In a recent memo to Ontario dentists, the RCDSO has praised the Precautionary Principle as the foundation on which to build infection control guidelines. Perhaps, before being so effusive in its support, the College should have taken the time to understand the true consequences of this principle.
The Precautionary Principle dictates that, “When an activity raises threats of harm to human health or environment precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.” 1 It is no wonder that governments and similar regulatory agencies are so enamoured of the principle as it permits them to enact any rules and regulations without the need to provide any demonstrable proof as to their necessity or effectiveness. The principle may be precautionary but is it democratic?
In his 2005 book, “Laws of Fear: Beyond the Precautionary Principle,” Cass R. Sunstein (one of the world’s most cited law professors) is emphatic that the precautionary principle offers no guidance because it either endorses taking no action, since to do so would incur greater risks or, it advocates an increasingly complex maze of recommendations and regulations that have little relationship to the original risk and are subject to no cost effective analyses. 2 There are two fundamental faults inherent in the Precautionary Principle. The first is that it allows regulatory agencies to shape and influence policy decisions that have little or no scientific substantiation. The second is the arrogant assumption by the Principle’s supporters that only good emanates from its practice. As stated by Professor Frank Cross of the University of Texas, “The truly fatal flaw of the precautionary principle, ignored by almost all commentators, is the unsupported presumption that an action aimed at public health protection cannot possibly have negative effects on public health.” 1 Does the RCDSO really wish to base its infection control policies on such a flawed principle?
The Precautionary Principle is supposed to provide the best practices for the prevention, surveillance and control of infectious diseases. These goals cannot be accomplished without first identifying the specific disease, its causative agent, its mode of transmission, its “at risk” patients and practical, effective control mechanisms. In other words, the successful attainment of the goals demands scientific certainty as to the nature of the infection.
The Precautionary Principle is being used by government agencies to plan for future epidemics of infectious diseases. Do such bodies not realise that certainty about the future is impossible. Professor Philip Alcabes in his 2009 book, “Dread, How Fear and Fantasy Have Fuelled Epidemics from the Black Death to Avian Flu” supports this claim by noting that, “Whatever disease causes the next great outbreak, we won’t see it coming.” 3 He is of the opinion that it would be foolish to believe that any shift in our risk behaviour will stop the next great plague. The Precautionary Principle will not stop this future epidemic. Only scientific enquiry will ensure its control and prevention.
In 1996, the RCDSO was proud of the fact that it had, “developed evidenced-based guidelines on the use of universal infection control precautions.” 4 It is unfortunate that this approach has been abandoned for one that empowers the College to regulate the profession while ignoring its scientific foundations. That is the ultimate fallacy of the Precautionary Principle. OH
REFERENCES
1. Adler JH. Dangerous Precautions. National Review Online. Available: www.nationalreview.com/script/printpage.p?ref=/adler/adler091302.asp
2. Sunstein CR. Laws of Fear: Beyond the Precautionary Principle. Cambridge University Press, New York, 2005.
3. Alcabes P. Dread, How Fear and Fantasy Have Fueled Epidemics from the Black Death to Avian Flu. Public Affairs, Perseus Books Group, Philadelphia, PA. 2009
4. CDA. ODA and RCDSO Clarify Guidelines on Universal Precautions and the Application of the Human Rights Code. RCDS Dispatch 1996;10(3)
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The principle may be precautionary but is it democratic?