in the Framework that it would not be appropriate to use the Framework for extending or developing guidelines through arbitrary reductions in exposure limits. The standards-setting process should remain firmly grounded in a rigorous assessment of the whole weight of scientific evidence. The document could usefully include a discussion of the role played by science-based standards as an option for managing risk.

3 Definitions of Terms

As mentioned above, it is important to define key terms clearly and use them consistently. For example, the term “uncertainty” is defined on page 7 of the document by reference to “a risk that has not been established according to conventional scientific standards, and where there is uncertainty, not only in the magnitude but also whether or not the risk exists”. This is a helpful definition, but it is undermined elsewhere in the Framework document where the term is used in a somewhat looser context. It would be useful to distinguish between what is meant by scientific uncertainty, as defined on page 7, and what the general public might understand by the general use of the term ‘uncertainty’. (See also 4 below).

4 Scope

The scope of the Framework should be made clearer – to deal with the issue of public health protection through the management of environmental risks, rather than to tackle broader issues such as poverty, social well-being and so on, which could be regarded as having an impact on health as defined by the WHO constitution (page 2). For the purposes of the Framework, the term ‘health’ could perhaps usefully be qualified and put into context. It seems to us also that it is important to draw a distinction between health risks and public concern. Precautionary measures will tend to address the former where there is uncertainty, but the latter are generally better addressed by risk communication and consultation programmes. Policies on precautionary approaches should be based on the best available scientific evidence, and not formulated solely or primarily to tackle public concern, as this would undermine the application of scientifically-based standards.

5 Cost Benefit Analysis

We note that the document recognises that the Framework is not intended to concentrate on a sub-set of risk, but rather to look at an issue in the round. Following on from this, we believe that, in carrying out a cost benefit analysis as a basis for making a decision on any precautionary approach to be taken, the broader benefits of the agent or technology under consideration should be taken fully into account, and the analysis should include the disbenefits to society of not using the agent or technology. The TETRA technology, for example, is used by many emergency services organisations around the world, and can improve the coverage, speed and reliability of communications to such an extent that lives can be saved. We believe that the broader societal, health and economic benefits of any agent being examined should be fully considered.

6 Weight of Evidence

Further to our comments on the importance of science-based standards, we recognise the advantages of taking into account broader stakeholder concerns. However, we believe that a distinction should be drawn between the greater weight which should be given to science-based evidence, and the lesser weight which should be given to information which is drawn from qualitative observation, anecdotal experience, or emotionally-based concern. As mentioned in 4 above, public concern does need to be addressed through appropriate risk communications and consultation programmes, but public concern alone should not be a basis for the setting of standards, nor the selection or application of precautionary measures.

7 Proportionality

The importance of proportionality should be emphasised. The Framework states that there is a need to prioritise according to the likelihood and impact of risk. The evaluation of a risk needs to be firmly founded on full consideration of the weight of evidence, and any selection of precautionary measures needs to be designed to be proportionate to that risk.

8 Legal Implications

We agree with the statement on page 5 that it should be acknowledged expressly that the implementation of precautionary measures should not be taken as an admission of liability for any consequences of not having acted earlier, or differently, or indeed that the measures are necessary. In an increasingly litigious society, this is an important principle.

In closing, we welcome the WHO’s commitment to a transparent and open communication and consultation process in developing the Framework. It is important that those developing the Framework are mindful of the context of the broader availability of information, heightened public interest and concern, and the poor handling of some health-related issues from a communications perspective in the past. These factors should not be allowed to result in the formulation of policies which ignore evidentially-based approaches in favour of appeasing the media or those who shout loudest.

That said, we fully agree that successful evaluation, selection, and implementation of any risk mitigation options can be achieved only with the full engagement of all relevant stakeholders. We believe that industry has an important role to play in such a dialogue and we remain ready to play our part.

ends