Risks and Responsibility

Abstract

The question whether EMF exposure can cause health effects is the subject of a heavily polarised scientific debate. However, a guideline of the Health Council of the Netherlands (HCN) states that a risk can be considered plausible if “some” recognised experts in the relevant field express concerns. When I apply this to the current state of affairs in which 249 recognised experts in the relevant field have expressed their concerns regarding EMF exposure, I argue that the risk of EMF causing health effects is plausible. The As Low As Reasonably Achievable (ALARA) principle is part of the system of radiation protection that was developed to manage risks in nuclear science. The government openly put aside the ALARA principle, despite HCN’s advice to apply the ALARA principle to EMF exposure and despite the fact that the government is an important stakeholder that should bear the accompanying responsibilities in the ALARA process. The telecom providers’ interpretation, of what reasonable is, is based on the rudimentary form of radiation protection, outdated exposure limits and lacks the adoption of the Linear No Threshold (LNT) model. It also lacks consideration of other economic and societal factors. Therefore, I argue that the argument of the government that the ALARA principle is already applied is not ethically justified. The precautionary principle is a weak version of the original responsibility principle that was developed by Hans Jonas to address the magnitude of risks of modern technology. By designating precaution as being the main principle, the precautionary principle’s susceptibility to criticism has increased. Sunstein criticises the precautionary principle because it does not seem to offer guidance in cases with both potential gains and potential harms. The application of the principle also seems influenced by cognitive limitations. Taking into account funding sources of scientific studies may be a more practical solution than assuming that rational risk assessment will be free from cognitive limitations. HCN judges Jonas’ decision rule not suitable as an universally applicable principle, because it would only be useful in situations where there is little to be gained and a great deal to be lost. This assumption seems to be contradicted by the examples Jonas gives, which involve situations that have considerable potential gains. Van Dijk et al. also argue that the precautionary principle is not suitable as a decision rule, and they argue that advisory bodies should not advise concrete decisions, but should only provide information. This seems to contradict the very task of advisory bodies, namely providing advice. Van Dijk et al. and HCN consider the aim of the precautionary principle; arriving at a proper balance between dynamism and caution. This excludes two out of three duties of Jonas’ moral compass. Van Dijk et al. state that sacrificing benefits to avoid a particular risk can introduce other risks. However, the precondition of being riskless, in applying the precautionary principle, does not seem a valid argument since creating new risks is rather inevitable. From 2000 until 2008 the government could ethically justify EMF policy by referring to the GSM-base stations report. Since the Prudent precaution report in 2008 and its advised assessment of a plausible risk, and given the fact the amount of recognised experts at that time was amply exceeded, the government could no longer ethically justify disregarding the application of the precautionary principle in EMF policy. Due to the fact that the ALARA principle is not applied according to the modern system of radiation protection, and the interpretation of the precautionary principle is not in line with Jonas’ responsibility principle, I argue that the government’s policy regarding exposure to EMF is not ethically justified.