Director of the French food safety agency ANSES, Marc Mortureux, recently issued a statement worth reading for a number of relatively subtle points which were lost in the conflagration surrounding a paper suggesting that the Roundup pesticide formula plus GMO corn may increase risk of cancer. Although primarily about GMOs, the ANSES statement touches on a number of themes of direct relevance to the research topic at hand, so it is well worth reflecting on. We have emphasised particular phrases to make the ensuing discussion easier to follow in relation to the text.
M. Mortureux’s statement in full
1. Calling into question current risk assessments. This is an idiosyncrasy of language around risk assessment which it is worth getting to grips with, and refers to due cause to change advice about safe exposure to a substance. If data is inadequate for calculating a safe exposure, then the exposure cannot be changed. This looks a little odd, however, when positioned next to the observation that the method employed by the study casts doubt on the veracity of the methods used for determining whether or not exposure to a chemical or technology such as GM. (In this case, Mortureux is referring to the absence of long-term studies; he could just as easily refer to the low-dose effects debate, non-monotonic dose-response curves, mixtures, and other methodological considerations informing the debate about how one should test chemicals or GMOs for safety.) If we don’t think we have the data to demonstrate the safety of a technology, how is it that there is no case to change the judgement on the safety of a technology? Ordinarily, one would say the jury is out; there is a case for observing a disconnect between language of risk assessment in describing a situation as being simultaneously unproven yet certain enough for the existing recommendation to stand. How an ordinary member of the public should interpret that is unclear, and there is a question as to whether or not the apparent contradiction can lead to confusion in the communication of the risk (or if, indeed, the contradiction shows a contradiction in the risk assessment itself). 2. Public funding. The idea that safety studies should be conducted by an independent body certainly attracts enough controversy; we won’t discuss this here, but it is worth noting that ANSES has alluded to this as something which can improve risk assessment. 3. Diversity of literature. The differences between academic research and regulatory findings has been discussed in the academic literature (see, for example, Alcock 2011, and a relatively early piece of writing by this author). The issue is how it can be that new data generated by researchers examining the potential health effects of chemicals can be irrelevant to risk assessment, when RA is supposed to be a calculation of health risk. To the public, it must seem bizarre that a study about the safety of e.g. BPA can be irrelevant to a risk assessment, or give no cause for changing a risk assessment. It is not clear that describing academic research as irrelevant to risk assessment helps much. First, why assume that, to the public, there are two types of evidence: the regulatory kind and the academic kind? (Does the distinction even make any sense?). Secondly, why expect the public to believe the risk assessors, if so much published data apparently contradicts the risk assessors’ published findings? Beyond the improved regulatory studies called for by Mortureux, options which spring to mind include: being clearer about the limitations of the regulatory studies as well as the academic ones; clarity on what a risk assessment actually means, and how it relates to the faster-moving world of academic research; for interpreting the findings of risk assessments into actionable advice for the public, rather than simple assurances of safety and authority of the assessor.