The first realization of the vast difference in scale and duration of the new scientific endeavors and technologies came with the splitting of the atom and the dropping of the atomic bombs over human populations in Japan in the last days of World War II. Although some of the scientists engaged in the top-secret U.S. government project—the Manhattan Project—had misgivings about pursuing the research and applying the results, and expressed their concerns, the weight of scientific orthodoxy prevailed, and nuclear weapons and, later, nuclear power continued to be developed unabated. The reasoning, until this day, has been that while nuclear weapons and nuclear power plants pose a potential threat to the continuance of human life on Earth, the benefits of military security and adequate energy supplies exceed the potential threat posed by misuse and abuse or negligence. The belief has always been that the potential for wrongdoing or accidents could be “rationally” avoided, controlled, or at least mitigated.
Although Americans, by and large, continue to champion the European Enlightenment vision, putting their unswerving faith in scientific advances and technological pursuits, Europeans are beginning to have doubts about the wisdom of uncritical acceptance of the old shibboleths. As in the case of governance and foreign policy and security matters, Europe is beginning to diverge, in a fundamental way, from the American approach to science and technology. At the heart of the difference is the way Americans and Europeans perceive risk.
We Americans take pride in being a risk-taking people. We come from immigrant stock who risked their very lives to journey to the New World and start over, often with only a few coins in their pockets and a dream of a better life. When Europeans and others are asked what they most admire about Americans, our risk-taking, can-do attitude generally tops the list. We are often willing to gamble it all on a whim, a hope, or just a gut feeling. That’s why Americans are so incredibly inventive, innovative, and entrepreneurial. Where others see difficulties and obstacles, Americans see opportunities. One of the traits that Americans most dislike in a person is the defeatist attitude that something can’t be done or isn’t worth attempting for fear of failure or unintended deleterious consequences. “You don’t know until you try” is a refrain that reverberates throughout American history. If people elsewhere really want to know what irks Americans the most, it’s this. We can’t abide pessimism, a quality often perceived in our European friends. We are eternal optimists—although many Europeans I know say we are just plain naïve.
Our optimism is deeply entwined with our faith in science and technology. It has been said that Americans are a nation of tinkerers. When I was growing up, the engineer was held in as high esteem as the cowboy. He was viewed as a rugged individualist willing to cut against the grain, always in search of creating a better machine. The engineer was admired for his efforts to improve the lot of society and contribute to the progress and welfare of civilization. I remember seeing the lights on late at night in my neighbor’s garage, as father and son experimented with various machines and engines at their homemade workbench, dreaming of a breakthrough invention that might change the world.
It’s hard to give all that up. It’s too ingrained. It’s who we are. But on the other side of the water, the sensibilities are different. It’s not that Europeans aren’t inventive. One could even make the case that over the course of history, Europe has produced most of the great scientific insights and not a few of the major inventions—although certainly the Chinese might justifiably lay claim to some of the accolade. Still, Europeans are far more mindful of the dark side of science and technology. They’ve had longer histories with the negative as well as the positive consequences of science and technology and are, therefore, less starry-eyed. Moreover, until the post-World War II era, science and technology in Europe were largely in the hands of an educated elite and associated with control over society and the perpetuation of class divisions, whereas in America, science and technology were always more democratically dispersed. The founder of my own alma mater, the University of Pennsylvania, Benjamin Franklin, as well as Thomas Paine, Thomas Jefferson, and many of the other founding fathers, fancied themselves as scientists and inventors as much as revolutionaries and spent endless time working on scientific pursuits and the creation of new inventions. They envisioned America as a nation of inventors. Thomas Jefferson, our third U.S. president, fashioned the first modern patent laws to reward the prowess of American inventors. He hoped that the patent laws would encourage the democratization of the inventive spirit. They did.
Just as Americans took up the European Enlightenment dream of material progress, the pursuit of self-interest, and individual autonomy, and ran with it in its most pure form, while European attachment was more tentative, so, too, with the Enlightenment notions of science and technology. The Brits come closest to the American sensibilities when it comes to our unflagging faith in the pursuit of Enlightenment science and technology. But, even they temper their enthusiasm with an occasional romantic and sometimes class-directed reaction from the likes of a Samuel Taylor Coleridge or the Luddites. We have our Thoreaus and our anti-technology populist traditions as well, although these countercurrents don’t run as deep in America as they do in Europe.
The divergence in views on science and technology between Americans and Europeans is growing and is now coming to the fore in a myriad of public policy debates, threatening a schism as significant as the divide over our different sense of how best to pursue foreign policy and domestic security.
Burden of Proof
In recent years, the European Union has turned upside down the standard operating procedure for introducing new technologies and products into the marketplace and society, much to the consternation of the United States. The turnaround started with the controversy over genetically modified (GM) foods and the introduction of genetically modified organisms (GMOs) into the environment. The U.S. government gave the green light to the widespread introduction of GM foods in the mid-1990s, and by the end of the decade, over half of America’s agricultural land was given over to GM crops. No new laws were enacted to govern the potential harmful environmental and health impacts. Instead, existing statutes were invoked. Nor was any special handling or labeling of the products required.
In Europe, the response was quite different. Massive opposition to GMOs erupted across the continent. Farmers, environmentalists, and consumer organizations staged protests, and political parties and governments voiced concern and even opposition. A de facto moratorium on the planting of GM crops and the sale of GM food products was put into effect. Meanwhile, the major food processors, distributors, and retailers pledged not to sell any products containing GM traits.
The European Union embarked on a lengthy review process to assess the risks of introducing GM food products. In the end, the European Union established tough new protections designed to mitigate the potential harm of GM food crops and products. The measures included procedures to segregate and track GM grain and food products from the fields to the retail stores to ensure against contamination; labeling of GMOs at every stage of the food process to ensure transparency; and independent testing as well as more rigorous testing requirements by the companies producing GM seeds and other genetically modified organisms.
The U.S. government charged the EU with foul play and suggested that the Union was using GMOs as a ploy to win concessions on other trade-related issues to which the two superpowers were at loggerheads. The U.S. trade representative even threatened to challenge the EU GMO policy at the World Trade Organization, suggesting that its restrictive policies violated existing free-trade agreements.
What the U.S. didn’t understand is that Europe’s opposition to the introduction of GMOs was not just a political maneuver to gain a bargaining chip with the U.S. on trade, but something far more important. For Europeans, the introduction of GMOs cuts much deeper, challenging many of the fundamental assumptions that underlie the nascent European Dream. The European public worries about the potential unforeseen environmental impacts of introducing large volumes of genetically modified organisms into the biosphere. They also worry about the possible consequences to human health that might result. The argument one hears over and over again by men and women on the streets of Europe, as well as by governing elites, is that while millions of dollars have been spent on readying the new products for market, far less care, attention, and funds have been committed to assessing the potential ecological and health risks that might accompany the introduction of this radical new agricultural technology. Europeans argue that because GMOs are alive, reproduce, mutate, proliferate, and can contaminate and create irreversible niches, they pose potential threats that are global in scale and therefore require a different level of oversight.
Europeans also express concern over the impact that GM foods may have on their cultural identity. In Europe, unlike America, food plays a critical role in defining culture—many would argue that food is as important or even more important than language in maintaining the social cohesion of Europe’s many cultures. Americans have a difficult time understanding the close cultural relationship Europeans have toward rural life, farming practices, food cultivation, processing, and consumption because we gave all that up long ago to become a fast-food, commercial culture. For Europeans, GM foods represent a potential threat to deeply held beliefs about sustainable development and the protection of cultural diversity, principles that go to the very heart of the European Dream. According to public opinion surveys, 89 percent of the French public, 81 percent of the German public, and 74 percent of the Italian public oppose the introduction of GM foods. On average, two out of three Europeans oppose GM foods, while in America, nearly half (48 percent) of all consumers support GM foods.
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Nor is the GMO issue an anomaly. The European Union is forging ahead on a wide regulatory front, changing the very conditions and terms governing how new scientific and technological pursuits and products are introduced into the marketplace, society, and the environment. Its bold initiatives put the Union far ahead of the United States, and the rest of the world, in procedures and protocols overseeing scientific and technological endeavors. Behind all of its newfound regulatory zeal is the looming question of how best to model global risks and create a sustainable and transparent approach to economic development.
In May 2003, the European Commission proposed sweeping new regulatory controls on chemicals to mitigate toxic impacts on the environment and human and animal health. The proposed new law would require companies to register and test for the safety of more than thirty thousand chemicals at an estimated cost to the producers of nearly €8 billion.
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Under existing rules, 99 percent of the total volume of chemicals sold in Europe have not passed through any environmental and health testing and review process.
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According to the EU environmental commissioner, Margot Wallstrom, “There is no control whatsoever of the 400 million tons of chemicals sold in the European Union each year.”
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In the past, there was no way to even know what kind of chemicals were being used by industry, making it nearly impossible to track potential health risks. The new regulations will change all of that. The REACH system—which stands for Registration, Evaluation, and Authorization of Chemicals—requires the companies to conduct safety and environmental tests to prove that the products they are producing are safe. If they can’t, the products will be banned from the market.
The new procedures represent an about-face to the way the chemical industry is regulated in the United States. In America, newly introduced chemicals are generally assessed to be safe, and the burden is primarily put on the consumer and the public at large or the government to prove that they cause harm. The European Union has reversed the burden of proof. Margot Wallstrom makes the point that “no longer do public authorities need to prove they [the products] are dangerous. The onus is now on industry” to prove that the products are safe.
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The new EU policy represents a sea change in the handling of risks. In the United States, regulation is designed, for the most part, to address environmental problems once they occur. The Toxic Substances Control Act (TOSCA), passed in 1976, is America’s primary governmental tool for regulating toxic chemicals but is generally regarded as “being weak and too deferential to industry.”
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The vast majority of non-pesticide chemicals are not screened or tested at all before introduction into the marketplace. Even though the National Environmental Policy Act (NEPA) requires environmental-impact statements in advance of some scientific experiments and technological applications, it has been narrowly applied by the federal courts and restricted in its use. Even when it has been used, the threshold criteria for fulfilling NEPA requirements is so weak as to be largely ineffective in most instances. The European Union’s regulatory approach, in stark contrast, is designed to prevent harm before it occurs.
Making companies prove that their chemical products are safe before they are sold is a revolutionary change. It’s impossible to conceive of the U.S. entertaining the kind of risk-prevention regulatory regime that the EU has rolled out. In a country where corporate lobbyists spend literally billions of dollars influencing congressional legislation, the chances of ever having a similar regulatory regime to the one being implemented in Europe would be nigh on impossible.
What makes the new risk-prevention regime even more impressive is that the European Union is the largest chemical producer in the world and makes up 28 percent of the entire world output of chemical products.
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The industry, which is the third largest in the European manufacturing sector, with annual sales of €519 billion, employs 1.7 million people, and is responsible for an additional 3 million jobs related to the industry.
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Even so, the European Commission drove the regulatory process forward.